Housing site selection: choosing the right Somerset location

For affordable housing developers, this is not a drafting technicality. It determines whether a proposed site is consistent with the municipality’s adopted growth framework.

Floodplain standards create a second immediate distinction. Somerset County Ordinance No. 93 requires the Flood Protection Elevation to equal the Base Flood Elevation plus 1 foot of freeboard. Princess Anne and Crisfield require Base Flood Elevation plus 2 feet. A parcel that appears suitable under a county-level screen may therefore require a different building elevation, foundation design, access solution, or cost estimate inside a municipal boundary.

Somerset County affordable housing site selection is consequently a regulatory comparison, not a search for the cheapest available tract. The correct location must align land use authority, floodplain controls, grant eligibility, municipal planning, infrastructure capacity, and the intended income profile of residents.

The first comparison: county jurisdiction or municipal jurisdiction

The initial decision is whether the project will proceed under county land-use controls or within Princess Anne or Crisfield. That distinction affects the applicable zoning ordinance, comprehensive-plan consistency review, floodplain elevation requirement, variance authority, and local endorsement process.

A parcel’s physical characteristics remain relevant in every jurisdiction. The compliance pathway does not.

This comparison should be completed before architectural plans are commissioned. A preliminary site plan based on the wrong jurisdictional standard can produce a false development budget.

The parcel screen should establish five facts

A defensible screen for eastern shore affordable housing development should identify:

• the parcel’s governing zoning authority and applicable district;
• the permitted residential use, density, dimensional standards, and setback requirements;
• the mapped flood zone and the controlling Base Flood Elevation;
• the required Flood Protection Elevation, including freeboard;
• the public infrastructure and access conditions necessary for the proposed unit count.

The screen should also identify whether the site is inside a municipal boundary, adjacent to one, or located in an area where municipal growth policies may influence future development decisions. Adjacency does not change current zoning authority. It can, however, affect the strategic value of the site and the plausibility of future service extensions or coordinated revitalization.

Why the non-entitlement CDBG structure changes site selection

Somerset County is a non-entitlement jurisdiction for federal Community Development Block Grant funding. It does not receive a direct, automatic annual federal allocation. Projects must compete for state-administered funds.

That funding structure changes the order of analysis. A developer cannot select a site first and assume that the CDBG application will follow. The project must be shaped around the program’s national objectives, the state’s competitive review, the service area, and the documented benefit to low- and moderate-income residents.

Somerset County’s FY 2026 CDBG award is $350,000 for a countywide owner-occupied housing rehabilitation program, with a projected capacity of 20 properties. That program is materially different from a new multifamily construction project. It demonstrates that housing rehabilitation is an active funding priority, but it does not establish that a proposed new development will receive funding or that the same allocation can be redirected to another use.

For a new affordable housing site, the funding analysis should proceed in this sequence:

1. Define the project activity.

New construction, rehabilitation, infrastructure work, public facility improvements, and housing services may be treated differently for program purposes. The application must state the activity precisely.

2. Define the service area.

The geographic area used to measure benefit must correspond to the project. A vague or oversized service area can weaken the LMI calculation. A narrowly drawn area may better reflect the actual residents served, but it must be supportable.

3. Test the LMI threshold.

For an Area Benefit activity, at least 51% of residents in the project service area must qualify as low- and moderate-income. The calculation is not satisfied by describing the county as economically distressed in general terms.

4. Separate project eligibility from cumulative program performance.

The state must direct 70% of its total CDBG allocation to LMI individuals over a three-year period. That cumulative standard does not replace the project-level requirement. Both levels matter.

5. Document local and state alignment.

The site should support the county’s housing objectives and, where applicable, the municipal growth and revitalization framework. A location that cannot be explained through adopted planning documents becomes a weaker competitive application.

A low acquisition price does not make a site affordable if flood elevation, utility extension, and grant-compliance costs eliminate the project margin.

The unknown element is equally important. The specific local endorsement steps and internal deadlines required by the Somerset County Economic Development Commission for non-entitlement CDBG applications should not be assumed. They must be confirmed before the application schedule is fixed.

Affordable housing zoning in Somerset County: what a variance can and cannot solve

A variance is not a general-purpose approval mechanism. In Somerset County, zoning variances are limited to dimensional and setback adjustments. They cannot change density, reduce required lot size, or authorize a prohibited land use.

This limitation should be incorporated into the first feasibility memorandum. If a proposed multifamily project depends on a variance to create the underlying use, the site is not merely difficult. It is incorrectly selected for that development program.

Permitted use comes before dimensional relief

The analysis should distinguish four separate questions:

• Is multifamily housing a permitted use in the zoning district?
• If not permitted by right, is it an expressly authorized conditional or special use?
• Does the proposed unit count comply with the district’s density controls?
• Can any dimensional deficiency be addressed through a lawful variance?

Only the fourth question concerns variance relief. The first three concern use authorization and density. They cannot be collapsed into a single request for flexibility.

A project may require relief from a side-yard setback or a building separation standard because of an irregular parcel. That is a dimensional problem. A project may also require a higher density than the district permits to achieve financially viable rents. That is a density problem. The second issue cannot be converted into the first by changing the wording of the application.

Common zoning failures in multifamily site selection

1. Selecting a parcel based on acreage alone

Gross acreage does not equal buildable acreage. Floodplain areas, access easements, drainage requirements, utility corridors, environmental constraints, and required setbacks reduce the usable development envelope.

2. Treating a municipal boundary as an administrative detail

Princess Anne and Crisfield have municipal zoning authority. Their standards must be reviewed independently from county standards. A county zoning interpretation cannot substitute for a municipal determination.

3. Assuming that affordable status creates automatic zoning flexibility

Income-restricted units do not, by themselves, authorize a prohibited land use or eliminate setback requirements.

4. Using a variance strategy to repair an incompatible site

A variance cannot cure prohibited use, excessive density, or noncompliant lot size. The site must be legally suitable before dimensional relief is considered.

5. Preparing a grant application before resolving use authorization

A funding narrative cannot compensate for an unresolved zoning pathway. Grant reviewers may accept a concept, but construction and occupancy still require statutory compliance.

The appropriate comparison is therefore not “which parcel has the lowest purchase price?” It is “which parcel reaches a lawful, fundable, and serviceable development configuration with the fewest unresolved approvals?”

Floodplain elevation is a direct capital-cost variable

Floodplain review is not a late-stage environmental formality. It affects the building footprint, finished-floor elevation, foundation system, site grading, accessible routes, parking configuration, stormwater design, utility placement, and construction cost.

The controlling standards in Somerset County and its municipalities are not identical:

• Somerset County: Flood Protection Elevation equals Base Flood Elevation plus 1 foot of freeboard.
• Princess Anne: Flood Protection Elevation equals Base Flood Elevation plus 2 feet.
• Crisfield: Flood Protection Elevation equals Base Flood Elevation plus 2 feet.

The one-foot difference between county and municipal requirements can alter the building section and the site plan. It should be included in the initial pro forma rather than treated as a contingency.

A practical floodplain comparison

The table does not establish that one jurisdiction is categorically cheaper. Construction cost depends on the actual BFE, parcel topography, soil conditions, access geometry, utility location, building type, and the number of units. It establishes only that the controlling freeboard requirement differs and must be priced accordingly.

The flood review sequence

A site-specific flood analysis should follow a fixed order:

1. Identify the applicable jurisdiction and floodplain ordinance.

2. Confirm the mapped flood zone and the relevant Base Flood Elevation.

3. Calculate the required Flood Protection Elevation.

4. Determine whether the parcel can accommodate the elevated structure, compliant access, parking, drainage, and utilities.

5. Test whether the resulting building footprint remains compatible with setbacks and easement delineations.

6. Update the construction budget and operating assumptions.

7. Reassess grant competitiveness after the flood-related costs are included.

The last step is necessary because a site can satisfy zoning and still fail financially. A compliant building that cannot maintain affordable rents or secure sufficient public funding is not a viable affordable housing location.

Princess Anne and Crisfield: planning alignment as a site-selection variable

Princess Anne and Crisfield are not interchangeable development environments. Both exercise municipal zoning authority, and both must include municipal growth elements under Maryland Land Use Article §3-102. The applicable plan language, local priorities, infrastructure conditions, and revitalization objectives must be reviewed separately.

The municipal growth element is the relevant planning instrument because it connects land-use decisions to the location and timing of development. For affordable housing, that connection can affect:

• whether residential growth is directed toward the proposed location;
• whether the project supports an adopted neighborhood or downtown objective;
• whether infrastructure investment is consistent with planned growth;
• whether the municipality can explain the project as part of a broader community development strategy;
• whether a state revitalization application has a clear local planning basis.

The October 1, 2026 reorganization of the municipal growth element as a subelement under the land element should be treated as a document-control issue. A project team preparing applications across that date must identify which adopted plan version, amendment, or reorganized element governs the submission.

Princess Anne

For a Princess Anne site, the analysis should connect the proposed housing program to the town’s adopted growth and land-use framework. It should also identify the municipal floodplain requirement, zoning district, available infrastructure, and any relationship to existing housing or service investments.

The February 2026 Maryland Affordable Housing Trust award of $133,962 to Operation Pathways included self-sufficiency services at The Residences at Pine Knoll in Princess Anne and other Eastern Shore sites. That award does not establish a new construction location. It does, however, demonstrate that housing-related services and resident-support programming are part of the regional development context.

A new project in Princess Anne should therefore distinguish between:

• physical development of additional housing;
• rehabilitation of existing units;
• supportive or self-sufficiency services;
• municipal infrastructure or neighborhood improvements.

These activities may involve different funding programs, eligible costs, and performance measures. Combining them in a single narrative without separating the activities creates compliance ambiguity.

Crisfield

For a Crisfield site, the same planning analysis applies, but the municipal code and floodplain requirements must be reviewed directly. Crisfield’s municipal requirement of BFE plus 2 feet of freeboard is a controlling design input.

A proposed location should be tested against the city’s adopted growth framework and any relevant revitalization objectives. The project team should not infer site eligibility from the existence of a general Crisfield revitalization effort. The specific parcel, use, density, access, elevation, and service-area benefit still require independent documentation.

The correct comparison between Princess Anne and Crisfield is therefore procedural:

• Which municipality permits the intended residential use?
• Which site produces the more manageable floodplain design?
• Which location has available infrastructure?
• Which municipal plan provides the stronger documented alignment?
• Which service area can support the required LMI benefit calculation?
• Which jurisdiction can complete local review within the grant schedule?

No exact future affordable housing development locations are established by the available information. Site-specific claims must remain separate from general municipal planning objectives.

LMI benefit is a site attribute, not a narrative appendix

For CDBG-funded activities, the LMI analysis must be tied to the project’s defined service area. At least 51% of residents in an Area Benefit service area must qualify as low- and moderate-income. This makes demographic geography part of the site-selection process.

The relevant question is not simply whether Somerset County has housing need. The question is whether the proposed project serves a properly defined area that meets the applicable program standard and can be documented through accepted data and methodology.

Comparing candidate service areas

A service area should be examined for:

• geographic boundaries that correspond to the actual project benefit;
• residential population affected by the activity;
• available LMI data;
• relationship between the proposed units and the surrounding neighborhood;
• whether the project serves a concentrated area or a dispersed countywide population;
• consistency between the service area, application narrative, and project budget.

A countywide statement may be appropriate for a countywide housing rehabilitation program, such as the FY 2026 award designed for owner-occupied properties. It may not be appropriate for a single-site multifamily development whose direct benefits are concentrated in one neighborhood or municipality.

The distinction matters because a project can have a strong affordable-housing purpose and still fail the selected CDBG national-objective test if the service-area methodology is unsupported.

Income limits and housing-program design

The Maryland Housing Rehabilitation Program in Somerset County provides assistance for critical health and safety repairs. For 2026, the stated income limits are $79,800 for a single-person household and $114,000 for a four-person household, representing 120% of Area Median Income.

These limits are relevant to rehabilitation-program eligibility. They should not be automatically substituted for the LMI standard used in a CDBG Area Benefit calculation. Different programs can use different income definitions, thresholds, household assumptions, and eligible activities.

A project matrix should separate the standards:

This separation prevents a common administrative error: treating any income-restricted housing program as interchangeable with the LMI requirements attached to CDBG funding.

Funding timing should be built into the parcel comparison

State and federal programs impose different schedules. The Maryland Department of Housing and Community Development opened the Housing Choice Voucher Program waiting list for Somerset County and the Eastern Shore from April 1 through April 30, 2026. That event concerns access to rental assistance and does not constitute a development award, zoning approval, or guarantee of project financing.

The FY2028 State Revitalization Programs application cycle opened June 22, 2026, and closed August 6, 2026. A development team evaluating sites for a future cycle should use the published cycle as a scheduling reference, not as evidence that a particular parcel will be funded.

A compliant schedule should place the following tasks before the application deadline:

1. Confirm jurisdiction and zoning authority.

2. Obtain a written use and density determination.

3. Establish the preliminary building program.

4. Complete floodplain and elevation screening.

5. Identify required easements, access rights, and utility connections.

6. Define the CDBG service area, if CDBG funding is proposed.

7. Test the LMI benefit percentage.

8. Obtain required municipal or county endorsements.

9. Reconcile the capital budget with flood and infrastructure costs.

10. Submit only after the site narrative and statutory compliance record agree.

The exact internal endorsement steps and deadlines for Somerset County non-entitlement CDBG applications are not established in the available record. They should be confirmed directly before the schedule is treated as final.

A decision framework for comparing Somerset locations

The most reliable site comparison uses a pass-fail sequence rather than an unweighted score. A parcel that fails a threshold requirement should not receive a high strategic score because it has favorable acquisition economics.

Pass 1: legal use

Reject or redesign any site where the intended housing use is prohibited and cannot be authorized through the applicable zoning mechanism. Do not rely on a variance to create density, reduce lot-size requirements, or authorize a prohibited use.

Pass 2: buildable envelope

Map setbacks, easement delineations, access, drainage areas, floodplain limits, utilities, and required separation distances. Calculate the usable envelope, not the gross parcel area.

Pass 3: floodplain cost

Apply the correct freeboard requirement. For county land, use BFE plus 1 foot under Ordinance No. 93. For Princess Anne and Crisfield, use BFE plus 2 feet. Price the resulting structure and site work.

Pass 4: infrastructure

Determine whether water, sewer, roads, stormwater management, and emergency access are available at the required capacity. If extensions are necessary, identify the responsible party, estimated cost, approval sequence, and funding source.

Pass 5: planning consistency

Match the project to the applicable county or municipal comprehensive-plan framework. For Princess Anne and Crisfield, review the municipal growth element and account for the October 1, 2026 reorganization.

Pass 6: benefit and funding

Define the service area. Test the 51% LMI requirement for CDBG Area Benefit activities. Separate CDBG rules from MHRP income limits and from Housing Choice Voucher administration.

Pass 7: implementation risk

Rank remaining parcels by unresolved approvals, acquisition conditions, flood exposure, infrastructure dependency, and local coordination requirements. The preferred site is the one with the clearest path to construction and long-term compliance.

In Somerset County, the preferred affordable housing site is the parcel with the strongest documented compliance pathway—not the parcel with the largest area or the lowest asking price.

Final determination

Somerset County affordable housing site selection requires a jurisdiction-specific analysis. County and municipal parcels are subject to different floodplain elevation standards, different planning documents, and different administrative pathways. Princess Anne and Crisfield must be evaluated independently under their municipal zoning authority and growth-element requirements.

The funding analysis is equally specific. Somerset County competes for state-administered CDBG funds as a non-entitlement jurisdiction. A project must satisfy the applicable national objective, including the 51% LMI Area Benefit threshold where that method is used. The state’s 70% cumulative LMI requirement operates at the program level. MHRP income limits and Housing Choice Voucher activity address separate program functions.

The site-selection sequence is definitive:

• establish the governing jurisdiction;
• confirm permitted use and density;
• calculate the buildable envelope;
• apply the correct floodplain elevation standard;
• verify infrastructure and easement conditions;
• document comprehensive-plan alignment;
• define and test the LMI service area;
• reconcile the capital budget with every statutory requirement.

A parcel that cannot pass those tests is not a viable affordable housing site, regardless of its purchase price or proximity to an established community development objective.