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OZ 2.0 | State Resource

How to Advocate for Nomination

Opportunity Zone designation runs through governors, not local governments. A city council, county commission, or EDD cannot directly nominate a tract — but local planners and community organizations are the ones who can make a tract nomination credible to a state agency. This page lays out how to do that work effectively before your state's window closes.

Step one: find your state's process

As of early May 2026, eighteen states had published a formal nomination process; the remaining thirty-two had identified a lead agency and contact but not opened a public submission channel. About a third of the states with open processes have deadlines in May 2026 — well before the federal window opens July 1.

Your first step is to confirm which tier your state is in, then go directly to the lead agency's landing page. The state directory on this site links to each agency's OZ 2.0 page and, where available, the direct submission portal. The HUD OZ portal maintains the authoritative state lead directory.

States that have closed public input — Nebraska and Florida had done so by early May — are not necessarily done. The governor still makes the final selection, and direct engagement with the lead agency remains meaningful even after a formal comment period closes.

Upcoming state deadlines

Several state nomination windows close in the coming weeks. These deadlines are for state-level input — the federal nomination tool opens July 1, 2026, and closes September 29, 2026 (extendable to October 28). State processes gather community nominations before the governor's office makes its federal submission.

State Deadline How to submit
Delaware May 15, 2026 Formstack portal
Missouri May 17, 2026 Submittable portal
Oregon May 22, 2026 RFA submission
Washington May 28, 2026 RFA portal
Kentucky May 29, 2026 Application portal
Mississippi May 31, 2026 Online feedback form
Ohio ~May 31, 2026 Via Greater Ohio Policy Center
South Carolina June 1, 2026 SC Commerce portal
Kansas June 1, 2026 Direct email, scoring matrix
North Carolina June 7, 2026 Public feedback form
Texas June 26, 2026 Nomination submission
New Mexico July 1, 2026 COG-based submission

Source: state agency pages, verified May 5, 2026. Check your state's page for the current portal link.

Building the case: data your state will expect

Every state evaluating nominations will want to see that the tract meets the statutory low-income community thresholds — median family income at or below 70 percent of the area median, or a poverty rate of at least 20 percent paired with income at or below 125 percent of the area median. The IRS used 2020–2024 ACS 5-year estimates to build the eligible list; your advocacy documentation should use the same or more recent vintage.

Beyond eligibility, states are weighing investment readiness: Is there a project or developer ready to deploy capital? Is there a community development strategy in place? Does the tract have infrastructure that supports productive investment? The Urban Institute's data tool classifies eligible tracts by distress level and "Goldilocks" readiness — high-need but not so distressed as to deter private investment — which is a useful frame for making the case to a state agency.

For rural tracts, two additional overlays strengthen a nomination: the EIG Distressed Communities Index provides tract-level distress scores, and the USDA ERS persistent poverty county list identifies jurisdictions with sustained high poverty that often align with the strongest community need arguments. If your tract falls in a persistent poverty county, say so explicitly in any submission.

The Sorenson Impact Center's Rural Opportunity Zone and Recovery Playbook and the NADO OZ 2.0 Resource Guide both offer practical frameworks for rural jurisdictions preparing nomination packages.

Understanding your state's scoring criteria

Several states have published scoring matrices that reveal exactly what they're looking for. Kansas and Texas have released the most detailed rubrics; Oregon and Washington published formal requests for applications with explicit criteria; North Carolina released three scoring criteria with a public feedback form. Even in states without published criteria, the EIG Guide for Governors and Mayors and the Frost Brown Todd/Gibbons Strategic Selection guide articulate the factors that experienced practitioners expect governors to weigh: community need, investment readiness, geographic diversity, and local government engagement.

Read the criteria before you submit. A common mistake is submitting a tract solely on need metrics when the state is also weighting project pipeline. If your jurisdiction doesn't yet have a developer or investor interest, be honest about that — and document any existing community development plans, CDFIs operating in the area, or prior OZ 1.0 activity that signals readiness.

Coalition strategy

A nomination submitted without political backing is easy to pass over. The most durable approach is to secure a letter of support from the highest local elected official available — mayor, county executive, or tribal council chair — before submitting. State legislators representing the district, especially if they sit on economic development committees, are also worth engaging early.

For jurisdictions that have a regional planning council or COG (Council of Governments), working through that entity often provides a more credible channel to the state. New Mexico's process is explicitly COG-based; in other states, regional economic development organizations carry informal weight with the lead agency. The NADO network and the six RCAP regional partners can help identify the right regional intermediary in your area.

Local CDFIs, community development corporations, and housing authorities who are already operating in the tract should be part of any submission. Their presence signals that community-serving capital is ready to deploy, not just speculative investment looking for a tax shelter.

In states with significant tribal land overlap — Washington is the clearest example, with formal tribal consultation required under Governor Ferguson's executive order — initiating government-to-government consultation as early as possible is both a legal obligation and a prerequisite for a credible application.

If your state has no public process yet

Thirty-two states are in the "contact only" tier as of early May 2026 — a lead agency is identified and reachable, but no formal nomination channel has been announced. This is not a reason to wait. States in this tier are likely still developing their process internally, and early outreach to the lead agency can shape what that process looks like.

A cold email to the agency contact with a brief summary of your tract — its eligibility status, community development context, and any investor interest — puts your jurisdiction in front of staff before the official window opens. Follow up monthly. The HUD OZ portal and OpportunityZones.com track state-by-state developments as they happen.

If your state has no identified process and no clear agency engagement, the most direct path is to work through your state legislators to push the governor's office for a public designation process. The federal window doesn't close until late September — states that move deliberately still have time.

Key references: EIG Guide for Governors and Mayors; EIG, "Where Things Stand After OBBBA" (Aug 2025); Frost Brown Todd/Gibbons, "A Governor's Guide to Best Practices" (Nov 2025); NADO OZ 2.0 Resource Guide; IRS Rev. Proc. 2026-14. State deadline data verified May 5, 2026 — check state pages for current status.