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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 mid-May 2026, twenty-two states have published a formal nomination process; the remaining twenty-eight have identified a lead agency and contact but not yet opened a public submission channel. Several states with open processes have deadlines in May and June 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. EIG's OZ 2.0 resources page maintains the most current designation leads map; the HUD OZ portal also lists state leads but lags on process-specific updates.

States that have closed public input — Florida, Nebraska, Virginia, Delaware, Missouri, and New Mexico's COG submission phase all closed by mid-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 Portal
Arizona June 30, 2026 Submit →
Colorado June 30, 2026 Submit →
Idaho June 30, 2026 Submit →
Minnesota June 30, 2026 See state page
West Virginia July 1, 2026 Submit →
Ohio July 10, 2026 Submit →
Georgia July 15, 2026 Submit →
Alabama July 31, 2026 Submit →
Wisconsin July 31, 2026 Submit →
Maryland August 7, 2026 Submit →
Massachusetts September 28, 2026 Submit →
17 states — input closed
Texas June 26, 2026 — closed In review
North Carolina June 21, 2026 — closed In review
Oklahoma June 19, 2026 — closed In review
South Carolina June 15, 2026 — closed In review
Pennsylvania June 5, 2026 — closed In review
Kansas June 1, 2026 — closed In review
Mississippi May 31, 2026 — closed In review
Kentucky May 29, 2026 — closed In review
Washington May 28, 2026 — closed In review
Oregon May 22, 2026 — closed In review
Missouri May 17, 2026 — closed In review
New Mexico May 15, 2026 — closed In review
Delaware May 15, 2026 — closed In review
Nebraska May 1, 2026 — closed In review
Maine April 30, 2026 — closed In review
Florida April 30, 2026 — closed In review
Virginia April 27, 2026 — closed In review

Source: state agency pages. Deadlines update automatically from state records — check individual state pages for current portal links.

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.

Accelerator for America — OZ Designation Toolkit

Walks local leaders through a five-step OZ Prioritization Framework — eligibility screening, market readiness, community needs assessment, local data integration, and making the case to state officials — backed by a downloadable tract-scoring rubric that evaluates market conditions and four community-need dimensions (housing supply, economic opportunity, industry growth, fiscal base). Includes anti-displacement guidance and stakeholder engagement checklists. Produced by Accelerator for America with Rvesta Consulting and New Localism Associates. Download PDF → Open Scoring Rubric → Download Tract Dataset →

One more element worth addressing honestly: OZ 1.0's track record in urban markets. Research by the NCRC (2025) and the Urban Institute (2025) found that despite $100 billion flowing into OZ 1.0 tracts between 2018 and 2024, evidence of community benefit — reduced poverty, job creation for existing residents — is thin, and investment was concentrated in already-appreciating urban tracts rather than the most distressed communities. For a state agency evaluating your submission, this history is context: if your tract is in an urban market that saw luxury residential investment under OZ 1.0 with no community benefit, acknowledge that history and document what accountability structures your nomination would carry.

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.

The Accelerator for America OZ Designation Toolkit includes practical guidance on translating state scoring criteria into nomination documentation — useful whether your state has published a formal rubric or not.

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, housing authorities, tenant organizations, and neighborhood associations who are already operating in the tract should all 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. Residents and tenants are often the most credible voices in a nomination packet — a letter from an organized tenant association in a potential workforce housing development carries weight that no developer projection can replicate.

OZ 2.0's new investor reporting requirements (IRC §§ 6039K, 6039L) give communities real accountability tools. QOFs must now track and report employment, housing units, and business activity — which means any community benefit agreement (CBA) you negotiate with a QOF investor can be tied to metrics the investor will produce by law anyway. Consider making CBA commitments (local hiring preferences, affordable housing set-asides, community advisory representation) a formal condition of your local political support for nomination, before the designation is made — not an afterthought once a developer arrives. See OZ 2.0 reporting and CBAs for the legal basis.

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

Twenty-eight states are in the "contact only" tier as of mid-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. EIG's designation leads map 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; Accelerator for America OZ Designation Toolkit; IRS Rev. Proc. 2026-14. State deadline data verified May 12, 2026 — check state pages for current status.