Streetscapes Program FAQ

• A: Project Delivery
• A2: Tier II Review after being awarded are also PD.

No, according to Iowa Code chapter 28E, not required if performed by a COG.

Yes

This is dependent upon the program applied for. Section 106 and some ERR processes can always start prior to the Application, and this can result in higher scores for readiness. Upper Story and other rehabilitation programs require a 2-tier ERR and have a different process to follow:

• “Responsible Entity” (the Applicant UGLG) completes an initial environmental review at a broad or programmatic level, followed by site ‑specific environmental clearance at a later stage:
• The first tier (draft ERR – unsigned, unpublished) evaluates the proposed project (typically a rehabilitation program of some kind) and the types of activities to be undertaken and identifies applicable environmental laws and authorities that can be addressed without knowing the specific project sites.
• The second tier is completed once individual properties are identified and addresses site specific environmental conditions—such as historic preservation, floodplain status, contamination, and other property specific environmental conditions— ‑specific environmental conditions—such as historic preservation, floodplain status, contamination, and other property‑level factors—before any rehabilitation work or choice limiting‑limiting actions occur.

If you attended the Third Thursdays prior to September 1, 2025, you will not be required to take the Basic Training Course. However, if you started attending on or any time after September 1st, you will be required to. Notifications and instructions will be sent out soon to start that process.   

Q: I have current projects who we are moving forward and am doing my contractor clearance checks on possible contractors and subs. I know that a SAM.gov registration isn’t required and a UEI is. What if I can’t find an active UEI account on SAM.gov? I typically do an entity search prior to the exclusion search. Some will note that they don’t have a full SAM.gov registration however they do have an active UEI#. If it does not show that they have an active UEI, however the engineer is able to provide the UEI #, would that work?

A: This is a common problem, but NO - If an entity does not appear in SAM.gov with an active UEI record, simply providing a UEI number is not sufficient for contractor clearance. IEDA’s Contractor Clearance Policy requires two separate checks for all vendors:

• 1) Verification of a valid Unique Entity Identifier (UEI)
• 2) Confirmation that the entity is not debarred, suspended, or otherwise excluded, as documented in SAM.gov:
  • SAM.gov entity search (business entity name) and
    • SAM.gov exclusion search (both biz entity level & Owner)

A UEI must be verifiable in SAM.gov for IEDA to complete the required exclusion / debarment review. Even entities that are not fully registered must still have a basic SAM.gov entity record to be issued a UEI and be searchable in SAM for exclusion (debarment) purposes. If a vendor provides a UEI number, but does not appear in SAM.gov under an entity search or exclusion search, then one of the following is likely true:

• The entity has not completed the SAM entity registration process,
• The record is inactive, incomplete, or incorrectly entered, or
• The UEI provided is invalid or associated with a different legal entity name

In these situations, IEDA cannot accept the UEI number alone. The vendor must create or update their SAM.gov entity record, at least to the level needed to obtain a UEI, and be searchable in SAM.gov. Also, the vendor must ensure the legal business name and address match what is being used for the contract. Once the entity appears in SAM.gov, or is able to provide proof of registration confirmation and the UEI can be verified, IEDA can complete the required exclusion check.

Q: Can a design professional be used that was not procured according to federal requirements since a Streetscape project could be undertaken without the consideration of CDBG funding inclusion?

A: All design professionals must be procured following the CDBG Procurement Policy to be included in the CDBG project budget.  The only exception to this would be if a design professional had already been working with the city on this specific scope of work before the city was aware that CDBG funds were available to apply for this project.  “Working with” is defined as: the design professional is already under a signed contract, the city has already been paying the design professional for their services for this particular scope of work, and/or the design professional has already created deliverables for this particular scope of work (such as design renderings, detailed cost estimates, and/or construction bid documents).

A2: The link to the webpage that addresses the RFQ process can be found on the CDBG Program Guidance and Related Resources page.

This program was designed as a “phase II” option for communities that have already invested significant sums into their downtown core (via a CDBG Commercial Facades project) and are now looking for assistance to put “icing on the cake” by investing in their streetscapes.  Completing a Commercial Facades project (previously known as “DTR”) is a keyway to demonstrate significant commitment to downtown revitalization.  This program seeks to capitalize on that commitment.

Q: In the instance of a community that has experienced a drastic change in the ACS data set for LMI %, what steps should be taken to demonstrate / justify the ACS errors and pursue an Income Survey?

A: It is understood that the ACS data for some communities has a higher margin of error than others, creating challenges. Generally, a citation of the ACS data and the margin of error demonstrating skewed data is sufficient to warrant an income survey. However, please see Question #3 on Page #4 regarding a similar issue regarding changes in LMI data from ACS as these scenarios require involvement with case-by-case specific evaluation.

A2: In other cases, a community may have experienced a significant demographic shift in the years since the ACS data was collected.  For example, old industries may have left the community, or alternatively new ones may have been created.  Population may have aged significantly, or conversely the community may have experienced a sudden increase in new, younger families. Natural disasters, annexation of land, consolidation of school districts, creation of new housing developments – anything that would have significantly changed the demographics of a community would be supported.  The city should just be able to describe this shift and explain when, why, and how it has manifested.

No. The application will be evaluated on a variety of things; the National Objective (LMA or SBA) will be one way, the degree of need will be another, the degree of impact in the community will be a third… all applications, regardless of which National Objective they use, should have a goal of revitalizing or growing their downtown commercial core.  Similarly, regardless of whether an application is using LMA or SBA, if the goal is simply to displace local maintenance/CIP funds or to simply install new features for the sake of installing new features, without any clear indication of how this will respond to need in the community and create that revitalizing impact, an application will score lower. 

Q: For the LMI justification, is that required for each program or just the streetscapes? Do you need to contact IEDA prior to starting an LMI to talk through the justification and confirm that a survey is justified?

A: To determine whether any sort of justification for conducting a local income survey is required for any other program, please refer to the Program Guidance. If there are still questions, please reach out to IEDA staff.  For Streetscapes, there should be some sort of justification included in the application if the applicant chooses to conduct a survey rather than simply use ACS data.

A2: You do not need to contact IEDA prior to starting a local income survey to confirm justification.  There will be a field in the IowaGrants.gov application where the applicant will explain why they conducted a survey rather than use the existing ACS data.  For guidance on what information should be entered there, see question 3 above.  IEDA will be looking to see that such a justification exists, not looking to review/approve the justification itself. 

Q: If the City is considering the streetscape program and wants to use blight as the national objective, what do they need to have to document blight?

A: The UGLG Applicant must provide a resolution defining the blighted area, with photos/narrative documenting the current blighted status, and  a new or revised urban renewal plan (if applicable, see below).

The Streetscapes program must align with 24 CFR 570.208(b)(1)(ii)(B), which states the following:

• Activities to address slums or blight on an area basis. An activity will be considered to address prevention or elimination of slums or blight in an area if:
  • (i) The area, delineated by the (sub)recipient, meets a definition of a slum, blighted, deteriorated or deteriorating area under State or local law;
  • (ii) The area also meets the conditions in either paragraph (A) or (B):
    • (B) The public improvements throughout the area are in a general state of deterioration.

Following the provisions of 24 CFR 570.208 above, we then pivot to Iowa Code Chapter 403.17, where by  “blighted area” is defined in part by the phrases, “defective or inadequate street layout,” “insanitary or unsafe conditions,” “deterioration of site or other improvements”.

With the above context provided, the city may utilize the definitions provided in Chapter 403.17 to define slum and blight to align with the federal requirements found in 24 CFR 570.208 and pursue the SBA national objective by passing a resolution that clearly cites the connection of this definition for the project area.

To document the current blight, applicants should create a PDF file that demonstrates that at least half of the existing streetscape components are in a general state of deterioration.  Notes for putting this document together:

• Include labeled photos of existing streetscape elements and their current condition. Note: photos that are both close-up for detail and wide-angle for context are appreciated.
• Additionally, an applicant may include compare and contrast photos to demonstrate the degree of deterioration.  For example, including a photo of one block of sidewalk that is in good condition and then a photo of the next block of sidewalk that is in poor condition.
• Each photo should have a narrative description.  As an aide when writing these narratives, please refer to the application workshop slides for a list of what is and isn't blight.
• Remember: the document should do more than illustrate a few sample snapshots of blight. It should clearly demonstrate that at least half of the existing streetscape elements are in a general state of deterioration.

• Note: if the project is located within an Urban Renewal Area, and Applicant seeks to utilize TIF or other Urban Renewal financing methods for their form of Match, then an Urban Renewal Plan (new, or revised of existing) will be required as part of the Application.