Planning Grant 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• The first tier (draft ERR – unsigned, unpublished) evaluates the proposed project (typically a rehabilitation program of some kind) and the types of activities to be undertaken and identifies applicable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.

Yes – those projects that have identified past adopted Plans will score higher on subsequent CDBG Applications. 

Q: Will non-profits qualify as eligible applicants? Or would they apply through a Council of Government?

Q2: Can the same COG be both the entity writing the plan and the entity administering the planning grant?

A: For the Planning Grants program, all Applicants must be a Unit of Local Government (i.e. a City or County) and may hire a CGA (COG or consultant) or other professional consultant firm to perform any of the Plans, provided they have experience and capacity to do so, according to the standards cited in the Program Guide. Further, the entity performing role of grant administration may perform the Plan or Study Activity, but only when the Applicant team can clearly demonstrate that the work is performed under distinct contracts and by distinct individuals to ensure there is separation of compliance oversight duties. This applies to COG or procured consultant equally and aligns with the CGA Policy. Note, SHPO has specified standards for such experience and certifications that must be followed for conducting Historic District Surveys. 

Q: Since the State Historic Preservation Office (SHPO) already funds intensive historic surveys, what is the goal of funding those with these funds and can Certified Local Government (CLG) Program match the CDBG funds?

A: Two Programs, Different Purposes:

• Iowa SHPO Historical Resource Development Program and CLG grants are designed to identify and evaluate historic resources for preservation purposes, including the National Register for eligibility and documentation.
• IEDA’s CDBG funded historic district survey grants are planning activities under the community development framework, where surveys are a means to community development neighborhood revitalization, not an end in themselves.
• As the plans must be linked to a future CDBG project, this aligns with community development and/or neighborhood revitalization efforts.

A2: Please see the Planning Grants Appendix regarding “Best Practices for Historic District Surveys” for greater detail. 

Yes – the application just requires dollar-for-dollar match, based on the application amount submitted. 

A: Future CDBG-funded infrastructure repair or replacement project that occurs because of the community’s adopted Asset Management Plan, in recognition of any noted assets that are demonstrating a failure risk or the useful life is expiring, would be a good example.

A2: The same could be applied to projects resulting from a Capital Improvement Plan.

A1: Applicants should acquire proposals from vendors that demonstrate robust experience in providing such plans, and the capacity to complete them in the terms of the grant agreement.

A2: However, regarding Asset Management Plans (AMPs) and Capital Improvement Plans (CIPs), Iowa Code Chapter 542B does clarify they are NOT required by Iowa law to be prepared by a licensed professional engineer, unless they include engineering design, plans, specifications, or calculations. A licensed Iowa professional engineer (PE) IS required once a plan advances into Engineering design, Construction documents, Permit applications, Plans submitted for regulatory approval. Since these plans must be linked to a future CBG-funded project, it is highly advised that an Applicant secure the services of an Iowa state licensed engineer to prepare these plans so they can be utilized in future projects and perhaps avoid duplicative costs.

A3: For Historic District Surveys, SHPO establishes minimum Professional Qualification Standards in their program rules, which according to the Program Guide, IEDA will also require adherence to SHPOs program rules: Iowa SHPO Architectural Survey Guidelines