To all Iowa State Revolving Fund (SRF) customers and recipients:
This announcement addresses recent changes stemming from the Interim Final Rule (IFR) issued by the U.S. Department of Transportation (DOT), effective October 3, 2025. This IFR ensures that the DOT’s DBE programs operate in a nondiscriminatory fashion consistent with the U.S. Constitution, primarily by removing race- and sex-based presumptions of social and economic disadvantage.
Impact on the Iowa DBE Directory:
In response to the IFR, the Iowa Department of Transportation (DOT) DBE Directory application is currently offline. The Iowa DOT is undertaking a reapplication process. Existing DBEs must reapply for their status, and a new DBE directory/list will not be published until this process is complete. The DOT will be working with USDOT/FHWA to develop guidance regarding the implementation of the IFR.
Continuing Requirement for Good Faith Efforts (GFEs):
Despite the unavailability of the Iowa DOT certified DBE directory, the EPA’s SRF DBE requirements for Good Faith Efforts (GFEs) still apply to projects funded by the Iowa State Revolving Fund (SRF).
As an alternative, SRF borrowers may use the services and assistance of the Small Business Administration (SBA) and the Minority Business Development Agency of the Department of Commerce.
https://search.certifications.sba.gov/
The DBE program is intended to level the playing field for small businesses owned and controlled by socially and economically disadvantaged individuals. A recipient of SRF funding is required to make Good Faith Efforts whenever procuring construction, equipment, services, and supplies under an EPA financial assistance agreement.
Guidance on Implementing Good Faith Efforts:
Because the DOT is removing the existing list of certified DBEs, it may be harder to determine if a contractor is a DBE during the outreach process. However, SRF recipients and contractors must still complete required SRF forms, such as Front-End Attachments 3, 4, and 5 (as applicable), to the best of their ability.
Good Faith Efforts for utilizing Minority Business Enterprises (MBEs) and Women Business Enterprises (WBEs) must be documented and are subject to EPA review upon request. These efforts include, but are not limited to:
- Ensuring DBEs are made aware of contracting opportunities to the fullest extent practicable through outreach and recruitment activities. For State and local government recipients, this involves placing DBEs on solicitation lists and soliciting them whenever they are potential sources.
- Making information on forthcoming opportunities available to DBEs and arranging time frames for contracts and delivery schedules in a way that encourages participation. This includes, whenever possible, posting solicitations for bids or proposals for a minimum of 30 calendar days before the bid or proposal closing date.
- Considering in the contracting process whether firms competing for large contracts could subcontract with DBEs.
- Encouraging contracting with a consortium of DBEs when a contract is too large for one firm to handle individually.
- Using the services and assistance of the Small Business Administration (SBA) and the Minority Business Development Agency of the Department of Commerce.
https://search.certifications.sba.gov/
Post-Project Reporting Obligations:
SRF borrowers are also still required to report their actual usage of DBE contractors/subs upon completion of the project. If a contractor or subcontractor was identified as a DBE when contractors were selected for an SRF project, that usage is still applicable to be reported as DBE usage at the conclusion of the project, regardless of whether their status changed due to the interim rule or recertification process.