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CDA cautions applicants: site control, environmental review, Davis‑Bacon and Section 3 requirements before construction
Summary
CDA reviewed the extra requirements for public-improvement and facility projects, including site control, environmental review before bids, Davis‑Bacon labor standards, Section 3 outreach and Buy America considerations, and prior CDA approval for procurement and RFPs.
CDA staff gave detailed guidance for applicants proposing public-improvement or facility construction projects with FY2026 CDBG funds, stressing multiple pre-construction compliance steps and monitoring obligations.
Golve Fethi, a CDA program manager, said applicants must demonstrate site control — for example, ownership or a lease with an allowance to rehabilitate — and provide design documents, construction budgets and photographs at application. She emphasized that CDA will complete a HUD-required environmental review and that construction cannot start until that review and any required Section 106 historic-preservation consultations are complete. "If you start doing the things like putting out for bids or doing construction prior to this happening, then that could lead us to have to rescind your funding," she warned, describing a "choice-limiting action."
On labor standards, the training covered Davis‑Bacon requirements (presenters said Davis‑Bacon applies to public-improvement or facility activities that meet the specified award threshold described in the RFP) and described certified payroll, worker interviews and CDA monitoring. Golve said CDA will require Section 3 plans and monitoring for larger projects; presenters noted Section 3 documentation (business certification, worker certification, quarterly and final reports) must be submitted and approved by CDA before construction begins. CDA also reviewed procurement practices: applicants should share draft RFPs with CDA for prior approval, advertise appropriately, and select the lowest responsive bidder unless a documented exception is approved.
CDA staff noted that Build America/Buy America (BABA) provisions can apply to projects with larger total development costs and that project-specific waivers must follow HUD guidance. The presenters emphasized that federal requirements for public improvements will apply across the entire project's capital stack if CDBG funds are used in the project.
CDA said it will provide templates and a pro forma workbook to help applicants assemble construction budgets and other required materials, and CDA program monitors will work with awarded agencies to ensure compliance through procurement, Section 3, Davis‑Bacon and other required steps.
