Local Systems

IIJA Information

The Infrastructure Investment and Jobs Act (IIJA) (also known as the Bipartisan Infrastructure Law (BIL)) was signed into law on November 15, 2021.

  • IIJA includes reauthorization of surface transportation programs for FFY 2022 to FFY 2026.
  • It also includes $550 billion in new funding with half of that going to transportation.
  • Appropriations were approved in March 2022.

As you may be aware, the increase in new federal funds has impacted the Iowa DOT’s ability to provide Swap funds for Local Public Agency (LPA) projects. Over the past few years, Iowa has let Federal-aid Swap projects totaling over $150 million, annually. Future projections for Federal-aid Swap availability are $50 million annually, meaning the difference will need to be converted to Federal-aid. With this reduced Federal-aid Swap capacity, program changes are necessary. We’ve worked with the IIJA Stakeholders to determine the best use of Federal-aid Swap moving forward. We’re still working through some logistics, but we’re hoping the below transition guidance will minimize the pain and frustration.

Guidance sent to LPAs stated that all programs transitioning from Federal-aid Swap to Federal-aid will be required to be Federal-aid starting with the January 2023 letting for Counties and February 2023 letting for Cities.

Our team will be working on updating/preparing funding agreements affected by the new funding bill after the implementation recommendations are officially approved by the Transportation Commission on July 12th.

Microsoft Teams Meeting

The Transportation Development Division, Local Systems Bureau and Systems Planning Bureau hosted an online Teams Meeting where the IIJA information was presented on June 15, 2022. Here are the slides from the presentation and the meeting recording.

The Iowa DOT Commission passed the IIJA Implementation Policies on July 12. The Commission also passed a revised Federal-aid Swap Policy. Those documents are linked here:

Funding Conversion Summary and Implementation Guidance

Funding Conversion Summary: Existing Federal-aid Swap funding agreements all include a standard “Exhibit 1”. Within that Exhibit, under General Requirements, 1.e it states “… the DEPARTMENT shall have the right to terminate this agreement without penalty and without any advance notice as a result of any of the following… if any funds or revenues needed by the DEPARTMENT to make any payment hereunder are insufficient or unavailable.” Iowa DOT does not intend to “terminate” funds for Federal-aid Swap, but converting them back to Federal-aid due to cash-flow limitations is unfortunately necessary. The Local Systems Bureau will be working with the impacted local agencies to rescind existing Federal-aid Swap funding agreements and replace them with new Federal-aid funding agreements for the same value, in accordance with the below programs.

Programs to be converted to Federal-aid:
  • City Bridge Program
  • County Highway Bridge Program (HBP)
  • Surface Transportation Block Grant (STBG) Program for:
    • All County projects
    • All City projects awarded through TMAs and MPOs
  • Iowa’s Clean Air Attainment Program (ICAAP)

Programs to remain Federal-aid Swap:
  • Surface Transportation Block Grant (STBG) Program for city projects awarded through RPAs

Implementation for Counties: It was earlier requested that Counties convert any possible Swap projects to Federal-aid and stated that all Surface Transportation Block Grant (STBG) Program and County Highway Bridge Program (HBP) projects let in January of 2023 and later must be Federal-aid. This guidance remains the same. We very much appreciate any projects in the December letting being converted to Federal-aid as well.

Implementation for Cities: Starting with the February 21, 2023, Iowa DOT bid letting, the Surface Transportation Block Grant (STBG) Program , Iowa’s Clean Air Attainment Program (ICAAP), and the City Bridge Program will utilize Federal-aid, except for STBG funding awarded through a Regional Planning Affiliation (RPA). Please be cognizant to plan ahead and anticipate potential delays in project development; if for example a project is utilizing Swap funding for the January letting and experiences a delay during project development, the project must become Federal-aid to be in the February letting.

Federal-aid Conversion Information (NEPA & Programming)

Typically, when developing a Federal-aid project, NEPA clearance is required prior to starting final design. (Final design is considered to begin at check plan stage.) However, the Federal Highway Administration (FHWA) realizes that Swap projects did not begin project development as Federal-aid projects and that Swap projects did not require a NEPA clearance. They also recognize that some projects scheduled for letting both before and after February 2023 may have already begun the final design phase.

Because many of these projects will result in a Programmatic Categorical Exclusion (PCE), and because many of the projects only have the 2 alternatives of either the preferred alternative or a no-build alternative, FHWA has determined that, for these routine projects, and in only this situation of converting Swap projects to Federal-aid, obtaining NEPA clearance after check-plan submittal will not violate the NEPA requirement. However, if rare/unique changes occur that would require changes to the project based on any discoveries found during the NEPA process, appropriate actions will need to be taken, which could possibly result in re-design.  If you have concerns that obtaining a NEPA clearance could significantly delay the project due to very unique or special circumstances, please reach out to our Local Systems Urban Engineer or Secondary Roads Engineer to discuss options. For general project development questions, please reach out to our Project Development Team, Christy VanBuskirk and Joe Albright

Programming: Federal-aid projects must be properly programmed in the appropriate Regional Planning Affiliation (RPA) or Metropolitan Planning Organization (MPO) Transportation Improvement Program (TIP) prior to final plan turn-in. All of the RPA and MPO TIPs are then combined with the Iowa DOT Federal-aid projects to form the Statewide Transportation Improvement Program (STIP). The LPA is responsible for working with the applicable RPA or MPO to ensure that their project is included in the TIP/STIP and is programmed with an adequate amount of funds for the correct Federal Fiscal Year (FFY).  For additional information, please see Section 2 of the Federal-aid Guide

The RPAs and MPOs are currently working on their draft TIPs. Draft TIPs are due June 15. Beginning July 1, the TIP will close for public comment and no changes can be made until October 1, 2022. This makes reaching out to your respective RPAs and MPOs sooner rather than later very important for any project converting from Federal-aid Swap to Federal-aid to ensure it is accurately programed in the STIP.  If you are unsure who your RPA or MPO contact is, please see the interactive map on this website .

As a refresher, Federal-aid projects require the following submittals:

  • Project Development Submittal Dates and Information (refer to I.M. 3.010)
  • Concept Statement (refer to I.M. 3.020) - as a reminder, a Concept Statement is required in order to obtain NEPA Clearance.
  • Preliminary Plans (refer to I.M. 3.400)
  • NEPA Clearance (refer to I.M. 4.020)
  • Cultural Resource Regulations (refer to I.M. 4.120)
  • ROW Acquisition (refer to I.M. 3.600)
  • Check Plans (refer to I.M. 3.700)
  • Final Plans (refer to I.M. 3.700)

This is not an all-inclusive list, and we strongly recommend reading the Federal-aid Project Development Guide and Iowa DOT Instructional Memorandums for Local Public Agencies as a refresher for the additional steps needed in developing Federal-aid projects. 

Federal Grant Application Reminders

As most of you are likely aware, this Infrastructure Bill includes several grant programs beyond the formula programs like STBG, HBP, TAP, and ICAAP. To minimize future challenges and avoid “surprises”, Local Systems wants you to be aware of the below items prior to submitting grant applications.

  • All programs transitioning from Federal-aid Swap to Federal-aid will be required to be Federal-aid starting with the February 2023 letting. This means the now Federal-aid programs shall not be proposed in new Federal-aid Swap grant applications since it will no longer be available. The programs for cities that will be Federal-aid moving forward include the STBG funds awarded through TMAs and MPOs, while the STBG funding awarded through RPAs will remain STBG Swap Funding. The City and County bridge projects will be Federal-aid moving forward as well.
  • STBG, STBG-Swap, and City Bridge Funds are to be used for Construction only. This should be taken into consideration as well in any grant application proposed funding.


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