If I use CDBG dollars for demolition and cleaning of a site for a larger project which triggers Davis-Bacon, is it required the private dollars invested for construction also follow the rules of Davis- Bacon? My State has done away with prevailing wage requirements.
Date Published: May 2015
Davis-Bacon wage rates apply when CDBG funds pay in whole or in part for any direct cost of construction and the construction meets one of the following thresholds:
Certain CDBG activities or soft costs such as real property acquisition or architectural and engineering fees do not trigger Davis-Bacon requirements. There are instances when CDBG funds are used for demolition to make way for related non-federal assisted construction. Davis-Bacon would not apply to the construction if the demolition is done under separate contract by the grantee or its contractor before transfer of land to the developer. Davis-Bacon would apply to the construction if the demolition was contracted by the same entity (developer, contractor, etc.) doing the private construction and will be carried out while the contracting entity controls the site.