Opportunity Zone 2.0 Application SubmissionCity of Dubuque
City Council
ACTION ITEMS # 4.
Copyrighted
August 3, 2026
ITEM TITLE: Opportunity Zone 2.0 Application Submission
SUMMARY: City Manager recommending City Council approval for
submission of an application for Opportunity Zone 2.0
designation through the Opportunity Iowa program,
administered by the Iowa Economic Development Authority
(IEDA).
SUGGUESTED Receive and File; Approve
DISPOSITION:
ATTACHMENTS:
1. MVM Memo Opportunity Zone 2_0 Application Submission
2. Staff Memo
3. Application Narrative
4. DI Support Letter
5. CFGD Support letter
6. Proposed Opportunity Zones Map
7. GDDC Support letter
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THE CITY OF
DUBE
Masterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Opportunity Zone 2.0 Application Submission
DATE: July 29, 2026
Dubuque
AI WIN av
2007-2012.2013
2017*2019
Economic Development Director Jill Connors is recommending City Council approval for
submission of an application for Opportunity Zone 2.0 designation through the
Opportunity Iowa program, administered by the Iowa Economic Development Authority
(IEDA). The application was submitted online using the attached narrative, and support
letters from key community partners were emailed directly to IEDA staff.
This application represents the first designation opportunity under the recently enacted
federal Opportunity Zone 2.0 legislation. While Dubuque previously received
Opportunity Zone designations under the Tax Cuts and Jobs Act of 2017, all prior
designations expired under the new federal law, requiring states to undertake a new
designation process.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Mic ael C. Van Milligen
MCVM:sv
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Jill Connors, Economic Development Director
Page 1258 of 1281
Dubuque Economic Development
Department
THE CITY OF 1300 (wain street
All-AM111094 Dubuque, Iowa 52001-4763
UB E vxxwi Office (563) 589-4393
1 I I TTY (563) 690-6678
I® http://www.cityofdubuque.org
2007-2012*2013
Masterpiece on the Mississippi 2017*2019
TO: Michael C. Van Milligen, City Manager
FROM: Jill M. Connors, Economic Development Director
SUBJECT: Opportunity Zone 2.0 Application Submission
DATE: July 29, 2026
INTRODUCTION
This memo recommends City Council approval for submission of an application for
Opportunity Zone 2.0 designation through the Opportunity Iowa program, administered by
the Iowa Economic Development Authority (IEDA). The application was submitted online
using the attached narrative, and support letters from key community partners were
emailed directly to IEDA staff.
This application represents the first designation opportunity under the recently enacted
federal Opportunity Zone 2.0 legislation. While Dubuque previously received Opportunity
Zone designations under the Tax Cuts and Jobs Act of 2017, all prior designations expired
under the new federal law, requiring states to undertake a new designation process.
BACKGROUND
Opportunity Zones were originally established through the federal Tax Cuts and Jobs Act
of 2017 to encourage long-term private investment in economically distressed communities
through federal capital gains tax incentives. Following enactment of the legislation, Iowa
nominated Opportunity Zones in 2018, and the City of Dubuque successfully received
designation for several census tracts
Congress recently enacted Opportunity Zone 2.0, creating a new program with updated
eligibility requirements and requiring every state to submit a new set of designated census
tracts. Previous designations do not automatically carry forward, making a new application
necessary.
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The Iowa Economic Development Authority (IEDA), through Opportunity Iowa, established
a competitive statewide application process to identify recommended census tracts for
designation. Applications required substantial documentation demonstrating economic
distress, redevelopment readiness, community support, and a pipeline of investment -ready
projects.
DISCUSSION
Preparation of the application required extensive collaboration among City staff, Greater
Dubuque Development Corporation (GDDC), and private -sector. The team evaluated
eligible census tracts, identified redevelopment opportunities expected to move forward
beginning in 2027, documented redevelopment barriers, and secured letters of support
from key community partners.
Particular emphasis was placed on identifying projects that meet the objectives of
Opportunity Zone 2.0 by demonstrating near -term investment potential, significant private
capital leverage, housing production, job creation, and catalytic redevelopment
opportunities.
The City's application narrative outlines a vision for transforming legacy industrial districts
into vibrant mixed -use neighborhoods, providing housing, employment, neighborhood -
serving businesses, recreation, and public amenities. The areas specifically
requested/prioritized for designation are Census Tracts 1.00 and 5.00. Census Tract 7.02
was submitted as a secondary priority.
Census Tracts 1.00 and 5.00 were identified as the City's highest priorities because they
contain a significant concentration of redevelopment opportunities with the greatest
potential to leverage private investment while advancing long-standing community
redevelopment goals. Census Tract 7.02 was submitted as the City's secondary priority
should additional designations become available.
These areas have long served as Dubuque's industrial backbone but continue to face
redevelopment barriers, including brownfield conditions, environmental uncertainty,
underutilized land, rising construction costs, and financing gaps.
The application documents a substantial pipeline of redevelopment projects anticipated to
begin construction on or after January 1, 2027. Collectively, these projects represent
hundreds of millions of dollars in potential private investment across mixed -use
development, housing, commercial redevelopment, health care, hospitality, industrial
expansion, and adaptive reuse. The availability of Opportunity Zone designation is
F,
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expected to strengthen project feasibility by attracting additional equity investment to
developments that continue to face challenging financing conditions.
Support letters were provided by:
• Greater Dubuque Development Corporation (GDDC), emphasizing the economic
need and investment opportunity in Census Tracts 1.00 and 5.00.
• Community Foundation of Greater Dubuque (CFGD), highlighting the importance of
flexible and catalytic capital for redevelopment and community benefit
• Dubuque Initiatives (DI), underscoring the need for patient investment and the
readiness of these neighborhoods for transformative projects.
All letters strongly support the City's application and encourage favorable consideration by
the State.
These organizations were selected because of their direct involvement in economic
development, community investment, and redevelopment financing within the proposed
Opportunity Zone areas. Their letters collectively demonstrate broad community support
and reinforce the readiness of these census tracts for additional private investment.
RECOMMENDATION
I respectfully request approval for submission of an application for Opportunity Zone 2.0
designation through the Opportunity Iowa program, administered by the Iowa Economic
Development Authority (IEDA). Staff will continue to coordinate with IEDA throughout the
review process and to update the City Council regarding designation decisions and any
subsequent implementation activities.
3
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What is the vision for the top priority census tract(s), and how will having an Opportunity
Zone assist in realizing that vision?
The City of Dubuque envisions a future in which its legacy industrial districts become
vibrant mixed -use neighborhoods that provide housing, employment opportunities,
neighborhood -serving businesses, recreation, and public amenities while strengthening
the community's connection to the Mississippi River. The priority census tracts encompass
the North Port, South Port, and Washington Neighborhood —areas that have long served as
the city's industrial backbone but continue to contain vacant, underutilized, and
environmentally challenged properties that limit private investment.
Over the past three decades, Dubuque has demonstrated that strategic public investment
can transform underutilized and environmentally challenged properties into thriving
community assets. Building on that success, the City is advancing a pipeline of
redevelopment opportunities that will expand housing choices, support commercial and
hospitality development, strengthen health care services, improve public infrastructure,
and create quality employment opportunities.
The recent award of a $500,000 EPA Brownfields Community -Wide Assessment Grant
positions the City to accelerate this vision by funding environmental assessments, cleanup
planning, and redevelopment strategies for priority sites. These activities will reduce
environmental uncertainty, improve site readiness, and provide developers and investors
with the information needed to move projects from concept to construction.
Opportunity Zone designation would provide another critical tool for financing projects that
remain challenging despite strong market potential. When combined with environmental
assessment, strategic public investment, and private capital, the designation can help
close financing gaps, accelerate redevelopment, and transform long -underutilized
properties into productive assets that expand the local tax base, increase housing and
employment opportunities, and strengthen the long-term economic vitality of these
neighborhoods. Dubuque has repeatedly demonstrated its ability to transform challenging
sites into productive community assets, and Opportunity Zone designation will help extend
that success to future redevelopment opportunities.
Describe any economic hardships the top priority census tract(s) has faced over the last 5
years.
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Many of the City's most significant brownfield sites are located within these census tracts,
where decades of manufacturing, rail activity, petroleum storage, utility operations, and
other industrial uses have left vacant and underutilized properties burdened by real or
perceived environmental contamination. The resulting uncertainty increases
redevelopment costs, limits access to conventional financing and discourages private
investment.
During the past five years, these longstanding challenges have been compounded by rising
construction costs, higher interest rates, supply chain disruptions, and increased
financing costs that have made complex redevelopment projects more difficult to
complete. Properties requiring environmental investigation have been particularly affected
because developers must absorb both market uncertainty and potential remediation costs
before redevelopment can begin. As a result, otherwise viable redevelopment projects
frequently experience financing gaps that cannot be bridged through conventional lending
alone.
The priority census tracts also continue to experience socioeconomic challenges,
including household incomes that remain below state and national averages and poverty
rates that exceed national averages in portions of the project area. These conditions
reduce market demand, limit private -sector willingness to assume redevelopment risk,
and reinforce the need for strategic public investment to catalyze private development.
Despite these challenges, Dubuque has continued to invest in planning and infrastructure
that position these neighborhoods for revitalization. Most recently, the City secured a
$500,000 EPA Brownfields Community -Wide Assessment Grant to evaluate priority
redevelopment sites within these census tracts. By reducing environmental uncertainty
and preparing sites for reuse, the grant will help remove one of the most significant barriers
to redevelopment. Opportunity Zone investment would complement these public
investments by providing an additional source of patient capital for projects that face
higher redevelopment costs because of environmental conditions, site preparation needs,
or adaptive reuse challenges.
Do you have any development projects proposed for the census tract(s) over the next 10
years?
Note: only projects with construction starting on or after January 1, 2027, are eligible.
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The City of Dubuque has identified a strong pipeline of redevelopment opportunities within
its priority Opportunity Zone census tracts that are expected to begin construction on or
after January 1, 2027. These projects represent a mix of housing, commercial, health care,
hospitality, industrial redevelopment, and adaptive reuse initiatives that are well positioned
to leverage Opportunity Zone investment in combination with local, state, and federal
resources. In each of the following potential projects there are cost challenges to moving
the project toward financial feasibility. Moving these projects forward has the potential to
transform our downtown and whole community— essential to growing our population.
(Census Tract 1)
South Port —This area has been the subject of multiple brownfields assessment, planning,
and cleanup activities of both private and public properties, using EPA brownfields grant
proceeds. A major private property owner is currently working with consultants to prepare
for the redevelopment of several buildings and parcels in the NE portion of the area to create
a mixed -use area including multi -residential, commercial and retail offerings.
Redevelopment expected to begin in 2027.
Bridge Lofts — The property owner has begun design of a $45 million mixed -use building at
the gateway to the City from Illinois, to include 94 apartments as well as commercial and
retail space. Opportunity Zone investment could help close the remaining financing gap and
advance the project toward construction.
North Port — The City has already invested in infrastructure improvements and
environmental due diligence that have reduced redevelopment risk and positioned the
district for continued private investment. With one hotel currently undergoing a $9 million
remodel and another $18 million hotel project scheduled to begin construction in the fall of
2026— and with more than 10 acres of land suitable for development in the area —we expect
additional development in the coming years. A developer has made an offer on a vacant
office building with the intention of creating for -sale condos. And we expect a variety of
additional projects to fill the open areas of the North Port in the near future. New
developments will spur additional activity at existing facilities such as the Grand River
Conference Center, Diamond Jo Casino, and the National Mississippi River Museum and
Aquarium.
Medical College Campus —The transformation of an existing office building into a facilitythat
will accommodate the first new medical college to open in over a century is currently
underway. However, we anticipate an expansion of the campus in the downtown area, as
the college grows its programs.
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Historic Federal Building — This building is currently comprised of the United States Post
Office; office space for several public and private lessees, as well as the City's Housing
Department; and City Council chambers. Multiple developers have expressed interest in
adaptive reuse opportunities such as multi -residential use or a boutique hotel,
demonstrating market demand once financing and redevelopment challenges can be
addressed. Its proximity to the Medical College would likely ensure success for either use.
Wilmac Building— Located in the Historic Millwork District, this vacant former warehouse is
currently held by a local developer/construction company which plans to undertake a $25
million redevelopment of the property, creating 126 apartments and with the intention to
include community benefit space that would provide commercial/office space for nonprofit
organization(s).
Millwork Flats —Also located in the Historic Millwork District, the property owner is working
to close the $17 million project's financing gap to create at least 62 apartments and first
floor commercial space.
ImOn Ice Expansion — Chaplain Schmitt Island along the Mississippi River boasts several
economic engines such as the Q Casino, two hotels, a new amphitheater, baseball fields,
restaurants, a marina, and an ice rink. This is the result of recent investments of over $71
million from the public sector and over $83 million in private dollars. Based on the rink's
demand exceeding available capacity, and given the popularity of hockey in the community,
there has been serious conversation about adding another sheet of ice to accommodate this
demand. We would anticipate a $10 million investment to bring this to reality.
Pack Site — This 35-acre site is privately held and is ripe for redevelopment. At the gateway
to Dubuque from Wisconsin and existing utilities adjacent to the site, it has been considered
by several potential projects over the past 10 years. With the nearby improvements on
Chaplain Schmitt Island, such as a new amphitheater and a new high -end hotel, we expect
complementary uses to locate on this property.
Crescent Health / Washington Neighborhood — The Greater Dubuque Impact Investment
Fund has recently purchased a brownfield site (former scrap yard) which, when
redeveloped, is intended to provide expansion space for the nearby federally -funded
Crescent Community Health Center. The site has taken advantage of several EPA
brownfields cleanup grants, as well as funds from an EPA revolving loan fund, and
requesting targeted brownfield assistance dollars from the EPA — with continuing
environmental challenges which make this property difficult to fund and finance. The City
and several non-profit organizations are committed to a collective effort involving multiple
stakeholders to bring this property back to its best and highest use in this census tract.
Page 1265 of 1281
(Census Tract 5)
Five Points — For nearly a decade the City has worked to identify a private developer to
undertake a project at this location. Adjacent to a $200 million stormwater flood mitigation
project, it has the potential to serve the residents of this census tract, as well as residents
from across the community who come to the area to enjoy the linear park that was created
as part of the flood mitigation project. Privately -held property across the street is being
considered for redevelopment by the owner, with several potential project ideas already
having been shared with City staff.
Dubuque Malting — This property, which holds historic and sentimental value for the
residents of this census tract, as well as residents across the community, has fallen into
disrepair over the years. Portions of the buildings have been demolished due to their
condition. The neighbors have long requested the redevelopment of this former brewing and
malting facility, but without additional funding/financing opportunities, the project is not
economically viable.
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DUBGQUE
INITIATIVES
July 28, 2026
To Whom It May Concern:
On behalf of Dubuque Initiatives, I am pleased to offer our strong support for the City of
Dubuque's application for Opportunity Zone 2.0 designation for its priority downtown
census tracts.
Dubuque Initiatives was created to advance transformative redevelopment projects that
strengthen neighborhoods, improve quality of life, and generate lasting community
benefit. Our organization has made significant investments within these census tracts
and understands firsthand both the opportunities they present and the financial
challenges that continue to limit redevelopment of former industrial and brownfield
properties.
Through our work, we have seen that many of these sites possess exceptional
redevelopment potential but require complex capital stacks and patient investment to
overcome environmental conditions, site preparation costs, and financing gaps. While
the City has made substantial investments in infrastructure, environmental assessment,
and redevelopment planning, additional private investment tools remain essential to
bringing many projects to fruition.
Opportunity Zone designation would provide an important financing resource that
complements these existing public investments. It would strengthen the ability of
organizations like ours, along with private developers and community partners, to attract
long-term investment for projects that create housing, expand access to healthcare,
stimulate commercial activity, and return underutilized properties to productive use.
Our experience demonstrates that these neighborhoods are ready for investment. With
strategic public leadership already in place and a strong pipeline of redevelopment
opportunities, Opportunity Zone designation would help accelerate projects that might
otherwise remain financially out of reach, creating lasting economic and community
benefits for Dubuque residents.
For these reasons, Dubuque Initiatives enthusiastically supports the City of Dubuque's
Opportunity Zone 2.0 application and respectfully encourages favorable consideration of
this request.
Sincerely,
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Kzv_-'� C�
0
Kevin Lynch
Dubuque Initiatives, President
(563) 582-2655
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Community
Foundation
OF GREATER DUBUQUE
July 22, 2026
To Whom It May Concern:
700 Locust St., Suite 195, Dubuque, IA 52001
563.588.2700 1 dbgfoundation.org
On behalf of the Community Foundation of Greater Dubuque, I am pleased to express our
support for the City of Dubuque's application for Opportunity Zone 2.0 designation for its
priority downtown census tracts.
The Community Foundation of Greater Dubuque supports efforts that strengthen communities
through redevelopment, expanded opportunity, and long term economic vitality. The City's
vision for these tracts to transform legacy industrial areas and underutilized properties into
vibrant mixed use neighborhoods with housing, employment opportunities, neighborhood
serving businesses, healthcare expansion, public amenities, and stronger connections to the
riverfront is both compelling and aligned with the kind of community building work that creates
lasting regional benefit.
These priority census tracts continue to face significant redevelopment barriers, including
brownfield conditions, environmental uncertainty, underutilized land, rising construction costs,
and financing gaps that limit private investment. Opportunity Zone designation would provide an
important additional tool to help close those gaps, complement existing public investments, and
attract the patient capital needed to move complex projects from concept to construction.
Through the Community Foundation's work, including the NEI Impact Investment Fund, we
recognize the importance of flexible and catalytic capital in helping community serving and
redevelopment projects advance where conventional financing alone may not be sufficient. We
see this designation as complementary to those efforts and as another way to strengthen the
broader toolbox available to the community.
We believe this designation would help advance projects that expand housing, strengthen
community health, improve public infrastructure, and create employment and investment
opportunities in areas that have long faced economic and environmental challenges. For these
reasons, the Community Foundation of Greater Dubuque strongly supports the City's request and
appreciates your consideration.
Please do not hesitate to reach out if additional information would be helpful.
Respectfully,
VG`l-fl/
Nancy Van Milligen
President and CEO
Community Foundation of Greater Dubuque
Our Mission: Strengthen communities and inspire giving.
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July 20, 2026
To Whom It May Concern:
On behalf of the Greater Dubuque Development Corporation and the greater Dubuque
community, we are pleased to submit our Census tract recommendations to Governor
Kim Reynolds for Opportunity Zone 2.o designation.
Based on the program's criteria, we understand the following Census tracts are
currently eligible:
Census Tract 1.00
Census Tract 5.00
Census Tract 7.02
The first two are active Opportunity Zones under the existing program. Their current
economic profiles are as follows:
Census Tract i.00
• Percent of People in Poverty: 13.89%
• Percent of Area Median Income: 56.o1%
Census Tract 5.00
• Percent of People in Poverty: 34.26
• Percent of Area Median Income: 43.58%
We convened a group of 20 private developers alongside City of Dubuque City Manager
and Economic Development staff. All participants concurred that the two current
Opportunity Zone tracts represent the greatest economic need and investment
opportunity for our community, with Census Tract too as the top priority.
While we would welcome designation for all three tracts, we recognize that the new
program rules result in fewer approved zones. Our primary ask is that Census Tracts
1.00 and 5.00 receive Opportunity Zone 2.o designation.
Please do not hesitate to reach out if we can provide additional information or
assistance.
Respectfully,
Jason E. White, President and CEO
Greater Dubuque Development Corporation
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