Montebello City Council
June 10, 2026

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applicant’ s SHSP and UASI allocation stated in this NOFO. All projects associated with the minimum spend of a National Priority Area must be submitted in the same IJ. SAAs may submit complete project- level information at the time of application but are not required to do so at the time of application.

However, any SHSP or UASI application that does not include IJs that ( 1) meet the minimum spend requirement for the Enhancing Election Security priority area and ( 2) meet the overall 30% spending requirement across the National Priority Areas will have that funding placed on hold (up to the National Priority Area minimum percent and up to 30% of the total SHSP or UASI allocations) until those IJs and project-level details that sufficiently address the National Priority Areas are received and approved by DHS/ FEMA.

Each IJ must demonstrate how proposed investments:
i. Support terrorism preparedness; and
ii. Support building capability and/or closing capability gaps or sustaining capabilities identified in the community’ s THIRA/SPR process.

Each IJ must explain how the proposed investments will support the applicant’ s efforts to:
i. Prevent a threatened or an actual act of terrorism;
ii. Prepare for all hazards and threats, while explaining the nexus to terrorism preparedness;
iii. Protect citizens, residents, visitors, and assets against the greatest threats and hazards, relating to acts of terrorism; and/or iv. Respond quickly and equitably to save lives, protect property and the environment, and meet basic human needs in the aftermath of an act of terrorism or other catastrophic incidents.

If not included in the application, SHSP and UASI recipients must submit complete project-level information for each SHSP and UASI IJ as part of the Biannual Strategic Implementation Report (BSIR) due by January 30, 2025. This includes IJs for the National Priority Areas.

DHS/FEMA will evaluate the effectiveness of the projects submitted in support of the National Priority Areas, either at the time of application or as part of the December 2024 BSIR due January 30, 2025. DHS/FEMA will not reduce FY 2024 HSGP awards based on the effectiveness review but will work with recipients to ensure compliance with the National Priority Area requirements based on the results of the effectiveness review. Recipients and subrecipients will not be permitted to expend funding under the National Priority Areas until the effectiveness of the proposed projects has been reviewed and confirmed by FEMA.
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II. DEVELOPMENT OF INVESTMENTS AND PROJECTS: SHSPAND UASI i. Applicants must propose at least two (2) and may include up to 12 investments.
ii. Within each investment, applicants must propose at least one project to describe the activities they plan to implement with SHSP and UASI funds. There is no limit to the number of projects that may be submitted.
iii. Required National Priority Area IJs must include the name of the priority in the investment name for easy identification. iv. All requested funding must be associated with specific projects. For each project, several pieces of information must be provided to submit the project for consideration in the application, including:
o Project name;
o Project description;
o Subrecipient name, if applicable;
o Recipient type (e.g., state or local);
o Project location ( zip code of the primary location of the project);
o Primary core capability the project supports;
o Whether the project activities are shareable and deployable; and
o Which National Priority Area (if any) the project supports. v. Projects should describe how the proposed investment supports building capability and/or closing capability gaps or sustaining capabilities identified in the THIRA/ SPR process.
vi. FEMA encourages states to use any DHS provided assessments, such as those performed by DHS’s Protective Security Advisors and Cybersecurity Advisors, when developing their IJs.

III. NATIONAL PRIORITY AREA INVESTMENTS: SHSPAND UASI
States are encouraged to review the Strategic Framework for Countering Terrorism and Targeted Violence when developing investments.

Soft Targets/Crowded Places (no minimum percent)
Soft targets and crowded places are increasingly appealing to terrorists and other violent extremist actors because of their relative accessibility and the large number of potential targets. This challenge is complicated by the prevalent use of simple tactics and less sophisticated attacks. Segments of our society are inherently open to the general public, and by nature of their purpose do not incorporate strict security measures. Given the increased emphasis by terrorists and other violent extremist actors to leverage less sophisticated methods to inflict harm in public areas, it is vital that the public and private sectors collaborate to enhance security of locations such as transportation centers, parks, restaurants, shopping centers, special event venues, polling places, and similar facilities.

Additionally, it is important that personnel responding to incidents at these locations are trained on key operational systems, such as ICS, to ensure proper 7

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command, control, and coordination of on- scene incident management.

The malicious use of unmanned aircraft systems poses a threat to the safety and security of the American people, communities, and institutions. Technologies to detect or mitigate unmanned aircraft systems are an allowable use under the HSGP in accordance with the Domestic Counter-Unmanned Aircraft Systems UAS) National Action Plan. Recipients should ensure that, prior to the testing, acquisition, installation, or use of UAS detection and/or mitigation systems, they seek the advice of counsel experienced with both federal and state criminal, surveillance, and communications laws which may apply to the use of such technologies.

While not required, applicants are encouraged to submit an investment related to protecting soft targets/crowded places. The proposed investment will be subject to DHS/ FEMA’ s evaluation of the effectiveness of the proposed investments. States are encouraged to engage DHS’ Protective Security Advisors’ security assessments of soft targets to ensure that recommendations from those assessments are taken into consideration when allocating grant funding.

Additional resources and information regarding securing soft targets and crowded places are available through the Cybersecurity and Infrastructure Security Agency and the National Institute of Standards and Technology.

Information and Intelligence Sharing (no minimum percent) Effective homeland security operations rely on access to, analysis of, and the timely sharing of open source, unclassified, and classified information, suspicious activity reports, tips/leads, and actionable intelligence on indicators and behaviors to accurately identify, assess, and mitigate a wide array of threats against the United States, including terrorism, threats to life, targeted violence, and other threats within the DHS mission space. Accordingly, DHS works diligently to enhance intelligence collection, integration, analysis, and information sharing capabilities to ensure partners, stakeholders, and senior leaders receive actionable intelligence and information necessary to inform their decisions and operations. A critical and statutorily charged mission of DHS is to deliver intelligence and information to federal, state, local, tribal, and territorial governments and private sector partners. Cooperation and information sharing among state, local, tribal, territorial, and federal partners across all areas of the homeland security enterprise, including counterterrorism, while upholding privacy, civil rights, and civil liberties protections, is critical to homeland security operations and the prevention of, preparation for, protection against, and response to acts of terrorism, and other threats to life and criminal acts of targeted violence.

Counterterrorism includes both international and domestic terrorism, cybersecurity, border security, transnational organized crime, immigration enforcement, economic security, and other areas.
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While there is no minimum spend for this National Priority Area, applicants are required to include at least one dedicated fusion center project under this priority area. Additional instructions on development of the fusion center project can be found below. Applicants must justify persuasively how they will contribute to the information sharing and collaboration purposes of the investment and a culture of national preparedness. The proposed investment will be subject to DHS/FEMA’s evaluation of the effectiveness of the proposed investments.

Additional resources and information regarding collaboration and information sharing are available through the Department’ s Office of Intelligence and Analysis.

Domestic Violent Extremism ( no minimum percent)
As stated in the Homeland Threat Assessment 2024, terrorism, including domestic violent extremism, remains a top threat to the Homeland. Domestic violent extremists capitalize on social and political tensions, which have resulted in an elevated threat environment. They utilize social media platforms and other technologies to spread violent extremist ideologies that encourage violence and influence action within the United States.

While not required, applicants are encouraged to submit an investment related to combatting the rise, influence, and spread of domestic violent extremism.

Investments under this priority may include the development, implementation, and execution of prevention-focused program and initiatives, such as threat assessment and management programs to identify, evaluate, and analyze indicators and behaviors indicative of terrorism and targeted violence. The investment will be subject to DHS/FEMA’s evaluation of the effectiveness of the proposed investments.

Additional resources and information regarding domestic violent extremism are available through Center for Prevention Programs and Partnerships | Homeland Security (dhs.gov).

Cybersecurity ( no minimum percent)
Today’ s world is more interconnected than ever before, but with increased connectivity comes increased risk of our adversaries, including terrorists, exploiting cyber vulnerabilities and weaknesses to disrupt our way of life. While not required, applicants are encouraged to submit an investment related to their ongoing or near-term high priority cybersecurity projects. The investment will be subject to DHS/ FEMA’ s evaluation of the effectiveness of the proposed investments.

Cybersecurity investments must support the security and functioning of critical infrastructure and core capabilities as they relate to preventing, preparing for, protecting against, or responding to acts of terrorism. Recipients of FY 2024 HSGP grant awards who do not accept the funding allocated to them through the 7

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FY 2024 State and Local Cybersecurity Grant Program ( SLCGP) will be required to complete the 2024 Nationwide Cybersecurity Review (NCSR), enabling agencies to benchmark and measure progress of improving their cybersecurity posture. Completion of the NCSR is optional for all other recipients of FY 2024 HSGP funding. The Chief Information Officer ( CIO), Chief Information Security Officer (CISO), or equivalent for each recipient should complete the NCSR. If there is no CIO or CISO, the most senior cybersecurity professional should complete the assessment. The NCSR is available at no cost to the user and takes approximately 2-3 hours to complete. The 2024 NCSR is estimated to be open from October 2024 through February 2025.

The NCSR is an annual requirement for recipients of SLCGP grant awards (and for those HSGP recipients who do not accept their allocated SLCGP funding) and is taken once for each fiscal year award.

Additional resources and information regarding cybersecurity and cybersecurity performance goals are available through the Cybersecurity and Infrastructure Security Agency, Cross-Sector Cybersecurity Performance Goals | CISA, and the National Institute of Standards and Technology.

Community Preparedness and Resilience ( no minimum percent) Community organizations are the backbones of American civic life, both during blue skies” and in the aftermath of terrorist attacks. Community organizations, such as homeless shelters, food banks, public libraries, faith-based institutions, and nonprofit medical providers must have the capabilities to withstand acts of terrorism and provide essential services, especially to members of underserved communities, in the aftermath of an attack. In addition, individual citizens and volunteer responders, such as Community Emergency Response Teams, are often the first on the scene after a terrorist attack. The ability of these volunteers to provide assistance to their fellow citizens prior to the arrival of professional first responders is paramount to a community’s resilience. According to FEMA’s 2023 National Household Survey, only 57% of adults have taken at least three preparedness actions to bolster individual and household resilience. . In addition, the COVID-19 pandemic has placed a significant burden on community-based organizations such as homeless shelters, food banks, public libraries, faith-based institutions, and nonprofit medical providers to continue to provide key services during and after disasters, including acts of terrorism. This National Priority Area will bolster community preparedness and resilience by investing in local, community-driven capabilities.

Additionally, equity in emergency management requires proactively prioritizing actions that reinforce cultural competency, accessibility, and inclusion, as well as reflect the historical context of specific groups of people. To that end, states, territories, and high-risk urban areas are strongly encouraged to explore how SHSP- and UASI-funded activities can address the needs of underserved, at-risk communities to help ensure consistent and systematic, fair, just, and impartial 7

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treatment of all individuals before, during, and after a disaster, consistent with applicable law.

The focus on equity and investing in strategies that meet the needs of underserved communities will strengthen the whole of community system of emergency management. Substantial and ongoing prioritization of, and investment in, underserved communities is essential for the entire system to be effective and efficient. Engaging the whole community requires all members of the community to be part of the emergency management team, including representatives of underserved communities, diverse community members, social and community service groups and institutions, faith- based and disability advocacy groups, academia, professional associations, the private and nonprofit sectors, and government agencies that may not traditionally have been directly involved in emergency management. The whole community includes children; older adults; individuals with disabilities and others with access and functional needs; those from religious, racial, and ethnically diverse backgrounds; people with limited English proficiency; and owners of animals including household pets and service animals.

While not required, applicants are encouraged to submit an investment related to addressing community preparedness and resilience. The investment will be subject to DHS/FEMA’s evaluation of the effectiveness of the proposed investments.

Additional resources and information regarding community preparedness and resilience are available through Individuals and Communities | FEMA. gov.

Election Security (3%)
In January 2017, DHS designated the infrastructure used to administer the Nation’s elections as critical infrastructure. This designation recognizes that the United States’ election infrastructure is of such vital importance to the American way of life that its incapacitation or destruction would have a devastating effect on the country. Additionally, the Homeland Threat Assessment 2024 indicates that electoral processes remain an attractive target for many adversaries.

Securing election infrastructure, ensuring its continued operation in the face of threats and harassment, advancing the safety of election officials, and ensuring an election free from foreign interference are national security priorities. Threats to election systems are constantly evolving, so defending these systems requires constant vigilance, innovation, and adaptation. As such, at least one (1) investment must be in support of the state’ s and high-risk urban area’ s efforts to enhance physical election security and/or cyber election security. Additionally, the proposed investment must meet or exceed the FY 2024 national priority percentage for election security and will also be subject to DHS/FEMA’s evaluation of the effectiveness of the proposed investments. 7

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The SAA must coordinate with the State’ s Chief Election Official for all projects and matters related to the election security National Priority Area. Any activities proposed that could be used to suppress voter registration or turnout will not be approved.

Additional resources and information regarding election security are available through the Cybersecurity and Infrastructure Security Agency.

IV. DEVELOPMENT OF FUSION CENTER PROJECTS: SHSPAND UASI Each applicant must identify a fusion center project that will:
i. Indicate alignment to a designated Fusion Center; and ii. Provide both a brief narrative description and funding itemization for the proposed project activities that directly support the designated fusion center.

The descriptive narrative and the financial itemization should align improvement or sustainment requests with fusion center activities as they relate to the Fusion Center Performance Measures found in the Preparedness Grants Manual.

Sample Fusion Center Funding Itemization
A sample project description and funding itemization are below. For the itemized projects, clearly identify the anticipated fusion center performance improvement or sustainment as a result of the proposed funding.

The X Fusion enhancement project will fund:
i. Salaries, benefits, and training for X number of Fusion Center intelligence analysts; and
ii. Travel costs associated with fusion center analyst training.

This project will directly sustain the Center’ s current capabilities and performance and directly aligns with performance measures 2024.XXX.

We anticipate seeing an improvement in the quality and quantity of analytic production and responses to requests for information as a direct result of the funding of this project.

The funding itemization for a fusion center project should include the amount and percent of each relevant solution area. As an example:

Solution Area and Amount of Proposed
Funding
Percent of Proposed
Funding
Planning:$ 10,000 2%
Organization:$ 200,000 48%
Equipment:$ 200,000 48%
Training:$ 10,000 2%
Exercises:$ 0 0%
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Solution Area and Amount of Proposed
Funding
Percent of Proposed
Funding
Total:$ 420,000 100%
V. COMPLETING IJS IN THE FEMA GO: SHSP AND UASI
In the Related Documents section of the Grants.gov posting, applicants can find the IJ template and instructions for collecting the required information for investments and projects. Additionally, applicants should utilize the Project Worksheet located in Grants.gov posting to assemble the information required for each project, which will facilitate the input of that information into FEMA GO.

Applicants must ensure the appropriate National Priority Area “Investment Type” Overview Tab – Investment Information Section) is selected for the corresponding National Priority Area.

VI. DEVELOPMENT OF CONCEPT OF OPERATIONS FOR OPSG
As part of the FY 2024 OPSG application process, each eligible local unit of government at the county or federally recognized tribal government level must develop a strategic plan called a Concept of Operations (CONOP)/Application, which is a formal proposal of action to address a specific situation and forms the basis for Operations Orders, in coordination with state and federal law enforcement agencies, to include, but not limited to CBP/USBP. CONOPs that are developed at the county level should be inclusive of city, county, tribal, and other local law enforcement agencies that are eligible to participate in OPSG operational activities, and the CONOP/Application should describe participating agencies in the Executive Summary.

CONOP/Application details should include the names of the agencies, points of contact, and individual funding requests. All CONOPs/Applications must be developed in collaboration with the local USBP sector office, the SAA, and the local unit of government. Requests for funding in CONOPs/Applications must be based on risks and the operational enforcement support requirements of its corresponding USBP Sector, as well as the national priorities identified below.

USBP Sector offices will forward the CONOPs to USBP Headquarters for vetting and coordination. Applicants will forward corresponding OPSG Applications to the SAA for submission to FEMA. USBP Headquarters will reconcile all submitted CONOPs with the OPSG Applications. FEMA will review and evaluate all CONOPs and OPSG Applications and funding will be allocated based on the review and selection criteria identified in this NOFO. OPSG Applicants will be required to clearly articulate and identify how the CONOPs will address the national priority identified below:

Information and Intelligence Sharing and Cooperation
Effective border security operations rely on access to, analysis of, and the timely sharing of open source, unclassified, and classified information, suspicious activity reports, tips/leads, and actionable intelligence on indicators and behaviors 7

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to accurately identify, assess, and mitigate a wide array of threats against the United States, including terrorism, threats to life, targeted violence, and other threats within the DHS mission space. Accordingly, DHS works diligently to enhance intelligence collection, integration, analysis, and information sharing capabilities to ensure partners, stakeholders, and senior leaders receive actionable intelligence and information necessary to inform their decisions and operations.

One critical, statutorily required mission of DHS is to deliver intelligence and information to federal, state, local, and tribal governments and private sector partners. Cooperation and information sharing among state, federal, and local partners across all areas of the homeland security enterprise, including both international and domestic terrorism, cybersecurity, transnational organized crime, economic security, border security, immigration enforcement, and other areas, while upholding privacy, civil rights and civil liberties protections, is critical to homeland security operations and the prevention of, preparation for, protection against, and responding to acts of terrorism, and other threats to life and criminal acts of targeted violence.

Given the importance of information sharing and collaboration to effective homeland security solutions, the CONOP must support the recipient’ s efforts to enhance information sharing and cooperation with DHS and other federal agencies. Applicants must justify persuasively how they will contribute to the information sharing and collaboration purposes of the OPSG program and a culture of national preparedness.

Additional resources and information regarding collaboration and information sharing are available through the Department’ s Office of Intelligence and Analysis.

VII. DEVELOPMENT OF OPERATIONS ORDERS FOR OPSG
Operations Order Template Instructions
To access the OPSG Operations Order Template:
i. Find the Homeland Security Grant Program posting via the search function on Grants.gov;
ii. Select the Related Documents tab on the posting; and iii. Click on the OPSG Operations Order Template and fill out all sections of the template.

Executive Summary Overview
Operations order executive summary must:
i. Identify the organization name, point of contact, committees, and other structures accountable for implementing OPSG in the jurisdiction typically this will be a program lead or manager overseeing operations and individuals assigned to that agency); and ii. Describe how federal and SLTT law enforcement agencies will work together to establish and enhance coordination and collaboration on border security issues.
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Budget Requirements Overview
Operations Order Detailed Annual Budget must:
i. Explain how costs and expenses were estimated; and
ii. Provide a narrative justification for costs and expenses. Supporting tables describing cost and expense elements ( e.g., equipment, fuel, vehicle maintenance costs) may be included.

Submission Requirements
Operations Orders must meet the following submission requirements:
i. Must be submitted as an Adobe PDF document;
ii. All documents submitted must use the unique identifier created by the OPSG data management system from the original associated operation order; and
iii. Applicable OPSG sector representatives must coordinate with the SAA and OPSG participants to submit an accurate inventory of all specified OPSG purchased property with each Operations Order/FRAGO. iv. Due to the competitive nature of this program, separate attachments will neither be accepted nor reviewed.

VIII. DETAILED BUDGET
Applicants must provide budget summary worksheets for all funds requested at the time of application. The budget summary worksheets must be complete, reasonable, and cost- effective in relation to the proposed project and should provide the basis of computation of all project-related costs (including management and administrative costs) and any appropriate narrative. FEMA must be able to thoroughly evaluate the projects being submitted based on the information provided. FEMA must be able to determine how much funding is being passed through to subrecipients for each sub-program (UASI, SHSP, OPSG). Consequently, applicants must provide an appropriate level of detail within the budget summary worksheets to clarify what will be purchased and spent. Sample budget summary worksheets are available on the Grants.gov posting for the HSGP in the Related Documents tab and may be used as a guide to assist applicants in the preparation of budgets and budget narratives.

11. Other Submission Requirements
a. Fusion Center Investments
Of the proposed SHSP- and UASI-funded investments, one single project must be in support of a designated fusion center. Recipients must coordinate with the fusion center when developing a fusion center project prior to submission. See additional information on how to develop the fusion center projects below and in the Preparedness Grants Manual.
b. Emergency Communications Investments
All emergency communications investments must describe how such activities align with needs identified in their Statewide Communication Interoperability Plan ( SCIP).

Recipients must coordinate with their Statewide Interoperability Coordinator (SWIC) 7

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and/ or Statewide Interoperability Governing Body ( SIGB) when developing an emergency communications investment prior to submission to ensure the project supports the statewide strategy to improve emergency communications and is compatible and interoperable with surrounding systems. Effective project alignment will require advance coordination with the SWIC and consultation with governing bodies such as the SIGB or Statewide Interoperability Executive Committee, as they serve as the primary steering group for the statewide interoperability strategy.

Additionally, recipients should consult subject matter experts serving on governance bodies, such as broadband experts, chief information officers, representatives from utilities, or legal and financial experts, when developing proposals. The investment name must include the words “ emergency communications” to easily identify any emergency communications investments.

12. Intergovernmental Review
An intergovernmental review may be required. Applicants must contact their state’ s Single Point of Contact (SPOC) to comply with the state’ s process under Executive Order 12372 See https:// www. archives. gov/federal- register/ codification/ executive- order/ 12372. html; Intergovernmental Review (SPOC List) (whitehouse.gov)

13. Funding Restrictions and Allowable Costs
All costs charged to awards covered by this NOFO must comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements at 2 C.F.R. Part 200, unless otherwise indicated in the NOFO, the terms and conditions of the award, or the Preparedness Grants Manual. This includes, among other requirements, that costs must be incurred, and products and services must be delivered, within the period of performance of the award. See 2 C.F.R. § 200.403(h) (referring to budget periods, which for FEMA awards under this program is the same as the period of performance).

Federal funds made available through this award may be used for the purpose set forth in this NOFO, the Preparedness Grants Manual, and the terms and conditions of the award and must be consistent with the statutory authority for the award. Award funds may not be used for matching funds for any other federal awards, lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to sue the Federal Government or any other government entity. See the Preparedness Grants Manual for more information on funding restrictions and allowable costs. a. Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services
See the Preparedness Grants Manual for information on prohibitions on expending FEMA award funds for covered telecommunications equipment or services. b. Pre-Award Costs
Pre-award costs are allowable only with the prior written approval of DHS/FEMA and as included in the award agreement. To request pre-award costs, a written request must be included with the application, signed by the AOR of the entity. The letter must outline what the pre-award costs are for, including a detailed budget break-out 7

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of pre- award costs from the post- award costs, and a justification for approval. c. Management and Administration ( M&A) Costs
M&A costs are allowed by the 2024 DHS Appropriations Act. Recipients may use a maximum of up to 5% of HSGP funds awarded for their M&A, and any funds retained are to be used solely for M&A purposes associated with the HSGP award.

Subrecipients may also use a maximum of up to 5% of the funding passed through by the state solely for M&A purposes associated with the HSGP award. M&A activities are those directly relating to the management and administration of HSGP funds, such as financial management and monitoring. M&A expenses must be based on actual expenses or known contractual costs. M&A requests that are simple percentages of the award, without supporting justification, will not be allowed or considered for reimbursement.

M&A costs are not operational costs but are necessary costs incurred in direct support of the federal award or as a consequence of it, such as travel, meeting-related expenses, and salaries of full/part- time staff in direct support of the program. As such, M&A costs can be itemized in financial reports. Other M&A cost examples include preparing and submitting required programmatic and financial reports, establishing and/or maintaining equipment inventory, documenting operational and equipment expenditures for financial accounting purposes, responding to official informational requests from state and federal oversight authorities, including completing the Civil Rights Evaluation Tool as required by DHS, and grant performance measurement or evaluation activities.

Recipients or subrecipients may apply or credit M&A funding toward the recipient’ s requirement to allocate funding toward the National Priority Areas. For example, if a recipient spends $5,000 to manage or administer its funding dedicated toward its election security investment, the recipient may credit that funding toward its requirement to allocate at least 3% of its award to the enhancing election security National Priority Area.

While the SAA may retain up to 5% of HSGP funds awarded for M&A, the state must still ensure that all subrecipient award amounts meet the mandatory minimum pass-through requirements that are applicable to each HSGP program. To meet this requirement, the percentage of SHSP, UASI, and OPSG funds passed through to subrecipients must be based on the state’ s total HSGP award prior to withholding any M&A. The maximum amount of M&A the SAAs may retain is calculated based on the total amount received under all HSGP awards. For example, if the award were as follows:

SHSP: $500,000
OPSG: $200,000
UASI: $300,000
Total HSGP Award: $1,000,000
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The maximum M&A the SAA is authorized for use of the total HSGP award would be $50,000. ($1,000,000 X 5% = $50,000). For OPSG subawards, the SAA must ensure that subrecipients receive 100% of their respective OPSG allocation amounts. In the above example, the SAA could not retain any amount of the OPSG award, including amounts for M&A, and would be required to ensure that the full 200,000 of that OPSG award was received by the subrecipients.

Because the OPSG allocation is a component of the SHSP award, SAAs may retain 5% of the total SHSP award ( SHSP + OPSG awards) for M&A and may use this amount to cover the costs of M&A that are directly allocable to both OPSG and SHSP. In the above example, the total amount of the SHSP and OPSG award is 700,000; therefore, the SAA may retain $35,000, which represents up to 5% of the 700,000. This represents $ 500,000 of the SHSP award for M&A while ensuring that the full amount of the OPSG award is distributed to the appropriate subrecipients.

HSGP recipients are also reminded that any M&A deducted by the SAA from the UASI grant program award must be directly allocable to administration of the UASI grant program and cannot be used to cover M&A costs that are directly allocable to an OPSG or SHSP award.

Specific for OPSG, subrecipients and friendly forces may retain funding for M&A purposes; however, the total amount retained cannot exceed 5% of the subrecipient’ s subaward. Friendly forces are local law enforcement entities that are subordinate subrecipients under OPSG. In other words, friendly forces are entities that receive a subaward from a subrecipient under the OPSG program. Friendly forces must comply with all requirements of subrecipients under 2 C.F.R. Part 200.

M&A charged to OPSG, SHSP, or UASI funding must be used to support that particular program.
d. Indirect Facilities & Administrative (F&A) Costs
Indirect (F&A) costs (IDC) mean those costs incurred for a common or joint purpose benefitting more than one cost objective and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. IDC are allowable by the recipient [and subrecipients] as described in 2 C.F.R. Part 200, including 2 C.F.R. § 200.414. Applicants with a current negotiated IDC rate agreement who desire to charge indirect costs to a federal award must provide a copy of their IDC rate agreement with their applications. Not all applicants are required to have a current negotiated IDC rate agreement. Applicants that are not required to have a negotiated IDC rate agreement but are required to develop an IDC rate proposal must provide a copy of their proposal with their applications. Applicants who do not have a current negotiated IDC rate agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to FEMA for further instructions. Applicants who wish to use a cost allocation plan in lieu of an IDC rate proposal must reach out to the FEMA Point of Contact for further instructions. As it relates to the IDC for subrecipients, a recipient must follow the requirements of 2 7

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C.F.R. §§ 200.332 and 200. 414 in approving the IDC rate for subawards. For information on procedures for establishing indirect cost rates, see the Preparedness Grants Manual.
e. Funds Transfer Restrictions
The recipient is prohibited from transferring funds between programs (includes SHSP, UASI, and OPSG). Recipients can submit an investment/ project where funds come from multiple funding sources (e.g., SHSP and UASI), however, recipients are not allowed to divert funding from one program to another due to the risk- based funding allocations, which were made at the discretion of DHS/FEMA. f. Evaluation Costs
Evaluation costs are allowable. See Section H.2 “ Program Evaluation” for more details.
g. Allowable Cost Matrix for SHSP, UASI, and OPSG
The following matrix lists allowable cost activities across cost categories described above and below. The Preparedness Grants Manual includes additional information on allowable costs. Recipients and subrecipients must follow all applicable requirements in 2 C.F.R. Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. HSGP funds may be used to cover the costs for evaluating the impact of these grants on the state or urban area’ s core capabilities and capability gaps. This list is not exhaustive, therefore, if there are any questions regarding allowable costs, please contact the appropriate FEMA Headquarters (HQ) Preparedness Officer.

Allowable Program Activities SHSP UASI OPSG
Allowable Planning Costs
Developing hazard/threat-specific annexes Y Y N
Developingandimplementinghomelandsecuritysupportprogramsandadopting ongoing DHS/FEMA nationalinitiatives Y Y N
Developing related terrorism and other catastrophic event prevention activities Y Y N Developing and enhancing plans and protocols Y Y N
Developing or conducting assessments Y Y N
Hiringoffull- orpart-timestafforcontract/consultantstoassistwithplanning, engagement, and volunteer management activities Y Y N
Materials required to conduct planning, engagement, and volunteer management activities Y Y N
Travel/per diem related to planning, engagement, and volunteer management activities Y Y Y Overtime and backfill costs ( in accordance with operational Cost Guidance) Y Y Y Issuance of Western Hemisphere Travel Initiative- compliant Tribal identification cards Y NN Activitiesto achieveplanninginclusiveofpeoplewithdisabilitiesandotherswith access and functionalneeds and limited English proficiency. Y Y N Coordination with Citizen Corps Councils for public information/ education and development of volunteer programs
Y Y N
Coordination and material support to Citizen Corps Councils and local firehouses for the establishment, training and maintenance of CERTs Y Y N Update governance structures and processes and plans for emergency communications Y Y N Development, and review and revision of continuity of operations plans Y Y N 7

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Allowable Program Activities SHSP UASI OPSG
Development, and review and revision of the THIRA/SPR and continuity of operations plans Y Y N
Developing or conducting equity assessments to address planning and preparedness disparities for historically underserved communities Y Y N Allowable Organizational Activities
Note: Personnel hiring, overtime, and backfill expenses arepermitted under this grantonly to the extent that such expenses are for the allowable activities within the scope of the grant.

Program management Y Y N
Development of whole community partnerships Y Y N
Structures and mechanisms for information sharing between the public and private sector Y Y N
Implementing models, programs, and workforce enhancement initiatives Y Y N Tools, resources, andactivitiesthatfacilitatesharedsituationalawarenessbetween the public and privatesectors Y Y N
Operational support Y Y N
Utilization of standardized resource management concepts Y Y N Responding to an increase in the threat level under the National Terrorism Advisory System ( NTAS), or needs in resulting from a National Special Security Event Y Y N Reimbursement for select operational expenses associated with increased security measures at critical infrastructure sites incurred ( up to 50% of the allocation) Y Y Y Overtimeforinformation, investigative, andintelligencesharingactivities( upto50% of theallocation) Y Y Y
Hiring of new staff positions/contractors/consultants for participation in information/intelligenceanalysisandsharinggroupsorfusioncenteractivities( upto 50% of theallocation).

Y Y Y
Hiring or maintaining staff positions/contractors/consultants at SLTT levels to deliver community preparedness training, resources and material to schools, community-based organizations, faith-based institutions and local businesses.

Y Y N
Hiring or maintaining staff positions/contractors/consultants to create, support and maintain CERT or Teen CERT Y Y N
Cost of migrating online services to the “. gov” domain Y Y N Allowable Equipment Categories
Personal Protective Equipment Y Y Y
Explosive Device Mitigation and Remediation Equipment Y Y N CBRNE Operational Search and Rescue Equipment Y Y N
Information Technology Y Y Y
Cybersecurity Enhancement Equipment Y Y N
Interoperable Communications Equipment Y Y Y
Detection Y Y Y
Decontamination Y Y N
Medical countermeasures Y Y Y
Power (e.g., generators, batteries, power cells) Y Y Y
CBRNE Reference Materials Y Y N
CBRNE Incident Response Vehicles Y Y N
Terrorism Incident Prevention Equipment Y Y Y
Physical Security Enhancement Equipment Y Y Y
Inspection and Screening Systems Y Y Y
Animal Care and Foreign Animal Disease Y Y N
CBRNE Prevention and Response Watercraft Y Y N
CBRNE Prevention and Response Unmanned Aircraft Y Y N
CBRNE Aviation Equipment Y Y N
CBRNE Logistical Support Equipment Y Y N
Intervention Equipment (e.g., tactical entry, crime scene processing) Y Y Y 7

43 FY 2024 HSGP NOFO
Allowable Program Activities SHSP UASI OPSG
Critical emergency supplies Y Y N
General use vehicle acquisition, lease, and rental NNY
Specialized vehicle acquisition, lease, and rental Y Y Y Other Authorized Equipment Y Y Y
Allowable Training Costs
Overtimeandbackfillforemergencypreparednessandresponsepersonnel attending DHS/FEMA-sponsoredandapprovedtraining classes Y Y N Overtime and backfill expenses for part-time and volunteer emergency response personnel participating in DHS/FEMA training Y Y N
Training workshops and conferences Y Y Y
Activities to achieve training inclusive of people with disabilities and others with access and functional needs and limited English proficiency Y Y N Full- or part-time staff or contractors/ consultants Y Y Y Travel Y Y Y
Supplies Y Y N
Instructor certification/ re-certification Y Y N
Coordination with Citizen Corps Councils and CERT in conducting training exercises Y Y N Preparedness training for community preparedness initiatives and programs Y Y N Interoperable communications training Y Y N
Activities to achieve planning inclusive of people with limited English proficiency Y Y N Immigration enforcement training Y Y Y
Allowable Exercise Related Costs
Design, Develop, Conduct, and Evaluate an Exercise Y Y N Full- or part-time staff or contractors/consultants Y Y N Overtime and backfill costs, including expenses for part-time and volunteer emergency response personnel participating in DHS/FEMA exercises Y Y N Implementation of HSEEP Y Y N
Activities to achieve exercises inclusive of people with disabilities and others with access and functional needs Y Y N
Travel Y Y N
Supplies Y Y N
Interoperable communications exercises Y Y N
Activities to achieve planning inclusive of people with limited English proficiency Y Y N Allowable M&A Costs
Hiring of full- or part-time staff or contractors/consultants to assist with the management of the respective grant program, application requirements, and compliance with reporting and data collection requirements Y Y Y
Development of operating plans for information collection and processing necessary to respond to DHS/FEMA data calls Y Y Y
Overtime and backfill costs Y Y Y
Travel Y Y Y
Meeting related expenses Y Y Y
Authorized office equipment Y Y Y
Recurring expenses such as those associated with cell phones and faxes during the period of performance of the grant program
Y Y N
Leasing or renting of space for newly hired personnel during the period of performance of the grant program
Y Y N
Completing the Civil Rights Evaluation Tool Y Y Y
Conducting activities related to evaluating project effectiveness for HSGP-funded projects Y Y Y
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44 FY 2024 HSGP NOFO
Allowable Program Activities SHSP UASI OPSG
LETPA Costs
Integration and interoperability of systems and data, such as CAD and RMS, to facilitate the collection, Y Y N
Maturation, enhancement, and sustainment of designated state and major Urban Area fusion centers, including information sharing and analysis, threat recognition, terrorist interdiction, and intelligence analyst training and salaries (subject to certain conditions) Y Y N
Regional counterterrorism training programs for small, medium, and large jurisdictions to exchange information and discuss the current threat environment, lessons learned, and best practices to help prevent, protect against, and mitigate acts of terrorism Y Y N
Coordination of regional full-scale training exercises (federal, state, and local law enforcement participation) focused on terrorism-related events Y Y N Law enforcement Chemical, Biological, Radiological, Nuclear, and high yield Explosives detection and response capabilities, such as bomb detection/ disposal capability development, sustainment, or enhancement, including canine teams, robotics platforms, and x-ray technology
Y Y N
Coordination between fusion centers and other operational analytic, and investigative efforts Y Y N
Implementation, maintenance, and sustainment of the Nationwide Suspicious Activity Reporting Initiative Y Y N
Implementation of the "If You See Something, Say Something®" campaign Y Y N Increase physical security, through law enforcement personnel and other protective measures, by implementing preventive and protective measures at critical infrastructure locations
Y Y N
h. SHSP and UASI Other Direct Costs
Recipients must comply with all the requirements in 2 C.F.R. Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards). In general, recipients should consult with their FEMA HQ Preparedness Officer prior to making any investment that does not clearly meet the allowable expense criteria. Funding guidelines established within this section support four of the five mission areas— Prevention, Protection, Mitigation, and Response— and associated core capabilities within the Goal. While Recovery is part of the Goal, it is not explicitly part of the HSGP. Allowable investments made in support of the national priorities, as well as other capability-enhancing projects must have a nexus to terrorism preparedness and fall into the categories of planning, organization, exercises, training, or equipment, aligned to building capability, closing capability gaps, and/ or sustaining capabilities, as defined by CPG 201: THIRA/ SPR Guide— 3rd Edition (Comprehensive Preparedness Guide (CPG) 201, 3rd Edition (fema.gov)).

Recipients are encouraged to use grant funds for evaluating grant- funded project effectiveness and return on investment. FEMA encourages recipients to provide the results of that analysis to FEMA.

I. PLANNING
SHSP and UASI funds may be used for a range of emergency preparedness and management planning activities, such as those associated with the development, review, and revision of the THIRA, SPR, continuity plans, and other planning activities that support the Goal and placing an emphasis on updating and maintaining a current Emergency Operations Plan (EOP) that conforms to the guidelines outlined in Comprehensive Preparedness Guide ( CPG) 101 v3. 7

45 FY 2024 HSGP NOFO
Planning efforts can also include conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Infrastructure Resilience Planning Framework and related Cybersecurity and Infrastructure Security Agency (CISA) resources.

Additionally, SHSP and UASI funds may be used for planning efforts related to state court cybersecurity, 911 call capabilities, alert and warning capabilities, and implementation of the REAL ID Act (Pub. L. No. 109-13).

II. ORGANIZATION
Organization costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual.

States and high-risk urban areas must justify proposed expenditures of SHSP or UASI funds to support organization activities within their Investment Justification IJ) submission. Organizational activities include:
i. Program management;
ii. Development of whole community partnerships, through groups such as Citizen Corp Councils;
iii. Structures and mechanisms for information sharing between the public and private sector;
iv. Implementing models, programs, and workforce enhancement initiatives to address ideologically inspired radicalization to violence in the homeland;
v. Tools, resources, and activities that facilitate shared situational awareness between the public and private sectors;
vi. Operational Support;
vii. Utilization of standardized resource management concepts such as typing, inventorying, organizing, and tracking to facilitate the dispatch, deployment, and recovery of resources before, during, and after an incident;
viii. Responding to an increase in the threat level under the National Terrorism Advisory System (NTAS) or needs resulting from a National Special Security Event;
ix. Paying salaries and benefits for personnel to serve as qualified Intelligence Analysts. Per the Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act PRICE Act), Pub. L. No. 110-412, § 2, codified in relevant part, as amended, at 6 U.S.C. § 609(a), SHSP and UASI funds may be used to hire new staff and/or contractor positions to serve as intelligence analysts to enable information/intelligence sharing capabilities, as well as support existing intelligence analysts previously covered by SHSP or UASI funding. See 6 U.S.C. § 609(a). To be hired as an intelligence analyst, staff and/or contractor personnel must meet at least one of the following criteria:
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46 FY 2024 HSGP NOFO
o Complete training to ensure baseline proficiency in intelligence analysis and production within six months of being hired; and/ or,
o Previously served as an intelligence analyst for a minimum of two years either in a federal intelligence agency, the military, or state and/or local law enforcement intelligence unit. x. All fusion center analytical personnel must demonstrate qualifications that meet or exceed competencies identified in the Common Competencies for state, local, and tribal intelligence analysts, which outlines the minimum categories of training needed for intelligence analysts. A certificate of completion of such training must be on file with the State Administrative Agency (SAA) and must be made available to the recipient’ s respective FEMA HQ Preparedness Officer upon request; and
xi. Migrating online services to the “. gov” internet domain.

All SAAs are allowed to use up to 50% of their SHSP funding, and all high-risk urban areas are allowed to use up to 50% of their UASI funding, for personnel costs per 6 U.S.C. § 609(b)(2)(A). Personnel hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such expenses are for the allowable activities within the scope of the grant. Personnel expenses may include, but are not limited to training and exercise coordinators, program managers and planners, intelligence analysts, and Statewide Interoperability Coordinators ( SWICs).

At the request of a recipient, the FEMA Administrator ( or their designee) may grant a waiver of this 50% limitation under 6 U.S.C. § 609(b)(2)(B). Requests for waivers to the personnel cap must be submitted by the authorized representative of the SAA to FEMA in writing on official letterhead, with the following information:
i. Documentation explaining why the cap should be waived; ii. Conditions under which the request is being submitted; and iii. A budget and method of calculation of personnel costs both in percentages of the grant award and in total dollar amount.

Please see IB 421b, Clarification on the Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of 2008 (Public L. No. 110–412 – the PRICE Act), dated October 30, 2019, for additional information on the waiver request process.

III. EQUIPMENT
Equipment costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual.

The 21 allowable prevention, protection, mitigation, and response equipment categories for HSGP are listed on the Authorized Equipment List (AEL). Some 7

47 FY 2024 HSGP NOFO
equipment items require prior approval from FEMA before obligation or purchase of the items. Please reference the grant notes for each equipment item to ensure prior approval is not required or to ensure prior approval is obtained if necessary.

Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior approval from FEMA.

Unless otherwise stated, all equipment must meet all mandatory regulatory and/ or FEMA-adopted standards to be eligible for purchase using these funds. In addition, recipients will be responsible for obtaining and maintaining all necessary certifications and licenses for the requested equipment. Investments in emergency communications systems and equipment must meet applicable SAFECOM Guidance on Emergency Communications Grants (SAFECOM Guidance) recommendations. Such investments must be coordinated with the SWIC and the State Interoperability Governing Body (SIGB) to ensure interoperability and long- term compatibility. For personal protective equipment PPE), recipients are encouraged to give procurement preference to domestic manufacturers of PPE or PPE raw materials to the maximum practicable and allowed by law.

Grant funds may be used for the procurement of medical countermeasures.

Procurement of medical countermeasures must be conducted in collaboration with state, city, or local health departments that administer federal funds from the Department of Health and Human Services for this purpose and with existing Metropolitan Medical Response System committees where available, to sustain their long-term planning for appropriate, rapid, and local medical countermeasures, including antibiotics and antidotes for nerve agents, cyanide, and other toxins. Procurement must have a sound threat-based justification with an aim to reduce the consequences of mass casualty incidents during the first crucial hours of a response. Prior to procuring pharmaceuticals, recipients must have in place an inventory management plan to avoid large periodic variations in supplies due to coinciding purchase and expiration dates. Recipients are encouraged to enter into rotational procurement agreements with vendors and distributors. Purchases of pharmaceuticals must include a budget for the disposal of expired drugs within each fiscal year’ s POP for HSGP. The cost of disposal cannot be carried over to another FEMA grant or grant period.

EMS electronic patient care data systems should comply with the most current data standard of the National Emergency Medical Services Information System.

Recipients are reminded that school hardening is an eligible activity under SHSP and UASI. School hardening measures include but are not limited to:
i. Bullet resistant doors and glass;
ii. Hinge-locking mechanisms;
iii. Immediate notification to emergency 911 systems;
iv. Mechanisms that provide real time actionable intelligence directly to law enforcement and first responders;
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48 FY 2024 HSGP NOFO
v. Installation of distraction devices or other countermeasures administered by law enforcement; and
vi. Other measures determined to provide significant improvements to schools’ physical security.

Additionally, SHSP and UASI funds may be used for equipment purchases related to state court cybersecurity, 911 call capabilities, alert and warning capabilities, and implementation of the REAL ID Act (Pub. L. No. 109-13).

Small Unmanned Aircraft Systems ( sUAS) and critical emergency supply costs are allowable under this program. See the Preparedness Grants Manual for more information.

General Purpose Equipment
HSGP allows expenditures on general purpose equipment if it aligns to and supports one or more core capabilities identified in the Goal and has a nexus to terrorism preparedness. General purpose equipment, like all equipment funded under the HSGP, must be sharable through the EMAC 4and allowable under 6 U.S.C. § 609, and any other applicable provision of the Homeland Security Act of 2002, as amended. Examples of such general- purpose equipment may include:
o Law enforcement/general use vehicles (OPSG only);
o Emergency medical services equipment andvehicles;
o Fire service equipment and vehicles, to include hose, pump accessories, and foam concentrate for specialized
chemical/biological/radiological/nuclear/explosive (CBRNE) response;
o Interoperability of data systems, such as computer aided dispatch CAD) and record management systems (RMS); and
o Office equipment for staff5
engaged in homeland security program
activity.

Controlled Equipment
For decades, the federal government has provided equipment to state, local, and tribal law enforcement agencies (LEAs) through federal grants. Some federal grant programs have assisted LEAs as they carry out their critical missions to keep the American people safe. The equipment acquired by LEAs through these programs includes administrative equipment, such as office furniture and computers. Some federal grant programs also may include military and militarystyled equipment, firearms, and tactical vehicles provided by the federal government, including property covered under 22 C.F.R. Part 121 and 15 C.F.R.

Part 774 (collectively, "controlled equipment").
4Except for American Samoa and the Commonwealth of the Northern Mariana Islands, which are not required to belong to EMAC at this time.
5This applies to all homeland security personnel and is not limited to M&A staff, and costs are to be captured outside the cap on M&A costs.
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49 FY 2024 HSGP NOFO
However, not all equipment that is considered controlled equipment is allowable under the HSGP. As noted in Section B of FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards, certain equipment is prohibited and is not allowable under HSGP. Grant funds under this program may not be used for the purchase of equipment not approved by DHS/ FEMA. For example, the purchase of tracked armored vehicles, camouflage uniforms, weapons, and weapons accessories, including ammunition, is generally not allowed with HSGP funds.6
For some controlled equipment that is allowable under the HSGP, additional documentation, justifications, reviews, and approvals are required, including but not limited to proof of policies and procedures to safeguard individuals’ privacy, civil rights, and civil liberties. Contact your Preparedness Officer if you have questions concerning HSGP requirements for controlled equipment requests.

Grant funds under this program must comply with the aforementioned FEMA Policy 207- 22-0002, Prohibited or Controlled Equipment Under FEMA Awards.

As per this FEMA Policy, excepted or controlled equipment must remain in the possession of the original FEMA grant recipient and may not be transferred. The use of controlled equipment under a Memorandum of Understanding or other regional sharing agreement ( see Section D.6 of this FEMA Policy) does not constitute a transfer of controlled equipment.

DHS/FEMA will continue to collaborate with federal agency partners to ensure that there is a consistent and reasonable approach to the restrictions placed on controlled equipment expenditures while continuing to support these investments when there is a justifiable need. Further, DHS/FEMA will continue to maintain an awareness of the evolving policy developments related to controlled equipment expenditures and keep grant recipients up to date on future developments.

Construction and Renovation
Construction and renovation costs to achieve capability targets related to preventing, preparing for, protecting against, or responding to acts of terrorism are allowed under this program. For construction and renovation costs to be allowed, they must be specifically approved by DHS/FEMA in writing prior to the use of any program funds. Limits on the total amount of grant funding that may be used for construction or renovation may apply. Additionally, recipients are required to submit SF-424C and SF-424D.

All proposed construction and renovation activities must undergo an 6 FEMA issued Policy 207-22-0002 in response to Executive Order (EO) 14074, Advancing Effective, Accountable Policing and Criminal Justice Practices to Enhance Public Trust and Public Safety, which President Joseph R. Biden issued on May 25, 2022. EO 14074 directs the DHS to prohibit the use of grant funding to purchase certain types of military equipment by state, local, tribal, and territorial law enforcement agencies and to comply with and implement the recommendations stemming from EO 13688, which established prohibited equipment and controlled equipment lists.
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50 FY 2024 HSGP NOFO
Environmental Planning and Historic Preservation ( EHP) review, including approval of the review from FEMA, prior to undertaking any action related to the project. Failure of a grant recipient to meet these requirements may jeopardize Federal funding. Please see the Preparedness Grants Manual for more information.

IV. TRAINING AND EXERCISES
Training and exercise costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual. Recipients are encouraged to consider tuition-free courses offered by FEMA first, before investing in training. For more information and a catalog of courses please refer to the National Preparedness Course Catalog at NTED.

Allowable training-related costs under HSGP include the establishment, support, conduct, and attendance of training specifically identified under the SHSP and UASI program and/or in conjunction with emergency preparedness training by other federal agencies ( e.g., HHS and Department of Transportation [ DOT]).

Training conducted using HSGP funds should address a performance gap identified through an Integrated Preparedness Plan ( IPP) or other assessments ( e.g., National Emergency Communications Plan [NECP] Goal Assessments) and contribute to building a capability that will be evaluated through a formal exercise. Any training or training gaps, including training related to under-represented, diverse populations that may be more impacted by disasters, including children, seniors, individuals with disabilities or other access and functional needs, individuals with diverse culture and language use, individuals with lower economic capacity and other underserved populations, should be identified in an IPP and addressed in the state or high-risk urban area training cycle. Emergency preparedness training related to those training gaps, including related to under-represented, diverse populations that may be more impacted by disasters, is allowable. Recipients are encouraged to use existing training rather than developing new courses. When developing new courses, recipients are encouraged to apply the Analysis, Design, Development, Implementation, and Evaluation (ADDIE) model of instructional design.

Law Enforcement Readiness
SHSP or UASI grant funds may be requested and may be approved on a case-bycase basis for immigration enforcement training in support of the border security mission. Requests for training will be evaluated on a case-by-case basis and can only be used for certification in the section 287(g) program provided by DHS/ICE. SHSP or UASI subrecipients with agreements under section 287(g) of the Immigration and Nationality Act (INA) (8 U.S.C. § 1357(g)) to receive delegated authority for immigration enforcement within their jurisdictions may also be reimbursed for section 287(g) related operational activities with approval from FEMA on a case-by-case basis.
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51 FY 2024 HSGP NOFO
V. MAINTENANCE AND SUSTAINMENT
Maintenance and sustainment related costs are allowed under this program only as described in the Preparedness Grants Manual.

VI. TRAVEL
Domestic travel costs are allowed under this program, as provided for in this NOFO. International travel is not an allowable cost under this program unless approved in advance by DHS/FEMA. See the Allowable Cost Matrix in Section D.13.g above for more information on allowable travel activities under SHSP and UASI.

VII. PERSONNEL
Personnel hiring, overtime, and backfill expenses are permitted under this grant to perform allowable HSGP planning, organization, training, exercise, and equipment activities. All recipients and subrecipients of HSGP funds, including SHSP and UASI allocations, may not use more than 50% of their awards to pay for personnel activities unless a waiver is approved by FEMA. For more information on the 50% personnel cap, please see FEMA IB 421b, Clarification on the Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of 2008 (Public Law 110-412) – the PRICE Act.

HSGP funds may not be used to support the hiring of any personnel to fulfill traditional public health and safety duties nor to supplant traditional public health and safety positions and responsibilities. The following definitions apply to personnel costs:
i. Hiring. State and local entities may use grant funding to cover the salary of newly hired personnel who are exclusively undertaking allowable FEMA grant activities as specified in this guidance. This may not include new personnel who are hired to fulfill any non-FEMA program activities under any circumstances. Hiring will always result in a net increase of Full Time Equivalent (FTE) employees.
ii. Overtime. These expenses are limited to the additional costs that result from personnel working over and above 40 hours of weekly work time as the direct result of their performance of FEMA-approved activities specified in this guidance. Overtime associated with any other activity is not eligible.
iii. Backfill-Related Overtime. Also called “Overtime as Backfill,” these expenses are limited to overtime costs that result from personnel who are working overtime (as identified above) to perform the duties of other personnel who are temporarily assigned to FEMA-approved activities outside their core responsibilities. Neither overtime nor backfill expenses are the result of an increase of FTE employees.
iv. Supplanting. Grant funds will be used to supplement existing funds and will not replace (supplant) funds that have been appropriated for the same purpose. Applicants or recipients may be required to supply documentation certifying that a reduction in non-federal resources 7

52 FY 2024 HSGP NOFO
occurred for reasons other than the receipt or expected receipt of federal funds.

Operational OvertimeCosts
In support of efforts to enhance capabilities for detecting, deterring, disrupting, and preventing acts of terrorism and other catastrophic events, operational overtime costs are allowable for increased protective security measures at critical infrastructure sites or other high-risk locations and to enhance public safety during mass gatherings and high- profile events. In that regard, HSGP recipients are urged to consider using grant funding to support soft target preparedness activities. SHSP or UASI funds may be used to support select operational expenses associated with increased security measures in the authorized categories cited in the table below, but this table is not exhaustive. FEMA retains the discretion to approve other types of requests that do not fit within one of the categories of the table.

Authorized Operational Overtime Categories
Category Description
1 National Terrorism
Advisory System
NTAS)
Security measures in response to an increase in the threat level under the NTAS to an “ elevated” or “imminent” alert status. FEMA Information Bulletin No. 367, Impact of National Terrorism Advisory System on Homeland Security Grant Programs, remains applicable; therefore, advance authorization from FEMA is not required. Refer to National Terrorism Advisory System | Homeland Security (dhs.gov) for additional information on the NTAS. 2 National Security
Special Event ( NSSE)
Security measures for a designated NSSE. NSSEs are events of national or international significance deemed by DHS to be a potential target for terrorism or other criminal activity. 3 Special Event
Assessment Rating
SEAR) Level 1 through
Level 4 Events
Security measures required for SEAR Level 1 through Level 4 events as designated by DHS and included in the DHS National Special Events List, as defined below:
x SEAR 1: A significant event with national and/or
international importance that may require extensive federal interagency support.
x SEAR 2: A significant event with national and/or
international importance that may require some level of federal interagency support.
x SEAR 3: An event of national and/or international
importance that requires only limited federal support.
x SEAR 4: An event with limited national importance that is managed at state and local level.

NOTE: In cases where a threat of terrorism can be associated with a SEAR Level 5 event, the event planners should coordinate with their state or territory Homeland Security Advisor to seek re-adjudication of the SEAR rating. Operational overtime for security measures associated with such events will be considered for approval by FEMA if re- adjudication results in a SEAR 1 through 4 rating. 7

53 FY 2024 HSGP NOFO
Category Description
4 States of Emergency
Declarations of states of emergency by the Governor associated with a terrorism-related threat or incident. This excludes Presidentially declared major disasters or emergencies where federal funding support for the proposed grant-funded activity is made available through the FEMA Public Assistance program or other federal disaster grants.
5 National Critical
Infrastructure
Prioritization Program
NCIPP)
Protection of Level 1 and Level 2 facilities identified through DHS’s NCIPP based on a terrorism-related threat to critical infrastructure. 6 Directed Transit Patrols Targeted security patrols in airports and major transit hubs based on a terrorism-related threat to transportation systems.
7 Other Related Personnel
Overtime Costs
Overtime costs may be authorized for personnel assigned to directly support any of the security activities relating to the categories above.

Examples include firefighters and emergency medical services personnel; public works employees who may be responsible for installing protective barriers and fencing; public safety personnel assigned to assist with event access and crowd control; emergency communications specialists; backfill and overtime for staffing state or major urban area fusion centers; state Active Duty National Guard deployments to protect critical infrastructure sites, including all resources that are part of the standard National Guard deployment package (note: consumable costs, such as fuel expenses, are not allowed except as part of the standard National Guard deployment package); contract security services for critical infrastructure sites; participation in Regional Resiliency Assessment Program activities, increased border security activities in coordination with USBP, etc.
8 Operational Support to
a Federal Agency
Overtime costs are allowable for personnel to participate in information, investigative, and intelligence sharing activities related to homeland security/terrorism preparedness and specifically requested by a federal agency. Allowable costs are limited to overtime associated with federally requested participation in eligible activities, including anti-terrorism task forces, Joint Terrorism Task Forces (JTTFs), Area Maritime Security Committees (as required by the Maritime Transportation Security Act of 2002), DHS Border Enforcement Security Task Forces, and Integrated Border Enforcement Teams. In addition, reimbursement for operational overtime law enforcement activities related to combating transnational crime organizations in support of efforts to enhance capabilities for detecting, deterring, disrupting, and preventing acts of terrorism is an allowable expense under SHSP and UASI on a case-by-case basis. Grant funding can only be used in proportion to the federal man- hour estimate and only after funding for these activities from other federal sources (i.e., FBI JTTF payments to state and local agencies) has been exhausted.
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54 FY 2024 HSGP NOFO
All allowable operational overtime costs are also subject to the administration requirements outlined in the following subsection.

Administration of Operational Overtime Requests
i. Except for an elevated NTAS alert, SHSP or UASI funds may only be spent for operational overtime costs upon prior written approval by FEMA. The SAA must submit operational overtime requests in writing to its assigned FEMA Preparedness Officer. FEMA will consider requests for special event activities up to one year in advance.

However such requests must be within the award’ s current POP and must not result in the need for a request to extend the period of performance. SAAs should contact FEMA Grants News by e-mail at [email protected] or by phone at (800) 368-6498, Monday through Friday, 9:00 AM – 5:00 PM ET, for clarification. ii. All operational overtime requests must clearly explain how the request meets the criteria of one or more of the categories listed in the table above. Requests must address the threat environment as it relates to the event or activity requiring operational overtime support and explain how the overtime activity is responsive to the threat. Request letters sent to FEMA must be UNCLASSIFIED but may be labeled “ For Official Use Only.” If explaining the threat will require the sharing of classified information, the letter should state that fact. FEMA will then plan for the sharing of classified information through official channels; iii. Post- event operational overtime requests will only be considered on a case-by-case basis, where it is demonstrated that exigent circumstances prevented submission of a request in advance of the event or activity;
iv. Under no circumstances may FEMA grant funding be used to pay for costs already supported by funding from another federal source; v. States with UASI jurisdictions can use funds retained at the state level to reimburse eligible operational overtime expenses incurred by the state ( per the above guidance limitations). Any UASI funds retained by the state must be used in direct support of the high-risk urban area.

States must provide documentation to the Urban Area Working Group UAWG) and FEMA upon request demonstrating how any UASI
funds retained by a state would directly support the high- risk urban area; and
vi. FEMA will consult and coordinate with appropriate DHS components as necessary to verify information used to support operational overtime requests.

VIII. SECURE IDENTIFICATION
Secure identification costs are allowed under this program. SHSP funds may be used to support the implementation activities associated with the Western Hemisphere Travel Initiative (WHTI), including the issuance of WHTI-compliant tribal identification cards.
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55 FY 2024 HSGP NOFO
IX. MULTIPLE PURPOSE OR DUAL-USE OF FUNDS
Please see the Preparedness Grants Manual for information on multiple purpose of dual-use of funds under SHSP and UASI.
i. OPSG Other Direct Costs
Recipients must comply with all the requirements in 2 C.F.R. Part 200 ( Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards). In general, recipients should consult with their FEMA HQ Preparedness Officer prior to making any investment that does not clearly meet the allowable expense criteria. Funding guidelines established within this section support four of the five mission areas— Prevention, Protection, Mitigation, and Response— and associated core capabilities within the Goal. While Recovery is part of the Goal, it is not explicitly part of the HSGP. Allowable investments made in support of the national priorities, as well as other capability- enhancing projects must have a nexus to terrorism preparedness and fall into the categories of planning, organization, exercises, training, or equipment, aligned to building capability, closing capability gaps, and/or sustaining capabilities, as defined by CPG 201: THIRA/SPR Guide—3rd Edition ( Comprehensive Preparedness Guide ( CPG) 201, 3rd Edition ( fema. gov)).

Recipients are encouraged to use grant funds for evaluating grant-funded project effectiveness and return on investment. FEMA encourages recipients to provide the results of that analysis to FEMA.

I. PLANNING
Planning costs are allowed under this program only as described in this funding notice. See the Allowable Cost Matrix in Section D.13.g above for more information on allowable planning activities for OPSG.

II. ORGANIZATION
Organization costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual. See the Allowable Cost Matrix in Section D.13.g above for more information on allowable organizational activities for OPSG.

III. EQUIPMENT
Equipment costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual.

OPSG equipment is intended to be incidental to the enhanced border security operations being performed. The grant is not intended to be used to outfit or supply general equipment to SLTT law enforcement agencies. Equipment must be relatable to and justified by the operational benefit it will provide. Each appropriate OPSG sector coordinator is required to keep an inventory of OPSG purchased equipment that includes at a minimum: 1) grant funding year; 2) purchase amount; 3) purchase date; 4) purchase quantity; 5) equipment ID; 6) source of funding for the property, including the Federal Award Identification Number; 7) who holds title to the property; 8) federal share percent of the 7

56 FY 2024 HSGP NOFO
property; 9) location of the property; 10) use and condition of the property; 11) disposal date; and 12) brief disposal justification information and sale price if sold. Each Operations Order/ FRAGO will require that each friendly force submit the equipment inventory for each Operations Order/FRAGO submission. i. Equipment Marking. Because equipment purchased with OPSG funding is intended to be used to support OPSG activities, it may be appropriately marked to ensure its ready identification and primary use for that purpose. When practicable, any equipment purchased with OPSG funding should be prominently marked as follows: " Purchased with DHS funds for Operation Stonegarden Use."
ii. Fuel Cost and Mileage Reimbursement. There is no cap for reimbursement of fuel or mileage costs in support of operational activities. Subrecipients and friendly forces may not claim reimbursements for both mileage and fuel/ maintenance for the same equipment at the same time.
iii. Vehicle and Equipment Acquisition, Including Leasing and Rentals. Allowable purchases under OPSG include patrol vehicles and other mission- specific equipment whose primary purpose is to increase operational capabilities on or near a border nexus in support of approved border security operations. A detailed justification must be submitted to the respective FEMA HQ Preparedness Officer prior to purchase.
iv. Medical Emergency Countermeasures. Allowable purchases under OPSG include narcotic antagonist pharmaceuticals, detection and identification equipment, safe storage and transportation, personnel protective equipment, and initial equipment training, as reflected in the AEL.

Requirements for Small Unmanned Aircraft Systems
Small Unmanned Aircraft Systems (sUAS) are allowable under the HSGP. See the Preparedness Grants Manual for more information.

General Purpose Equipment
HSGP allows expenditures on general purpose equipment if it aligns to and supports one or more core capabilities identified in the Goal and has a nexus to terrorism preparedness. General purpose equipment, like all equipment funded under the HSGP, must be sharable through the EMAC7and allowable under 6 U.S.C. § 609, and any other applicable provision of the Homeland Security Act of 2002, as amended. Examples of such general-purpose equipment may include:
o Law enforcement/general use vehicles (OPSG only);
o Emergency medical services equipment andvehicles;
o Fire service equipment and vehicles, to include hose, pump accessories, and foam concentrate for specialized
7Except for American Samoa and the Commonwealth of the Northern Mariana Islands, which are not required to belong to EMAC at this time.
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57 FY 2024 HSGP NOFO
chemical/ biological/ radiological/ nuclear/ explosive ( CBRNE) response;
o Interoperability of data systems, such as computer aided dispatch CAD) and record management systems (RMS); and
o Office equipment for staff 8engaged in homeland security program activity.

Controlled Equipment
For decades, the federal government has provided equipment to state, local, and tribal law enforcement agencies ( LEAs) through federal grants. Some federal grant programs have assisted LEAs as they carry out their critical missions to keep the American people safe. The equipment acquired by LEAs through these programs includes administrative equipment, such as office furniture and computers. Some federal grant programs also may include military and militarystyled equipment, firearms, and tactical vehicles provided by the federal government, including property covered under 22 C.F.R. Part 121 and 15 C.F.R.

Part 774 (collectively, "controlled equipment").

However, not all equipment that is considered controlled equipment is allowable under the HSGP. As noted in Section B of FEMA Policy 207- 22-0002, Prohibited or Controlled Equipment Under FEMA Awards, certain equipment is prohibited and is not allowable under HSGP. Grant funds under this program may not be used for the purchase of equipment not approved by DHS/FEMA. For example, the purchase of tracked armored vehicles, camouflage uniforms, weapons, and weapons accessories, including ammunition, is generally not allowed with HSGP funds. 9
For some controlled equipment that is allowable under the HSGP, additional documentation, justifications, reviews, and approvals are required, including but not limited to proof of policies and procedures to safeguard individuals’ privacy, civil rights, and civil liberties. Contact your Preparedness Officer if you have questions concerning HSGP requirements for controlled equipment requests.

Grant funds under this program must comply with the aforementioned FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards.

As per this FEMA Policy, excepted or controlled equipment must remain in the possession of the original FEMA grant recipient and may not be transferred. The use of controlled equipment under a Memorandum of Understanding or other 8This applies to all homeland security personnel and is not limited to M&A staff, and costs are to be captured outside the cap on M&A costs.
9 FEMA issued Policy 207-22-0002 in response to Executive Order (EO) 14074, Advancing Effective, Accountable Policing and Criminal Justice Practices to Enhance Public Trust and Public Safety, which President Joseph R. Biden issued on May 25, 2022. EO 14074 directs the DHS to prohibit the use of grant funding to purchase certain types of military equipment by state, local, tribal, and territorial law enforcement agencies and to comply with and implement the recommendations stemming from EO 13688, which established prohibited equipment and controlled equipment lists.
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regional sharing agreement ( see Section D.6 of this FEMA Policy) does not constitute a transfer of controlled equipment.

DHS/FEMA will continue to collaborate with federal agency partners to ensure that there is a consistent and reasonable approach to the restrictions placed on controlled equipment expenditures while continuing to support these investments when there is a justifiable need. Further, DHS/ FEMA will continue to maintain an awareness of the evolving policy developments related to controlled equipment expenditures and keep grant recipients up to date on future developments.

Construction and Renovation
OPSG funds may not be used for any construction.

IV. TRAINING AND EXERCISES
Training and exercise costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual (e.g., related to EHP compliance). Recipients are encouraged to consider tuition- free courses offered by FEMA first, before investing in training. For more information and a catalog of courses please refer to the National Preparedness Course Catalog at NTED.

Law Enforcement Readiness
OPSG grant funds may be used to increase operational, material, and technological readiness of SLTT law enforcement agencies. The Delegation of Immigration Authority, Section 287(g) of the INA program allows a state or local law enforcement entity to enter into a partnership with Immigration and Customs Enforcement (ICE), under a joint Memorandum of Agreement (MOA), to receive delegated authority for immigration enforcement within their jurisdictions.

OPSG grant funds may be requested and may be approved on a case-by-case basis for immigration enforcement training in support of the border security mission.

Requests for training will be evaluated on a case-by-case basis and can only be used for certification in the section 287(g) program provided by DHS/ICE. OPSG subrecipients with agreements under section 287(g) of the INA (8 U.S.C. § 1357(g)) to receive delegated authority for immigration enforcement within their jurisdictions may also be reimbursed for section 287(g) related operational activities with approval from FEMA on a case-by-case basis. For OPSG, subrecipients must be authorized by USBP Headquarters and Sectors, and operational activities must be coordinated through a USBP Sector.

V. MAINTENANCE AND SUSTAINMENT
Maintenance and sustainment related costs are allowed under this program only as described in the Preparedness Grants Manual.

VI. TRAVEL
Domestic travel costs are allowed under this program, as provided for in this NOFO and in the Preparedness Grants Manual. International travel is not an 7

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allowable cost under this program unless approved in advance by DHS/ FEMA.

See the Allowable Cost Matrix in Section D.13.g above for more information on allowable travel activities under OPSG.

VII. PERSONNEL
Personnel hiring, overtime, and backfill expenses are permitted under this grant to perform allowable HSGP planning, organization, training, exercise, and equipment activities. Under OPSG, overtime costs are allowable only in so far as they meet the intent of the program. All recipients and subrecipients of HSGP funds, including OPSG allocations, may not use more than 50% of their awards to pay for personnel activities unless a waiver is approved by FEMA. For more information on the 50% personnel cap, please see FEMA IB 421b, Clarification on the Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of 2008 (Public Law 110-412 – the PRICE Act).

Further, changes in scope or objective also require FEMA’s prior written approval pursuant to 2 C.F.R. § 200. 308( c)(1). If the cost changes are allowable under the grant, a Fragmentary Order (FRAGO) must be submitted to Homeland Security Information Network ( HSIN) to obtain FEMA’ s prior written approval of such changes in accordance with 2 C.F.R. § 200.308(c)(1). These modifications will be annotated in the annex section of the FRAGO.

OPSG funds may be used for domestic travel and per diem, including costs associated with the deployment/redeployment of personnel to border areas and for travel associated with law enforcement entities assisting other local jurisdictions in law enforcement activities. In addition, allowable costs include supporting up to six-month deployment of law enforcement personnel to critical Southwest Border locations for operational activities (travel costs must be in accordance with applicable travel regulations).

OPSG funds may be used to pay additional current part-time law enforcement personnel salaries to bring them to temporary full-time status. OPSG funds may support a Governor’ s request to activate, deploy, or redeploy specialized National Guard Units/Package and/or elements of state law enforcement serving as friendly forces to increase or augment specialized/technical law enforcement elements’ operational activities. Costs associated with backfill for personnel supporting operational activities are allowable.

As with all OPSG personnel costs, OPSG grant funds will be used to supplement existing funds and will not replace (supplant) funds that have been appropriated for the same purpose. Applicants or recipients may be required to supply documentation certifying that a reduction in non-federal resources occurred for reasons other than the receipt or expected receipt of federal funds. 7

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Operational Overtime Costs
OPSG funds should be used for operational overtime costs associated with law enforcement activities in support of border law enforcement agencies for enhanced border security. Overtime pay is for increased patrol time for certified public safety officers, along with limited support for other law enforcement direct support personnel (e.g., Communication Officers/Dispatchers, non-sworn patrol pilots, etc.). Overtime shall be reimbursed consistent with the non-federal entity’ s overtime policy and the requirements as stated below:
i. Overtime is time worked that exceeds the required number of hours during an employee’ s designated shift;
ii. Overtime must be worked to increase patrol capacity and be in support of identified and approved United States Border Patrol (USBP) border security operations;
iii. The OPSG overtime hourly rate of pay will be no more than the approved overtime rate per local law and policy and must be in accordance with applicable state and federal regulations; iv. All overtime expenses under OPSG must be reasonable for the services rendered and conform to the non-federal entity’ s established written policy, which must apply to both federally funded and nonfederally funded activities and comply with the other applicable requirements under 2 C.F.R. §§ 200. 430- 200. 431; and
v. The non-federal entity may not utilize OPSG funding to pay for an employee’ s overtime hours or pay that exceeds 16 hours worked in any 24-hour period.

Intelligence Support
Per 6 U.S.C. § 609(a), OPSG funds may, as applicable and operationally beneficial, be used to pay salaries and benefits or overtime for personnel to serve as qualified Intelligence Analysts to enable and enhance information/intelligence sharing capabilities, as well as support existing intelligence analysts previously covered by OPSG funding. Qualified OPSG-funded intelligence analysts can be assigned to an applicable law enforcement facility/intelligence function as long as information/intelligence sharing is maintained. To serve as an OPSG-funded intelligence analyst, personnel must meet at least one of the following criteria:
i. Complete training to ensure baseline proficiency in intelligence analysis and production within six (6) months of being hired; and/or, ii. Previously served as an intelligence analyst for a minimum of two years either in a federal intelligence agency, the military, or state and/or local law enforcement intelligence unit.

OPSG-funded intelligence analysts must demonstrate qualifications that meet or exceed competencies identified in the Common Competencies for state, local, and tribal intelligence analysts, which outlines the minimum categories of training needed for intelligence analysts. A certificate of completion of such training must be on file with the SAA and must be made available to the recipient’ s respective FEMA HQ Preparedness Officer upon request.
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VIII. REGIONAL BORDER PROJECTS
Recipients are encouraged to prioritize the acquisition and development of regional projects on the borders to maximize interoperability and coordination capabilities among federal agencies and with state, local, and tribal law enforcement partners. Such regional projects include:
i. Communications equipment;
ii. Radio systems and repeaters;
iii. Integration with regional intelligence and information sharing effort i.e., fusion centers):
o Intelligence analysts.
iv. Situational Awareness equipment:
o License Plate Reader Networks;
o Visual detection and surveillance systems;
o Sensor Systems;
o Radar Systems (for air and/or marine incursions); and o Aircraft systems ( manned or unmanned).

IX. TRANSPORTATION COSTS AND COSTS RELATED TO THE PROVISION OF ACUTE

MEDICAL CARE
Vehicle, fuel, mileage, operational overtime, and other types of costs otherwise allowable under an OPSG award’ s HSGP NOFO are allowable where the costs are in support of the necessary transportation of individuals interdicted while carrying out allowable OPSG-funded activities or operations from the point of interdiction to an applicable law enforcement facility.

When transporting individuals interdicted in the course of carrying out allowable OPSG-funded activities or operations from the point of interdiction, non-Federal entities may charge vehicle, fuel, mileage, operational overtime, and other types of costs otherwise allowable under an OPSG award’ s HSGP NOFO associated with necessary transportation to provide acute medical care for individuals being transported from the point of interdiction. In such cases, non-Federal entities may also charge operational overtime for personnel that monitor a detained individual receiving acute medical care where the individual remains in the custody of the non-Federal law enforcement agency. Costs incurred beyond the acute phase of medical care (e.g., upon admission to the hospital, or after transfer from an acute care facility to the hospital) and costs incurred once the custodial responsibility of the individual is transferred to CBP are not allowable under OPSG.

Costs described above are allowable regardless of what entity or agency initially makes the interdiction. Personnel costs incurred by non-Federal law enforcement agencies eligible under OPSG (including deputies, corrections officers, or detention officers) for costs described above are allowable. 7

62 FY 2024 HSGP NOFO
X. TEMPORARY OR TERM APPOINTMENTS
Temporary or term appointments are allowable under an OPSG award, so long as they comply with the following:
i. Subrecipients may utilize temporary or term appointments to augment the law enforcement presence on the borders. However, applying funds toward hiring full-time or permanent sworn public safety officers is unallowable;
ii. OPSG-funded temporary or term appointments may not exceed the approved period of performance:
o For OPSG purposes, temporary appointments are non-status appointments for less than one year; and
o For OPSG purposes, term appointments are non-status
appointments for one year, extendable for one year as
necessary.
iii. OPSG funding for temporary or term appointments may pay for salary only. Benefits are not allowable expenses for term or temporary employees;
iv. OPSG remains a non-hiring program. Appropriate uses of temporary or term appointments include:
o To carry out specific enforcement operations work for ongoing OPSG-funded patrols throughout the Sector Area of Operation; o To staff operations of limited duration, such as OPSGenhanced enforcement patrols targeting specific locations or criminal activity; and
o To fill OPSG positions in activities undergoing transition or personnel shortages and local backfill policies
medical/ military deployments).
v. OPSG term and temporary appointments must have all necessary certifications and training to enforce state and local laws. OPSG funds will not be used to train or certify term or temporary appointments except as otherwise stated in this NOFO and the Preparedness Grants Manual; and
vi. FEMA provides no guarantee of funding for temporary or term appointments. In addition to the terms of this NOFO, subrecipients must follow their own applicable policies and procedures regarding temporary or term appointments.
j. Unallowable Costs for SHSP, UASI, and OPSG
Per FEMA policy, the purchase of weapons and weapons accessories, including ammunition, is not allowed with HSGP funds. Grant funds may not be used for the purchase of equipment not approved by FEMA. Grant funds must comply with FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards, and may not be used for the purchase of the following equipment: firearms; ammunition; grenade launchers; bayonets; or weaponized aircraft, vessels, or vehicles of any kind with weapons installed. Unauthorized exercise- related costs include:
7

63 FY 2024 HSGP NOFO
x Reimbursement for the maintenance or wear and tear costs of general use vehicles ( e.g., construction vehicles), medical supplies, and emergency response apparatus (e.g., fire trucks, ambulances); and x Equipment that is purchased for permanent installation and/or use, beyond the scope of the conclusion of the exercise (e.g., electronic messaging sign).

I. UNALLOWABLE COSTS FOR OPSGONLY
OPSG unallowable costs include costs associated with evidence collection, arrest processing, prosecution, and Traffic/DUI checkpoints, such as evidence documentation cameras, fingerprinting supplies, alcohol breathalyzers, portable work lights, traffic barricades, and similar law enforcement expenses. OPSG unallowable costs also include costs associated with staffing and general IT computing equipment and hardware, such as personal computers, faxes, copy machines, modems, etc. OPSG is not intended as a hiring program. Therefore, applying funds toward hiring full-time or permanent sworn public safety officers is unallowable. OPSG funding shall not be used to supplant inherent routine patrols and law enforcement operations or activities not directly related to providing enhanced coordination between local and federal law enforcement agencies. Finally, construction and/ or renovation costs are prohibited under OPSG. Applicants should refer to IB 421b, or contact their FEMA HQ Preparedness Officer for guidance and clarification. Due to the nature of OPSG, exercise expenses are not allowable costs under OPSG.

E. Application Review Information

1. Application Evaluation Criteria
a. Programmatic Criteria
I. RISK METHODOLOGY
The risk methodology determines the relative risk of terrorism faced by a given area considering the potential risk of terrorism to people, critical infrastructure, and economic security. The analysis includes, but is not limited to, threats from violent domestic extremists, international terrorist groups, individuals inspired by terrorists abroad, and the assessment of vulnerabilities and potential consequences. DHS defines risk as: “ potential for an adverse outcome assessed as a function of hazard/threats, assets and their vulnerabilities, and consequences.” See DHS Lexicon Terms and Definitions: 2018 Edition – Revision 04, (Apr. 2018). The FEMA risk methodology is focused on three elements:
i. Threat: the likelihood of an attack being attempted by an adversary; ii. Vulnerability: the likelihood that an attack is successful, given that it is attempted; and
iii. Consequence: the effect of an event, incident, or occurrence.

NOTE: The THIRA/SPR process is separate from the risk methodology and its results do not affect grant allocations.

The Risk Methodology is used to inform allocations under HSGP. For more information on the SHSP, UASI, and OPSG allocation processes, please see 7

64 FY 2024 HSGP NOFO
Section B.1 of this NOFO, “ Available Funding for the NOFO.” II. APPLICATION EVALUATION CRITERIA
FEMA will evaluate the FY 2024 HSGP applications for completeness, adherence to programmatic guidelines, and anticipated effectiveness of the proposed investments. FEMA’s review will include verification that each IJ and project:
x Aligns with at least one core capability identified in the Goal; x Demonstrates how investments support building capability and/ or closing capability gaps or sustaining capabilities identified in the THIRA/SPR process; and
x Supports a NIMS- typed resource and whether those assets are deployable/shareable to support emergency or disaster operations per existing EMAC agreements.

In addition to the above, FEMA will evaluate whether proposed projects are: 1) both feasible and effective at reducing the risks for which the project was designed; and 2) able to be fully completed within the three-year period of performance. FEMA will use the information provided in the application and after the submission of the first BSIR to determine the feasibility and effectiveness of a grant project. To that end, IJs should include:
x An explanation of how the proposed project(s) will achieve objectives as identified in the SPR, including expected long-term impact where applicable, and which core capability gap(s) it helps to close and how; x A summary of the status of planning and design efforts accomplished to date (e.g., included in a capital improvement plan); and x A project schedule with clear milestones.

Recipients are expected to conform, as applicable, with accepted engineering practices, established codes, standards, modeling techniques, and best practices, and participate in the development of case studies demonstrating the effective use of grant funds, as requested.

FEMA will also review any submitted National Priority Area-aligned IJs and projects to ensure they meet the minimum spend requirements. Additional information on how the National Priority Area IJs and projects will be reviewed for effectiveness is included in the Review and Selection Process section below. b. Financial Integrity Criteria
Prior to making a federal award, FEMA is required by 31 U.S.C. § 3354, as enacted by the Payment Integrity Information Act of 2019, Pub. L. No. 116-117 (2020); 41 U.S.C. § 2313; and 2 C.F.R. § 200.206 to review information available through any Office of Management and Budget (OMB)-designated repositories of governmentwide eligibility qualification or financial integrity information, including whether SAM.gov identifies the applicant as being excluded from receiving federal 7

65 FY 2024 HSGP NOFO
awards or is flagged for any integrity record submission. FEMA may also pose additional questions to the applicant to aid in conducting the pre-award risk review.

Therefore, application evaluation criteria may include the following risk- based considerations of the applicant:
i. Financial stability.
ii. Quality of management systems and ability to meet management standards.
iii. History of performance in managing federal award.
iv. Reports and findings from audits.
v. Ability to effectively implement statutory, regulatory, or other requirements.
c. Supplemental Financial Integrity Criteria and Review Prior to making a federal award where the anticipated total federal share will be greater than the simplified acquisition threshold, currently $250,000:
i. FEMA is required by 41 U.S.C. § 2313 and 2 C.F.R. § 200.206(a)(2) to review and consider any information about the applicant, including information on the applicant’s immediate and highest-level owner, subsidiaries, and predecessors, if applicable, that is in the designated integrity and performance system accessible through the System for Award Management ( SAM), which is currently the Federal Awardee Performance and Integrity Information System (FAPIIS).
ii. An applicant, at its option, may review information in FAPIIS and comment on any information about itself that a federal awarding agency previously entered.
iii. FEMA will consider any comments by the applicant, in addition to the other information in FAPIIS, in making a judgment about the applicant’ s integrity, business ethics, and record of performance under federal awards when completing the review of risk posed by applicants as described in 2 C.F.R. § 200.206.

2. Review and Selection Process
a. SHSP and UASI
All proposed investments will undergo a federal review by DHS/FEMA to verify compliance with all administrative and eligibility criteria identified in the NOFO. The federal review will be conducted by FEMA HQ Preparedness Officers. FEMA HQ Preparedness Officers will use a checklist to verify compliance with all administrative and eligibility criteria identified in the NOFO. Recipients must be able to demonstrate how investments support building capability and/or closing capability gaps or sustaining capabilities identified in the THIRA/SPR process. IJs will be reviewed at both the investment and project level.
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66 FY 2024 HSGP NOFO
Emergency communications investments will be jointly reviewed by FEMA and CISA’s Emergency Communications Division (ECD) to verify compliance with SAFECOM Guidance on Emergency Communications Grants ( SAFECOM Guidance). FEMA and ECD will coordinate directly with the recipient on any compliance concerns and will provide technical assistance as necessary to help ensure full compliance.

Additional Effectiveness Evaluation Criteria for the National Priority Areas FEMA will evaluate the FY 2024 HSGP IJs and projects submitted in support of the National Priority Areas for anticipated effectiveness. FEMA’s review will include verification that each IJ or project meets the National Priority Area required spend percentages.

Cybersecurity investments will be reviewed by DHS/FEMA, CISA, and other DHS components as appropriate, for compliance with purposes and requirements of the priority investment area. Proposed investments will be reviewed for effectiveness using the criteria set forth in this NOFO.

Soft Targets/ Crowded Places investments will be reviewed by DHS/ FEMA, CISA, and other DHS components as appropriate, for compliance with purposes and requirements of the priority investment area. Proposed investments will be reviewed for effectiveness using the criteria set forth in this NOFO.

Information Sharing and Cooperation Investments will be reviewed by DHS/FEMA, DHS Office of Intelligence and Analysis, and other DHS components as appropriate, for compliance with purposes and requirements of the priority investment area.

Proposed investments will be reviewed for effectiveness using the criteria set forth in this NOFO.

For additional information on Fusion Center requirements, please see the Preparedness Grants Manual.

Domestic violent extremism investments will be reviewed by DHS/FEMA, DHS Office of Intelligence and Analysis, DHS Center for Prevention Programs and Partnerships, and other DHS components as appropriate, for compliance with purposes and requirements of the priority investment area. Proposed investments will be reviewed for effectiveness using the scoring criteria set forth in this NOFO.

Community preparedness and resilience investments will be reviewed by DHS/FEMA and other DHS components as appropriate, for compliance with purposes and requirements of the priority investment area. Proposed investments will be reviewed for effectiveness using the scoring criteria set forth in this NOFO.

Election security investments will be reviewed by DHS/FEMA, CISA, and other DHS components as appropriate, for compliance with purposes and requirements of 7

67 FY 2024 HSGP NOFO
the priority investment area. Proposed investments will be reviewed for effectiveness using the scoring criteria set forth in this NOFO.

FEMA will determine whether the proposed approach is clear, logical, and reasonable to address the priority areas of interest and contribute to a culture of national preparedness. This includes factors such as the objectives and strategies proposed to address the priority area, how the objectives and strategies overcome legal, political, or practical obstacles to reduce overall risk, the process, and criteria to select additional relevant projects, and the approach to monitor awards to satisfy the funding percentage allocations.

For applicants that elect to submit IJs and project-level details for the National Priority Areas at the time of application, effectiveness will be evaluated prior to award. If the projects are found to not sufficiently align with the National Priority Area( s), applicants may have funds placed on hold ( up to 30%) until the projects are revised to satisfactorily address the National Priority Areas.

For applicants that elect to submit IJs and project-level details for the National Priority Areas as part of their December 2024 BSIR, they will have funds placed on hold in the amount of 30%. The hold will be released only after their December 2024 BSIR submission has been reviewed, projects related to the National Priority Areas deemed in alignment by DHS/FEMA, and the funding hold is removed by FEMA.

SAAs are still required to meet pass-through requirements even if funds are on hold related to the National Priority Areas.

To that end, IJs should include:
x How the proposed investment addresses the National Priority Area; x An explanation of how the proposed projects were selected and will achieve objectives and strategies to build or sustain the core capability gaps identified in the SPR, including expected long-term impact where applicable; and x A summary of the collaboration efforts to prevent, prepare for, protect against, and respond to acts of terrorism as well as anticipated outcomes of the project.

For FY 2024 SHSP and UASI investments and projects related to the National Priority Areas, effectiveness will be evaluated based on the following four factors:
x Investment Strategy ( 40%): Proposals will be evaluated based on the quality and extent to which applicants describe an effective strategy that demonstrates that proposed projects support the program objective of preventing, preparing for, protecting against, and responding to acts of terrorism, to meet its target capabilities, and otherwise reduce the overall risk to the high- risk urban area, the state, or the Nation.
x Budget (20%): Proposals will be evaluated based on the extent to which applicants describe a budget plan for each investment demonstrating how the applicant will maximize cost effectiveness of grant expenditures. 7

68 FY 2024 HSGP NOFO
x Impact/Outcomes (40%): Proposals will be evaluated on how the investment helps the jurisdiction close capability gaps identified in its SPR and addresses the relevant National Priority Area outlined in this NOFO. Further, proposals will be evaluated on their identification and estimated improvement of core capability(ies), the associated standardized target(s) that align with their proposed investment, and the ways in which the applicant will measure and/ or evaluate improvement.
x Past Performance (additional consideration): Proposals will be evaluated based on the applicants demonstrated capability to execute the proposed investments.

In evaluating applicants under this factor FEMA will consider the information provided by the applicant and may also consider relevant information from other sources.
b. OPSG
Applications will be reviewed by the SAA and USBP Sector Headquarters for completeness and adherence to programmatic guidelines and evaluated for anticipated feasibility, need, and impact of the Operations Orders. For more information on Operations Orders and other requirements of OPSG, see section D.10 above and the Preparedness Grants Manual.

DHS/ FEMA will verify compliance with all administrative and eligibility criteria identified in the NOFO and required submission of Operations Orders and Inventory of Operations Orders by the established due dates. DHS/ FEMA and USBP will use the results of both the risk analysis and the federal review by DHS/FEMA to make recommendations for funding to the Secretary of Homeland Security.

FY 2024 OPSG funds will be allocated among the eligible jurisdictions based on riskbased prioritization using the OPSG Risk Assessment described above. Final funding allocations are determined by the Secretary of Homeland Security, who may consider information and input from various law enforcement offices or subject-matter experts within the Department. Factors considered include, but are not limited to threat, vulnerability, miles of the border, and other border-specific law enforcement intelligence, as well as the feasibility of FY 2024 Operations Orders to designated localities within border states and territories.

F. Federal Award Administration Information

1. Notice of Award
Before accepting the award, the AOR and recipient should carefully read the award package.

The award package includes instructions on administering the grant award and the terms and conditions associated with responsibilities under federal awards. Recipients must accept all conditions in this NOFO and the Preparedness Grants Manual, as well as any specific terms and conditions in the Notice of Award to receive an award under this program.

See the Preparedness Grants Manual for information on Notice of Award. 7

69 FY 2024 HSGP NOFO
FEMA will provide the federal award package to the applicant electronically via FEMA GO.

Award packages include an Award Letter, Summary Award Memo, Agreement Articles, and Obligating Document. An email notification of the award package will be sent through FEMA’s grant application system to the AOR that submitted the application.

Recipients must accept their awards no later than 60 days from the award date. The recipient shall notify FEMA of its intent to accept and proceed with work under the award through the FEMA GO system.

Funds will remain on hold until the recipient accepts the award through the FEMA GO system and all other conditions of the award have been satisfied or until the award is otherwise rescinded. Failure to accept a grant award within the specified timeframe may result in a loss of funds.

2. Pass- Through Requirements
Awards made to the SAA for HSGP carry additional statutorily mandated pass-through requirements. Pass- through is defined as an obligation on the part of the SAA to make funds available to local units of government, combinations of local units, tribal governments, or other specific groups or organizations. These entities are defined at 6 U.S.C. § 101( 13) as:
x A county, municipality, city, town, township, local public authority, school district, special district, intrastate district, council of governments (regardless of whether the council of governments is incorporated as a nonprofit corporation under State law), regional or interstate government entity, or agency or instrumentality of a local government.
x An Indian tribe or authorized tribal organization, or in Alaska a Native village or Alaska Regional Native Corporation.
x A rural community, unincorporated town or village, or other public entity.

Four criteria must be met to pass-through grant funds:
x The SAA must make a firm written commitment to passing through grant funds to subrecipients;
x The SAA’s commitment must be unconditional (i.e., no contingencies for the availability of SAA funds);
x There must be documentary evidence (i.e., award document, terms, and conditions) of the commitment; and
x The award terms must be communicated to the subrecipient.

Timing and Amount
The SAA must pass- through at least 80% of the funds awarded under SHSP and UASI to the above-defined local or tribal units of government within 45 calendar days of receipt of the funds. “ Receipt of the funds” occurs either when the SAA accepts the award or 15 calendar days after the SAA receives notice of the award, whichever is earlier.

SAAs are sent notification of HSGP awards via the FEMA GO system. If an SAA accepts its award within 15 calendar days of receiving notice of the award in the FEMA GO system, the 45 calendar days pass-through period will start on the date the SAA accepted the award. 7

70 FY 2024 HSGP NOFO
Should an SAA not accept the HSGP award within 15 calendar days of receiving notice of the award in the FEMA GO system, the 45 calendar days pass-through period will begin 15 calendar days after the award notification is sent to the SAA via the FEMA GO system.

It is important to note that the period of performance start date does not directly affect the start of the 45 calendar days pass-through period. For example, an SAA may receive notice of the HSGP award on August 25, 2024, while the period of performance dates for that award are September 1, 2024, through August 31, 2027. In this example, the 45-day pass-through period will begin on the date the SAA accepts the HSGP award or September 9, 2024 ( 15 calendar days after the SAA was notified of the award), whichever date occurs first. The period of performance start date of September 1, 2024 would not affect the timing of meeting the 45-calendar day pass-through requirement.

Other SHSP and UASI Pass-Through Requirements
The signatory authority of the SAA must certify in writing to DHS/ FEMA that pass- through requirements have been met. A letter of intent (or equivalent) to distribute funds is not considered sufficient. A letter of intent is not a firm commitment and if issued before FEMA makes the award, then a letter of intent is also not unconditional since it is inherently conditioned on receipt of funds.

The pass- through requirement does not apply to SHSP awards made to the District of Columbia, Guam, American Samoa, the U.S. Virgin Islands, or the Commonwealth of the Northern Mariana Islands. The Commonwealth of Puerto Rico is required to comply with the pass-through requirement, and its SAA must also obligate at least 80% of the funds to local units of government within 45 calendar days of receipt of the funds.

Under SHSP, the SAA may retain more than 20% of funding for expenditures made by the state on behalf of the local unit(s) of government, such as expenditures by the state in order to pass through goods or services to local unit(s) of government in lieu of cash. This may occur only with the written consent, such as a Memorandum of Understanding, between the SAA and the local unit(s) of government. Separate written consent is necessary for each local unit of government in which more than 20% of funding is retained on their behalf by the state. The written consent must specify the amount of funds to be retained and the intended use of funds, including whether any goods or services will be passed through in lieu of cash.

It must also be signed by authorized representatives of both the state and the local unit of government.

States shall review their written consent agreements yearly and ensure that they are still valid. If a written consent agreement is already in place from previous fiscal years, DHS/FEMA will continue to recognize it for FY 2024, unless the written consent review indicates the local government is no longer in agreement. If modifications to the existing agreement are necessary, the SAA should contact their assigned FEMA HQ Preparedness Officer. However, even if a written consent agreement is in place from previous fiscal years, the SAA must still initially carry out the pass-through documentation for its FY 2024 award and comply with the four pass-through criteria described above before the written consent agreement can take effect for purposes of the FY 2024 funding. 7

71 FY 2024 HSGP NOFO
Additional OPSG Requirements
The recipient is prohibited from obligating or expending funds provided through this award until each unique and specific county-level or equivalent Operational Order/Fragmentary Operations Order budget has been reviewed and approved through an official electronic mail notice issued by DHS/FEMA removing this special programmatic condition.

3. Administrative and National Policy Requirements
In addition to the requirements of in this section and in this NOFO, FEMA may place specific terms and conditions on individual awards in accordance with 2 C.F.R. Part 200.

In addition to the information regarding DHS Standard Terms and Conditions and Ensuring the Protection of Civil Rights, see the Preparedness Grants Manual for additional information on administrative and national policy requirements, including the following:
x Environmental Planning and Historic Preservation (EHP) Compliance x FirstNet
x National Incident Management System ( NIMS) Implementation x SAFECOM
a. DHS Standard Terms and Conditions
All successful applicants for DHS grant and cooperative agreements are required to comply with DHS Standard Terms and Conditions, which are available online at:

DHS Standard Terms and Conditions.

The applicable DHS Standard Terms and Conditions will be those in effect at the time the award was made. What terms and conditions will apply for the award will be clearly stated in the award package at the time of award. b. Ensuring the Protection of Civil Rights
As the Nation works towards achieving the National Preparedness Goal, it is important to continue to protect the civil rights of individuals. Recipients and subrecipients must carry out their programs and activities, including those related to the building, sustainment, and delivery of core capabilities, in a manner that respects and ensures the protection of civil rights for protected populations.

Federal civil rights statutes, such as Section 504 of the Rehabilitation Act of 1973 and Title VI of the Civil Rights Act of 1964, along with
DHS and FEMA regulations, prohibit discrimination on the basis of race, color, national origin, sex, religion, age, disability, limited English proficiency, or economic status in connection with programs and activities receiving federal financial assistance from FEMA, as applicable.

The DHS Standard Terms and Conditions include a fuller list of the civil rights provisions that apply to recipients. These terms and conditions can be found in the DHS Standard Terms and Conditions. Additional information on civil rights 7

72 FY 2024 HSGP NOFO
provisions is available at https:// www.fema. gov/ about/ offices/ equal- rights/ civilrights.

Monitoring and oversight requirements in connection with recipient compliance with federal civil rights laws are also authorized pursuant to 44 C.F.R. Part 7 or other applicable regulations.

In accordance with civil rights laws and regulations, recipients and subrecipients must ensure the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment.
c. Environmental Planning and Historic Preservation ( EHP) Compliance See the Preparedness Grants Manual for information on EHP compliance. d. National Incident Management System ( NIMS) Implementation In expending funds under this program, recipients that are state, local, tribal, or territorial governments must ensure and maintain adoption and implementation of NIMS, including implementation of important operational systems defined under NIMS, such as ICS. The state, local, tribal, or territorial government must show adoption of NIMS during any point of the period of performance. See the Preparedness Grants Manual for information about NIMS implementation. e. Emergency Communication Investments
If an entity uses HSGP funding to support emergency communications investments, the following requirements shall apply to all such grant- funded communications investments in support of the emergency communications priorities and recognized best practices:
x The signatory authority for the SAA must certify in writing to DHS/ FEMA their compliance with the SAFECOM Guidance. The certification letter should be coordinated with the SWIC for each state and must be uploaded to FEMA GO at the time of the first Program Performance Report submission. x All states and territories must designate a full-time SWIC who has the authority and resources to actively improve interoperability with emergency management and response agencies across all levels of government, to include establishing statewide plans, policies, and procedures, and coordinating decisions on communications investments funded through federal grants. Note that the designated full-time SWIC may also be the state’ s or territory’ s cybersecurity point of contact. SWIC status information will be maintained by CISA and will be verified by FEMA GPD through programmatic monitoring activities. x By the period of performance end date, all states and territories must update the SCIP, with a focus on communications resilience/continuity, to include assessment and mitigation of all potential risks identified in the SCIP: natural disasters, accidental damage (human failures), intentional damage (sabotage, terrorism), cybersecurity, etc. Following the initial update, the SCIP should be updated on an annual basis. SCIP status information will be maintained by 7

73 FY 2024 HSGP NOFO
CISA and will be verified by FEMA GPD through programmatic monitoring activities.

All states and territories must test their emergency communications capabilities and procedures ( as outlined in their operational communications plans) in conjunction with regularly planned exercises (separate/addition emergency communications exercises are not required). Exercises should be used to both demonstrate and validate skills learned in training and to identify gaps in capabilities. Resilience and continuity of communications should be tested during training and exercises to the greatest extent possible. Further, exercises should include participants from multiple jurisdictions, disciplines, and levels of government and include emergency management, emergency medical services, law enforcement, interoperability coordinators, public health officials, hospital officials, officials from colleges and universities, and other disciplines and private sector entities, as appropriate. Findings from exercises should be used to update programs to address gaps in emergency communications as well as emerging technologies, policies, and partners. Recipients are encouraged to increase awareness and availability of emergency communications exercise opportunities across all levels of government.

States, territories, and other eligible grant recipients are advised that HSGP funding may be used to support communications planning ( including the cost of hiring a SWIC, participation in governance bodies and requirements delineated above), training, exercises, and equipment costs. Costs for transitioning to the FirstNet network may also be eligible. More information regarding FirstNet can be found in the Preparedness Grants Manual.
f. Mandatory Disclosures
The non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. (2 CFR 200.113)
Please note applicants and recipients may report issues of fraud, waste, abuse, and mismanagement, or other criminal or noncriminal misconduct to the Office of Inspector General (OIG) Hotline. The toll-free numbers to call are 1 (800) 323-8603, and TTY 1 (844) 889-4357.

4. Reporting
Recipients are required to submit various financial and programmatic reports as a condition of award acceptance. Future awards and funds drawdown may be withheld if these reports are delinquent.

See the Preparedness Grants Manual for information on reporting requirements. 7

74 FY 2024 HSGP NOFO

5. Monitoring and Oversight
The regulation at 2 C.F.R. § 200.337 provides DHS and any of its authorized representatives with the right of access to any documents, papers, or other records of the recipient [ and any subrecipients] that are pertinent to a federal award in order to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the recipient’ s or subrecipient’ s personnel for the purpose of interview and discussion related to such documents. Pursuant to this right and per 2 C.F.R. § 200.329, DHS may conduct desk reviews and make site visits to review project accomplishments and management control systems to evaluate project accomplishments and to provide any required technical assistance. During site visits, DHS may review a recipient’ s or subrecipient’ s files pertinent to the federal award and interview and/ or discuss these files with the recipient’ s or subrecipient’ s personnel. Recipients and subrecipients must respond in a timely and accurate manner to DHS requests for information relating to a federal award.

See the Preparedness Grants Manual for information on monitoring and oversight.

G. DHS Awarding Agency Contact Information

1. Contact and Resource Information
a. Program Office Contact
FEMA has assigned state- specific Preparedness Officers for the HSGP. If you do not know your Preparedness Officer, please contact FEMA Grants News by phone at 800) 368- 6498 or by email at fema- grants- news@fema. dhs. gov, Monday through Friday, 9:00 AM – 5:00 PM ET.
b. FEMA Grants News
FEMA Grants News is a non- emergency comprehensive management and information resource developed by FEMA for grants stakeholders. This channel provides general information on all FEMA grant programs and maintains a comprehensive database containing key personnel contact information at the federal, state, and local levels. When necessary, recipients will be directed to a federal point of contact who can answer specific programmatic questions or concerns. FEMA Grants News can be reached by e-mail at fema- grants- news@fema. dhs.gov OR by phone at (800) 368-6498, Monday through Friday, 9:00 AM – 5:00 PM ET. c. Grant Programs Directorate (GPD) Award Administration Division GPD’ s Award Administration Division ( AAD) provides support regarding financial matters and budgetary technical assistance. Additional guidance and information can be obtained by contacting the AAD’ s Help Desk via e-mail at ASK[email protected]. d. FEMA Regional Offices
FEMA Regional Offices provide some fiscal support functions, including cash analysis and financial monitoring for this program. The FEMA Grant Programs Directorate, Office of Grants Administration, is responsible for financial and programmatic management of this program, and provides technical assistance, as needed or requested.
7

75 FY 2024 HSGP NOFO
FEMA Regional Office contact information is available at:
https:// www.fema. gov/fema- regional- contacts.
e. Equal Rights
The FEMA Office of Equal Rights (OER) is responsible for compliance with and enforcement of federal civil rights obligations in connection with programs and services conducted by FEMA and recipients of FEMA financial assistance. All inquiries and communications about federal civil rights compliance for FEMA grants under this NOFO should be sent to [email protected]. f. Environmental Planning and Historic Preservation
GPD’ s EHP Team provides guidance and information about the EHP review process to recipients and subrecipients. All inquiries and communications about GPD projects under this NOFO or the EHP review process, including the submittal of EHP review materials, should be sent to [email protected].

2. Systems Information
a. FEMA GO
For technical assistance with the FEMA GO system, please contact the FEMA GO Helpdesk at femago@fema. dhs. gov or (877) 585- 3242, Monday through Friday, 9:00 AM – 6:00 PM ET.
b. FEMA Preparedness Toolkit
The FEMA Preparedness Toolkit ( PrepToolkit) provides access to the tools and resources needed to implement the National Preparedness System and provide a collaborative community space for communities completing the Unified Reporting Tool (URT). Recipients complete and submit their THIRA/SPR, and other required assessments using the tools on PrepToolkit. For assistance, contact [email protected].

H. Additional Information
GPD has developed the Preparedness Grants Manual to guide applicants and recipients of grant funding on how to manage their grants and other resources. Recipients seeking guidance on policies and procedures for managing preparedness grants should reference the Preparedness Grants Manual for further information. Examples of information contained in the Preparedness Grants Manual include:
x Actions to Address Noncompliance
x Audits
x Case Studies and Use of Grant-Funded Resources During Real-World Incident Operations
x Community Lifelines
x Conflicts of Interest in the Administration of Federal Awards and Subawards x Disability Integration
x National Incident Management System
x Payment Information
7

76 FY 2024 HSGP NOFO
x Period of Performance Extensions
x Procurement Integrity
x Record Retention
x Termination Provisions
x Whole Community Preparedness
x Report Issues of Fraud, Waste, and Abuse
x Hazard Resistant Building Codes
x Other Post- Award Requirements

1. Termination Provisions
FEMA may terminate a federal award in whole or in part for one of the following reasons.

FEMA and the recipient must still comply with closeout requirements at 2 C.F.R. §§ 200.344-200.345 even if an award is terminated in whole or in part. To the extent that subawards are permitted under this NOFO, pass-through entities should refer to 2 C.F.R. § 200.340 for additional information on termination regarding subawards. Note that all information in this Section H.1 “Termination Provisions” is repeated in the Preparedness Grants Manual.
a. Noncompliance
If a recipient fails to comply with the terms and conditions of a federal award, FEMA may terminate the award in whole or in part. If the noncompliance can be corrected, FEMA may first attempt to direct the recipient to correct the noncompliance. This may take the form of a Compliance Notification. If the noncompliance cannot be corrected or the recipient is non-responsive, FEMA may proceed with a Remedy Notification, which could impose a remedy for noncompliance per 2 C.F.R. § 200.339, including termination. Any action to terminate based on noncompliance will follow the requirements of 2 C.F.R. §§ 200.341-200.342 as well as the requirement of 2 C.F.R. § 200.340(c) to report in FAPIIS the recipient’ s material failure to comply with the award terms and conditions. See also the section on Actions to Address Noncompliance in this NOFO. See also the section on Actions to Address Noncompliance in the Preparedness Grants Manual.
b. With the Consent of the Recipient
FEMA may also terminate an award in whole or in part with the consent of the recipient, in which case the parties must agree upon the termination conditions, including the effective date, and in the case of partial termination, the portion to be terminated.
c. Notification by the Recipient
The recipient may terminate the award, in whole or in part, by sending written notification to FEMA setting forth the reasons for such termination, the effective date, and in the case of partial termination, the portion to be terminated. In the case of partial termination, FEMA may determine that a partially terminated award will not accomplish the purpose of the federal award, so FEMA may terminate the award in its entirety. If that occurs, FEMA will follow the requirements of 2 C.F.R. §§ 200.341-200.342 in deciding to fully terminate the award. 7

77 FY 2024 HSGP NOFO

2. Program Evaluation
Federal agencies are required to structure NOFOs that incorporate program evaluation activities from the outset of their program design and implementation to meaningfully document and measure their progress towards meeting agency priority goal( s) and program outcomes.

OMB Memorandum M-21-27, Evidence-Based Policymaking: Learning Agendas and Annual Evaluation Plans, implementing Title I of the Foundations for Evidence- Based Policymaking Act of 2018, Pub. L. No. 115-435 (2019) (Evidence Act), urges federal awarding agencies to use program evaluation as a critical tool to learn, improve equitable delivery, and elevate program service and delivery across the program lifecycle. Evaluation means “ an assessment using systematic data collection and analysis of one or more programs, policies, and organizations intended to assess their effectiveness and efficiency.” Evidence Act, § 101 ( codified at 5 U.S.C. § 311).

As such, recipients and subrecipients are required to participate in a DHS-, Component, or Program Office-led evaluation if selected, which may be carried out by a third-party on behalf of the DHS, its component agencies, or the Program Office. Such an evaluation may involve information collections including but not limited to surveys, interviews, or discussions with individuals who benefit from the federal award program operating personnel, and award recipients, as specified in a DHS-, component agency-, or Program Office- approved evaluation plan. More details about evaluation requirements may be provided in the federal award, if available at that time, or following the award as evaluation requirements are finalized. Evaluation costs incurred during the period of performance are allowable costs (either as direct or indirect). Recipients and subrecipients are also encouraged, but not required, to participate in any additional evaluations after the period of performance ends, although any costs incurred to participate in such evaluations are not allowable and may not be charged to the federal award.

3. Financial Assistance Programs for Infrastructure
a. Build America, Buy America Act
Recipients and subrecipients must comply with the Build America, Buy America Act BABAA), which was enacted as part of the Infrastructure Investment and Jobs Act 70901-70927, Pub. L. No. 117-58 (2021); and Executive Order 14005, Ensuring the Future is Made in All of America by All of America’ s Workers. See also 2 C.F.R.

Part 184 and Office of Management and Budget (OMB) Memorandum M-24-02, Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure.

None of the funds provided under this program may be used for a project for infrastructure unless the iron and steel, manufactured products, and construction materials used in that infrastructure are produced in the United States.

The Buy America preference only applies to articles, materials, and supplies that are consumed in, incorporated into, or affixed to an infrastructure project. As such, it 7

78 FY 2024 HSGP NOFO
does not apply to tools, equipment, and supplies, such as temporary scaffolding, brought to the construction site and removed at or before the completion of the infrastructure project. Nor does a Buy America preference apply to equipment and furnishings, such as movable chairs, desks, and portable computer equipment, that are used at or within the finished infrastructure project but are not an integral part of the structure or permanently affixed to the infrastructure project.

For FEMA's official policy on BABAA, please see FEMA Policy 207-22-0001: Buy America Preference in FEMA Financial Assistance Programs for Infrastructure available at https://www.fema.gov/sites/default/files/documents/fema_build-americabuy- america- act- policy. pdf To see whether a particular FEMA federal financial assistance program is considered an infrastructure program and thus required to include a Buy America preference, please see Programs and Definitions: Build America, Buy America Act | FEMA.gov. and
https:// www.fema. gov/ sites/ default/ files/ documents/ fema_build- america- buyamerica-act-policy.pdf b. Waivers
When necessary, recipients ( and subrecipients through their pass- through entity) may apply for, and FEMA may grant, a waiver from these requirements.

A waiver of the domestic content procurement preference may be granted by the agency awarding official if FEMA determines that:
x Applying the domestic content procurement preference would be inconsistent with the public interest.
x The types of iron, steel, manufactured products, or construction materials are not produced in the United States in sufficient and reasonably available quantities or of a satisfactory quality.
x The inclusion of iron, steel, manufactured products, or construction materials produced in the United States will increase the cost of the overall project by more than 25%.

For FEMA awards, the process for requesting a waiver from the Buy America preference requirements can be found on FEMA’ s website at: " Buy America" Preference in FEMA Financial Assistance Programs for Infrastructure | FEMA.gov. c. Definitions
For BABAA specific definitions, please refer to the FEMA Buy America website at:

Programs and Definitions: Build America, Buy America Act | FEMA.gov.” Please refer to the applicable DHS Standard Terms & Conditions for the BABAA specific term applicable to all FEMA financial assistance awards for infrastructure. 7

79 FY 2024 HSGP NOFO

4. Report issues of fraud, waste, abuse
Please note, when applying to this notice of funding opportunity and when administering the grant, applicants may report issues of fraud, waste, abuse, and mismanagement, or other criminal or noncriminal misconduct to the Office of Inspector General (OIG) Hotline. The toll-free numbers to call are 1 (800) 323- 8603, and TTY 1 (844) 889- 4357.

5. National Threat Evaluation and Reporting ( NTER) Program Office As the threat landscape continues to evolve, the DHS Office of Intelligence and Analysis I&A) National Threat Evaluation and Reporting ( NTER) Program Office empowers homeland security partners to adapt to new threats and prevent terrorism and targeted violence. NTER equips homeland security partners with tools and resources to identify, report, and mitigate threats of terrorism and targeted violence to keep the Homeland safe primarily through two lines of effort: the Nationwide Suspicious Activity Reporting ( SAR) Initiative (NSI) and Behavioral Threat Assessment Integration. a. Behavioral Threat Assessment Integration
NTER assists federal, state, local, tribal, and territorial ( F/SLTT) partners with integrating a behavioral approach to violence prevention into their processes for identifying and mitigating homeland security threats of targeted violence, regardless of motive. Through training, partner capacity building, and information sharing, NTER supports the identification and mitigation of threats. The Office fills a national gap by providing a framework for Behavioral Threat Assessment and Management BTAM) as a best practice for targeted violence prevention. x The Master Trainer Program certifies F/SLTT partners in the instruction of BTAM techniques and best practices. This instructor development and certification program prepares F/SLTT partners to engage their local communities and empowers homeland partners to help mitigate threats and aid in preventing acts of targeted violence. ·
x Foundations of Targeted Violence Prevention eLearning: This one- hour eLearning empowers partners to recognize threats or potentially concerning behaviors; understand what behaviors may be displayed by a person who is on a pathway to violence; learn where to report information of concern; and understand how the information reported will be used to keep our communities safe.
b. Nationwide Suspicious Activity Reporting Initiative
The NSI is a joint collaborative effort by the U.S. Department of Homeland Security, the Federal Bureau of Investigation, and F/SLTT law enforcement partners. This initiative provides law enforcement with a tool to help prevent terrorism and other related criminal activity by establishing a national capacity for identifying, gathering, documenting, processing, analyzing, and sharing tips and leads. The NSI is a standardized process for identifying, reporting, and sharing suspicious activity in jurisdictions across the country.
x SAR Standardized Technical Assistance Consultation Guide: This document provides an overview of the technical assistance and training services. 7

80 FY 2024 HSGP NOFO
x Online SAR Training for Law Enforcement and Hometown Security Partners:

To increase the effectiveness of this multifaceted approach, the NSI has developed training programs for frontline officers and hometown security partners on how to report identified suspicious activity to the proper authorities while maintaining the protection of citizens' privacy, civil rights, and civil liberties.
x Nationwide Suspicious Activity Reporting ( SAR) Initiative ( NSI) Fundamentals Homeland Security (dhs.gov): This one-hour training course provides an interactive overview of the NSI. It provides users an understanding of the evaluation process used to determine whether identified behavior adheres to the Information Sharing Environment Functional Standard criteria, in accordance with privacy, civil rights, and civil liberties protections. 7

Fiscal Year 2024
Homeland Security Grant Program
California Supplement to the
Federal Notice of Funding Opportunity
December 2024
7

SECTION 1—OVERVIEW………………………………………………………………………… 1
Federal Program Announcement
Information Bulletins
Grant Management Memoranda
Purpose of the California Supplement
Eligible Subrecipients
Tribal Allocations
Subrecipient Allocations
Supplanting
Public/ Private Organizations
Debarred/ Suspended Parties
Key Changes to the FY 2024 Homeland Security Grant Program SECTION 2—FEDERAL CHANGES AND INITIATIVES ....................................................... 5 FY 2024 National Priorities
National Campaigns and Programs
National Cybersecurity Review
NIMS Implementation
Law Enforcement Terrorism Prevention Activities
Management and Administration
Indirect Costs
Organization Costs – Overtime
Personnel Cap
Equipment Typing/ Identification and Use
Equipment Maintenance/ Sustainment
Emergency Communications Projects
Telecommunications Equipment and Services Prohibitions
Prohibited and Controlled Equipment
Small Unmanned Aircraft Systems
Emergency Operations Plans
Conflict of Interest
Build America Buy America Act (BABAA)
SECTION 3—STATE CHANGES AND INITIATIVES .......................................................... 18 FY 2024 Investments
California Homeland Security Strategy Goals
State Initiative Funding
On Behalf Of”
Public Alert and Warning
SECTION 4—REQUIRED STATE APPLICATION COMPONENTS ...................................... 20 Financial Management Forms Workbook
Subrecipient Grants Management Assessment
Application Attachments
Standard Assurances
7

Program Standard Assurances Addendum
Operational Areas and Urban Areas
Operational Areas Only
Urban Areas Only
Fusion Centers Only
State Agencies and Tribes Only
SECTION 5—THE STATE APPLICATION PROCESS .............................................................. 25 Application Submission
Late or Incomplete Application
HSGP Contact Information
Subaward Approval
SECTION 6—POST AWARD REQUIREMENTS .................................................................... 26 Payment Request Process
Advances and Interest Earned on Advances
Semi-Annual Drawdown Requirements
Modifications
Training
Exercises, Improvement Plans, and After-Action Reporting Procurement Standards and Written Procedures
Procurement Thresholds
Procurement Documentation
Noncompetitive Procurement
Performance Bond
Environmental Planning and Historic Preservation
Construction and Renovation
Inventory Control and Property Management
Equipment Disposition
Performance Reporting
Extension Requests
Progress Reports on Grant Extensions
Monitoring
Failure to Submit Required Reports
Suspension/ Termination
Closeout
Records Retention

ATTACHMENTS
A – FY 2024 HSGP Allocations
B – FY 2024 HSGP Timeline
C – FY 2024 HSGP Program Checklist
7

1 Section 1 Overview | 2024 Federal
Program
On
Announcement April 16, 2024, the U.S. Department of Homeland Security ( DHS)/Federal Emergency Management Agency FEMA)
issued the Fiscal Year (FY) 2024 Homeland Security Grant Program (HSGP), Notice of Funding Opportunity NOFO)
and the FEMA Preparedness Grants Manual.Subrecipients
must
the NOFO, FEMA Preparedness
follow the
Grants
programmatic requirements
Manual, and
in
the applicable
provisionsofthe Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal
Awards
C.
located in Title 2, Code of Federal Regulations (
F.R.), Part 200.Information
Bulletins
DHS
issues Information Bulletins (IBs) to provide updates, clarification, and new requirements throughout thelife of the
grant. Grant
Management
Memoranda
Cal
OES issues Grant Management Memoranda (GMMs) which
provide additional information and requirements regarding HSGP funds.Purpose
ofthe California
Supplement
The
FY 2024 HSGP California Supplement tothe NOFO State
Supplement) isintended tocomplement, rather than replace, the NOFO and the FEMA Preparedness Grants Manual.

Applicants arehighly encouraged tothoroughly read
the NOFO and the Preparedness Grants Manual before
referring tothe State Supplement. The State Supplement
will emphasize differences between theFY
2023 and FY 2024 HSGP and highlight additional California policies and requirements applicable toFY 2024 HSGP.

Eligible
Subrecipients
Eligible
Applicants, referred toas Subrecipients, include Counties/ Operational Areas (OAs), Urban Areas (UAs), State
Agencies (SAs), Departments, Commissions, and Boards
who have or can obtain appropriate state Department
of Finance budget authority for awarded funds,
and federally recognized tribes located in California.7

2 Section 1 Overview | 2024 Tribal
Allocations
The
NOFO strongly encourages Cal OES toprovide HSGP funds
directly
a
totribes in California. To implement this requirement,
special Competitive Funding Opportunity CFO)
will be issued to California’sfederally recognized tribes.

All Subrecipients areencouraged tocoordinate with tribal governments toensure that tribal needs are considered
intheir grant applications. Subrecipient
Allocations
FY
2024
A
HSGP Subrecipient final allocations areprovided in Attachment and reflect reductions to Subrecipients who did
not submit minimum thresholds for National Priority Areas, including Subrecipients opting outof the award altogether, and increases to Subrecipients that are helping meet
statewide minimum level National Priority Area requirements.

Supplanting
Grant funds must be used tosupplement existing funds, not replace ( supplant) funds that have been appropriated forthe
same purpose. Subrecipients maybe required toprovide
supporting documentation that certifiesareduction
innon-federal resources that occurred forreasons
other than the receipt or expected receiptoffederal
funds. Supplanting will result inthe disallowance ofthe activity associated with this improper use of federal grant funds.Public/
Private Organizations
Subrecipients
maycontract with other public or private organizations
toperform eligible activities onapproved HSGP
projects.Debarred/
Suspended
Parties
Subrecipients
must not make or permit any award subaward
or contract) at any tier, to any party, that is debarred, suspended, or otherwise excluded from, or ineligible
for, participation infederal assistance programs. Subrecipients must obtain documentation of eligibility before
making any subaward or contract using HSGP funds and
must be prepared topresent supporting documentation
tomonitors/ auditors. Before
entering into a Grant Subaward, the Subrecipient must
notify Cal OES ifit knows if any ofthe principals under the subaward fall under one or more ofthe four criteria listed at2 C.F.R. § 180. 335.7

3 Section 1 Overview | 2024 Debarred/
Suspended
Parties
Cont.

The
rule also applies to Subrecipients whopass through funding toother local entities. If
at any time after accepting asubaward, Subrecipients learn that any ofits principals fall under one or more ofthe criteria listed at2 C.F.R. § 180. 335, immediate written notice must be provided to Cal OES and all grant activities halted until further instructions arereceived from Cal OES. The rule also applies tosubawards passed through by Subrecipientso
local entities.Key
Changes tothe
FY 2024 HSGP
National
Priority Areas: There are six National Priority Areas NPAs) for FY 2024. The primary change for FY 2024 isthat only the Enhancing Election Security NPA maintainsa3% minimum spend. SHSP and UASI applicants must include one
Investment Justification (IJ) for each NPA that hasa minimum spend requirement, where applicable. For the NPAs
with no minimum spend requirement, the Departmentof
Homeland Security strongly encourages recipients to make investments inthose areas as they are of critical national concern. For those NPAs that have an associated minimum spend, all projects related to meeting the minimum
spend forthose NPAs must be included inthe same
IJ.The
six NPAs, along with the relevant minimum spend requirement, are:x
Enhancing information and intelligence sharing and cooperation withfederal agencies, including the Department
of Homeland Security – NEW: no minimum spend;
x
Enhancing theprotection of soft targets/ crowded places – NEW: no minimum spend; x
Enhancing cybersecurity – no minimum spend; x
Enhancing community preparedness andresilience –NEW:
no minimum spend; x
Combating domestic violent extremism – NEW: no minimum
spend ; x
Enhancing election security – 3% minimum. 7

4 Section 1 Overview | 2024 Key
Changes tothe
FY 2024 HSGP
Cont.

Purchasing
Undera FEMA Award: 2024 OMB Revisions:The
Office of Management and Budget (OMB) has updated parts ofthe OMB Guidance for Grants and Agreements inTitle 2
of the Code of Federal Regulations. These updates will apply to FEMA awards with an award date on or after October1, 2024.

Key
changes include updates tothe federal procurement standards at2 C.F.R. §§ 200. 317 – 200. 327, which govern how FEMA award recipients andsubrecipients must conduct purchases undera FEMA award.FEMA
will update its policy and guidance documents toincorporate these revisions, but for now, please refer tothe Purchasing Undera FEMA Award: 2024 OMB Revisions Fact Sheet
for more information. Details
onall the 2 C.F.R. revisions can be found on the Federal Register’s Guidance for Federal Financial Assistance webpage.

For
more information onthe federal procurement standards, visit Contracting with Federal Funds for Goods and Services Before, During and After Disasters | FEMA. gov. 7

5 Section 2 Federal Changes and Initiatives |2024 FY
2024 National Priorities
DHS/
FEMA annually publishes the National Preparedness Report ( NPR) to report national progress inbuilding, sustaining, and delivering thecore capabilities outlined inthe
goal ofa secure and resilient nation. This analysis provides anational perspective oncritical preparedness trends
for whole community partners touse to inform program
priorities, allocate resources, and communicate with
stakeholders about issues of concern. HSGP
Subrecipients arerequired toprioritize grant funding to demonstrate howinvestments support closing capability gaps or sustaining capabilities identified inthe Threat Hazard Identification and Risk Assessment THIRA)/
Stakeholder Preparedness Review (SPR) process. DHS/
FEMA continually assesses changes tothe threat landscape tofurther the National Preparedness Goal NPG)
of a secure and resilient nation. The following are national priority areas for FY 2024, including thecorresponding
percentage offunds required ineach area: x
Enhancing information and intelligence sharing and cooperation withfederal agencies, including DHS – no minimum;
x
Enhancing theprotection of soft targets/ crowded places – no minimum; x
Enhancing cybersecurity – no minimum; x
Enhancing community preparedness andresilience – no minimum; x
Combating domestic violent extremism through enhanced
intelligence collection & analysis, training, and
community resilience – no minimum; and x
Enhancing election security – 3% minimum. Subrecipients must spend a minimum of30% of their SHSP and
UASI awards across the six NPAs but have flexibility onhow that funding is allocated. Only the Enhancing Election Security NPA hasa minimum spend requirementof3%. The remaining
27% can be allocated across any of the NPAs.7

6 Section 2 Federal Changes and Initiatives |2024 FY
2024 National Priorities
Cont. National
Priority projects will be reviewed for effectivenessby
DHS/ FEMA and must be deemed effective prior tothe obligation or expenditure offunds. Projects
requiring additional information for DHS/ FEMA todetermine effectivenessofthe project, or projects deemed
ineffective, will have ahold placed ontheir subaward
pending submission ofrequested information and
DHS/FEMA approval. Once aproject is approved by DHS/
FEMA, modifications tothe project have special restrictions regarding modificationsasindicated below: Modifications which donot change theproject scope and do
not decrease theoverall project budget can be processed viaregular modification request. Modifications
which change theproject scope or decrease
theoverall project budget will require DHS/FEMA approval and must be requested onthe National Priority Project
Modification Form. Effectiveness
will be evaluated by DHS/ FEMA, Cybersecurity
andInfrastructure Security Agency,DHS
Office ofIntelligence and Analysis, DHS Center for Prevention Programs and Partnerships, and/or other DHS
components, as appropriate. FEMA will determine whether theproposed approach isclear, logical, and reasonable
toaddress thepriority areas ofinterest and contribute
toa culture of national preparedness, based on the
following four factors:x
Investment Strategy (40%): Projects will be evaluated based on the quality and extent to which the strategy effectively demonstrates supporting theprogram objective
of preventing, preparing for, protecting against,
and responding toacts ofterrorism, to meet itstarget
capabilities, and otherwise reduce the overall risk to
the high-risk urban area, the state, or the nation.x
Budget ( 20%): Projects will be evaluated based onthe extent to which abudget plan for each investment demonstrates
how
7 grant expenditures maximize cost effectiveness.

7 Section 2 Federal Changes and Initiatives |2024 FY
2024 National Priorities
Cont. x
Impact/ Outcomes (40%): Projects will be evaluated onhow this investment helps the jurisdiction close capability gaps identified inits Stakeholder Preparedness
Review and addresses NPs outlined inthe FY
2024 NOFO. Further, projects will be evaluated ontheir
identification andestimated improvementof core capability( ies), the associated standardized target(s) that
align with their proposed investment, and the ways in
which
x
improvements are measured and/or evaluated.

Past Performance (additional consideration):Projects will be evaluated based on the Subrecipient’s demonstrated
capability toexecute theproposed investments.

Under this factor, FEMA will consider theinformation
provided bythe Subrecipient and may also consider
relevant information from other sources. A
detailed description of allowable investments for each NP is included inthe FY 2024 HSGP NOFO (Section A).National Campaigns
and Programs
Whole
Community Preparedness – Subrecipients should engage
with the whole community toadvance individual and
community preparedness andto work as a nation tobuild
and sustain resilience. Indoing so, Subrecipients areencouraged toconsider theneeds ofindividuals withaccess
and functional needs and limited English proficiency
inthe activities and projects funded bythe grant.

Subrecipients
should utilize established best practices for whole
community inclusion and engage with stakeholders to
advance individual andjurisdictional preparedness andresilience.

Subrecipients areencouraged toconsider thenecessities
ofall Californians inthe activities and projects funded bythe grant, including children, seniors, individuals with disabilitiesor access and functional needs, individuals with diverse culture and language use, individuals with lower economic capacity, and other underserved populations.

Additional information regarding community preparedness andresilience is available through Individuals
and Communities.7

8 Section 2 Federal Changes and Initiatives |2024 National Campaigns
and Programs
Cont. Active
Shooter Preparedness – DHS developed acomprehensive
Active Shooter Preparedness website,which
strives toenhance national preparedness through a wholecommunity approach by providing thenecessary products, tools, and resources tohelp all stakeholders prepare
for and respond toan active shooter incident. Subrecipients areencouraged toreview thereferenced active
shooter resources and evaluate their preparedness needs.

Soft
Targets and Crowded Places – States, territories, UAs, and public and private sector partners areencouraged toidentify security gaps and build capabilities that address security needs and challenges related toprotecting locations
or environments thatare easily accessible tolarge
numbers of people onapredictable or semi- predictable
basis that have limited security or protective measures inplace, including town centers, shopping malls, openair venues, outside hard targets/ venue perimeters, and other places of meeting and gathering. For more information, please see DHS’s Hometown Security Program.Community
Lifelines – FEMA created Community Lifelines to
reframe incident information and impacts using plain language andunity of effort toenable theintegration of preparedness efforts, existing plans, and identifies unmet needs
tobetter anticipate response requirements. Additional
information may be found atthe Community Lifelines
Implementation Toolkit website. Strategic
Framework for Countering Terrorism and Targeted Violence – DHS adopted the DHS Strategic Framework for Countering
Terrorism and Targeted Violence which explains
how the department will use the tools and expertise
that have protected and strengthened thecountry
from foreign terrorist organizations toaddress theevolving challengesoftoday.7

9 Section 2 Federal Changes and Initiatives |2024 National Campaigns
and Programs
Cont. Countering
Violent Extremism (CVE) Training - Foreign terrorist
groups and individual terrorist thought leaders recruit orinspire Westerners tocarry out attacks against western andU.S. targets, including individuals living incommunities with the U.S. via, but not limited to, print, video,
and social media, as well as through personal interaction.

But we also know that violent extremism isnot a
phenomenon restricted solely toone community and that
any effort tocounter violent extremism must be applicable toall ideologically motivated violence. Efforts to
provide information andtraining regarding CVEshould emphasize thestrength oflocal communities’ approach. National
Cybersecurity
Review
The
National Cybersecurity Review (NCSR) is a required assessment forall SubrecipientsofState Homeland Security Program ( SHSP) and Urban Areas Security Initiative (UASI) funding tobe completed between October 2024 and February
2025.The
NCSR is a no- cost, anonymous, and annual self-assessment designed to measure gaps and capabilitiesof state,
local, tribal, territorial, nonprofit, and private sector agencies’ cybersecurity programs.Additionally,
FEMA recognizes that some subawards will not
be issued until after the NCSR has closed. In these cases, Subrecipients willbe required tocomplete thefirst available NCSR offered after the subaward has been issued
by Cal OES.The
Chief Information Officer (CIO), Chief Information Security Officer (CISO), or equivalent should complete the NCSR.

Ifthere is no CIO or CISO, the most senior cybersecurity professional should complete theassessment.

Additional information maybe found inIB 439 and
429a.NIMS
Implementation
Prior
tothe allocation ofany federal preparedness awards,Subrecipients must
of
ensure and maintain theadoption andimplementation
the National Incident Management System (
NIMS).7

10 Section 2 Federal Changes and Initiatives |2024 Law
Enforcement Terrorism
Prevention
Activities
At
least 35% of the grant funding under SHSP and UASI must be dedicated toLaw Enforcement Terrorism Prevention Activities ( LETPA). This required LETPA allocation can be from
SHSP, UASI, or both and may be met by funding projects
inany combination ofthe six NPAs and any other investments.

Allowable
expenditures canbe found inthe authorizing legislation, Preparedness Grants Manual,Information Bulletin (
IB) No. 473 Supplemental Guidance for LETPA Expenditures, the National Prevention Framework, and National
Protection Framework. For
an activity tobe counted towards the LETPA requirement, it must have alaw enforcement terrorism prevention
nexus. If an activity islisted inthe authorizing legislation or can be directly tied to a capability inthe National
Prevention Frameworkor shared capability inthe National Protection Framework, then itis presumed tohave law
enforcement nexus and be aLETPA. For all other claimed
activities, nexus tolaw enforcement andterrorism prevention must be clearly explained.Refer
toIB 485 - FY23 LETPA Supplemental Guidance tothe NOFO
forfurther direction onhow to account for LETPA activities, best practices for submitting LETPA investments, and
information onhow todistinguish LETPA from other activities .

Management
and
Administration
The
Management and Administration (M&A) allowance for Subrecipients isset at a maximum of5% for FY 2024 HSGP.Indirect
Costs Indirect costs are allowable under the FY 2024 HSGP Grant Award.

Subrecipients
withan indirect cost rate approved bytheir cognizant
federal agency may claim indirect costs based on
the established rate. Indirect costs claimed must be calculated using the base approved inthe indirect cost negotiation agreement. Acopy ofthe approved negotiation
agreement
7 isrequired atthe time of application.

11 Section 2 Federal Changes and Initiatives |2024 Indirect Costs Cont.

Indirect
costs are in addition tothe M&A allowance and must
be included inthe Grant Award application asa Project”
and reflected inthe FMFW on the Indirect Cost Tab
if being claimed under the award. Indirect
costs must be claimed no more than once annually,
and only at the end of the Subrecipient’sfiscal year.

An exception tothis rule applies ifthere isa mid- year change tothe approved indirect cost rate; in this case, costs
incurred todate must be claimed. At that time, a Grant
Subaward Modification reflecting therate change must
also be submitted toCal OES, along with acopy ofthe
new Indirect Cost Rate Agreement. The
FEMA Preparedness Grants Manual, published by FEMA,
states that State and local governments arenot permitted touse the de minimis rate. These costs are allowable
only when an exception is granted tothe SAA by
FEMA per2 C.F.R. Part 200, Appendix VII, paragraph D.

1.b. Subrecipients should not include these costs intheir future applications until further notice. If necessary, subrecipients may work with their Grants Analyst to modify their
existing projects toremove these costs that were included intheir advanced application. Organization
Costs –
Overtime Operational
overtime costs are allowable forincreased security
measuresat critical infrastructure sites if associated with detecting, deterring, disrupting, and preventing acts of terrorism and other catastrophic events. Pursuant
topage 52of the Fiscal Year (FY) 2024 Homeland Security Grant Program (HSGP), Notice of Funding Opportunity,
all operational overtime requests must clearly explain
how the request meets the criteria of one or more of
the listed Authorized Operational Overtime Categories.Requests must address the threat environment asit relates to
the event or activity requiring operational overtime support and explains how the overtime activity isresponsive
tothe threat. Postevent operational overtime requests will only be considered onacase- by-case basis, where itis demonstrated
exigent circumstances prevented 7

12 Section 2 Federal Changes and Initiatives |2024 Organization Costs –
Overtime Cont.
submission
ofa request inadvance ofthe event or activity. Requests for overtime costs must be submitted to Cal OES via
Allowability Request Log (ARL) Form atthe time of application, ifthe activity will occur within one year ofthe final
application submission. All subsequent requests must be submitted atleast 60 days inadvance ofthe activity. All operational overtime costs must be formally pre-approved in writing by DHS/ FEMA. Personnel
Cap Pursuant to6 U.S.C. § 609( b), SHSP and UASI funds may be used for personnel costs, totaling upto 50 percent of each fund source. ASubrecipient mayrequest this requirement be
waived by DHS/ FEMA, via Cal OES. Requests for personnel cap waivers must be submitted separately for each
fund source in writing onofficial letterhead, with the following information:x
Documentation explaining why the cap should be waived;
x
Conditions under which the request is being submitted; and x
Abudgetand method of calculation of personnel costs both inpercentagesofthe Grant Award and intotal dollar
amount (waivers must be calculated separately for
SHSP and UASI, outlining salary, fringe benefits, and any M&A costs). Subrecipient
requests toexceed the personnel cap must be
received by Cal OES at the time of application. Subaward modifications impacting thepersonnel cap will be
reviewed onacase- by-case basis and may require the submittal ofthe above- mentioned information. Please
see IB421b for more information onthe waiver process.

Allowable
HSGP equipment islisted on the FEMA Authorized
Equipment List (AEL) website. 7

13 Section 2 Federal Changes and Initiatives |2024 Equipment Typing/
Identification
and
Use Subrecipients
that allocate HSGP funds towards equipmentare
required totype and identify the capability associated with that equipment. The FEMA Resource Typing Library Tool ( RTLT) can be used tohelp determine thetype and capability.

Per
FEMA policy, the purchase of weapons and weapon accessories arenot allowed with HSGP funds. Special rules apply
topharmaceutical purchases, medical countermeasures,
and critical emergency supplies; refer topage
A-10 of the FEMA Preparedness Grants Manual for additional information.Expenditures
for general purpose equipment areallowable if
they align toand support one or more core capabilities identified inthe NPG, and inaddition, are deployable/
sharable through the Emergency Management
Assistance Compact and allowable under6
U.S.C. § 609. Refer tothe NOFO and Preparedness Grants Manual for examples of allowable general-purpose equipment.

Equipment
Maintenance/
Sustainment
Use
of HSGP funds for maintenance contracts, warranties, repair orreplacement costs, upgrades, and user fees are allowable as described in FEMA IBs 336 and 379, as well as Grant
Programs Directorate (GPD) Policy FP-205- 402-125-1.Emergency Communications
Projects
All
Subrecipient emergency communications projects must comply with the SAFECOM Guidance on Emergency Communications
Grants and describe intheir FMFW how such
activities align with the goals ofthe Statewide Communications Interoperability Plan.Telecom
Equipment
and Services
Prohibitions
Effective
August 13, 2020, section 889(f)(2)-( 3) of the John S.

McCain National Defense AuthorizationActfor FY 2019 NDAA) and 2 C.F.R. § 200. 216, 200. 471, and Appendix IIto 2
C.F.R. Part 200 prohibit DHS/FEMA Recipients and Subrecipients ( including their contractors andsubcontractors)
from using any FEMA funds under open or new
awards forthe following telecommunications equipment
or services: 7

14 Section 2 Federal Changes and Initiatives |2024 Telecom Equipment
and Services
Prohibitions
Cont. 1)
Telecommunications equipment produced by Huawei Technologies Companyor ZTE Corporation, (or any subsidiary
or affiliate of such entities); 2)
For the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video
surveillance andtelecommunications equipment produced
by Hytera Communications Corporation, Hangzhou
Hikvision Digital Technology Company, or Dahua
Technology Company (or any subsidiaryor affiliate
of such entities); 3)
Telecommunications or video surveillance services provided bysuch entities or using such equipment; or4)
Telecommunications orvideo surveillance equipmentor services produced or provided by an entity that the Secretary
of Defense, inconsultation with the Director of
National Intelligence orthe Director ofthe Federal Bureau ofInvestigation, reasonably believes tobe an entity
owned or controlled by, or otherwise connected to,
the People’s Republic of China. Additional
guidance is available in FEMA Policy #405- 143-1,
Prohibitions on Expending FEMA Award Funds for Covered
Telecommunications Equipmentor Services Prohibited
and Controlled
Equipment
Effective
May 25, 2022, Executive Order (EO) 14074, Advancing
Effective, Accountable Policing and Criminal Justice
Practices to Enhance Public Trust and Public Safety,Section 12(a) of EO 14074 directs the Departmentof Homeland
Security (DHS) to review its grant programs and, consistent withapplicable law, prohibits theuse of grant funding
topurchase certain typesof military equipmentbystate,
local, tribal, and territorial law enforcement agencies ( LEAs).For
all awards issued onor after January1, 2023, the policy directly prohibits certain types of equipment outright prohibited equipment), whereas other typesof equipment may
be controlled, or LEAs are required tosubmit certifications prior topurchase. Even
if equipment islisted as controlled equipment and is not outright prohibited, that does not automatically7

15 Section 2 Federal Changes and Initiatives |2024 Prohibited and Controlled
Equipment
Cont. make
it allowable underaparticular FEMA program. Subrecipients should refer toapplicable program guidance
or contact your Grants Analyst todeterminefa particular type of equipment is allowable under that program.

Additional
information regarding Prohibited and Controlled Equipment is available on FEMA Policy 207-22-0002. Small
Unmanned Aircraft
Systems All
requests topurchase Small Unmanned Aircraft Systems SUAS) with FEMA grant funding must comply with FEMA Policy
207-22-0002 and include copiesofthe policies and procedures inplace tosafeguard individuals’ privacy, civil rights, and civil liberties ofthe jurisdiction that will purchase, take title to, or otherwise usethe SUAS equipment. The Authorized Equipment Listing for 03OE-07-SUAS details questions
that must be included inthe Aviation Request justification.

Reference the Presidential Memorandum: Promoting
Economic Competitiveness While Safeguarding Privacy,
Civil Rights, and Civil Liberties in Domestic Use of Unmanned Aircraft Systems for additional information. Subrecipients must submit Cal OES’ UAS- Drone Request Form,
Controlled EquipmentSelf-Certification Form and FEMA’
s Controlled Equipment Request Form for FEMA approval.

Requests for drone/ UAS accessories follow the same
UAS process that requires FEMA review and approval.

FEMA
approval isrequired before a SUAS can be purchased
with HSGP grants funds.Emergency
Operations
Plans Subrecipients
should update their Emergency Operations Plan (
EOP) at least once every two years toremain compliant
withthe Comprehensive Preparedness Guide 101
version 2.0.7

16 Section 2 Federal Changes and Initiatives |2024 Conflict ofInterest
To
eliminate andreduce theimpact of conflicts ofinterest in the subaward process, Subrecipients andpass-through entities must follow their own policies and procedures regarding theelimination orreduction of conflicts ofinterest
when making subawards. Subrecipients andpass-through
entities are also required tofollow any applicable federal, state, local, and tribal statutes orregulations governing conflictsofinterest inthe making of subawards. Subrecipients must disclose totheir Grants Analyst, in writing,
any real or potential conflictofinterest as defined by
the federal, state, local, or tribal statutes orregulations, which may arise during the administration ofthe HSGP subaward within five days oflearning ofthe conflict ofinterest.

Build
America, Buy
America Act BABAA)
Under
FEMA financial assistance programs, the BABAA requirements apply to:x
New awards made on or after January2, 2023, x
New funding that FEMA obligates toexisting awards orthrough renewal awards onor after January2, 2023; and
x
Infrastructure projects. Funds
provided under this program may not be used foraproject forinfrastructure unless the iron and steel, manufactured products, and construction materials used in
that infrastructure areproduced inthe United States.The Buy America preference only applies toarticles, materials, and supplies that are consumed in, incorporated into,
or affixed toan infrastructure project. As such, it does not apply totools, equipment, and supplies, such as temporary scaffolding, brought tothe construction siteand
removed ator before the completion ofthe infrastructure project. Additionally, the Buy America preference
does not apply toequipment andfurnishings, such
as movable chairs, desks, and portable computer equipment, that are used at or within the finished infrastructure
project but are not an integral partofthe structure
or permanently affixed tothe infrastructure project.
7

17 Section 2 Federal Changes and Initiatives |2024 Build America, Buy
America Act BABAA)
Cont. When
necessary, Subrecipients may apply fora waiver from
these requirements. Additional information regarding the BABAA can be found on FEMA’s website under Buy
America Preference Buy America Preference. 7

18 Section 3 State Changes and Initiatives |2024 FY
2024 Investments
The
State prioritized thefollowing investment strategies forthe FY 2024 subawards:1.

Enhance Information and Intelligence Sharing and Cooperation with Federal Agencies, including DHS National
Priority); 2.

Enhance the Protection of Soft Targets/ Crowded Places National Priority); 3.

Enhance Cybersecurity (National Priority); 4.

Enhancing Community Preparedness and Resilience National Priority); 5.

Combating Domestic Violent Extremism (National Priority);

6. Strengthen Emergency Communications Capabilities Through Planning,

7. Governance, Technology, and Equipment;
Enhance Medical and Public Health Preparedness;8.

Strengthen Information Sharing and Collaboration (non-Fusion Center);9.

Enhance Multi-Jurisdictional/ Inter-Jurisdictional All- Hazards/ Whole Community Incident Planning, Response Recovery
Capabilities; 10.

Protect Critical Infrastructure and Key Resources includes Food and Agriculture); and 11.

Enhance Election Security (National Priority).7

19 Section 3 State Changes and Initiatives |2024 California Homeland
Security
Strategy Goals
The
State prioritized thefollowing California Homeland Security Strategy Goals forthe FY 2024 subawards: 1.

Enhance Information Collection, Analysis, and Sharing, in Support of Public Safety Operations Across California;2.

Protect Critical Infrastructure and Key Resources from All Threats and Hazards;3.

Strengthen Security

4. and Preparedness Across Cyberspace;
Strengthen Communications Capabilities through Planning, Governance, Technology, and Equipment;5.

Enhance Community Preparedness;6.

Enhance Multi-Jurisdictional/ Inter-Jurisdictional All-Hazards Incident Catastrophic Planning, Response, and Recovery
Capabilities;7.

Improve Medical and Health Capabilities;8.

Enhance Incident Recovery Capabilities;9.

Strengthen Food and Agriculture Preparedness; and 10.

Enhance Homeland Security Exercise, Evaluation, and Training Programs.State
Initiative Funding
For
FY 2024, Cal OES shall retain 20% of the SHSP and 17.3%ofthe UASI funding for state initiatives.On
Behalf Of” Cal OES may, in conjunction with local approval authorities, designate funds “on behalf of” local entities who
choose todecline orfail to utilize their subaward ina timely manner.Public
Alert and Warning
Cal
OES encourages Subrecipients toconsider the use of this funding toassist their jurisdiction’s alignment withthe State of California Alert and Warning Guidelines, developed
pursuant to Senate Bill 833 of the 2018 Legislative
Session.7

20 Section 4 Required State Application Components |2024 Financial Management
Forms
Workbook
The
FY 2024 Cal OES FMFW includes:Grant
Subaward Face Sheet – Use the Grant Subaward Face Sheet toapply for grant programs. The Grant Subaward Face Sheet must be signed and submitted inportrait format. An active UEI# ( Formerly DUNS#) is required. UEI registration information is available sam.gov. Authorized
Bodyof5 – Provide thecontact information ofAuthorized
Agents (AA), delegated viathe Governing Body Resolution ( GBR) or Signature Authorization Form, including staff related togrant activities. More than one person isrecommended
for designation asthe AA; in the absence ofan AA,
an alternate AAcan sign requests. Project
Ledger – The project ledger is used inthe application process tosubmit funding information andis used for submitting cash requests, Grant Subaward Modifications, and assists with the completion ofthe Biannual Strategy Implementation Report BSIR).

Planning
Tab – Provides detailed information ongrant- funded planning activities with afinal product identified.Organization
Tab – Provides detailed information ongrant- funded organizational activities.Equipment
Tab – Detailed information must be provided under the
equipment description forall grant- funded equipment. AEL numbers must be included forall items of equipment. Always refer to the AEL for alist of allowable equipment and conditions, if any. Training Tab – Provides detailed information ongrant- funded training activities. All training activities must receive Cal OES approval prior tostarting the event, including a Training Feedback number. The Training Request Form must be submitted and approved toobtain a Training Feedback number and should be submitted atleast 30 days inadvance. Exercise
Tab – Provides detailed information ongrant- funded exercises. 7

21 Section 4 Required State Application Components |2024 Financial Management
Forms
Workbook
Cont.

M&
A Tab – Provides information ongrant- funded M&A activities. Indirect Costs Tab – Provides information onindirect costs.ConsultantContractor Tab – Provides detailed information ongrantfunded consultants andcontractors. Authorized Agent Page – The AA Page must be submitted with the
application, all cash requests, and Grant Subaward Modifications.

The AA Page must include avalid signature onfile with
Cal OES and the date.Subrecipient
Grants
Management
Assessment
Per
2 C.F.R. § 200. 332, Cal OES is required toevaluate the risk of noncompliance withfederal statutes, regulations, and grant terms and conditions posed by each Subrecipientofpass- through funding. The Subrecipient Grants Management Assessment
Form contains questions related toan organization’sexperience inthe managementoffederal grant awards. Itis used to
determine and provide anappropriate level oftechnical assistance, training, and grant oversight to Subrecipients during the subaward. The questionnaire mustbe completed andreturned with the grant application. Application
Attachments
Federal
Funding Accountability and Transparency Act (FFATA) Financial Disclosure – Use the FFATA Financial Disclosure Form toprovide theinformation required bythe Federal Funding Accountability and Transparency Actof 2006. Intelligence
Analysts Certificates – Pursuant tothe Preparedness Grants Manual, Cal OES must have certificates for completion oftraining forfusion center analytical personnel. Please provide copies of certificates for each intelligence analyst, if applicable. UASI Footprint (UASIs Only) – The Urban Area Working Group UAWG) establishes the ‘footprint’ of the UA. A map orlist defining the footprint must be included with the application. UAWG
Member Roster (UASIs Only) – A list of all current UAWG members withpositions ortitles. Indirect
Cost Rate Agreement –If claiming indirect costs ata federallyapproved rate, please provide acopy ofthe approved indirect cost rate agreement.7

22 Section 4 Required State Application Components |2024 Standard Assurances
The
Standard Assurances listthe requirementsowhich the Subrecipients will be held accountable. All Applicants will be required tosubmit an electronic signed, copy ofthe FY 2024 Standard Assurancesas part oftheir FY 2024 HSGP application. The required Standard Assurances can be found only in PDF format onthe Cal OES website. NOTE:

Self-created Standard Assurances will not be accepted. Program Standard
Assurances
Addendum
The
Program Standard Assurances Addendum specifies additional requirements that Subrecipients must meet. All
Subrecipients must submit anelectronic signed Program Standard Assurances Addendum aspart ofthe FY 2024 HSGP application.

The required Program Standard Assurances Addendum
canbe found only in PDF format onthe Cal OES website.

Operational
Areas
and Urban
Areas Governing
Body Resolution – The GBR appoints AAs (identified bythe individual’s name or by a position title) to act on behalf ofthe governing body and the Applicant by executing any actions necessary for each application and subaward. All Applicants arerequired tosubmitacopy of an approved GBR with their grant application.

Resolutions maybe valid for up to three grant years given the following:x
The resolution identifies the applicable grant program (e.g., EMPG and/or HSGP);x
The resolution identifies theapplicable grant years, (e.g., FY 2024, FY 2025, FY 2026; and x
Adheres toany necessary elements required bylocal protocols, rules, etc., if applicable. Resolutions
that only identifyasingle grant program will only be valid for that single program. Resolutions that do not identify applicable grant years will only be valid forthe grant year in which the resolution was submitted. Authorized
Agent Information – For each person or position appointed bythe governing body, identify theindividual inthe All
changes inAA and contact information must be provided toCal OES in writing. Ifthe GBR identifies the AA by name, anew Resolution is needed when changes are made. Ifthe GBR identifies
theAA by position and/or title, changes may be made 7

23 Section 4 Required State Application Components |2024 Operational Areas
and Urban
Areas Cont.
by
submitting arequest onthe entity’sletterhead, signed by an existing AA. Cal OES will not accept signaturesof an AA’s designee, unless authorized bythe GBR. A change toan AA's designee must be submitted onagency letterhead andsigned by
the AA, announcing thechange totheir designee. Operational Areas
Only Approval
Authority Body – OAs must appoint an Anti-Terrorism Approval Body (Approval Authority) tohave final approvalofthe OA’ s application for HSGP funds. Each member ofthe Approval Authority must provide written agreement with the OA’s application for HSGP funds. The Approval Authority shall consist ofthe following representatives, and additional voting members may be added bya simple majority vote ofthe following standing members:x
County Public Health Officeror designee responsible for Emergency Medical Services x
County Fire Chief or Chief of Fire Authority x
Municipal Fire Chief (selected bythe OA Fire Chiefs)x
County Sheriffx
Chief of Police (selected bythe OA Police Chiefs) Urban Areas Only
Urban
Area Working Groups –Membership inthe UAWG must provide either direct orindirect representation forall relevant jurisdictions andresponse disciplines (including law enforcement, fire service, EMS, hospitals, public health, and emergency management) that comprise thedefined UA. It also must beinclusive
oflocal Citizen Corps Council and tribal representatives. The UAWG should also ensure the integration oflocal emergency management, public health, and health care systems into acoordinated sustained local capability torespond effectively toa mass casualty incident. Additional group composition criteria are found inthe FEMA Preparedness Grants Manual. Threat
Hazard Identification and Risk Assessment – Subrecipients are required tosubmita THIRA for all 32 core capabilities. Beginning in2019, UAs are required tosubmita THIRA every three years.

An annual capability assessment will still be required.7

24 Section 4 Required State Application Components |2024 Urban Areas Only
Cont. Stakeholder
Preparedness Review – The SPR is an annual grant requirement for all states, territories, and UAs. It is an annual capability assessment, which helps jurisdictions identify capability gaps and prioritize investment requirements toreach the targets set in their THIRA. Fusion
Centers
OnlyAll
fusion center investments must align to, and reference, specific performance areasofthe assessment thatthe funding isintended tosupport. Fusion
Centers are also required tofollow all Reporting and Administrative Metrics for California Fusion Centers, as set forth inthe Governor’s Homeland Security Advisor/Cal OES Director’sletter dated March 16, 2016. These operational and administrative metrics setforth an integrated andcoordinated approach forregular and proactive information andintelligence sharing between all fusion centers inthe California State Threat Assessment System (STAS).State
Agencies
and Tribes
Only State
Agencies, and federally recognized tribes may submit the Signature Authorization Form inlieu of a GBR, signed by the most senior ranking official, such as the Secretary, Director, President, Chancellor, or Chairperson.7

25 Section 5 State Application Process |2024 Application Submission
Subrecipients
must submit anelectronic copyoftheir completed FMFW
to
a
their Grants Analyst forreview. After the application is approved, completed copyofthe FMFW, along with all other application components mustbe submitted, with official signatures,
by the application due date. During the application process, ifit is determined not all allocated funds can be expended bythe end ofthe period of performance, please inform
a Grants Analyst assoon as possible. The completed application should be received by Cal OES no later than the date provided inthe FY 2024 HSGP Timeline, referenced as AttachmentB.

Late
orIncomplete
Application
Late
orincomplete applications may be denied. If an application is incomplete, the Grants Analyst may request additional information.

Requests forlate submission of applications mustbe made in writing tothe Grants Analyst prior tothe application due date.

Cal OES has sole discretion toaccept orreject alate orincomplete grant application.HSGP
Contact Information
The
Grants Analyst Regional Assignments Map islinked and available onthe Cal OES website under “Regional Assignments”.Subaward Approval
Subrecipients
will receive aformal notification of award nolater than 45 days after Cal OES accepts thefederal grant award. The award letter must be signed, dated, and returned to Cal OES within 20calendar days. Once the completed application, along with the
of
signed award letter, is received andapproved, reimbursement eligible subaward expenditures may be requested
using the Cal OES FMFW.7

26 Section 6 Post Award Requirements |2024 Payment
Request Process
To
request anadvance or cash reimbursementofHSGP funds,
Subrecipients must first complete apayment request using the Cal OES HSGP FMFW, returning itto the appropriate Grants Analyst. Subrecipients whofail to follow the workbook instructions may experience delays inprocessing thepayment
request.Payments
canonly be made ifthe Subrecipient hasan approved
application. Advances
and Interest
Earned on Advances
An
Advance payment isa payment that is requested before Subrecipients havedisbursed thefunds for program purposes. Subrecipients maybe paid an advance, provided they maintain
a willingness and ability to maintain procedures to minimize thetime elapsing between thereceipt offunds and their
disbursement. The timing and amountof advance payments
must be as close as administratively feasible tothe actual disbursements bythe Subrecipient for project costs. Federal rules require advances tobe deposited ininterest- bearing accounts. Interest earned inamounts upto $500 per year
may be retained by Subrecipients for administrative expenses; any additional interest earned onfederal advance payments must be returned annually toCal OES.SemiAnnual Drawdown Requirements
All
Subrecipients must report expenditures andrequest funds at least semi-annually throughout theperiod of performance. Semiannual drawdowns should occur by March and October of each calendar year following final approval ofthe
subaward application, except forthe final cash request, which must be submitted within 20calendar days after the end
of the period of performance. Modifications
Post- award budget and scope modifications must be requested using
s
the Cal OES HSGP FMFW v1.24, signed bythe Subrecipient’ AA, and submitted tothe Grants Analyst. The
Subrecipient may implement grant modification activities, and incur associated expenses, only after receiving written final approvalofthe modification fromCal OES.7

27 Section 6 Post Award Requirements |2024 Modifications Cont.

Subrecipients
must provide awritten justification withall modification requests. The justification may be included inthe body
ofthe e-mail transmitting therequest, or in a document attached tothe transmittale-mail. Please reference GMM 2018-
17 for additional information regarding modification requests.

Modifications
toNP Projects have additional restrictionsasindicated
below:Modifications
which do not change the project scope and do
not decrease theoverall project budget can be processed viaregular modification request.Modifications
which change the project scope or decrease the
overall project budget will require DHS/FEMA approval and must be requested onthe National Priority Project Modification Form.Training
Requirements
All
grant- funded training activities must receive Cal OES approval priortostarting thetraining event. Cal OES shall allow
Subrecipients todevelop a “placeholder” for future training conferences when an agenda has not been established
atthe time Subrecipient applications aredue. Please
work with a Grants Analyst and the Training Branch toidentify apossible “ placeholder” for these types oftraining activities.

When
seeking approvalof non-DHS/FEMA developed courses,
course materials must be submitted with the approval
requests. Conditional approvals arenot offered. Subrecipients must complete aTraining Request Form and submit
it electronically tothe Cal OES Training Branch tobe approved with a Training Feedback Number before beginning
anytraining activities. This includes project components liketravel to, materials for, or attendance intraining
courses. Training Feedback Numbers should be obtained
nolater than 30 days before the first day ofthe training orrelated activities. Requests that are submitted withless than 30 days prior tothe start of the training or activity are not guaranteed tobe approved intime and run the risk of training being unallowable. Training Feedback numbers must7

28 Section 6 Post Award Requirements |2024 Training
Requirements
Cont.
be
included onthe FMFW Training Ledger tobe considered for reimbursement. For
more information onthis or other training-related inquiries, contact theCal OES Training Branch at (916) 845- 8745 or Training@CalOES. ca.gov.Exercises,
Improvement
Plans,
and After-Action
Reporting Subrecipients
should engage stakeholders toidentify long-term
training and exercise priorities. These priorities should address capability targets and gaps identified through the THIRA and SPR process, real-world events, previous exercises, and national areas forimprovement identified inthe NPR. Subrecipients must report onall exercises conducted with HSGP
grant funds. An After-Action Report AAR)/
Improvement Plan (IP) or Summary Report (for Seminars
and Workshops) must be completed andsubmitted to
Cal OES within 90 days after exercise/ seminars/ workshops are conducted. Itis acceptable tosubmit an Exercise Summary Report for Seminars and Workshops inlieu ofa full AAR/
IP. Please
e-mail AAR/IPs and Summary Reports to:x
hseep@fema. dhs.gov x
exercise@caloes. ca.gov x
Olivia. [email protected] For
exercise- related issues and/or questions, please email the Cal OES Exercise Team at [email protected]. Exercise
costs will not be considered forreimbursement until an
AAR/ IP is received by Cal OES. Procurement
Standards
and Written
Procedures
Subrecipients
arerequired toconduct procurement activities in
with documented procurement procedures that align with federal procurement standards outlined in2 C.F.R. Part 200.In cases where there isa conflict between thelocal procedures and federal standards, the more stringent requirements mustbe followed. Additionally, subrecipients must implement written conflictofinterest policies that govern theactions of employees involved
of
inthe selection, award, and administration
contracts. These policies should include provisions
for disciplinary actions inthe event of violations.7

29 Section 6 Post Award Requirements |2024 Procurement
Thresholds
Under
2C.F.R. Part 200, procurement thresholds aredefined as
follows:x
Micro- purchase threshold: This is the maximum amount for which purchases can be made without requiring competitive
quotes orformal procurement processes, provided
theprice isreasonable. The micro-purchase threshold
isset at $10, 000. x
Simplified acquisition threshold: This sets the maximum amount for which federal procurement procedures maybe simplified.

The threshold is $250, 000. For purchasesator below
this amount, subrecipients may use streamlined methods, such as obtaining competitive priceorrate quotations
from an adequate number of qualified sources. Purchases exceeding $250,000 require more formal procurement
procedures, including sealed bids or competitive
proposals.Subrecipients
must adhere tothese thresholds and, in cases of
conflict between local procurement procedures andfederal requirements, must apply the more stringent threshold.

Procurement
Documentation
Subrecipients
must maintain records that document theprocurement
process, including therationale forthe procurement
method, contract type, contractor selection orrejection, and the basis for the contract price. To be allowable,
costs must be properly documented. Acceptable documentation includes, but is not limited to:x
Solicitation materials (
x
e.g., requests for quotes, bids, or proposals)
Responses
Independent
to
cost
solicitations (e.
estimates and
g., quotes,
postbids, solicitation cost/
or proposals)x
price analyses,
Contract
Evidence
Other
if
documents
of
documents mandated
and
applicable
required
x
contract
by
provisions
amendments x
federal
x
regulationsatthe time
the grant was awarded 7

30 Section 6 Post Award Requirements |2024 Noncompetitive Procurement
All
noncompetitive procurements exceeding thesimplified acquisition threshold requires Cal OES prior written approvalto
be eligible forreimbursement. This method of procurement must be
a
approved bythe local Purchasing Agent prior tosubmitting request for Cal OES approval. Acopy ofthe Purchasing
Agent’s approval must be included with the Cal
OES Request for Noncompetitive Procurement Authorization form. Cal OES may request additional documentation
that supports the procurement effort.Cal
OES will not reimburse for any noncompetitive procurement contracts for any HSGP terrorism-related training,
regardless ofthe cost ofthe training. Exceptions tothis policy may be approved inlimited circumstances,.g., related toa procurement effort that has resulted ininadequate
competition. Please refer to GMM2017- 01A and GMM2021-
05for additional guidance.Performance
Bond
Due
tothe risks associated withdelays invendor deliveryoflarge equipment procurements, DHS/FEMA allows Subrecipients
toobtain a “performance bond” for items that are
paid for up front toensure deliveryofthe equipment within the grant period of performance. Cal
OES requires Subrecipients toobtain aperformance bond when procuring any equipment itemover $250, 000, or for any vehicle, aircraft, or watercraft that requires fullor partial payment prior toreceiving the final product(s). Performance
Bond Waivers may be granted onacase- by-case
basis and must be submitted toCal OES prior toprocurement.

Environmental
Planning
and Historic
Preservation (

EHP) DHS/
FEMA isrequired toensure all activities and programs that are funded bythe agency comply with federal Environmental Planning and Historic Preservation (EHP) regulations.

Subrecipients proposing projects or activities including, but not limited to, training, exercises, the installation of equipment, and construction orrenovation projects)
that have the potential toimpact the environment, or
a historic structure must participate inthe EHP screening process.

EHP Screening Memos must include detailed project information, explain the goals and objectivesofthe proposed 7

31 Section 6 Post Award Requirements |2024 Environmental Planning
and Historic
Preservation (
EHP) Cont.
project
and include supporting documentation.DHS/
FEMA may also require the Subrecipientoprovide aconfidential California Historical Resources Information System CHRIS) report inaddition tothe EHP Screening Form.Determination onthe necessity ofa CHRIS report is based upon
information disclosed onthe form. GrantAnalysts will provide additional instructions should this report berequired. EHP Screening Requests should be submitted to Cal OES as early as possible. All projects/ activities triggering EHP must receive DHS/FEMA written approval priortocommencementof
the funded activity.Updated
information may be referenced inthe FEMA GPD EHP
Policy Guidance. Construction
and Renovation
When
applying for construction activityatthe time of application, including communication towers, Subrecipients must
submit evidence of approved zoning ordinances, architectural plans, any other locally required planning permits,
and anotice offederal interest. Additionally, Subrecipients arerequired tosubmit an SF-424C Budget and Budget
Detail that cites project costs. Communication tower construction requests also require evidence thatthe Federal Communications Commission’sSection 106 review process was
completed. Subrecipients
using funds for construction projects must comply
with the Davis-Bacon Act. Subrecipients must ensure that their contractorsor subcontractors for construction projects pay workers noless than the prevailing wages forlaborers and mechanics employed onprojects ofa character
like the contract work inthe civil subdivision ofthe state in which the work isto be performed. Project
construction using SHSP and UASI funds may not exceed $ 1,000, 000 or 15% of the grant subaward (for the purposes oflimitations onfunding levels, communications towers
are not considered construction).7

32 Section 6 Post Award Requirements |2024 Construction and Renovation
Cont. Written
approval for construction mustbe provided by DHS/
FEMA prior tothe use of any HSGP funds for construction or renovation. No construction activities (including site preparation, utility installations, and any groundbreaking activities) or equipment installations onexisting structures, may
begin until the EHP review process iscomplete. Inventory Control and
Property Management
Subrecipients
must use standardized resource management concepts
forresource typing and credentialing, inaddition to maintaining aninventory by which tofacilitate the effective identification, dispatch, deployment, tracking, and recoveryof
resources. Subrecipients
must have an effective inventory management system,
to include:x
Property records that document description, serial/ID number, fund source, title information, acquisition date, cost, federal cost share, location, use, condition, and ultimate A
disposition;
physical inventory
x
conducted atleast every two years;x
A control system toprevent loss, damage, and theft of grant purchased equipment andsupplies; and x
Adequate maintenance procedures tokeep the property in
good condition. Equipment
Disposition
When
originalorreplacement equipment acquired under the HSGP is no longer needed for program activities, the Subrecipient must contact the Grants Analyst torequest disposition
instructions. See 2 C.F.R. § 200. 313€.Performance
Reporting
Subrecipients
must complete aBSIR each Winter and Summer using
the DHS/ FEMA Grants Reporting Tool (GRT) for all awards prior to FY 2024. All subsequent BSIR reports will be submitted in FEMA GO. BSIR must be completed forthe duration
of each subaward period of performance oruntil all grant activities are completed and the subaward isformally closed by Cal OES. Failure tosubmitaBSIR could result insubaward reduction, suspension, ortermination. Access
tothe BSIR for all awards prior to FY 2024 may be obtained through the GRT. To create anew account, please click
the link that reads, “Register for an account” and follow the instructions provided. The Subrecipient will be required to7

33 Section 6 Post Award Requirements |2024 Performance
Reporting
Cont.ensure
up-to-date project information is entered. The Project Ledger inthe FMFW may assist with the BSIR data entry process.

For additional assistance with the GRT, please contact
your Grants Analyst.Extension
Requests
Extensions
tothe initial period of performance identified inthe subaward will only be considered through formal, written requests toyour Grants Analyst. Upon receiptofthe extension request, Cal OES will: 1.

Verify compliance with performance reporting requirements byconfirming the Subrecipient hassubmitted
all necessary performance reports; 2.

Confirm the Subrecipient has provided sufficient justification forthe request; and 3.

If applicable, confirm the Subrecipient has demonstrated sufficient progress inpast situations where anextension was
authorized by Cal OES. Extension
requests will be granted only due tocompelling legal,
policy, or operational challenges, must be project- specific and will only be considered forthe following reasons:1.

Contractual commitments withvendors that prevent completion of

2. the project within the period of performance;
The project must undergo acomplex environmental review
which cannot becompleted within this timeframe;3.

Projects are long-term by design and therefore, acceleration would compromise core programmatic goals;
and 4.

Where other special circumstances exist.To
be considered, extension requests must be received nolater than 60 days prior tothe end ofthe Subrecipient’speriod of performance and must contain specific and compelling justifications asto why an extension isrequired. All extension requests must address thefollowing:1.

Grant program, fiscal year, and award number;2.

Reason for delay;3.

Current statusofthe activity/ activities;4.

Approved period of performance termination dateand new
project completion date;7

34 Section 6 Post Award Requirements |2024 Extension
Requests
Cont.

5. Amount offunds drawn down todate;6.

Remaining available funds, both federal and non-federal; 7.

Budget outlining how remaining federal and non-federal funds will be expended;8.

Plan for completion, including milestones and timeframes for each milestone and the position/ person responsible forimplementing theplan for completion; and 9.

Certification theactivity/ activities will be completed within the extended period of performance without any modification tothe original Project Scope. General
questions regarding extension requirements andthe extension request form, should bedirected toyour Grants Analyst.

For additional information, please see IB379. Extension requests for personnel andsalaries donot meet the requirements ofIB 379 and will not be granted. Subrecipients are
expected tocomplete all grant- funded personnel activities bythe end ofthe subaward period of performance. Progress Reports on
Grant Extensions
All
Subrecipients that receive Cal OES approval toextend their FY 2024 Grant Subaward period of performance may be required tosubmit progress reports indicating completed andfuture project milestones onall extended projects. Progress reports must be submitted electronically tothe Subrecipient’s Grants Analyst. Deadlines forthe submission of progress reports will be established atthe time of extension approval.Monitoring Cal OES Grants Monitoring actively monitors Subrecipients, through day-to-day communications, programmatic sitevisits,
desk, and on-site compliance assessments. The purpose of the compliance assessment isto ensure Subrecipients arein compliance with applicable state and federal regulations, grant guidelines, and programmatic requirements. Monitoring
activities may include, but are not limited to:x
Verifying entries recorded onthe FMFW categories areproperly Eligibility
supported
of and
with
support for
source
expenditures,
documentation;
typically
x
covering
two to three years of data;x
Comparing actual Subrecipient activities tothose approved inthe grant application andsubsequent7

35 Section 6 Post Award Requirements |2024 Monitoring
Cont.
modifications,
including thereview oftimesheets andinvoices
Procurements
Ensuring
as
and
equipment
applicable;
lists
x
contracts; x
are properly maintained andphysical
Ensuring
inventories
advances have
are
been
conducted;x
disbursed inaccordance with
applicable guidelines; and x
Confirming compliance with Standard Assurances; and x
Information provided onperformance reports and payment
requests NOTE:

Itis the responsibilityofall Subrecipients that pass down grant funds toother entities, to maintain and utilize aformal process to monitor thegrant activitiesoftheir subawards. This requirement includes, but is not limited to, on- site verification of grant activities, as required. Itis common for Subrecipientso receive findings ina programmatic sitevisit or compliance assessment, which require a Corrective Action Plan (CAP) to be
submitted by Subrecipients. Those Subrecipients who fail to submita CAP, as required, shall have a “hold” placed onany future reimbursements untilthe “finding” is resolved. Failure to Submit Required
Reports Periodic
reporting isrequired bythe grant. Subrecipients who miss asingle reporting deadline may receive aletter addressed totheir Board of Supervisors informing them ofthe failure toreport. County OAs and tribes who fail to report twice consecutively may have subsequent awards reduced by
10% until timely reporting isreestablished; UASIs may have a “ hold” placed onany future reimbursements. Suspension/
Termination
Cal
OES may suspend orterminate grant funding, in whole orin part, orother measures may be imposed for any of the following reasons:x
Failure tosubmit required reports.x
Failure toexpend funds ina timely manner consistent with the Failure
grant
to
milestones,
comply with
guidance,
the
and
requirementsor
assurances.x
statutory progress
toward thegoals or objectivesoffederal or state law.
x
Failure to make satisfactory progress toward the goals or objectives Failure
set
tofollow Grant
forth in
Subaward
the Subrecipient
requirements
application.
or
x
Special7

36 Section 6 Post Award Requirements |2024 Suspension/
Termination
Cont.Conditions.
x
Proposing orimplementing substantial plan changes tothe extent that, if originally submitted, the application would not have been selected forfunding.x
False
Failure
certification
to
in
adequately manage,
the application
monitor,
or
or
document.x
direct the grant
funding activitiesoftheir Subrecipients. Before
taking action, Cal OES will provide the Subrecipient reasonable notice ofintent toimpose corrective measures and
will make every effort toinformally resolve theproblem. Closeout Cal
OES will close-out Subrecipient awards when it determines all applicable administrative actions and all required
workofthe federal award have been completed. Subawards
willbe closed after:x
All funds
x
have been requested and reimbursed, or disencumbered;
Receiving all applicable Subrecipient reports indicating all approved work has been completed, and all funds have been
Completing
distributed;
a
x
x
review toconfirm theaccuracyof reported information;
Reconciling actual costs tosubawards, modifications, and payments; and x
Verifying the Subrecipient hassubmitted afinal BSIR showing all grant funds have been expended. Records
Retention The records retention period isthree years from the date ofthe Cal OES Grant Closeout letter, or until any pending litigation, claim, or audit started before the expiration ofthe threeyear retention period has been resolved and final action istaken. For
indirect cost rate proposals, cost allocation plans, or other rate computation records, the start of the record retention period is dependent on whether theproposal, plan, or other computation isrequired tobe submitted tothe federal government (
orto the pass-through entity) for negotiation purposes.

See 2 C.F.R. § 200. 334(f). 7

37 Section 6 Post Award Requirements |2024 Records
Retention Cont.

In
order for any cost tobe allowable, it must be adequately documented per2 C.F.R. § 200. 403(g). The
Cal OES Grant Closeout Letter will notify the Subrecipientof the start ofthe records retention period for all programmatic andfinancial grant-related records. If
the State Administrative Agency’s award remains open after the Subrecipient’ssubmissionfthe final BSIR, Cal OES will complete any additional BSIR reporting required under the award onbehalf ofthe Subrecipient. Closed
grants may still be monitored andaudited. Failure to maintain all grant records forthe required retention period could result ina reduction of grant funds, and an invoice toreturn costs associated withthe unsupported activities. If
documents areretained longer than the required retention period, FEMA, the DHS Office ofInspector General, Government
Accountability Office, and pass-through entity have
the right toaccess these records as well. See 2 C.F.R. §§ 200. 334,200. 336.7

38 Attachment A FY 2024 HSGP Allocations | 2024 SHSP
allocations reflect National Priority Area project adjustments State Homeland Security Program (SHSP) Operational
Area Total Award Operational Area Total Award ALAMEDA
1, 453, 851 ORANGE 2, 718, 746 ALPINE
75, 998 PLACER 420, 772 AMADOR
108, 571 PLUMAS 91, 008 BUTTE
248, 256 RIVERSIDE 2, 130, 587 CALAVERAS
112, 830 SACRAMENTO 1, 400, 136 COLUSA
93, 346 SAN BENITO 130, 337 CONTRA
COSTA 1, 042, 148 SAN BERNARDINO 1, 913, 858 DEL
NORTE 97, 417 SAN DIEGO 2, 830, 483 EL
DORADO 234, 278 SAN FRANCISCO 775, 892 FRESNO
927, 408 SAN JOAQUIN 737, 499 GLENN
96, 159 SAN LUIS OBISPO 316, 482 HUMBOLDT
187, 964 SAN MATEO 696, 626 IMPERIAL
226, 248 SANTA BARBARA 446, 265 INYO
90, 923 SANTA CLARA 1, 664, 434 KERN
839, 747 SANTA CRUZ 295, 835 KINGS
202, 266 SHASTA 226, 214 LAKE
127, 354 SIERRA 77, 691 LASSEN
98, 828 SISKIYOU 111, 698 LOS
ANGELES 8, 300, 952 SOLANO 448, 956 MADERA
208, 274 SONOMA 477, 966 MARIN
288, 172 STANISLAUS 535, 072 MARIPOSA
89, 272 SUTTER 158, 389 MENDOCINO
150, 140 TEHAMA 129, 162 MERCED
315, 459 TRINITY 88, 432 MODOC
82, 186 TULARE 475, 346 MONO
86, 086 TUOLUMNE 121, 004 MONTEREY
437, 680 VENTURA 770, 793 NAPA
188, 460 YOLO 261, 139 NEVADA
159, 879 YUBA 144, 674 Total
37, 165,648 7

39 Attachment A FY 2024 HSGP Allocations | 2024 Fusion
Centers Region
Total Award SAN
FRANCISCO BAYAREA 1, 792, 050 SACRAMENTO/
CENTRAL VALLEY AREA 2, 565, 000 GREATER
LOS ANGELES AREA 2, 887, 500 SAN
DIEGO AREA 2, 047, 500 ORANGE
AREA 835, 000 Total
10, 127,050 SHSP
allocations reflect National Priority Area project adjustments Urban Areas Security Initiative (UASI) A
minimum of 35% of UASI funding must be for Law Enforcement Terrorism Prevention Urban Area Federal
Allocation
toState
Allocation
toUASI
State Initiatives ANAHEIM/
SANTA ANA AREA 4, 712, 190 3, 896, 981 815, 209 BAY
AREA 32, 754,895 27, 088,298 5, 666, 597 LOS
ANGELES/ LONG BEACH AREA 59, 395,378 49, 119,978 10, 275,400 RIVERSIDE AREA 3, 500, 484 2, 894, 900 605, 584 SACRAMENTO
AREA3, 410, 728 2, 820, 672 590, 056 SAN
DIEGO AREA 14, 760, 877 12, 207, 245 2, 553, 632 Total
118, 534,552 98, 028,075 20, 506,477 7

40 Attachment B FY 2024 HSGP Timeline |2024 DHS/
FEMA Announcementof2024 HSGP NOFO April 16, 2024 Cal
OES Application Due to DHS June 24, 2024 DHS
Award to California September 27, 2024 Subrecipient
period of performance begins September 1, 2024 2024
HSGP California Supplement release November 2024 Subrecipient Workshops October 2024 Subrecipient
Awards (45 days from DHS award) October 2024 Subrecipient Final Applications for FY24 Due to Cal
OES February
10, 2024 Subrecipient
period of performance ends May 31, 2027 Final
Cash Requests due to Cal OES Within twenty (20) calendar days after end of grant Cal
OES’s period of performance ends August 31, 2027 7

Attachment C: FY 2024 HSGP Application Checklist | 2024 UEI LETPA 35% or > M&A 5% or <Subrecipient: FIPS#: Grants Analyst: Financial
Management Forms
Workbook: Grant Award Face
Sheet Authorized Bodyof5
Project Ledger Planning Tab Organization
Tab Equipment Tab
Training Tab Exercise
Tab Consultant/Contractor
Tab Management & Administration
Tab Indirect Cost
Tab Authorized Agent
Sheet Attachments: Original CounterSigned Award Letter Governing Body Resolution (Certified)Standard
Assurances Program Standard
Assurance
Addendum FFATA Certification Subrecipient Grant Management Assessment Form Indirect Cost Rate
Negotiation Agreement Personnel
Cap Waiver (IfApplicable)Intelligence
Analyst( s) Certificates (
If Applicable)UASI Only: UASI Footprint
UAWG Roster State Agencies andTribes
Only: Signature Authority Form (in lieu
of Governing Body Resolution) For Cal OES
Use Only
Reviewed by:Date:

Management Approval:Date:
7

0.00

ITEM # 22

CITY OF MONTEBELLO

CITY COUNCIL AGENDA STAFF REPORT
TO: Honorable Mayor and City Council Members
FROM: Raul Alvarez, City Manager

BY: David Sosnowski, Director of Recreation and Community Services SUBJECT: AUTHORIZE INCREASING THE NOT TO EXCEED AMOUNT ON THE

BLANKET PURCHASE ORDER WITH GRAINGER
DATE: June 10, 2026
RECOMMENDATIONS:

It is recommended that the City Council:

1. Authorize increasing the not to exceed amount on the existing blanket Purchase Order with Grainger by $10,000; and

2. Take such additional, related action that may be desirable.

FISCAL IMPACT:

A blanket purchase order currently exists with Grainger in the amount of $49,999. Staff is requesting an increase of $10,000 to the not-to-exceed amount in order to purchase field light bulb replacements — to $59,999. There are sufficient funds in the Fiscal Year 2025-26 Recreation Division budget for the purchase and a budget amendment is not required as part of the recommended actions.

BACKGROUND/DISCUSSION:

A purchase order was created for Fiscal Year 2025-26 with Grainger for the purchase of various items by the Transit, Public Works, Fire and Parks and Recreation Departments.

Due to use of the vendor by multiple departments citywide, the purchase order has reached the $50,000 threshold and requires City Council approval to make any additional purchases (per the Montebello Municipal Code Section 3.20.090).

The Recreation and Community Services Department is requesting to increase the purchase order by $10,000 for the purchase of replacement field light bulbs at several

CITY COUNCIL AGENDA REPORT - MEETING OF JUNE 10, 2026

baseball fields. The current lighting systems at most of the city parks require metal halide bulbs and several lights are out and in need of replacement. Metal halide bulbs are in limited supply in California and only certain vendors have stock available due to State regulations on the sale of similar types of lights. Grainger has confirmed with staff that they have the light bulbs needed in stock. Upon approval by City Council to increase the amount of the purchase order, staff can proceed with the procurement of the equipment, ensuring sufficient supply of the light bulbs.

ENVIRONMENTAL:

N/A
ANALYSIS:

N/A
SUMMARY:

It is recommended that the City Council authorize increasing the existing blanket purchase order with Grainger by $10,000 for the replacement of field lights at various City parks, to a new not-to-exceed amount of $59,999. Sufficient appropriations exist in the FY 2025-26 budget, therefore no budget amendment is neede as part of the recommended actions.

ATTACHMENT(S)
None

ITEM # 23

CITY OF MONTEBELLO

CITY COUNCIL AGENDA STAFF REPORT
TO: Honorable Mayor and City Council Members
FROM: Raul Alvarez, City Manager

BY: Luis Lopez, Police Chief
SUBJECT: ACCEPTANCE OF BUREAU OF JUSTICE ASSISTANCE (BJA),

PATRICK LEAHY BULLETPROOF VEST PARTNERSHIP (BVP) GRANT

PROGRAM FUNDING
DATE: June 10, 2026
RECOMMENDATIONS:

It is recommended that the City Council:

1. Approve the use of funding awarded to the Police Department by the Bureau of Justice Assistance (BJA), Patrick Leahy Bulletproof Vest Partnership (BVP) grant program in the amount of $7,295; and

2. Take such additional, related action that may be desirable.

FISCAL IMPACT:

The City of Montebello is being awarded $7,295 from the Bureau of Justice Assistance (BJA), Patrick Leahy Bulletproof Vest Partnership (BVP) program (Attachment B). The total expected cost for the purchase of ballistic vests is $14,589.. There is a 50% required match from the City in the amount of $7,295. The City’s 50% match will come from the General Fund. There is sufficient funding included in the Police Department's proposed Fiscal Year 2026-27 budget for this required matching amount. The grant amount of $7,295 is in the proposed FY 2026-27 budget.

To keep up to date on safety requirements, a ballistic vest must be replaced every five years. It should be noted that the overall fiscal impact to the City of Montebello is reduced because the Police Department would have to purchase these vests at full replacement costs if the grant is not accepted. The department applies for this grant annually to assist with the purchase of new and replacement vests.

CITY COUNCIL AGENDA REPORT - MEETING OF JUNE 10, 2026

BACKGROUND/DISCUSSION:

The Patrick Leahy Bulletproof Vest Partnership (BVP), created by the Bulletproof Vest Partnership Grant Act of 1998, is a unique U.S. Department of Justice (DOJ) initiative designed to provide a critical resource to state and local law enforcement to help offset the cost of purchasing ballistic vests.

On May 14, 2026, the Police Department was awarded a BJA-BVP Grant in the amount of $7,295 (Attachment B). The performance period of the Grant is May 14, 2026 to August 31, 2027. Funding from this Grant has been approved for the reimbursement of half of the total cost of the purchase of National Institute of Justice (NIJ) compliant ballistic vests.

Every sworn police officer with the Montebello Police Department is issued a ballistic vest that they are required to wear while on duty. These vests have a manufacturers warranty of five years, at which time they must be replaced. This equipment is crucial in providing public safety personnel with live-saving equipment during the performance of their duties.

ENVIRONMENTAL:

N/A
ANALYSIS:

Montebello Police Department Policy 1024 states the guidelines for the proper use and replacement of body armor. Per policy, “all field officers in uniform shall wear their Department issued soft body armor at all times. The Administration supervisor shall ensure that body armor is issued to all officers when the officer begins service at the Montebello Police Department and that, when issued, the body armor meets or exceeds the standards of the National Institute of Justice. The Administration supervisor shall establish a body armor replacement schedule and ensure that replacement body armor is issued pursuant to the schedule or whenever the body armor becomes worn or damaged to the point that its effectiveness or functionality has been compromised.” Best practice strategies will be implemented to ensure that Department equipment is issued to personnel as required per Policy 1024.

SUMMARY:

The Department has been awarded a BVP Grant in the amount of $7,295 (Attachment B). The Grant award will enable the Department to purchase and equip all sworn personnel with a uniquely fitted ballistic vest that shall be replaced on a 5-year replacement cycle per manufacturing specifications. It is critical that sworn personnel are provided with the necessary equipment to perform their duties in the safest manner. City Council is being asked to accept the Grant award, as further outlined in the attached award letter (Attachment B). The FY 2026-27 proposed budget will include the grant funding and General Fund matching funds, therefore, no budget amendment is required as part of the recommended actions.

CITY COUNCIL AGENDA REPORT - MEETING OF JUNE 10, 2026

ATTACHMENT(S)

1. Attachment A - Application Details

2. Attachment B - Award Letter

ITEM # 24

CITY OF MONTEBELLO

CITY COUNCIL AGENDA STAFF REPORT
TO: Honorable Mayor and City Council Members
FROM: Raul Alvarez, City Manager

BY: Michael Solorza, Director of Finance
SUBJECT: ANNUAL APPROVAL OF CITY'S INVESTMENT POLICY
DATE: June 10, 2026
RECOMMENDATIONS:

It is recommended that the City Council:

1. Adopt Resolution No. 26-44 approving the Investment Policy Statement for the City and Successor Agency as required by Government Code Section 53601 et al; and,

2. Take such additional, related action that may be desirable.

FISCAL IMPACT:

Approval of the updated Investment Policy Statement has no immediate fiscal impact. State Government Code requires annual review and approval of the investment policy by a City’s governing body, even if no changes are made to the policy.

The attached policy has no updates for Fiscal Year 2026-27. Staff is bringing the policy for City Council review and approval so this process is aligned with annual budget development and adoption.

BACKGROUND/DISCUSSION:

State Government Code requires cities to have a City Council approved investment policy that guides the investment of idle cash. The policy is intended to provide specific criteria for the prudent investment of City and Successor Agency funds. The ultimate goal of the policy is to enhance the economic status of the City while protecting funds under management and meeting daily cash flow needs.

CITY COUNCIL AGENDA REPORT - MEETING OF JUNE 10, 2026

The City of Montebello has an investment policy statement most recently reviewed, approved and updated on June 25, 2025 (and prior to that, August 19, 2019, October 28, 2020, June 23, 2021, June 8, 2022, June 14, 2023 and June 12, 2024). Government Code requires an annual review and approval of the investment policy statement – even if no changes are made. The 2019 approval was the first time the City’s investment policy was updated since 2011, with a previous update done in 2007. The irregular nature of review and updating of the policy required a much more thorough updating in October, 2020. Since then, each annual update has been routine, as the review process is aligned on an annual basis and coincides with budget review and adoption.

The updated version of the City’s investment policy was submitted to the California Municipal Treasurers Association (CMTA) for consideration of their investment policy review and award program in 2020. The CMTA investment policy program utilizes public treasury officials to review public agency policies to ensure they comply with best practices and Government Code. For the first time in the City’s history, the City’s policy was submitted and passed the review with flying colors. Having passed this review process is one more indication of the progress made in achieving fiscal sustainability in Montebello.

The policy (Attachment B) fully incorporates Government Code Section 53601 et al allowable investments. There are no changes to the policy for FY 2026-27.

ENVIRONMENTAL:

N/A
ANALYSIS:

N/A
SUMMARY:

The City Council is being asked to adopt Resolution No. 26-44 (Attachment A) approving the Investment Policy Statement of the City and Successor Agency (Attachment B). This approval continues the annual investment policy consideration so that it occurs regularly in June, in line with budget review and adoption.

ATTACHMENT(S)

1. ATTACHMENT A - Resolution No. 26-44 Investment Policy Update 06_10_2026

2. ATTACHMENT B - City Montebello FY 2026_27 Investment Policy ADOPTED

ATTACHMENT A
RESOLUTION NO. 26-44

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

MONTEBELLO ADOPTING AN INVESTMENT POLICY STATEMENT

FOR THE CITY AND SUCCESSOR AGENCY

RECITALS
WHEREAS, State Government Code Section 53646(a) sets guidelines for how local officials should submit an investment policy; and, WHEREAS, Government Code requires the investment policy to be considered, reviewed and approved annually at a public meeting; and, WHEREAS, the Investment Policy Statement of the City and Successor Agency was last reviewed and considered by the City Council on June 24, 2025; and

NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF MONTEBELLO HEREBY RESOLVES, FINDS, AND DECLARES AS FOLLOWS:

SECTION 1. Investments of City funds shall be made in accordance with the Investment Policy Statement attached hereto as Exhibit A and made part hereof.

SECTION 2. The policies adopted by this resolution are in addition to and supplement any other legal requirements.

SECTION 3. The City Treasurer and/or Director of Finance shall deliver a copy of the Investment Policy Statement to any and all financial institutions which hold City and/or Successor Agency funds and investments.

SECTION 4: That the City Clerk shall certify to the passage and adoption of this Resolution and that the same shall be in full force and effect.

APPROVED AND ADOPTED THIS 10TH DAY OF JUNE 2026.

_______________________________
Georgina Tamayo, Mayor

RESOLUTION NO. 26-44

ATTEST: APPROVED AS TO FORM:

________________________________ ________________________________ Christopher Jimenez, City Clerk Arnold M. Alvarez-Glasman, City Attorney

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS:

CITY OF MONTEBELLO )
I, Christopher Jimenez, City Clerk of the City of Montebello, County of Los Angeles, State of California, hereby certify that the foregoing Resolution No. 26-44 was passed and adopted by the City Council of the City of Montebello, signed by the Mayor and attested by the City Clerk at a regular meeting of said Council held on the 10th day of June, 2026 and that said Resolution was adopted by the following vote, to-wit:

AYES:

NOES:

ABSTAIN:

ABSENT:

The undersigned, City Clerk of the City of Montebello, does hereby attest and certify that the foregoing Resolution is a true, full and correct copy of a resolution duly adopted at a meeting of said City which was duly convened and held on the date stated thereon, and that said document has not been amended, modified, repealed or rescinded since its date of adoption and is in full force and effect as of the date hereof.

DATE:

Christopher Jimenez, City Clerk

City and Successor Agency
Montebello
Investment Policy
Fiscal Year 2026-27
Adopted by City Council
June 2026

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Investment Policy Statement
Adopted June 10, 2026
City/Successor Agency of Montebello
Investment Policy

TABLE OF CONTENTS
Introduction ...................................................................................................................2 Scope ............................................................................................................................2 Delegation of Authority ..................................................................................................2 Ethics and Conflicts of Interest .................................................................................... 2 Prudence/Prudent Investor Standard .......................................................................... 2 Internal Controls .......................................................................................................... 3 Investment Objectives ................................................................................................. 3 Performance Evaluation .............................................................................................. 3 Diversification .............................................................................................................. 3 Portfolio Segregation ................................................................................................... 4 Bond Issuance Arbitrage Rebate ..................................................................................4 Qualified Dealers ......................................................................................................... 4 Safekeeping of Securities .............................................................................................4 Collateralization ........................................................................................................... 5 Maximum Maturities .....................................................................................................5 Investment Pools/Money Market Mutual Funds .......................................................... 5 Authorized and Suitable Investments ...........................................................................6 Ineligible Investments ...................................................................................................9 Portfolio Reporting ........................................................................................................9 Review of Investment Portfolio .................................................................................. 10 Investment Policy Adoption ........................................................................................10 Glossary ...................................................................................................................11

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Investment Policy Statement
Adopted June 10, 2026

1. INTRODUCTION
This Statement of Investment Policy (“Investment Policy” or “Policy”) is intended to provide specific criteria for the prudent investment of City and Successor Agency funds. The ultimate investment goal is to enhance the economic status of the City while protecting funds under management and meeting the daily cash flow demands of the City and Successor Agency. This investment policy has been prepared in conformance with all pertinent existing laws of the State of California including California Government Code Sections 53600, et seq. (NOTE: throughout this Policy, it is understood that any reference to “City” is inclusive of the “Successor Agency.”)

2. SCOPE
This investment policy applies to all of the City's idle cash invested in various vehicles and encompasses all monies under the direct oversight of the City Treasurer and Director of Finance and include the General Fund, Reserve Funds, Special Revenue Funds, Debt Service Funds, Capital Project Funds, Permanent Fund, Proprietary Funds, Trust and Agency Funds, including the Successor Agency to the Dissolved Montebello Redevelopment Agency, and any other funds that may be created.

These funds are accounted for in the City of Montebello’s Comprehensive Annual Financial Report (CAFR).

3. DELEGATION OF AUTHORITY
Authority to manage the City of Montebello’s investment program is derived from California Government Code Section 53601 et al. The authority of the City Council to invest or reinvest monies of the City has been delegated by the City Council to the City Treasurer and Director of Finance until such time the delegation is revoked. No person may engage in an investment transaction except as provided under the terms of this policy and the procedures established by the Director of Finance.

4. ETHICS AND CONFLICTS OF INTEREST
Officers and employees involved in the investment process shall refrain from personal business activity that conflicts with proper execution of the investment program or that impairs their ability to make impartial investment decisions. Employees and investment officials shall disclose any material financial interests that could be related to the performance of the City's investment policy annually with the California Fair Political Practices Commission or as necessary under the Political Reform Act and Government Code Section 1090 et seq.

5. PRUDENCE/PRUDENT INVESTOR STANDARD
The City's pooled investment program operates under the Prudent Investor Standard, Government Code Section 53600.3, and applicable State laws. When investing, reinvesting, purchasing, acquiring, exchanging, selling, and managing public funds, responsible/delegated officials shall act with care, skill, prudence, and diligence under the circumstances then prevailing, including, but not limited to, the general economic conditions and the anticipated needs of the City, that a prudent person acting in a like capacity and familiarity with those matters would use in the conduct of funds of a like character and with like aims, to safeguard the principal and maintain the liquidity needs of the City.

Within the limitations of this section and considering individual investments as part of an overall strategy, investments may be acquired and sold as authorized by law. This affords a broad spectrum of investment opportunities so long as the investment is deemed prudent and permissible by the State of California, various bond indentures and this policy. It is the goal of officials so authorized under this Policy to strive to invest 100 percent of idle funds.

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Investment Policy Statement
Adopted June 10, 2026

6. INTERNAL CONTROLS
The Director of Finance and/or his/her designee shall establish procedures that separate the internal responsibility for management and accounting of the investment portfolios. An analysis by an external independent auditor shall be conducted annually to review internal controls, account activity and compliance with policies and procedures.

7. INVESTMENT OBJECTIVES
The City's cash management system is designed to accurately monitor and forecast revenues and expenditures, thus enabling funds to be invested to the fullest extent possible. A diversified portfolio is maintained to accomplish the primary objectives in the order of safety, liquidity, and yield.

Safety: The safety/risk associated with an investment refers to the potential loss of principal, accrued interest or a combination of these. Credit risk is mitigated by monitoring financial institutions with which he/she will do business, and by careful scrutiny of the credit worthiness of the investment instruments as well as the institutions. Such resources as nationally recognized statistical-rating organization (NRSRO) services are utilized for this review. Mitigation of interest rate risk is sought through diversification of instruments as well as maturities.

Liquidity: The portfolio will be structured with sufficient liquidity to allow the City to meet anticipated cash requirements. This will be accomplished through the purchase of a diversity of instruments to include those with active secondary markets, those that can match maturities to expected cash needs, and the State Local Agency Investment Fund (LAIF) with immediate withdrawal provisions.

Yield: A competitive market rate of return is the third objective of the investment program after the fundamental requirements of safety and liquidity have been met. The portfolio shall be managed to consistently attain a market rate of return throughout budgetary and economic cycles. Whenever possible, and consistent with risk limitations and prudent investment management, the City will seek to augment returns above the market average rate of return through the implementation of active portfolio management strategies.

8. PERFORMANCE EVALUATION
Investment performance is continually monitored and evaluated by the City. Investment portfolio reports are generated on a monthly and quarterly basis and submitted to the City Council, City Manager, and Investment Committee. A quarterly Treasurer’s report is also presented to the City Council and Investment Committee.

9. DIVERSIFICATION
The City will diversify use of investment instruments to avoid unreasonable risks inherent in over-investing in specific instruments, individual financial institutions, or maturities.

Market price volatility shall be controlled through maturity diversification, as well as ensuring adequate liquidity is available to meet cash flow requirements, thereby precluding the need to sell instruments at a market loss.

Risk of default will be controlled by acquiring instruments such as Government Securities, or by diversifying the portfolio within the constraints and parameters of Section 17 of this Policy, Authorized and Suitable Investments.

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Investment Policy Statement
Adopted June 10, 2026

10. PORTFOLIO SEGREGATION
Within the overall funds managed, bond proceeds held by fiscal agents or trustees shall also be segregated and invested in accordance with each indenture.

The primary purpose of any separately managed bond proceeds is to structure investment maturities to meet current and future liabilities. The preservation of principal and the maintenance of liquidity are the most important factors regarding the investment of bond proceeds. Portfolio yield is not a primary factor since the portfolio structure, eligible investment assets and maturity restrictions are governed by draws and expenditure schedules of the issues. Performance will be based upon maximizing permitted positive arbitrage within the context of principal preservation as a first priority (pre-1986 Tax Reform Act issuances) or minimizing or eliminating negative arbitrage (yield-restricted issues).

11. BOND ISSUANCE ARBITRAGE REBATE
The U.S. Tax Reform Act of 1986 requires the City to perform annual arbitrage calculations and rebate excess earnings to the U.S. Treasury for investment returns that exceed the allowable interest earnings limit of each bond issue. The arbitrage calculation process must be conducted for the investment of proceeds of bond issues sold after the effective date of this law. This arbitrage calculation will be contracted out to provide the necessary technical expertise to comply with this regulation. The City's investment position relative to the interest rate arbitrage restrictions is to have safety and the highest permitted return the law allows as the highest priority while ensuring the preservation of principal and liquidity.

12. QUALIFIED DEALERS
The City shall transact business only with Registered Investment Advisors, national or state-chartered banks, savings and loans, and broker dealers. The dealers should be primary dealers regularly reporting to the New York Federal Reserve Bank, or approved regional or secondary market dealers that qualify under the Securities and Exchange Commission Rule 15C3-1 (uniform net capital rule).

Authorized officials of the City may direct a fiscal agent or trustee to execute investment transactions on behalf of the City for funds held by that fiscal agent or trustee.

The City will monitor broker/dealers and their firms to ensure they are in good standing with the appropriate regulatory agencies.

13. SAFEKEEPING OF SECURITIES
To protect against losses caused by the collapse of individual securities dealers, all securities owned by the City, including collateral for repurchase agreements, shall be held in safekeeping by a third party bank trust department acting as agent for the City under the terms of a custody agreement or, in the case of funds held by the fiscal agent or trustee, the fiscal agent or trustee shall segregate and report securities held on the City's behalf. Any trade executed by a dealer is required to settle on a delivery versus payment basis with the City's safekeeping agent.

Fiscal agents or trustees in receipt of City of Montebello bond proceeds will settle security transactions on a delivery versus payment method based upon instructions provided by the authorized City official or the City's investment advisor. The fiscal agents or trustees will issue monthly custodian statements evidencing securities held in safekeeping, including the receipt of interest and maturity proceeds, the disbursement of funds for the purchase of securities, and the receipt of any sale proceeds.

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Investment Policy Statement
Adopted June 10, 2026

14. COLLATERALIZATION
All demand deposits, time deposits and repurchase agreements are to be fully collateralized with securities authorized by the California Government Code and the City. • The cost value (book value) of collateral pledged for demand deposits must at all times be equal to or greater than the amount on deposit, plus accrued interest, in accordance with the following ratio:
o U.S. Treasury Securities: 110%
• The cost value (book value) of collateral pledged for repurchase agreements must at all times be equal to or greater than the par amount, plus accrued interest, with the following ratios:
o U.S. Treasury Securities: 102%
o U.S. Government Agencies: 102%
• It is the policy of the City to require reports at least on a quarterly basis from institutions with which the City has pledged security interest. The adequacy of collateralization shall be monitored to ensure that balances are collateralized in accordance with the ratios approved herein.
• With regard to repurchase agreements, it is the policy of the City to initiate a margin call in the event pledged collateral falls below the appropriate ratio. • Collateralized investments and deposits often require substitution of collateral. Any broker or financial institution requesting substitution must contact the City for approval in the event the counterparty to the transaction is not authorized under agreement with the City to make substitutions.

15. MAXIMUM MATURITIES
In accordance to California Government Code Section 53601, The City will not invest in any securities maturing more than five (5) years from the settlement date of purchase. If there is a desire to make investments longer than five years, express authority to make those investments, either specifically or as part of an investment program, must be approved by the City Council no less than three months prior to the investment.

16. INVESTMENT POOLS/MONEY MARKET MUTUAL FUNDS
A thorough investigation of any government sponsored pool and/or mutual fund is required prior to investing and on a continual basis. There shall be a questionnaire completed which will provide the following information:
• A description of eligible investment securities, and a written statement of investment policy and objectives.
• A description of interest calculations and how it is distributed, and how gains and losses are treated.
• A description of how the securities are safeguarded (including the settlement processes), and how often the securities are priced and the program audited. • A description of who may invest in the program, how often and what size of deposits and withdrawals are allowed.
• A schedule for receiving statements and portfolio listings.

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Investment Policy Statement
Adopted June 10, 2026
• A description of how the pool/fund utilizes reserves, retained earnings, etc. • A fee schedule, including when and how fees are assessed. • The eligibility of the pool/fund to invest in bond proceeds and special district funds, and a description of its practices.

17. AUTHORIZED AND SUITABLE INVESTMENTS
The City is governed by the California Government Code, Sections 53600 et seq. Within the context of these limitations and based on the cost at the time of purchase, the following investments are authorized:

INVESTMENT TYPE MAXIMUM

MATURITY

MAXIMUM
SPECIFIED %

OF PORTFOLIO

MINIMUM QUALITY

REQUIREMENTS

GOVERNMENT
CODE

SCTIONS
U.S. Treasury
Obligations 5 years None None 53601(b)
U.S Agency
Obligations 5 years None None 53601(f)
State Obligations— CA
And Others 5 years None None 53601(d)
CA Local Agency
Obligations 5 years None None 53601(e)
Local Agency Bonds 5 years None None 53601(a)
Bankers’ Acceptances 180 days 40% None 53601(g)
Commercial Paper—
Non-Pooled Funds
(under $100 million of
investments)
270 days or less
25% of the
Agency's
Money
Highest letter and
number rating by an
NRSROH
53601(h)(2)(C)
Commercial Paper—
Non-Pooled Funds
(minimum $100 million
of investments)
270 days or less
40% of the
Agency's
Money
Highest letter and
number rating by an
NRSROH
53601(h)(2)(C)
Commercial Paper—
Pooled Funds 270 days or less
40% of the
Agency's
Money
Highest letter and
number rating by an
NRSROH
53635(a)(1)
Negotiable Certificates
of Deposit 5 years 30% None 53601(i)
Non-negotiable
Certificates of Deposit 5 years None None 53630 et seq.

Placement Service
Deposits 5 years 50% None 53601.8 and 53635.8
Placement Service
Certificates of Deposit 5 years 50% None 53601.8 and 53635.8 Repurchase
Agreements 1 year None None 53601(j)
Reverse Repurchase
Agreements and
Securities Lending
Agreements
92 days
20% of the base
value of the
portfolio
None 53601(j)
Medium-Term Notes 5 years or less 30% “A” rating category or its equivalent or better 53601(k)

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Investment Policy Statement
Adopted June 10, 2026
Mutual Funds And
Money Market Mutual
Funds
N/A 20% Multiple 53601(l) and
53601.6(b)
Collateralized Bank
Deposits 5 years None None 53630 et seq.
and 53601(n)
Mortgage
Pass–Through and
Asset–Backed
Securities
5 years or less 20% “AA” rating category or its
equivalent or better 53601(o)
County Pooled
Investment Funds N/A None None 27133
Joint Powers Authority
Pool N/A None Multiple 53601(p)
Local Agency
Investment Fund
(LAIF)
N/A None None 16429.1
Voluntary Investment
Program Fund N/A None None 16340
Supranational
Obligations 5 years or less 30% “AA” rating category or its equivalent or better 53601(q) Public Bank
Obligations 5 years None None
53601(r),
43635(c ) and
57603
A. United States Treasury Obligations: Bills, Bonds, and Notes, or those for which the full faith and credit of the United States are pledged for payment of principal and interest. There is no limitation as to the percentage of the portfolio that can be invested in this category.

B. United States Agency Obligations: Issued by United States Federal agencies or government-sponsored enterprise obligations, or other instruments, including those issued by or fully guaranteed as to principal and interest by Federal agencies or United States government-sponsored enterprises. Although there is no percentage limitation on these issues, the "prudent investor" standard shall apply to investments from a single agency.

C. State Obligations (California/Other States) and California Local Agency Obligations:

Registered state warrants or treasury notes or bonds of the State of California or any of the other 49 states and bonds, notes, warrants or other evidences of indebtedness of any local agency within California, including bonds payable solely out of the revenues from a revenue producing property owned, controlled or operated by the state or local agency or by a department, board, agency or authority of the state or local agency.

D. Local Agency Bonds: Includes bonds payable solely out of the revenues from a revenue-producing property owned, controlled, or operated by the local agency or by a department, board, agency, or authority of the local agency.

E. Bankers’ Acceptances: If purchased may not exceed 180 days to maturity or 40 percent of the cost (book) value of the portfolio. No more than 5 percent of the cost (book) of the portfolio may be invested in Bankers’ Acceptances issued by any one bank. Prior to the purchase of any Banker’s Acceptance, the portfolio manager shall review the rating of the issuing bank. Bankers’ Acceptances of issuing financial institutions shall have both a short and long term rating in the highest category by at least one nationally recognized rating agency at the time of purchase.

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Investment Policy Statement
Adopted June 10, 2026
F. Commercial paper (Pooled and Non-Pooled Funds): Ranked of "prime" quality of the highest ranking or of the highest letter and number rating as provided for by NRSRO and issued by a domestic corporation having assets in excess of $500 million. The commercial paper must also have an “A” or better rating for the issuer’s debt, other than commercial paper, if any, as provided by a NRSRO. Purchase of commercial paper from corporations on negative credit watch by a major rating agency shall be prohibited. Purchases of eligible commercial paper may not exceed 270 days to maturity. Local agencies with less than one hundred million dollars ($100,000,000) of investments under management may invest no more than 25% in eligible commercial paper. Whereas, agencies having one hundred million dollars ($100,000,000) or more may invest no more than 40% in eligible commercial paper.

G. Negotiable and Non-Negotiable Certificates of Deposit (including Placement Service Deposits/Certificates of Deposit): Negotiable Certificates of Deposit are limited to 30% of the City’s monies which may be invested, with no maximum limit for Non-Negotiable Certificates of Deposit. Placement Service Deposits/Certifications of Deposit have a limit of 50% of the portfolio.

H. Repurchase agreements: The City may invest in repurchase agreements with banks and primary dealers with whom the City has entered into a master repurchase agreement that specifies terms and conditions of repurchase agreements. The maturity of repurchase agreements shall not exceed 365 days. In order to conform with provisions of the Federal Bankruptcy Code which provides for the liquidation of securities held as collateral for repurchase agreements, the only securities acceptable as collateral shall be securities that are direct obligations of, or that are fully guaranteed as to principal and interest by, the United States Government such as Treasury bills, Treasury notes or Treasury bonds with less than a five year maturity.

I. Reverse repurchase agreements/Securities Lending Agreements: The City may invest in reverse repurchase agreements only with those banks and primary dealers with whom the City has entered into a master repurchase agreement outlining terms and conditions of repurchase and reverse repurchase agreements.

J. Corporate medium term notes: Issued by a domestic corporation having an “A” or better rating criteria at time of purchase on its long-term debentures as provided by a NRSRO. The aggregate total of all purchased medium term notes may not exceed 30 percent of the cost value of the portfolio. No more than 5 percent of the cost value of the portfolio may be invested in corporate medium term notes issued by any one corporation. Commercial paper and bankers’ acceptance holdings shall be considered when calculating the maximum percentage in any issuer name.

K. Mutual Funds/Money market mutual funds: Having a rating of “AAA” or an equivalent by no less than two NRSRO with no load and maintained at $1 par value. No more than 20 percent of the cost value of portfolio value at time of purchase should be invested in this category, and the City's investment in any specific mutual fund will not exceed 10 percent of that mutual fund's total assets.

L. Mortgage Pass-through and Asset Backed Securities: A mortgage pass-through security, collateralized mortgage obligation, mortgage-backed or other pay-through bond, equipment lease-backed certificate, consumer receivable pass-through certificate, or consumer receivable-backed bond. Securities eligible for investment under this subdivision shall be rated in a rating category of “AA” or its equivalent or better by an NRSRO and have a maximum

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Investment Policy Statement
Adopted June 10, 2026
remaining maturity of five years or less. Purchase of securities authorized by this subdivision shall not exceed 20 percent of the agency’s surplus moneys that may be invested pursuant to this section.

M. County Pooled and/or Joint Powers Authority Investment Funds: The city may invest in a joint powers authority organized pool that invests in the securities and obligations authorized in 53601(a) to (q) inclusive. There is no limitation as to the percentage of monies that can be invested in either a County or Joint Powers Authority pool N. Local Agency Investment Fund: The City may invest in the LAIF established by the State Treasurer for the benefit of local agencies up to the maximum permitted by State law.

O. Voluntary Investment Program: This fund is created within the State Treasury for the receipt of voluntary deposits. The minimum deposit into this fund is $200,000,000 (two hundred million dollars).

P. Supranational Obligations: Securities of United States dollar denominated senior unsecured unsubordinated obligations issued or unconditionally guaranteed by the International Bank for Reconstruction and Development, International Finance Corporation, or Inter-American Development Bank, with a maximum remaining maturity of five years or less, and eligible for purchase and sale within the United States. Investments under this subdivision shall be rated “AA” or better by an NRSRO and shall not exceed 30 percent of the agency’s moneys that may be invested pursuant to this section.

Q. Public Bank Obligations. Notwithstanding Section 53601, any local agency that does not pool money in deposits or investments with other local agencies that have separate governing bodies may invest in debt securities or other obligations of a public bank. Notwithstanding Section 53635, any local agency that pools money in deposits or investments with other local agencies, including local agencies that have the same governing body, may invest in debt securities or other obligations of a local public bank. This investment option sunsets on January 1, 2026.

18. INELIGIBLE INVESTMENTS
Investments not described herein including, but not limited to, equity securities such as common stocks, preferred stocks, convertibles, inverse floaters, range notes and interest-only strips that are derived from a pool of mortgages are prohibited from use in this portfolio. The City is prohibited from entering into a margin agreement and/or borrowing on margin.

19. PORTFOLIO REPORTING
In accordance with California Government Code, Sections 53607 and 53646(b), the Director of Finance shall provide on a monthly and quarterly basis an investment portfolio report to the City Council. The quarterly report shall be presented to the City Council no later than sixty (60) days from the end of the prior quarter.

The report shall include a listing of each of the City's investments (a description that adequately describes the security), the purchase date, maturity date, cost basis, current cost value (book value), interest rate, weighted average maturity, current unrealized loss or gain and a listing of investment transactions that includes purchase/deposit and sale/withdrawal activity. Various investment types will be categorized and grouped in the same structure as the qualified investment categories identified in

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Investment Policy Statement
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this policy. The portfolio report shall include a statement certifying the ability of the City to meet its expenditure requirements for the next six months or provide an explanation as to why sufficient money shall, or may, not be available.

The investment portfolio report shall include market value information for all investments. A monthly market value will be obtained for each security owned by the City. For purposes of reporting, the market value of each security may be obtained from the City’s custodian bank or other pricing source(s) utilized by the City’s designated investment management firm (registered investment advisor).

The City shall record interest revenue on a modified accrual basis of accounting that is typical for reporting and recording of interest earnings. Securities held by a fiscal agent or trustee shall also be recorded on a modified accrual basis of accounting. The Director of Finance will report year-end investments in conformance with Governmental Accounting Standards Board (GASB) Statement Nos. 31, 40, and 72 and all current and relevant GASB pronouncements in effect.

20. REVIEW OF INVESTMENT PORTFOLIO
The securities held by the City must be in compliance with Section 17, Authorized and Suitable Investments, at the time of purchase. A quarterly review of investments will be done to identify any securities that are no longer in compliance.

21. INVESTMENT POLICY ADOPTION
The City Council shall review and adopt this Investment Policy by resolution annually.

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Investment Policy Statement
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GLOSSARY
AGENCIES – Agencies of the Federal government set up to supply credit to various classes of institutions (e.g., S&L's, small business firms, students, farmers, housing agencies, etc.) Examples include Federal Home Loan Mortgage Corporation (FHLMC), Federal National Mortgage Association (FNMA), Federal Home Loan Bank (FHLB), and Federal Farm Credit Bank (FFCB).

ASSET BACKED SECURITIES - Securities supported by pools of installment loans or leases or by pools of revolving lines of credit.

ASK/OFFER – The price at which securities are offered. (The price at which a firm will sell a security to an investor)
BANKERS’ ACCEPTANCE (BA) – A draft or bill of exchange accepted by a bank or trust company.

The accepting institution guarantees payment of the bill as well as the issuer.

BASIS POINT – One one-hundredth of a percent (i.e., 0.01 percent) BEAR MARKET – A period of generally pessimistic attitudes and declining market prices.

BID PRICE – The price at which a broker/dealer will buy securities from an investor.

BOND EQUIVALENT YIELD – The basis on which yields on notes and bonds are quoted.

BOOK VALUE (COST VALUE) – The purchase price of the security as recorded on the City’s books.

BROKER – An individual or firm acting as intermediary by purchasing and selling securities for others.

BULL MARKET – A period of generally optimistic attitudes and increasing market prices.

CALLABLES – Securities that the issuer has the right to redeem prior to maturity.

CERTIFICATE OF DEPOSIT (CD) - A time deposit with a specific maturity evidenced by a certificate.

Large denomination CD's are typically negotiable.

CMT – Constant Maturity Treasury – An index of the average yield on United States Treasury securities adjusted to a constant maturity.

COLLATERAL – Securities, evidence of deposit or other property which a borrower pledges to secure repayment of a loan. Also refers to securities pledged by a bank to secure deposits of public monies.

COMPREHENSIVE ANNUAL FINANCIAL REPORT (CAFR) - The official annual financial report of the City. It includes combined statements for each individual fund and account group prepared in conformity with Generally Accepted Accounting Principles (GAAP). It also includes supporting schedules necessary to demonstrate compliance with finance-related legal and contractual provisions, extensive introductory material, and a detailed Statistical Section.

CORPORATE MEDIUM TERM NOTE – A security issued by a corporation doing business in the U.S. with a maturity not to exceed five years.

COST VALUE (BOOK VALUE) – The purchase price of the security as recorded on the City’s books.

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COUPON – a) The annual rate of interest that a bond's issuer promises to pay the bondholder on the bond's face value; b) a certificate attached to a bond evidencing interest due on a payment date.

DEALER – An individual or firm acting as principal in a security transaction.

DEBENTURE - A bond secured only by the general credit of the issuer.

DELIVERY VS PAYMENT - Delivery of securities with a simultaneous exchange of money.

DEMAND ACCOUNT – An account with a commercial bank from which check withdrawals may be made at any time.

DERIVATIVES – Financial products that are dependent for their value on (or derived from) an underlying financial instrument, a commodity, or an index representing values of groups of such instruments or assets.

DISCOUNT – The difference between the cost price of a security and its par value when the cost is lower than par. A security selling below original offering price shortly after sale also is considered to be at a discount.

DIVERSIFICATION – Dividing investment funds among a variety of securities offering independent returns.

FEDERAL FUNDS RATE – Interest rate charged by one institution lending federal funds to another.

FEDERAL OPEN MARKET COMMITTEE (FOMC) – Consists of seven members of the Federal Reserve Board and five of the twelve Federal Reserve Bank Presidents. The President of the New York Federal Reserve Bank is a permanent member, while the other presidents serve on a rotating basis.

The Committee periodically meets to set Federal Reserve guidelines regarding purchases and sales of Government Securities in the open market as a means of influencing the volume of bank credit and money.

FINANCIAL ADVISOR – A firm or bank that acts in a financial advisory capacity with respect to a new issue of municipal securities pursuant to a written contract.

FISCAL AGENT – A financial institution which performs payment of principal and interest to bondholders, and certain administrative duties on the bond issuer’s behalf.

GOVERNMENTAL ACCOUNTING STANDARDS BOARD – The independent organization that establishes and improves standards of accounting and financial reporting for U.S. state and local governments.

INTERNAL RATE OF RETURN – Rate of return over the life of a security on variables.

LOCAL AGENCY INVESTMENT FUND (LAIF) – The aggregate of all funds from political subdivisions that are placed in the custody of the State Treasurer for investment and reinvestment.

MARKET VALUE – The price at which a security is trading, usually the liquidation value.

MASTER REPURCHASE AGREEEMENT – A written contract covering all future transactions between the parties to repurchase-reverse repurchase agreements that establishes each party’s rights in the

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transactions. A master agreement will often specify, among other things, the right of the buyer-lender to liquidate the underlying securities in the event of default by the seller borrower.

MONEY MARKET MUTUAL FUNDS – Open-ended mutual fund that invests in commercial paper, banker’s acceptances, repurchase agreements, government securities, certificates of deposit and other highly liquid and safe securities, and pays money market rates of interest. The fund’s net asset value remains a constant $1 a share, with the interest rate increasing or decreasing.

MORTGAGE PASS-THROUGH SECURITIES – A securitized participation in the interest and principal cash flows from a specified pool of mortgages. Principal and interest payments made on the mortgages are passed through to the holder of the security.

NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION (NRSRO) – A rating organization designated by the SEC as being nationally recognized.

OFFER PRICE – The price at which a broker/dealer will offer securities to an investor.

OPEN MARKET OPERATIONS – Federal Reserve activity. Under the Federal Reserve Act, the Fed uses purchases and sales of Government and Federal Agency securities to add to or subtract from commercial bank reserves. Goals are to sustain economic growth, high employment and reasonable price stability.

PAPER GAIN OR LOSS – Term used for unrealized gain or loss on securities being held in a portfolio based on comparison of current market quotes and their original cost. This situation exists as long as the security is held while there is a difference between cost value (book value) and the market value.

PORTFOLIO – Collection of securities held by an investor.

PREMIUM – The difference between the cost price of a security and its par value, when the cost is higher than par.

PRIMARY DEALER – A group of government securities dealers that serve as trading counterparties of the New York Fed in its implementation of monetary policy. This role includes the obligations to: (i) participate consistently in open market operations to carry out U.S. monetary policy pursuant to the direction of the Federal Open Market Committee (FOMC); and (ii) provide the New York Fed's trading desk with market information and analysis helpful in the formulation and implementation of monetary policy. Primary dealers are also required to participate in all auctions of U.S. government debt and to make reasonable markets for the New York Fed when it transacts on behalf of its foreign official accountholders.

RATE OF RETURN – The yield obtainable on a security based on its purchase price or its current market price. This may be the amortized yield to maturity; on a bond, the current income return.

REPURCHASE AGREEMENT (REPO) – A holder of securities sells these securities to an investor with an agreement to repurchase them at a fixed price on a fixed date. The security “buyer” in effect lends the “seller” money for the period of the agreement, and the terms of the agreement are structured to compensate them for this.

REVERSE REPURCHASE AGREEMENT (REVERSE REPO) – A reverse-repurchase agreement (reverse repo) involves an investor borrowing cash from a financial institution in exchange for securities. The investor agrees to repurchase the securities at a specific date for the same cash value plus an agreed upon interest rate. Although the transaction is similar to repo, the purpose of entering

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Investment Policy Statement
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into a reverse repo is quite different. While a repo is a straightforward investment of public funds, the reverse repo is a borrowing.

SAFEKEEPING – The service provided by banks and trust companies for clients when the bank or trust company stores the securities, takes in coupon payments, and redeems issues at maturity.

SECURITIES & EXCHANGE COMMISSION (SEC) - Agency created by Congress to protect investors in securities transactions by administering securities legislation.

SEC RULE 15(C) 3-1 – See Uniform Net Capital Rule.

SPREAD – a) The yield or price difference between the bid and offer on an issue; b) the yield or price difference between different issues.

SUPRANATIONALS – International institutions formed by two or more governments that transcend boundaries to pursue mutually beneficial economic or social goals. There are three supranational institutions that issue obligations that are eligible investments for California local agencies: the International Bank for Reconstruction and Development (IBRD), International Finance Corporation (IFC), and Inter-American Development Bank (IADB).

SWAP – The sale of one issue and the simultaneous purchase of another for some perceived advantage.

TREASURY BILLS – A non-interest bearing discount security issued by the U.S. Treasury to finance the national debt. Most bills are issued to mature in three months, six months or one year.

TREASURY BONDS – U.S. Treasury securities that have initial maturities of more than 10 years.

TREASURY NOTES – Intermediate-term coupon bearing U.S. Treasury securities having initial maturities from one year to ten years.

TRUSTEE – A financial institution with trust powers that acts in a fiduciary capacity for the benefit of the bondholders in enforcing the terms of the bond contract.

UNIFORM NET CAPITAL RULE – Securities and Exchange Commission requirement that member firms as well as nonmember broker-dealers in securities maintain a maximum ratio of indebtedness to liquid capital of 15 to 1; also called net capital rule and net capital ratio. Indebtedness covers all money owed to a firm, including margin loans and commitments to purchase securities. Liquid capital includes cash and assets easily converted into cash.

WHEN ISSUED BASIS (WI) – A term applied to securities that are traded before they are actually issued with the stipulation that transactions are null and void if securities are not issued.

YIELD CURVE – Yield calculations of various maturities at a given time to observe spread difference.

YIELD TO MATURITY – The current coupon yield minus any premium above par, or plus any discount from par in the purchase price with the adjustment spread over the period from date of purchase to maturity.

DRAFT

CITY OF MONTEBELLO

REGULAR MEETING

MINUTES
WEDNESDAY, MAY 27, 2026 AT 6:00 PM

CITY HALL COUNCIL CHAMBERS
1600 WEST BEVERLY BOULEVARD

MONTEBELLO, CALIFORNIA

OPENING CEREMONIES
CALL TO ORDER - 6:00 P.M.

Mayor Tamayo called the meeting to order at 6:01 p.m.

ROLL CALL
Members present were Mayor Tamayo, Mayor Pro Tem Romero, Councilmember Peralta, and Councilmember Melendez.

City Treasurer Matanga was also present.

Councilmember Alonzo arrived during Closed Session.

City Clerk Jimenez was absent.

City Attorney Arnold Alvarez-Glasman, City Manager Raul Alvarez, Assistant City Manager Angelica Palmeros, Management Analyst Samantha Nevarez, and Department Directors Kimberly Guillen, Michael Solorza, Joseph Palombi, Ramon Figueroa, John Soria, David Sosnowski, Cesar Roldan, Fire Chief Pelaez, and Police Chief Lopez were present.

ANNOUNCEMENT OF CLOSED SESSION ITEMS
City Attorney Alvarez-Glasman announced the Closed Session Items.

PUBLIC COMMENTS ON CLOSED SESSION ITEMS
At this time, the public may submit a speaker card to the City Clerk staff for Closed Session items, prior to the beginning of this statement. Speakers will be called in the order received. Please be aware that the maximum time allotted for members of the public to speak on Closed Session items shall not exceed three (3) minutes per person. State Law prohibits the City Council from taking action or entertaining extended discussion on a topic not listed on the agenda. Please show courtesy to others and direct all of your comments to the Mayor and City Council.

None.

CLOSED SESSION
The City Attorney shall provide a briefing on the item listed for Closed Session as follows:

Mayor Tamayo recessed the meeting into Closed Session at 6:02 p.m. to consider the following Closed Session items:

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May 27, 2026: City Council Meeting Minutes Page 2 of 10

1. CONFERENCE WITH LEGAL COUNSEL – EXISTING LITIGATION
Government Code Section 54956.9(d)(1)
Jesus Macias v. City of Montebello
Los Angeles Superior Court Case No: 25STCV37986

2. CONFERENCE WITH LEGAL COUNSEL – EXISTING LITIGATION
Government Code Section 54956.9(d)(1)
Hermes Carbajal vs. City of Montebello
Los Angeles Superior Court Case No. 26STCV02126

3. CONFERENCE WITH LABOR NEGOTIATORS
Government Code Section 54957.6
Agency Negotiators: Raul Alvarez
Employee Group: Montebello Police Management Association

4. CONFERENCE WITH LEGAL COUNSEL – ANTICIPATED LITIGATION Government Code Section 59456.9(d)(4)
Consideration of initiation of litigation in one matter REGULAR SESSION - 7:00 P.M.

CLOSED SESSION REPORT
Mayor Tamayo reconvened the meeting at 7:10 p.m.

All five members were present to discuss all Closed Session items. City Attorney Arnold Alvarez-Glasman provided the following report to City Council: Item No. 3, a briefing was provided to City Council, no action was taken, and nothing further to report. City Council will reconvene in Closed Session following the Regular Session to discuss Item Nos. 1, 2, and 4.

INVOCATION
Led by City Treasurer Matanga.

PLEDGE OF ALLEGIANCE
Led by the Future Leader of Montebello, Miguel Moreno Venegas.

CORRECTIONS TO THE AGENDA - CITY MANAGER
None.

CEREMONIAL ITEMS/PRESENTATIONS

5. CITIZEN OF THE MONTH — LORRAINE RICHARDS
Presented by Mayor Tamayo.

6. CERTIFICATES OF RECOGNITION FOR MONTEBELLO BUS LINES EMPLOYEES PARTICIPATING IN THE 5-STAR, REGIONAL, AND INTERNATIONAL ROADEOS
Presented by Mayor Tamayo.

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May 27, 2026: City Council Meeting Minutes Page 3 of 10

7. EASTSIDE LIGHT RAIL EXTENSION PRESENTATION
Jill Liu, Countywide Planning Manager, and Lorena Sanchez, Community Relations Manager, presented the item.

8. PROPOSED FY 2026-27 BUDGET OVERVIEW
Director of Finance, Michael Solorza, presented the item.

9. CAPITAL PROJECTS FY 2026-27 PRESENTATION
Public Works Manager Vanessa Ramos presented the item.

PUBLIC COMMENTS ON NON-AGENDA ITEMS (30 MINUTES)
At this time, the public may submit speaker card(s) to the City Clerk staff, for both agenda and non-agenda items, prior to the beginning of this statement; Public Hearing items do not require a speaker card.

The City Council will address non-agenda items during this section and speakers will be called in the order received. Those persons not accommodated during this 30-minute period will have an opportunity to speak under “Public Comments – Continued”, after all scheduled matters have been considered. Public Hearing, Regular Business and/or Consent Calendar items will be addressed at the time that matter of business is heard, in the order received.

Please be aware that the maximum time allotted for members of the public to speak shall not exceed three (3) minutes per speaker. State Law prohibits the City Council from taking action or entertaining extended discussion on a topic not listed on the agenda. Please show courtesy to others and direct all of your comments to the Mayor and City Council.

The City Clerk’s Office acknowledged eleven(11) members of the public wishing to address the City Council. Speakers were provided three minutes to address the City Council and said speaker cards are on file at the City Clerk’s office.

STAFF COMMUNICATIONS ON ITEMS OF COMMUNITY INTEREST
City Manager Alvarez announced the upcoming Food Distribution event with Supervisor Hilda L. Solis, scheduled for Friday, May 29, 2026.

He also announced the upcoming Bluff Road Fence Ribbon Cutting Ceremony, scheduled for Saturday, May 30, 2026.

PUBLIC HEARING

10. PUBLIC HEARING - RESIDENTIAL SOLID WASTE COLLECTION AND RECYCLING CHARGES ANNUAL

RATE ADJUSTMENT
RECOMMENDATION: It is recommended that the City Council:

1. Conduct a Public Hearing and approve Resolution No. 26-36 establishing the residential solid waste collection and recycling rate for Fiscal Year 2026-27 (Attachment A) per Agreement No. 4279 between the City of Montebello and Arakelian Enterprises (dba Athens Services); and,

2. Direct staff to forward the Resolution to the Los Angeles County Auditor-Controller to place the revised charges on the property tax rolls; and,

3. Take such additional, related action that may be desirable.

Mayor Tamayo opened the Public Hearing at 9:18 p.m.

The City Clerk’s Office acknowledged two(2) members of the public wishing to address the City Council. Speakers were provided three minutes to address the City Council, and said speaker cards are on file at the City Clerk’s office. Both speakers asked clarifying questions.

Mayor Tamayo closed the Public Hearing at 9:21 p.m.

Mayor Pro Tem Romero motioned, seconded by Councilmember Peralta, to approve the item; the motion was approved unanimously.

REGULAR BUSINESS

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11. APPROVE AMENDMENT NO. 1 TO AGREEMENT NO. 4454 WITH INSIGHT STRATEGIES INC., FOR ORGANIZATIONAL HEALTH AND HIGH-PERFORMANCE ASSESSMENT SERVICES – PHASE II RECOMMENDATION: It is recommended that the City Council:

1. Approve Amendment No. 1 to Agreement No. 4454 with Insight Strategies, Inc. for a one-year (1-year) term, and increase the total not-to-exceed amount for an additional $49,800, to implement Phase II – Agency Strategic Plan Development and Activation for Montbello Bus Lines (MBL); and

2. Authorize the City Manager to execute Amendment No. 1 on behalf of the City of Montebello; and

3. Authorize the City Manager and/or his designee to approve change orders for up to fifteen percent (15%) or $7,470, of the amended agreement amount; and

4. Amend the Fiscal Year 2025-26 adopted operating budget to increase appropriations by $57,720, in Account No. 600-90-900-6040.95 (Transit Fund, Administration, Contract Services - Other Professional Services); and

5. Take such additional, related action as may be desirable.

Teri Fisher, CEO and Managing Partner of Insight Strategies Inc., presented the item.

Councilmember Peralta motioned, seconded by Councilmember Melendez, to approve the item; the motion was approved unanimously.

12. AWARD PROFESSIONAL SERVICES AGREEMENT NO. 4418 TO WEST COAST ARBORISTS, INC. FOR

URBAN FOREST MANAGEMENT PLAN GRANT IMPLEMENTATION SERVICES RECOMMENDATION: It is recommended that the City Council:

1. Rescind the prior award of the professional services Agreement No. 4419 to TreePeople, Inc. for Urban Forest Management Plan grant implementation services due to the firm’s formal withdrawal from the project; and

2. Award Professional Services Agreement No. 4418 to West Coast Arborists, Inc. in the amount of $597,500 payable from Cal Fire grant funds in Account No. 249-30-320-6040.10 (Cal Fire Urban Forestry Management, Public Works, Trees, Contract Services -utside Contracts); and

3. Authorize the City Manager to execute Professional Services Agreement No. 4418 in good faith; and

4. Take such additional, related action that may be desirable.

Cesar Roldan, Director of Public Works, provided a brief overview of the item.

Councilmember Peralta motioned, seconded by Councilmember Melendez, to approve the item; the motion was approved unanimously.

CONSENT CALENDAR
All matters listed under the Consent Calendar are considered to be routine. Any items a member wishes to discuss, including any items the public submitted speaker cards for, should be designated at this time. All other items may be approved in a single motion. Such approval will also waive the reading of any Ordinance.

Mayor Pro Tem Romero pulled Item No. 19 for discussion.

Councilmember Melendez motioned, seconded by Councilmember Peralta, to approve Item Nos. 13-18 and 20-27; the motion was approved unanimously.

13. FISCAL YEAR 2026-27 CONFIRMATION OF ANNUAL TAX RATE FOR VOTER APPROVED INDEBTEDNESS RECOMMENDATION: It is recommended that the City Council:

1. Review and adopt the attached resolution establishing property tax override rates on voter approved indebtedness for retirement expenditures for the Fiscal Year 2026-27; and,

2. Direct staff to forward the resolution to the Los Angeles County Auditor Controller within the required time limit; and