1 INTERGOVERNMENTAL COOPERATION AGREEMENT
STANISLAUS URBAN COUNTY
COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
Three Year Agreement
October 1, 2023 To September 30,2026
This Intergovernmental Cooperation Agreement for the Stanislaus Urban County Community Development Block Grant Program for Federal Fiscal Years (“FY”) 2023-2025 (which begins on October 1, 2023 and ends on September 30, 2026) (“Agreement”) is made and entered into this ____ day of _____, 202___ by and between the Cities of Ceres, Hughson, Newman, Oakdale, Patterson, Riverbank and Waterford, each a municipal corporation of the State of California (individually a “City” and collectively, "Cities”) and Stanislaus County through its Department of Planning and Community Development (the “County”). The Cities and the County are collectively referred to herein as the “Parties”; and, individually, a “Party”.
WITNESSETH
WHEREAS, in 1974, the U.S. Congress enacted and the President signed a law entitled The Housing and Community Development Act of 1974, herein called the “Act.” The Act is omnibus legislation relating to federal involvement in a wide range of housing and community development activities and contains eight separate titles; and
WHEREAS, Title I of the Act is entitled “Community Development” and governs programs for housing and community development within metropolitan cities and urban counties or communities by providing financial assistance annually for area-wide plans and for housing, public services and public works programs; and
WHEREAS, the Community Development Block Grant Program (hereinafter referred to as “CDBG”), the HOME Investment Partnerships Act Program (hereinafter referred to as “HOME Program”), and the Emergency Solutions Grants Program (hereinafter referred to as “ESG”) are consolidated under Title I of the Act (collectively, the “Programs”); funds from the Programs are referred to herein as “Program Funds”; and
WHEREAS, the Stanislaus Urban County (hereinafter referred to as “Urban County”) formed in 2000 to receive entitlement CDBG and ESG funds. The Urban County includes the unincorporated areas of Stanislaus County and the cities of Ceres, Hughson, Newman, Oakdale, Patterson, Riverbank and Waterford; and
WHEREAS, since 1991, Stanislaus County has been a member jurisdiction in the City of Turlock/Stanislaus HOME Consortium (hereinafter referred to as the “Consortium”) to obtain a direct allocation of funds under the Cranston-Gonzalez National Affordable Housing Act of 1990.
The Consortium includes the City of Turlock and all of the Urban County participants. In 2022, the City of Turlock notified the County that it was withdrawing as Lead Agency for the Consortium effective September 30, 2022. The County has agreed to take over as Lead Agency for the Consortium effective October 1, 2022.
2 WHEREAS, because Turlock opted out of the Urban County, Turlock is not entitled to receive any Program Funding under this Agreement. However, the County and the Cities of Ceres, Hughson, Newman, Oakdale, Patterson, Riverbank, Turlock and Waterford have entered into or will enter into a separate Consortium Agreement relating to funding through the HOME Program (“Consortium Agreement”); and
WHEREAS, the CDBG regulations issued pursuant to the Act provide that qualified urban counties must submit an application to the HUD for Program Funds, and cities and smaller communities within the metropolitan area not qualifying as metropolitan cities may join the County in said application and thereby become a part of a more comprehensive County effort; and WHEREAS, to have their populations counted and to be eligible for an allocation of grant funding, the Cities desire to participate jointly with the County in the Programs; and WHEREAS, as the Urban County applicant, the County must take responsibility and assume all obligations of an applicant under federal statues, including: the analysis of needs, the setting of objectives, the development of community development and housing assistance plans, the consolidated plan, and the assurances of certifications; and WHEREAS, by executing this Agreement, the Parties hereby give notice of their intention to participate in the Programs.
NOW THEREFORE, in consideration of the mutual promises, recitals and other provisions hereof, the Parties agree as follows:
1. Scope of Agreement. This Agreement covers the CDBG Entitlement program and, where applicable, the HOME Investment Partnerships (HOME) and Emergency Solutions Grants (ESG) Programs (i.e., where the Urban County receives funding under the ESG program, or receives funding under the HOME program as an urban county or as a member of a HOME consortium).
2. Full Cooperation and Affordable Housing. The County and the Cities, each as a cooperating unit of general local government, agree to cooperate to undertake, or assist in undertaking, community renewal and lower-income housing assistance activities.
3. Term of Agreement.
a. The term of this Agreement shall be for a period of three (3) years commencing on October 1, 2023 and ending on September 30, 2026 (Federal FY 2023-2025), for the County/City program years commencing on July 1, 2023 and ending on June 30, 2026. b. This Agreement shall remain in effect until the CDBG (and, where applicable, HOME and ESG) funds and program income received with respect to activities carried out during the three-year qualification period are expended and the funded activities completed. The County 3 and each City cannot terminate or withdraw from this Cooperation Agreement while it remains in effect.
c. By the date specified in HUD's Urban County qualification notice for the next three year qualification period, the Urban County will notify the City in writing of its right not to participate.
A copy of the County's notification to the jurisdiction must be sent to the HUD Field Office by the date specified in the Urban County qualification schedule.
4. Responsible Officers. The County’s Chief Executive Officer is the responsible officer for the County, and the Director of the Stanislaus County Department of Planning and Community Development (hereinafter referred to as “Director”) is hereby authorized to implement and administer Program activities and requirements on behalf of the County. The City Manager or his/her designee for each City is hereby authorized to act as the responsible officer for each City under the Programs.
5. Cities as Subrecipients.
a. Pursuant to the Act and 24 CFR 570.501(b), each City is subject to the same requirements applicable to subrecipients as set forth in 24 CFR 570.503. Where a City carries out an eligible activity funded by the Urban County, the Urban County and the City shall, prior to disbursing any Program Funds for any such activity or project, execute a written Subrecipient Agreement containing the minimum requirements found at 24 CFR 570.503. The Subrecipient Agreement must remain in effect during any period that the unit of local government has control over CDBG funds, including program income.
b. The written Subrecipient Agreement between the County and each City shall specify whether program income received is to be returned to the County or retained by the City.
Where program income is to be retained by the City, the Subrecipeint Agreement shall specify the activities that will be undertaken with the program income and that all provisions of the written agreement shall apply to the specified activities. (See 24 CFR 570.504).
6. Acknowledgement by Cities. By executing this Agreement, each City understands that it a) may not apply for grants from appropriations under the State CDBG Program for the fiscal years during the period in which it participates in the Urban County's CDBG program; and b) may receive a formula allocation under the HOME Program only through the Urban County.
7. Ad Hoc Committee and Panel.
a. Each Party to this Agreement (i.e., the governing body or its designee) shall designate one individual from its staff to serve on the ad hoc Technical Committee and the ad hoc Ranking Panel (each, a “Designated Representative”). An alternate may be designated to serve if the Designated Representative is unable to attend. Each Designated Representative shall act on behalf of and in an advisory capacity to its respective jurisdiction. 4 b. An ad hoc Technical Committee consisting of one (1) Designated Representative from the County and one (1) Designated Representative from each participating City may meet from time to time to review, aid in development, and provide recommendations on policies, procedures, and documentation required by HUD for the implementation and administration of Program Funds. The Technical Committee will facilitate distribution of information to residents within their respective jurisdictions and the opportunity to participate in the development of programs and priorities.
c. An ad hoc Ranking Panel consisting of (1) representative from the County, one (1) Designated Representative from each participating City may meet from time to time to review, evaluate, and rank projects proposing to be funded with Program Funds. The Panel shall convene as determined necessary by the County. Panel rankings will be used by the County in making recommendations for allocation and awarding of funding.
8. Consolidated Plan.
a. Each City shall assist the County by participating in the preparation of a Consolidated Plan pursuant to 24 CRF 91.1-91.600, which identifies community development and housing needs, projects and programs for each City, and specifies both short and long-term City objectives, consistent with requirements of the Act. The County agrees to: (1) include City projects the program application, and (2) take into consideration each City’s priorities as submitted by each City.
b. The County has final responsibility for selecting CDBG (and, where applicable, HOME and ESG) activities and submitting the Consolidated Plan to HUD. However, since the County is a member of a HOME Consortium, as the lead Agency the County will approve the Plan for the entire geographic area encompassed by the Consortium prior to its submittal to HUD. The Parties hereto agree that the responsible entity with the final responsibility for analyzing needs, setting objectives, developing plans, selecting projects for community development and housing assistance, selecting CDBG Public Service and ESG programs to be funded, and filing the Consolidated Plan, and other plans and reports required by the Act, is the County. c. Each City understands and agrees that the County shall have final responsibility for selecting the Program activities and projects to be included in each annual grant request and project grant request and for filing the Consolidated Plan with HUD on an annual basis.
d. During the period of time during which the County has qualified as an Urban County, the Parties agree not to veto or otherwise obstruct the implementation of the approved Consolidated Plan during that three-year period and for such additional time as may be required for the expenditure of funds granted for that period.
9. Grant Eligibility. The Parties acknowledge that they shall not be eligible to apply for grants under the Small Cities or State CDBG Programs for appropriations for fiscal years during 5 which the Parties are participating in the Urban County CDBG entitlement program; and further, each City shall not be eligible to participate in the HOME, or ESG Programs except through the Urban County or the Consortium Agreement.
10. County Responsibility.
a. The County shall, as applicant, be responsible for holding meetings and preparing and submitting the required plans and applications for CDBG, HOME and ESG Program Funding as required by the Act and the applicable federal regulations. b. The County shall be the primary general-purpose local governmental unit pursuant to the Act. The County shall apply for grants, execute grant agreements, administer all funds received, and undertake or assist in undertaking essential community development and housing assistance activities. The County shall have the authority to carry out activities which will be funded from annual Program Funds covered by this Agreement. Records shall be kept by County in accordance with approved accounting procedures and said records shall be available for public inspection at all times. The County shall be responsible thereunder for the proper performance, implementation or monitoring of the plans and the Programs. c. The environmental effects of activities carried out with Program Funds must be assessed in accordance with the provisions of the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321) and the related authorities listed in HUD's implementing regulations at 24 CFR parts 50 and 58. The County is the responsible entity for the environmental review and each City agrees to assist the County by securing all information and documentation relating to projects within their respective jurisdictions under the National Environmental Policy Act (NEPA) and the California Environmental Quality Act (CEQA), if required, including paying for consulting services and technical evaluations, and providing the same to the County for final review and approval.
11. City Responsibilities.
a. Each City agrees to undertake the necessary actions to support the County’s efforts to obtain Program Funding, and to meet the requirements of the Programs under the Act and the applicable laws and regulations.
b. Each City agrees to act in good faith and with due diligence in performance of City obligations and responsibilities under this Agreement and under the Consortium Agreement (when applicable), the Allocation Agreement(s), Subrecipient Agreement(s) and all Grant Agreements (collectively, Program Agreements”).
12. Compliance with Urban County Certification and Applicable Laws. 6 a. The County and each City agrees to take all actions necessary to assure compliance with the Urban County's certification under section 104(b) of Title I of the Housing and Community Development Act of 1974, that the grant will be conducted and administered in conformity with Title VI of the Civil Rights Act of 1964, and the implementing regulations at 24 CFR part 1, and the Fair Housing Act, and the implementing regulations at 24 CFR part 100, and will affirmatively further fair housing. See 24 CFR § 91.225(a) and Affirmatively Furthering Fair Housing Definitions and Certifications (86 FR 30779, June 10, 2021), to be codified at 24 CFR
5.151 and 5.152, available at https://www.federalregister.gov/documents/2021/06/10/2021- 12114/restoring-affirmativelyfurthering-fair-housing-definitions-and-certifications. These requirements include the obligation to comply with section 109 of Title I of the Housing and Community Development Act of 1974, and the implementing regulations at 24 CFR part 6, which incorporates Section 504 of the Rehabilitation Act of 1973, and the implementing regulations at 24 CFR part 8, Title II of the Americans with Disabilities Act, and the implementing regulations at 28 CFR part 35, the Age Discrimination Act of 1975, and the implementing regulation at 24 CFR part 146, and Section 3 of the Housing and Urban Development Act of 1968. The County and the Cities also agree to comply with other applicable laws. This Agreement prohibits Urban County funding for activities that do not affirmatively further fair housing within its own jurisdiction or that impede the County's actions to comply with the County's fair housing certification.
13. Program Funding
a. All funds received by the County pursuant to this Agreement shall be identified and allocated pursuant to HUD regulations and as described in the Annual Action Plan to the specific HUD approved projects or activities; provided, however, that a different distribution may be made when required by HUD to comply with Title I of the Housing and Community Development Act of 1974, as amended.
b. The County shall notify the participating Cities of the availability of the funds. It is understood by the Parties, hereto, the Program funds being used for the purposes of this Agreement are funds furnished to the County, through HUD, pursuant to the provisions of the Act.
Notwithstanding any other provision of this Agreement, the liability of the County shall be limited to Program funds actually received by the County. Each City understands that the County must wait for release of Program funds from HUD before the funds may be distributed. The County shall incur no liability to any City, its officers, agents, employees, suppliers, or contractors for any delay in making any such payments. All requests for payment requests must be made on forms approved by HUD and the County, with supporting documentation required by HUD and the County.
c. Program Administrative Costs may be allocated pursuant to 24 CFR 570.206 and applicable laws and regulations.
7 14. Public Services. An amount not to exceed fifteen (15) percent of the total annual CDBG funds, may be allocated for eligible public services, as defined in 24 CFR 570.201, and related projects. Eligible public services (labor, supplies, and materials) include but not limited to those concerned with employment, crime prevention, child care, health, drug abuse, education, fair housing counseling, energy conservation, welfare (but excluding the provision of income payments identified under 24 CFR 570.207(b)(4)), homebuyer down payment assistance, or recreational needs. (24 CFR 570.201(e)).
15. Program Income.
a. Program income shall be tracked received, expended and reported as required by 24 CFR 570.504 and applicable laws and regulations.
b. The County shall monitor the use of any program income. Each City shall maintain appropriate record-keeping and provide prompt reporting of program income.
16. Change in Use of Property. A City shall obtain the County’s prior written approval to modify or change the use of real property acquired or improved in whole or in part using Program Funds, to a use which was not contemplated at the time of acquisition or improvement, including disposition. Such notification shall be made within six (6) months before the effective date of such proposed change of use, and any change in use shall comply with the provisions of 24 CFR 570.505.
17. Fair Housing Implementation. The Parties agree no Program funding shall be allocated or expended for activities in or in support of any cooperating unit of general local government that does not affirmatively further fair housing within its own jurisdiction or that impedes the County’s actions to comply with its fair housing certification.
18. Claims and Indemnification.
a. To the fullest extent permitted by law, a Party (including its employees, agents, elected officials and volunteers) whose act, omission, negligence, misconduct or other fault gives rise to any claim, loss, liability, cost or expense, including, but not limited to, reasonable attorneys’ fees, court costs, penalties, claims for reimbursement and sanctions (hereinafter collectively referred to as “claims”), made by HUD or any third party shall defend and hold harmless the other Parties from and against any and all such claims.
b. Each City agrees to indemnify and hold harmless the County and each of their respective officers, directors, agents, designated representatives, employees and affiliates (“Indemnified Parties”) from any all claims arising out of, or in any way related to any its negligence or wrongful acts, breach or failure to comply with the terms and conditions of this Agreement or the Program Agreements, or failure to comply with applicable law. The obligations under this provision are independent of all other rights or obligations set forth herein. This 8 indemnification provision shall survive the disbursement of the Award funds, as well as any termination of this Agreement or the Program Agreements.
19. Audit. Each City agrees to cooperate, at no cost to the County, in any audit of Program activities involving Program Funds received by that City, including not limited to preparing appropriate financial statements, including the schedule of expenditures of Federal awards in accordance with 24 CFR 200.510; promptly follow up and take corrective action on audit findings; comply with any corrective action plans issued in connection with the audit; and provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit required applicable regulations.
20. Default and Remedial Action. Pursuant to 2 CFR 200, et seq., if a Party fails to comply with any term(s) outlined in this Agreement or the Program Agreements, the County may take appropriate corrective or remedial action against the defaulting Party in accordance with 2 CFR 570.910.
21. Consolidated and Further Continuing Appropriations Act. No City may sell, trade, or otherwise transfer all of any portion of Program funds to another metropolitan city, Urban County, unit of general local government, or Indian tribe, or insular area that directly or indirectly receives Program funds in exchange for any other funds, credits or non-Federal considerations, but must use such funds for activities eligible under Title I of the Act.
22. Allocation Agreement. For each fiscal year during the term of this Agreement, the County and each City may enter into an Annual Allocation Agreement, prepared jointly by the County and each City, which identifies the City’s annual allocation of Program funds that the County will administer during that program year. The reimbursements made shall not exceed the amount of the annual allocation.
23. Amendments. Any amendments to this Agreement shall be in writing. Parties agree any such fully executed amendment or amendments to this Agreement may be entered into at any time if required or necessary to implement the plans contemplated hereunder, or to comply with any related grant agreement or the regulations issued pursuant to the Act. Periodically, statutory or regulatory changes may require the County to amend this Agreement to add the new provision(s).
The County may draft a separate amendment to its existing agreements that includes the new provision(s) rather than drafting a new Cooperation Agreement that contains the new provisions.
However, the separate amendment must be executed by the City Manager of each of the Cities or his/her designee.
24. Compliance with Federal Regulations.
a. General. The Parties agree to take all actions necessary to assure compliance with the Urban County’s certifications required by section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 9 1964, the Fair Housing Act, affirmatively furthering fair housing, Section 109 of Title I of the Housing and Community Development Act of 1974; the National Environmental Policy Act of 1969; the Uniform Relocation Assistance and Real Property Acquisition Act of 1970; and other applicable laws.
b. Citizen Participation. The Parties agree to comply with federal citizen participation requirements of 24 CFR Part 91, and provide citizens with:
i) An estimate of the amount of Program funds proposed to be used for activities that will benefit persons of low and moderate income; and ii) A plan for minimizing displacement of persons as a result of Program - assisted activities and programs, and to provide assistance to such persons. c. Citizen Participation Plan. The Parties agree to follow a citizen participation plan which:
i) Provides for and encourages citizen participation, particularly those of low or moderate income who reside in slum or blighted areas where CDBG funds are proposed to be used;
ii) Provides citizens with reasonable and timely access to local meetings, staff reports, and other information relating to grantee’s proposed use of funds, as required by HUD regulations related to the actual use of funds under the Act; iii) Provides for meetings to obtain citizen views and to respond to proposals and questions at all stages of the community development program, including at least: 1) formulation of needs; 2) review of proposed grant activities; and 3) review of program performance; for which public hearings shall be held after adequate notice, at times and locations convenient to potential or actual beneficiaries, and with accommodation of handicapped persons; iv) Provides for a timely written answer to written complaints and grievances, within 15 working days where practicable;
v) Identifies how the needs of non-English speaking residents will be met in the case of meetings where a significant number of non-English speaking residents can be reasonably expected to participate.
25. Conflict of Interest. No federal grant monies have been paid or will be paid, by or on behalf of the Parties, to any officer or employee or any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any federal contract, the making of any federal grant, the making of any federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment or modification of any federal contract, grant, loan, or cooperative agreement. 10 26. Influence. If any funds other than federally appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this federal contract, grant, loan, or cooperative agreement, the undersigned shall complete and submit standard form LLL, “Disclosure Form to Report Lobbying,” in accordance with its instructions.
27. Certifications Disclosure. The Parties agree to include this certification in the award documents for all subawards at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements), and that all grant subrecipients shall certify and disclose accordingly. This certification is a material representation of fact upon which reliance was placed when this transaction was entered into.
a. Certification Regarding Policies Prohibiting Use of Excessive Force and Regarding Enforcement of State and Local Laws Barring Entrances. In accordance with Section 519 Public Law 101-144 (the 1990 HUD Appropriations Act), each Party certifies that it has adopted and is enforcing:
i) A policy prohibiting the use of excessive force by law enforcement agencies within their respective jurisdictions against any individuals engaged in non-violent civil rights demonstrations; and
ii) A policy of enforcing applicable State and local laws against physically barring entrance to or exit from a facility or location which is the subject of such non-violent civil rights demonstrations within their jurisdictions.
28. Qualification Documentation. A fully executed copy of this Agreement, together with the approving resolutions of both the City and the County, shall be submitted to HUD by the County as part of its qualification documentation and the City does hereby give the County the authority to carry out Program activities and projects which will be funded from annual Program funds during the term of his agreement and from any Program income generated from the expenditures of those funds.
29. HUD Certification. Program recipients shall make all certifications required under 24 CFR 91.225 and applicable laws and regulations.
30. Maintenance of Records. Each City shall maintain records of activities for any projects undertaken pursuant to the Programs and said records shall be open and available for inspection by auditors assigned by HUD and/or the County on reasonable notice during the normal business hours of the City.
31. General Provisions.
11 a. Headings or captions to the provisions of this Agreement are solely for the convenience of the parties, are not part of this Agreement, and shall not be used to interpret or determine the validity of this Agreement. Any ambiguity in this Agreement shall not be construed against the drafter, but rather the terms and provisions hereof shall be given a reasonable interpretation as if both parties had in fact drafted this Agreement. b. Any notice, communication, amendment, addition or deletion to this Agreement, including change of address of either party during the term of this Agreement, which any Consortium Member shall be required or may desire to make shall be in writing and may be personally served or, alternatively, sent by prepaid first class mail to the respective parties as set forth in Attachment 1 to this Agreement.
c. This Agreement shall be deemed to be made under and shall be governed by and construed in accordance with, the laws of the State of California. Any action brought to enforce the terms or provisions of this Agreement shall have venue in the County of Stanislaus, State of California.
d. The Board of Supervisors and the City Council of each City shall authorize this Agreement. The Chief Executive Officer of the County or the City Manager of the City, or their authorized designees must sign this Agreement on behalf of their respective jurisdiction. This Agreement must include as attachments the authorizing resolutions from the governing body stating that the party signing the agreement has the authority to sign the Agreement. e. This Agreement may be executed in one or more counterparts, each of which will be deemed to be an original copy of this Agreement, and all of which, when taken together, will be deemed to constitute one and the same agreement. The facsimile, email or other electronically delivered signatures of the Parties shall be deemed to constitute original signatures, and facsimile or electronic copies hereof shall be deemed to constitute duplicate originals.
IN WITNESS WHEREOF, the Parties have executed this Agreement on the day and year first hereinabove written.
[SIGNATURES BEGIN ON THE FOLLOWING PAGE]
12 STANISLAUS COUNTY:
By _____________________________ ________________________ Jody Hayes Dated
Chief Executive Officer
APPROVED AS TO CONTENT:
Angela Freitas, Director
Planning and Community Development Department
By ____________________________
Angela Freitas
Director
OPINION OF COUNTY COUNSEL
The terms and provisions of this Agreement are fully authorized under Federal, State and local law. This Agreement provides that Stanislaus County will serve as Lead Agency under applicable laws and regulations; and that Stanislaus County has the authority to undertake, or assist in undertaking, essential community renewal and lower income housing assistance activities.
STANISLAUS COUNTY COUNSEL
Thomas E. Boze
By: __________________________
G. Michael Ziman, Deputy County Counsel
17 CITY OF PATTERSON:
By ___________________________ ________________________ Dennis McCord Dated
Mayor
ATTEST:
By ___________________________
Aracely Alegre
City Clerk
APPROVED AS TO CONTENT:
By ____________________________
Ken Irwin
City Manager
APPROVED AS TO FORM:
By ____________________________
Tom Hallinan
City Attorney
20 Attachment 1
Member Notice Information
County of Stanislaus
Department of Planning and Community Development
Attention: Deputy Director
1010 Tenth Street, Suite 3400
Modesto, CA 95354
City of Ceres
Department of Planning and Building
2720 Second Street
Ceres, CA 95307
City of Hughson
Department of Community Development
P.O. Box 9
Hughson, CA 95326
City of Newman
Department of Community Development
P.O. Box 787
Newman, CA 95360
City of Oakdale
Department of Community Development
455 S. Fifth Street
Oakdale, CA 95361
City of Patterson
Department of Community Development
P.O. Box 667
Patterson, CA 95363
City of Riverbank
Department of Economic Development and Housing
6707 3rd Street
Riverbank, CA 95367
City of Waterford
City Manager’s Office
P.O. Box 199
Waterford, CA 95386