Agenda packet — San Marino City Council, December 10, 2025 (part 2 of 3)

PROFESSIONAL SERVICES AGREEMENT
between
The City of San Marino
2200 Huntington Drive
San Marino, CA 91108
&
The Sauce Creative Services Corp
2600 South California Avenue, Suite C
Monrovia, CA 91016
This Professional Service Agreement (“the Agreement”) is made as of September 13, 2025 (the “Effective Date”), by and between The Sauce Creative Services Corp (“Consultant”), and the City of San Marino (“City”), a California municipal corporation, (collectively, “the Parties”).

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RECITALS
A. City desires certain professional services as specified in this Agreement.

B. Consultant represents that it is qualified and able to provide City with such services.

NOW THEREFORE, in consideration of the Parties’ performance of the promises, covenants, and conditions stated herein, the Parties hereto agree as follows:

AGREEMENT

1.0 Scope of Services

1.1. Consultant shall provide those services (“Services”) set forth in the attached Exhibit A.

1.2. Consultant shall perform all Services under this Agreement in accordance with the standard of care generally exercised by like professionals under similar circumstances and in a manner reasonably satisfactory to City.

1.3. In performing this Agreement, Consultant shall comply with all applicable provisions of federal, state, and local laws, ordinances, codes, and regulations.

1.4. Consultant shall not be compensated for any work performed unless it is specified in Exhibit A or City authorizes such work in advance and in writing. Any work so authorized by City shall become part of the Services for purposes of this Agreement.

2.0 Term
The term of this Agreement shall commence as of the Effective Date and shall continue through September 12, 2028 unless sooner terminated as provided in Section

5.0 of this Agreement.

Any additional work authorized by the City pursuant to Section 1.4 will be compensated in accordance with the fee schedule set forth in Exhibit B, unless otherwise approved by City in writing. Pursuant to Section 02.06.05 of the San Marino City Code, this PAGE 177 of 704

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Agreement shall not be effective unless previously approved by the City Council if it is for professional services of greater than thirty thousand dollars ($30,000.00).

4.0 Method of Payment

4.1. Consultant shall submit to City monthly invoices for all services rendered pursuant to this Agreement. Such invoices shall be submitted within 15 days of the end of the month during which the services were rendered and shall describe in detail the services rendered during the period, the days worked, number of hours worked, the hourly rates charged, and the services performed for each day in the period. City will pay Consultant all undisputed charges within 30 days of receiving Consultant’s invoice.

City will not withhold any applicable federal or state payroll and other required taxes, or other required or authorized deductions from payments made to Consultant.

4.2. Upon 24-hour notice from City, Consultant shall allow City or City’s agents or representatives to inspect at Consultant’s offices during reasonable business hours all records, invoices, time cards, cost control sheets and other records maintained by Consultant in connection with this Agreement. City’s rights under this Section 4.2 shall survive for two years following the expiration or earlier termination of this Agreement.

5.0 Termination

5.1. City may terminate this Agreement at any time, at will, for any reason or no reason, after giving written notice to Consultant at least thirty (30) calendar days before the termination is to be effective.

5.2. Consultant may terminate this Agreement for cause in the event City fails to cure a default under this Agreement within thirty (30) days after Consultant has given City notice of such default.

5.3. Upon termination of this Agreement, Consultant shall cease all work under this Agreement and deliver to City all materials, reports, documents, notes or other written materials compiled through the last working day this Agreement is in effect. City shall pay Consultant for all services satisfactorily rendered through the last working day this Agreement is in effect; provided that in no event, including but not limited to termination, shall Consultant be entitled to receive more than the maximum compensation set forth in Section 3. Neither party shall have any other claim against the other party by reason of termination pursuant to this Section 5.0.

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6.0 Reports, Information, and Work Product

6.1. Consultant shall deliver to City: (1) any reports on the status of the Services upon City’s request and in such time and in such form as City may require; and (2) all material furnished to Consultant by City upon City’s request and/or upon the expiration or termination of this Agreement.

6.2. Unless the Parties agree in writing, all draft and final reports, documents, and other written material, and any and all images, ideas, concepts, designs including without limitation any website designs, source code, object code, electronic data and files, and/or other media whatsoever created or developed by Consultant in the performance of this Agreement (collectively, “Work Product”) shall be considered to be “works made for hire” for the benefit of City. All Work Product and any and all intellectual property rights arising from their creation, including, but not limited to, all copyrights and other proprietary rights, shall be and remain the property of City without restriction or limitation upon their use, duplication or dissemination by City upon final payment being made. Consultant shall not obtain or attempt to obtain copyright protection as to any of the Work Product. Consultant hereby assigns to City all rights of ownership to the Work Product, including but not limited to any and all related intellectual property and proprietary rights that are not otherwise vested in the City pursuant to this paragraph.

6.3. Consultant warrants and represents that it has secured all necessary licenses, consents or approvals necessary to the production of the Work Product, and that upon final payment, City shall have full legal title to the Work Product, and full legal authority and the right to use and reproduce the Work Product for any purpose.

Consultant shall defend, indemnify, and hold City, and its elected officials, officers, employees, servants, attorneys, designated volunteers, and agents serving as independent contractors in the role of city officials, harmless from any loss, claim, or liability in any way related to a claim that any use by the City of any of the Work Product violates federal, state, or local laws, or any contractual provisions, or any rights or laws relating to trade names, licenses, franchises, copyrights, patents, or other means of protecting intellectual property rights, and/or interests in products, ideas, or inventions.

Consultant shall bear all costs arising from the use of patented, copyrighted, trade secret, or trademarked documents, materials, equipment, devices, or processes in connection with its provision of the Work Product produced under this Agreement. If any use by city of any of the Work Product or other deliverables is held to constitute an infringement and the use of any of the same is enjoined, Consultant, at its expense, shall: (a) secure for City the right to continue using such Work Product and/or other deliverables by suspension of any injunction, or by procuring a license or licenses for PAGE 179 of 704

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City; or (b) modify the Work Product and other deliverables so that they become noninfringing while remaining in compliance with the requirements of this Agreement.

6.4. Consultant’s obligations under this Section 6.0 shall survive the expiration or termination of this Agreement.

7.0 Party Representatives

7.1. City’s representative for purposes of this Agreement is the City Manager or the person designated in writing by the City Manager. The City Manager’s designee may exercise the authority of the City Manager provided in this Agreement excepting approval of any expenditure that would exceed a total compensation allowed under the Agreement.

7.2. Sergio Balandran, CEO, is Consultant’s representative for purposes of this Agreement.

8.0 Notices

8.1. All notices permitted or required under this Agreement shall be deemed made when personally delivered or when mailed 48 hours after deposit in the United States Mail, first class postage prepaid and addressed to the party at the following addresses:

To City: City of San Marino
2200 Huntington Drive
San Marino, CA 91108
Attn: City Manager
To Consultant: The Sauce Creative Services Corp
2600 South California Avenue, Suite C
Monrovia, CA 91016
Attn: Sergio Balandran

8.2. Actual notice shall be deemed adequate notice on the date actual notice occurred, regardless of the method of service.

9.0 Independent Consultant

9.1. Consultant is an independent contractor and not an employee of City. All services provided pursuant to this Agreement shall be performed by Consultant or under its supervision. Consultant will determine the means, methods, and details of performing the services. Any additional personnel performing services under this PAGE 180 of 704

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Agreement on behalf of Consultant shall also not be employees of City and shall at all times be under Consultant’s exclusive direction and control. Consultant shall pay all wages, salaries, and other amounts due such personnel in connection with their performance of services under this Agreement and as required by law. Consultant shall be responsible for all reports and obligations respecting such additional personnel, including, but not limited to: social security taxes, income tax withholding, unemployment insurance, disability insurance, and workers’ compensation insurance.

9.2. Consultant shall indemnify and hold harmless City and its elected officials, officers, employees, servants, designated volunteers, and agents serving as independent contractors in the role of City officials, from any and all liability, damages, claims, costs, and expenses of any nature to the extent arising from Consultant’s personnel practices.

City shall have the right to offset against the amount of any fees due to Consultant under this Agreement any amount due to City from Consultant as a result of Consultant’s failure to promptly pay to City any reimbursement or indemnification arising under this Section. All duties of Consultant under this Section 9.2 shall survive termination of this Agreement.

9.3. In the event that Consultant provides any of the Services by or through any employee or any person whose work under this Agreement becomes cause for any payment or contribution required by law, including but not limited to the California Public Employees' Pension Reform Act (PEPRA), to the Public Employee Retirement System, Consultant shall be solely responsible for all such payments or contributions.

Consultant shall indemnify and hold harmless City and its elected officials, officers, employees, servants, designated volunteers, and agents serving as independent contractors in the role of City officials, from any and all liability, damages, claims, costs, and expenses of any nature to the extent arising from Consultant’s failure to make any such payment or contribution. City shall have the right to offset against the amount of any fees due to Consultant under this Agreement any amount due to City from Consultant as a result of Consultant’s failure to promptly pay to City any reimbursement or indemnification arising under this Section. All duties of Consultant under this Section

9.3 shall survive termination of this Agreement.

10.0 Subcontractors
Unless otherwise specified in Exhibit A, no portion of this Agreement shall be subcontracted without the prior written approval of the City Manager. Consultant is fully responsible to City for the performance of any and all subcontractors, if any.

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11.0 Assignment
Consultant shall not assign or transfer any interest in this Agreement whether by assignment or novation, without the prior written consent of City Manager. Any purported assignment without such consent shall be void and without effect.

12.0 Insurance

12.1. Consultant shall not commence work under this Agreement until it has provided evidence satisfactory to the City that Consultant has secured all insurance required under this Section. Consultant shall furnish the City with original certificates of insurance and endorsements, including but not limited to additional insured endorsements, effecting coverage required by this Agreement on forms satisfactory to the City. The certificates and endorsements for each insurance policy shall be signed by a person authorized by that insurer to bind coverage on its behalf, and shall be on forms provided by the City, if requested. All certificates and endorsements shall be received and approved by the City before work commences. The City reserves the right to require complete, certified copies of all required insurance policies, at any time.

12.2. General liability insurance. Consultant shall maintain commercial general liability insurance with coverage at least as broad as Insurance Services Office form CG 00 01, in an amount not less than $1,000,000 per occurrence, $2,000,000 general aggregate, for bodily injury, personal injury, and property damage. The policy must include contractual liability that has not been amended. Any endorsement restricting standard ISO “insured contract” language will not be accepted.

12.3 Automobile liability insurance. Consultant shall maintain automobile insurance at least as broad as Insurance Services Office form CA 00 01 covering bodily injury and property damage for all activities of the Consultant arising out of or in connection with Work to be performed under this Agreement, including coverage for any owned, hired, non-owned, or rented vehicles, in an amount not less than $1,000,000 combined single limit for each accident.

12. 4 Professional liability (errors & omissions) insurance. Consultant shall maintain professional liability insurance that covers the Services to be performed in connection with this Agreement, in the minimum amount of $1,000,000 per claim and in the aggregate. Any policy inception date, continuity date, or retroactive date must be before the effective date of this agreement and Consultant agrees to maintain continuous coverage through a period no less than three years after completion of the services required by this agreement.

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12.5 Workers’ compensation insurance. Consultant shall maintain Workers’ Compensation Insurance (statutory limits) and Employer’s Liability insurance (with limits of at least $1,000,000).

Consultant shall submit to the City, along with the certificate of insurance, a Waiver of Subrogation endorsement in favor of the City, its officers, agents, employees, and volunteers.

Other provisions or requirements

12.6. Proof of insurance. Consultant shall provide certificates of insurance and required endorsements to the City as evidence of the insurance coverage required herein. Insurance certificates and endorsements must be approved by the City’s Risk Manager prior to commencement of performance. Current certification of insurance shall be kept on file with the City for the contract period and any additional length of time required thereafter. The City reserves the right to require complete, certified copies of all required insurance policies, at any time.

12.7 Duration of coverage. Consultant shall procure and maintain for the contract period, and any additional length of time required thereafter, insurance against claims for injuries to persons or damages to property, or financial loss which may arise from or in connection with the performance of the Work hereunder by Consultant, their agents, representatives, employees, or sub-consultants.

12.8 Primary/noncontributing. Coverage provided by Consultant shall be primary and any insurance or self-insurance procured or maintained by the City shall not be required to contribute with it. The limits of insurance required herein may be satisfied by a combination of primary and umbrella or excess insurance. Any umbrella or excess insurance shall contain or be endorsed to contain a provision that such coverage shall also apply on a primary and non-contributory basis for the benefit of the City before the City’s own insurance or self- insurance shall be called upon to protect it as a named insured.

12.9 City’s rights of enforcement. In the event any policy of insurance required under this Agreement does not comply with these specifications or is canceled and not replaced, the City has the right but not the duty to obtain the insurance it deems necessary, and any premium paid by the City will be promptly reimbursed by Consultant or the City will withhold amounts sufficient to pay premium from Consultant payments.

In the alternative, the City may cancel this Agreement.

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12.10 Acceptable insurers. All insurance policies shall be issued by an insurance company currently authorized by the Insurance Commissioner to transact business of insurance or is on the List of Approved Surplus Line Insurers in the State of California, with an assigned policyholders’ Rating of A- (or higher) and Financial Size Category Class VII (or larger) in accordance with the latest edition of Best’s Key Rating Guide, unless otherwise approved by the City’s Risk Manager.

12.11 Waiver of subrogation. All insurance coverage maintained or procured pursuant to this agreement shall be endorsed to waive subrogation against the City, its elected or appointed officers, agents, officials, employees, and volunteers or shall specifically allow Consultant or others providing insurance evidence in compliance with these specifications to waive their right of recovery prior to a loss. Consultant hereby waives its own right of recovery against the City and shall require similar written express waivers and insurance clauses from each of its subconsultants.

12.12 Enforcement of contract provisions (non estoppel). Consultant acknowledges and agrees that any actual or alleged failure on the part of the City to inform Consultant of non-compliance with any requirement imposes no additional obligations on the City nor does it waive any rights hereunder.

12.13 Requirements not limiting. Requirements of specific coverage features or limits contained in this Section are not intended as a limitation on coverage, limits or other requirements, or a waiver of any coverage normally provided by any insurance. Specific reference to a given coverage feature is for purposes of clarification only as it pertains to a given issue and is not intended by any party or insured to be all inclusive, or to the exclusion of other coverage, or a waiver of any type. If the Consultant maintains higher limits than the minimums shown above, the City requires and shall be entitled to coverage for the higher limits maintained by the Consultant. Any available insurance proceeds in excess of the specified minimum limits of insurance and coverage shall be available to the City.

12.14 Notice of cancellation. Consultant agrees to oblige its insurance agent or broker and insurers to provide the City with a thirty (30) day notice of cancellation (except for nonpayment for which a ten (10) day notice is required) or nonrenewal of coverage for each required coverage. If any of the Consultant’s insurers are unwilling to provide such notice, then Consultant shall have the responsibility of notifying the City immediately in the event of Consultant’s failure to renew any of the required insurance coverages, or insurer’s cancellation or non-renewal.

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12.15 Additional insured status. General liability, automobile liability, and umbrella/excess liability insurance policies shall provide or be endorsed to provide that the City and its officers, officials, employees, agents, and volunteers shall be additional insureds under such policies.

12.16 Prohibition of undisclosed coverage limitations. None of the coverages required herein will be in compliance with these requirements if they include any limiting endorsement of any kind that has not been first submitted to the City and approved of in writing.

12.17 Separation of insureds. A severability of interests provision must apply for all additional insureds ensuring that Consultant’s insurance shall apply separately to each insured against whom claim is made or suit is brought, except with respect to the insurer’s limits of liability. The policy(ies) shall not contain any crossliability exclusions.

12.18 Pass through clause. Consultant agrees to ensure that its subconsultants, subcontractors, and any other party who is brought onto or involved in the project/service by Consultant (hereinafter collectively “Subcontractor”), provide the same minimum insurance coverage and endorsements required of Consultant under this Agreement. Consultant agrees to monitor and review all such coverage and assumes all responsibility for ensuring that such coverage is provided in conformity with the requirements of this section. However, in the event Consultant’s Subcontractor cannot comply with this requirement, which proof must be submitted to the City, Consultant may still be able to utilize the Subcontractor provided Consultant shall be required to ensure that its Subcontractor provide and maintain insurance coverage and endorsements sufficient to the specific risk of exposure involved with Subcontractor’s scope of work and services, with limits less than required of the Consultant, but in all other terms consistent with the Consultant’s requirements under this Agreement. This provision does not relieve the Consultant of its contractual obligations under the Agreement and/or limit its liability to the amount of insurance coverage provided by its subcontractors. This provision is intended solely to provide Consultant with the ability to utilize a Subcontractor who may be otherwise qualified to perform the work or services but may not carry the same insurance limits as required of the Consultant under this Agreement given the limited scope of work or services provided by the subcontractor.

Consultant agrees that upon request, all agreements with Subcontractors, and others engaged in the project and/or services, will be submitted to the City for review.

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required by giving the Consultant ninety (90) days advance written notice of such change. If such change results in substantial additional cost to the Consultant, the City and Consultant may renegotiate Consultant’s compensation.

12.20 Self-insured retentions. Any self-insured retentions must be declared to and approved by the City. The City reserves the right to require that self-insured retentions be eliminated, lowered, or replaced by a deductible, or require proof of ability to pay losses and related investigations, claim administration, and defense expenses within the retention through confirmation from the underwriter.

12.21 Timely notice of claims. Consultant shall give the City prompt and timely notice of claims made or suits instituted that arise out of or result from Consultant’s performance under this Agreement, and that involve or may involve coverage under any of the required liability policies.

12.22 Additional insurance. Consultant shall also procure and maintain, at its own cost and expense, any additional kinds of insurance, which in its own judgment may be necessary for its proper protection and prosecution of the work.

Indemnification, Hold Harmless, and Duty to Defend

12.23 To the fullest extent permitted by law, Consultant shall indemnify and hold harmless the City and any and all of its officials, employees and agents (“Indemnified Parties”) from and against any and all losses, liabilities, damages, costs and expenses, including attorney’s fees and costs, caused in whole or in part by the negligent or wrongful act, error or omission of Consultant, its officers, agents, employees or subconsultants (or any agency or individual that Consultant shall bear the legal liability thereof) in the performance of services under this agreement. Consultant’s duty to indemnify and hold harmless the City shall not extend to the City’s sole or active negligence.

12.24 In the event the City, its officers, employees, agents and/or volunteers are made a party to any action, lawsuit, or other adversarial proceeding arising from the performance of the services encompassed by this agreement, and upon demand by the City, Consultant shall defend the City at Consultant’s cost or at the City’s option, to reimburse the City for its costs of defense, including reasonable attorney’s fees and costs incurred in the defense of such matters to the extent the matters arise from, relate to or are caused by Consultant’s negligent acts, errors or omissions. Payment by the City is not a condition precedent to enforcement of this provision. In the event of any dispute between Consultant and the City, as to whether liability arises from the sole or PAGE 186 of 704

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active negligence of the City or its officers, employees, or agents, Consultant will be obligated to pay for the City’s defense until such time as a final judgment has been entered adjudicating the City as solely or actively negligent. Consultant will not be entitled in the absence of such a determination to any reimbursement of defense costs including but not limited to attorney’s fees, expert fees, and costs of litigation.

13.0 Equal Opportunity
Consultant shall not discriminate against any subcontractor, employee, or applicant for employment because of race, religion, color, national origin, handicap, ancestry, sex, sexual orientation, or age. Such non-discrimination includes, but is not limited to, all activities related to initial employment, upgrading, demotion, transfer, recruitment or recruitment advertising, layoff, or termination.

14.0 Labor Certification

14.1. By its signature hereunder, Consultant certifies it is aware of the provisions of Section 3700 of the California Labor Code that require every employer to be insured against liability for Workers’ Compensation or to undertake self-insurance in accordance with the provisions of that Code. Consultant shall provide evidence of such coverage before commencing the performance of the Services.

14.2. Consultant certifies that in the performance of the Services, Consultant shall not, in any manner, employ any person or contract with any person so that any Services so performed by such person would be subject to the workers’ compensation laws of the State of California unless and until Consultant gives City a certificate of consent to self-insure or a certificate of Workers' Compensation Insurance Coverage.

14.3. In the event Consultant hires a subcontractor who has employees to perform the Services or any part thereof, then Consultant shall either require the subcontractor to obtain Workers’ Compensation Insurance Coverage, or must obtain Workers’ Compensation Insurance Coverage for the subcontractor’s employees.

14.4. Any Workers’ Compensation Insurance Coverage required by or for this Agreement shall be endorsed with a waiver of subrogation in favor of City for all work performed by Consultant, its employees, its agents, and its subcontractors.

15.0 Entire Agreement
This Agreement contains the entire agreement of the parties with respect to the subject matter hereof, and supersedes all prior negotiations, understandings, or agreements. This Agreement may only be modified by a writing signed by both parties.

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16.0 Severability
The invalidity in whole or in part of any provisions of this Agreement shall not void or affect the validity of the other provisions of this Agreement.

17.0 Governing Law
This Agreement shall be governed by and construed in accordance with the laws of the State of California.

18.0 No Third Party Rights
No third party shall be deemed to have any rights hereunder against either party as a result of this Agreement.

19.0 Waiver
No waiver of any default shall constitute a waiver of any other default or breach, whether of the same or other covenant or condition. No waiver, benefit, privilege, or service voluntarily given or performed by a party shall give the other party any contractual rights by custom, estoppel, or otherwise.

20.0 Headings
Headings used in this Agreement are for reference purposes only and shall not be deemed a part of this Agreement.

21.0 Force Majeure
Consultant shall not be liable for any failure to perform any obligation under this Agreement if Consultant presents that City in its sole judgment deems acceptable that such failure was due to strikes, lockouts, labor disputes, embargoes, acts of God, governmental restrictions, governmental regulations, governmental controls, judicial orders, enemy or hostile governmental action, civil commotion, fire or other casualty, or other causes beyond Consultant’s reasonable control and not due to any act by Consultant.

22.0 Final Payment Acceptance Constitutes Release
Consultant’s acceptance of City’s final payment under this Agreement shall operate as and be a release of City from all claims and liabilities for compensation to Consultant for the Services or anything done or furnished relating thereto. Neither City’s payment to Consultant nor approval of payment constitute, nor be deemed, a PAGE 188 of 704

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release of the responsibility and liability of Consultant, its employees, sub-contractors and agents for the accuracy and competency of the information provided and/or work performed; nor shall such or payment or approval be deemed to be an assumption of such responsibility or liability by City for any defect or error in the work prepared by Consultant, its employees, subcontractors and agents.

23.0 Prohibited Interests; Conflict of Interest

23.1. Consultant covenants that it presently has no interest and shall not acquire any interest, direct or indirect, which may be affected by the Services, or which would conflict in any manner with the performance of the Services. Consultant further covenants that, in performance of this Agreement, no person having any such interest shall be employed by it. Furthermore, Consultant shall avoid the appearance of having any interest, which would conflict in any manner with the performance of the Services.

Consultant shall not accept any employment or representation during the term of this Agreement which is or may likely make Consultant “financially interested” (as provided in California Government Code §§1090 and 87100) in any decision made by City on any matter in connection with which Consultant has been retained.

23.2. Consultant further warrants and maintains that it has not employed or retained any person or entity, other than a bona fide employee working exclusively for Consultant, to solicit or obtain this Agreement. Nor has Consultant paid or agreed to pay any person or entity, other than a bona fide employee working exclusively for Consultant, any fee, commission, gift, percentage, or any other consideration contingent upon the execution of this Agreement. Upon any breach or violation of this warranty, City shall have the right, at its sole and absolute discretion, to terminate this Agreement without further liability, or to deduct from any sums payable to Consultant hereunder the full amount or value of any such fee, commission, percentage or gift.

23.3. Consultant warrants and maintains that it has no knowledge that any officer or employee of City has any interest, whether contractual, noncontractual, financial, proprietary, or otherwise, in this transaction or in the business of Consultant, and that if any such interest comes to the knowledge of Consultant at any time during the term of this Agreement, Consultant shall immediately make a complete, written disclosure of such interest to City, even if such interest would not be deemed a prohibited “conflict of interest” under applicable laws as described in this subsection.

24.0 Attorneys’ Fees
If either party commences any legal, administrative, or other action against the other party arising out of or in connection with this Agreement, the prevailing party in PAGE 189 of 704

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such action shall be entitled to have and recover from the losing party all of its attorneys’ fees and other costs incurred in connection therewith.

25.0 Exhibits
Each exhibit referenced in this Agreement is hereby incorporated into the Agreement as if set forth in full herein. In the event of any material discrepancy between the terms of any exhibit so incorporated and the terms of this Agreement, the terms of this Agreement shall control.

26.0 Corporate Authority

26.1. Each person executing this Agreement on behalf of Consultant warrants that he or she is duly authorized to execute this Agreement on behalf of Consultant and that by his or her execution, Consultant is formally bound to the provisions of this Agreement.

26.2. Consultant certifies it is aware of the requirements of Sections 313 of the California Corporations Code. If Consultant is a corporate entity, it shall either:
(a) provide City written proof that each person executing this Agreement on Consultant’s behalf is duly authorized to bind Consultant; or (b) provide two signatories to this Agreement, of whom the first must be Consultant’s chairman of the board, president, or a vice president and the second must be Consultant’s secretary, an assistant secretary, its chief financial officer, or an assistant treasurer.

IN WITNESS WHEREOF, the Parties hereto, through their respective authorized representatives have executed this Agreement as of the Effective Date.

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CITY OF SAN MARINO
By: ______________________________________
Philippe Eskandar
City Manager
Attest:

By: ______________________________________
City Clerk
Approved as to Form:

By: ______________________________________
Joseph Montes
City Attorney

CONSULTANT
By: ______________________________________
(Sign)
Name: ____________________________________
(Print)
Title: _____________________________________
(Print)
By: _____________________________________
(Sign)
Name: ___________________________________
(Print)
Title: ___________________________________
(Print)
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Exhibit A
Scope of Services
The Community Services Department is looking for a vendor to be responsible for the design, print, and preparation for mailing of the quarterly Community Services Guide. Postage shall not be a cost to be included in the quote. The tentative production timeline is provided in Exhibit C.

The City shall be responsible for:
• Providing the vendor with copy in the preferred layout in a Word Document • Providing the vendor with images via Google Drive
The vendor shall be responsible for:
• Providing comprehensive project management for each publication • Ensuring consistency and conformance with the City’s branding efforts and strategy o Utilizing the City’s branded colors and fonts, as well as logos o Ideally, maintaining existing sequence of pages, but are open to design enhancements • Providing graphic design services for each publication with occasional full centerpiece spreads • Providing access to and selection of stock photography • Providing at least two electronic proofs of the publication to the City for review and one final electronic pre-production sign off
• Proofreading and editing to include grammar, spelling, and formatting • Producing hard copy and electronic (PDF) format publications • Coordinating all necessary communications (email, phone, etc.) with City staff throughout the development stages
• Pre-sorting and bundling publications for the post office, EDDM (Every Door Direct Mail) • Providing and hosting a digital flipbook (or similar) Requirements for the Community Services Guide:
• Color: full-color
• Pages: 24 pages
• Format: follow the general format of the City’s existing Community Services Guide; see Exhibit D and E for two of the City’s latest publications
• Stock: 70# or 80# dull book stock
• Bindery: cut, fold, stitch, and trim
o 8.5” x 11.0”
• Quantity: 5,000 shall be printed
o About 4,500 for mail distribution, remaining quantity to be dropped off at the Crowell Public Library (1890 Huntington Drive, San Marino, CA 91108) • Issues per year: 4
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Exhibit B
Fee Schedule
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Exhibit C
Production Schedule
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Doc No. 2547482
AMENDMENT NO. 1 TO AGREEMENT BETWEEN THE CITY OF SAN MARINO

AND THE SAUCE CREATIVE SERVICES CORP
THIS AMENDMENT NO. 1 TO THE AGREEMENT (“Amendment No. 1”) by and between the CITY OF SAN MARINO (“City”) and THE SAUCE CREATIVE SERVICES CORP a California corporation (“Contractor”) is effective as of September 13, 2025. City and Contractor are collectively referred to as the “Parties.”

RECITALS
A. City and Contractor entered into that certain Agreement for Professional Services dated September 13, 2025 (“Original Agreement”) whereby Contractor agreed to provide those professional services specified in the Original Agreement.

B. City and Contractor now desire to amend the Original Agreement, in accordance with Section 3 of the Agreement to include postage costs as part of the Contractor’s compensation.

TERMS

1. Contract Changes. The Original Agreement is amended as provided herein.

A. Section 3 of the Original Agreement is amended to read as follows:

3.0 Consultant’s Compensation
City will pay Consultant in accordance with the fee schedule set forth in Exhibit B but in no event will the City pay more than $143,908.00 for the initial three-year term plus true costs of postage and a 5% service fee based on the true cost of postage. Any additional work authorized by the City pursuant to Section 1.4 will be compensated in accordance with the fee schedule set forth in Exhibit B, unless otherwise approved by City in writing. Pursuant to Section 02.06.05 of the San Marino City Code, this Agreement shall not be effective unless previously approved by the City Council if it is for professional services of greater than $30,000.00.

2. Continuing Effect of Agreement. Except as amended by this Amendment No. 1, all provisions of the Original Agreement shall remain unchanged and in full force and effect. From and after the date of this Amendment No. 1, whenever the term “Agreement” appears in the Agreement, it shall mean the Original Agreement, as amended by Amendment No. 1.

3. Authority. The persons executing this Amendment No. 1 on behalf of the Parties hereto warrant that (i) such party is duly organized and existing, (ii) they are duly authorized to execute and deliver this Amendment No. 1 on behalf of said party, (iii) by so executing this Amendment No. 1, such party is formally bound to the provisions of this Amendment No. 1, and (iv) the entering into this Amendment No. 1 does not violate any provision of any other agreement to which said party is bound.

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Doc No. 2453984
IN WITNESS WHEREOF, the Parties hereto have executed this Amendment No. 1 as of the date and year first hereinabove written.

City of San Marino The Sauce Creative Services Corp
By:_____________________________ By:______________________________ Philippe Eskandar Signature
City Manager
______________________________
Print Name and Title
Date:____________________________ Date: ____________________________ ATTEST: APPROVED AS TO FORM:
___________________________ ________________________________ Alison Walker Joseph Montes
City Clerk City Attorney
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TO: Mayor and City Council
FROM: Philippe Eskandar, City Manager
BY: Amber Shah, Parks & Public Works Director/City Engineer DATE: December 10, 2025
SUBJECT: APPROVAL OF 1) CONTRACT AMENDMENT NO. 4 TO THE

PROFESSIONAL SERVICES AGREEMENT WITH DUDEK

FOR ENGINEERING SERVICES DURING CONSTRUCTION

FOR THE LIFT STATION IMPROVEMENT PROJECT,
EXTENDING THE TERM THROUGH JUNE 30, 2026, 2)
CONTRACT AMENDMENT NO. 1 TO THE PROFESSIONAL

SERVICES AGREEMENT WITH Z&K CONSULTANTS FOR

CONSTRUCTION MANAGEMENT & INSPECTION SERVICES

FOR THE LIFT STATION IMPROVEMENT PROJECT,
EXTENDING THE TERM THROUGH JUNE 30, 2026, AND 3)

AUTHORIZE THE CITY MANAGER TO EXECUTE THE

AMENDMENTS ON BEHALF OF THE CITY

STRATEGIC PLAN CRITICAL SUCCESS FACTORS
Efficient, Responsive, and Effective City Services
Fiscally Responsible and Transparent City Government
Safe Community
Well-Maintained Infrastructure

BACKGROUND
The City owns and operates approximately 50 miles of gravity pipelines and three (3) sewer lift stations located on Orlando Road, Avondale, Road, and Monterey Road. To comply with State Water Resources Control Board (SWRCB) Orders, the City must maintain a Sewer System Management Plan (SSMP) and provide sufficient resources to operate, maintain and rehabilitate the sewer system to prevent sanitary sewer overflows (SSOs). As part of the Gretchen Shepherd Romey, Mayor
Tony Chou, Vice Mayor
Hunter Chang, Council Member
John Chou, Council Member
Calvin Lo, Council Member
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City’s 2019 SSMP, a Sewer Condition Assessment (SCA) report was completed to identify priority projects for inclusion in the City’s Capital Improvement Program (CIP) to ensure sustained reliability of the sewer system. The SCA recommended rehabilitation of all three City-owned sewer lift stations due to identified deficiencies. The Lift Station Improvement Project was subsequently added to the CIP.

On January 10, 2021, the City awarded a Professional Services Agreement (PSA) to Dudek for the preparation of plans, specifications and estimates (PS&E). As the project scope evolved, the PSA was amended three times. On January 10, 2024, the City Council awarded a construction contract to CWS Systems Inc. for the Lift Station Improvement Project in the amount of $2,276,000 plus a $100,000 contingency. Council also approved PSAs with Z&K Consultants for construction management and inspection services ($230,000) and approved Dudek’s third amendment ($45,500) for engineering support during construction, bringing Dudek’s total compensation to $165,875. The construction support provided by both Dudek and Z&K Consultants, including daily monitoring, inspection, review of submittals and RFIs, and resolution of field issues, is critical to successful project delivery Following contract award, an administrative Notice to Proceed (NTP) allowed the Contractor to begin submittals and order long-lead electrical components.

Construction was initially expected to begin in late 2024; however, work began approximately four (4) months later than anticipated, on April 11, 2025 with completion originally scheduled on February 4, 2026. Since then, additional delays have occurred due to unforeseen site conditions, and extensions of the Dudek and Z&K agreements, currently expiring December 31, 2025, are now required to maintain construction support services through project completion.

DISCUSSION
Construction Notice to Proceed was issued later than anticipated due to extended lead times on critical electrical components and additional coordination during the administrative phase. Once construction began on April 11, 2025, further delays occurred due to unforeseen electrical deficiencies encountered at all three lift stations.

At Orlando Lift Station, the existing incoming electrical service wiring was found to be non-compliant with current National Electric Code (NCE) requirements. This necessitated redesign and coordination with Southern California Edison (SCE) for a new, legal, meter/main service connection.

Similar conditions were then identified at both Monterey and Avondale Lift Stations. Additionally, one of the existing pumps at Monterey Lift Station PAGE 198 of 704
originally not scheduled for replacement now requires replacement.

Procurement of the replacement pump has introduced additional delays due to required manufacturing lead times.

Construction at Orlando Lift Station is now complete. Staff are working closely with SCE and the contractor to resolve the pending issues at Monterey and Avondale Lift Stations.

Given the current construction schedule and the December 31, 2025 expiration of the Dudek and Z&K agreements, staff recommend approval of contract amendments to extend both agreements through June 30, 2026.

These amendments extend the contract terms only; no additional compensation is requested at this time. Staff will return to Council early next year with a comprehensive update on schedule and budget impacts associated with the unforeseen site conditions.

FISCAL IMPACT & PROCUREMENT REVIEW
The proposed contract amendments with Dudek and Z&K Consultants include no additional cost. Staff will return to the Council early next year with updates on project schedule and any required budget adjustments once the outstanding issues are fully resolved. No additional appropriation is required at this time.

LEGAL REVIEW
The City Attorney's office has reviewed and approved as to form.

RECOMMENDATION
Staff recommends that the City Council 1) approve Amendment No. 4 with Dudek for engineering services during construction for the Lift Station Improvement Project, extending the term through June 30, 2026, 2) approve Amendment No.1 with Z&K Consultants for construction management and inspection services for the Lift Station Improvement Project, extending the term through June 30, 2026, and 3) authorize the City Manager to execute the amendments on behalf of the City. If the City Council concurs with staff’s recommendation, an appropriate motion would be:
“I move to 1) approve Amendment No. 4 with Dudek for engineering services during construction for the Lift Station Improvement Project, extending the term through June 30, 2026, 2) approve Amendment No. 1 with Z&K Consultants for construction management and inspection services for the Lift Station Improvement Project, extending the term through June 30, 2026, and PAGE 199 of 704
3) authorize the City Manager to execute the amendments on behalf of the City.”

ATTACHMENTS

1. Draft Amendment No. 4 with Dudek

2. Original Agreement and Amendments No. 1, No. 2, and No. 3 with Dudek

3. Draft Amendment No. 1 with Z&K Consultants

4. Original Agreement with Z&K Consultants
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Doc No. 2547482
AMENDMENT NO. 4 TO AGREEMENT BETWEEN THE CITY OF SAN MARINO

AND DUDEK
THIS AMENDMENT NO. 4 TO THE AGREEMENT (“Amendment No. 3”) by and between the CITY OF SAN MARINO (“City”) and DUDEK a California corporation (“Contractor”) is effective as of December 10, 2025. City and Contractor are collectively referred to as the “Parties.”

RECITALS
A. City and Contractor entered into that certain Agreement for Professional Services dated February 10, 2021 (“Original Agreement”) whereby Contractor agreed to provide those professional services specified in the Original Agreement.

B. City and Contractor entered into Amendment No. 1 to the Original Agreement between the City and Contractor dated June 9, 2022 to include an additional twelve months of services from July 1, 2022 through June 30, 2023.

C. City and Contractor entered into Amendment No. 2 to the Original Agreement between the City and Contractor dated May 10, 2023, increasing the compensation amount by $47,100 and to include an additional six months of service from July 1, 2023 through December 31, 2023.

D. City and Contractor entered into Amendment No.3 to the Original Agreement between the City and Contractor dated January 10, 2024, increasing the compensation amount by $45,500 and to include an additional twenty-four months of service from January 1, 2024 through December 31, 2025.

E. City and Contractor now desire to amend the Original Agreement, as amended by Amendment No. 1, Amendment No. 2, and Amendment No.3, in accordance with Section 16 of the Agreement to include an additional six months of service from January 1, 2026 through June 30, 2026.

TERMS

1. Contract Changes. The Original Agreement is amended as provided herein.

A. Section 2 of the Original Agreement is amended to read as follows:

2.0 Term
The term of this Agreement shall commence as of the Effective Date and shall continue through June 30, 2026, unless sooner terminated as provided in Section

5.0 of this Agreement.

Continuing Effect of Agreement. Except as amended by Amendments No. 1, No. 2, No.3, and by this Amendment No. 4, all provisions of the Original Agreement shall remain PAGE 201 of 704
Doc No. 2453984
unchanged and in full force and effect. From and after the date of this Amendment No. 4, whenever the term “Agreement” appears in the Agreement, it shall mean the Original Agreement, as amended by Amendment No. 1, Amendment No. 2, Amendment No.3 and Amendment No. 4.

Authority. The persons executing this Amendment No. 4 on behalf of the Parties hereto warrant that (i) such party is duly organized and existing, (ii) they are duly authorized to execute and deliver this Amendment No. 4 on behalf of said party, (iii) by so executing this Amendment No. 4, such party is formally bound to the provisions of this Amendment No. 4, and (iv) the entering into this Amendment No. 4 does not violate any provision of any other agreement to which said party is bound.

IN WITNESS WHEREOF, the Parties hereto have executed this Amendment No. 4 as of the date and year first hereinabove written.

City of San Marino Dudek
By:_____________________________ By:______________________________ Philippe Eskandar Signature
City Manager
______________________________
Print Name and Title
Date:____________________________ Date: ____________________________ ATTEST: APPROVED AS TO FORM:
___________________________ ________________________________ Alison Walker Joseph Montes
City Clerk City Attorney
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AMENDMENT NO. 1 TO AGREEMENT BETWEEN THE CITY OF SAN MARINO

AND Z&K CONSULTANTS
THIS AMENDMENT NO. 1 TO THE AGREEMENT (“Amendment No. 1”) by and between the CITY OF SAN MARINO (“City”) and Z&K Consultants Consultant”) is effective as of December 10, 2025. City and Consultant are collectively referred to as the “Parties.”

RECITALS
A. City and Consultant entered into that certain Agreement for Professional Services dated January 10, 2024 (“Original Agreement”) whereby Consultant agreed to provide those services specified in the Original Agreement.

B. City and Consultant now desire to amend the Original Agreement C. City and Consultant now desire to amend the Original Agreement, in accordance with Section 16 of the Agreement to extend the term for an additional six months through June 30, 2026.

TERMS

1. Contract Changes. The Original Agreement is amended as provided herein.

A. Section 2.0 of the Original Agreement is amended to read as follows:

2.0 Term
The term of this Agreement shall commence on the effective date and shall continue through June 30, 2026 unless sooner terminated as provided in Section 5.0 of this Agreement.

IN WITNESS WHEREOF, the Parties hereto have executed this Amendment No. 1 as of the date and year first hereinabove written.

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City of San Marino Z&K Consultants
By:_____________________________ By:______________________________ Philippe Eskandar Signature
City Manager
______________________________
Print Name and Title
Date:____________________________ Date: ____________________________ ATTEST: APPROVED AS TO FORM:
___________________________ ________________________________ Alison Walker Joe Montes
City Clerk City Attorney
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TO: Mayor and City Council
FROM: Philippe Eskandar, City Manager
BY: Mario Rueda, Fire Chief
DATE: December 10, 2025
SUBJECT: ACCEPTANCE OF 2024 STATE HOMELAND SECURITY

PROGRAM (SHSP) GRANT FUNDS

STRATEGIC PLAN CRITICAL SUCCESS FACTORS
Efficient, Responsive, and Effective City Services
Fiscally Responsible and Transparent City Government
Safe Community

BACKGROUND
Every year, the U.S. Department of Homeland Security, Federal Emergency Management Agency, allocates grant funding through the State Homeland Security Program (SHSP) to enhance the capabilities of local agencies to prevent, respond to, and recover from disasters, emergencies, and other threats to homeland security. The Los Angeles County Chief Executive Office provides regional administration of the SHSP grant and has notified staff that $30,000 of grant funding is available to the San Marino Fire Department through the 2024 SHSP.

DISCUSSION
The State Homeland Security Program provides funding to support the implementation of risk-driven, capabilities-based State Homeland Security Strategies to address capability targets. The SHSP grant is 100% federally funded by the U.S. Department of Homeland Security and managed through the State of California’s Office of Emergency Services. There is no local match requirement; however, grant funding is reimbursement based. Funds cannot be used for general purposes and must be specified at the time of application.

Homeland Security purchases and training programs must be pre-approved Gretchen Shepherd Romey, Mayor
Tony Chou, Vice Mayor
Hunter Chang, Council Member
John Chou, Council Member
Calvin Lo, Council Member
PAGE 276 of 704
by the State and align with grant guidelines. The San Marino Fire Department has been approved for the purchase of unified response to violent incident rescue tools.

FISCAL IMPACT & PROCUREMENT REVIEW
The State Homeland Security Program grant has awarded the City of San Marino up to $30,000 in fully reimbursable grant funds, with no matching funds due from the City of San Marino. The acceptance of grant funds would require a FY 2025-26 budget increase of $30,000 to revenue Account #240- 00-3202-0000 Homeland Security Grant) and a budget increase of $30,000 to expenditure Account #240-30-4399-0000 (Non-Capitalized Equipment).

LEGAL REVIEW
The City Attorney's office has reviewed and approved as to form.

RECOMMENDATION
Staff recommends the Council 1) authorize the City Manager to accept the 2024 SHSP grant funds and execute the subrecipient agreement with the County of Los Angeles for a performance period of September 1, 2024, to May 31, 2027; and 2) approve budget amendments needed. If the City Council concurs with staff’s recommendation, an appropriate motion would be:
“I move to authorize the City Manager to accept the 2024 SHSP grant funds and 1) execute the subrecipient agreement with the County of Los Angeles for a performance period of September 1, 2024, to May 31, 2027; and 2) approve budget amendments needed.”

ATTACHMENTS

1. State Homeland Security Program Subrecipient Agreement Grant Year 2024 Between the County of Los Angeles and the City of San Marino PAGE 277 of 704
State Homeland Security Program
Subrecipient Agreement
Grant Year 2024
Between the
County of Los Angeles
and the
City of San Marino
PAGE 278 of 704

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SUBRECIPIENT AGREEMENT

BETWEEN THE

COUNTY OF LOS ANGELES
AND

THE CITY OF SAN MARINO
THIS AGREEMENT ("Agreement") is made and entered into by and between the County of Los Angeles, a political subdivision of the State of California (the "County of Los Angeles"), and the City of San Marino, a public agency (the "Subrecipient").

W I T N E S S E T H
WHEREAS, the U.S. Department of Homeland Security Title 2 Code of Federal Regulations (CFR) through the Office of Grants and Training (G&T), has provided financial assistance for the State Homeland Security Program (SHSP), Assistance Listings Number (formerly Catalog of Federal Domestic Assistance Number) 97.067 - Homeland Security Grant Program directly to the California Governor's Office of Emergency Services (Cal OES) for the 2024 SHSP, Federal Award Identification No. 037-00000, Federal Award dated October 28, 2024 with a performance period of September 1, 2024 to May 31, 2027. This Federal Award is not a R&D award; and WHEREAS, the Cal OES provides said funds to the County of Los Angeles, Unique Entity ID (UEI) #MKQ9AQH7R2S5, as its Subgrantee, and the Chief Executive Office (CEO) is responsible for managing and overseeing the SHSP funds that are distributed to other specified jurisdictions within Los Angeles County; and WHEREAS, this financial assistance is being provided to the Subrecipient in order to address the unique equipment, training, organization, exercise and planning needs of the Subrecipient, and to assist the Subrecipient in building effective prevention and protection capabilities to prevent, respond to, and recover from threats or acts of terrorism; and
WHEREAS, the County of Los Angeles as Subgrantee has obtained approval of the 2024 SHSP grant from Cal OES in the total amount of $8,300,952; and WHEREAS, the CEO now wishes to distribute 2024 SHSP grant funds to the Subrecipient in the amount of $30,000, as further detailed in this Agreement; and WHEREAS, the CEO is authorized to enter into subrecipient agreements with cities providing for re-allocation and use of these funds; and to execute all future amendments, modifications, extensions, and augmentations relative to the subrecipient agreements, as necessary; and
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WHEREAS, the County of Los Angeles and Subrecipient are desirous of executing this Agreement, and the County of Los Angeles Board of Supervisors on July 15, 2025 authorized the CEO to prepare and execute this Agreement.

NOW, THEREFORE, the County of Los Angeles and Subrecipient agree as follows:

SECTION I

INTRODUCTION
§101. Parties to this Agreement
The parties to this Agreement are:

A. County of Los Angeles, a political subdivision of the State of California, having its principal office at Kenneth Hahn Hall of Administration, 500 West Temple Street, Los Angeles, CA 90012; and
B. City of San Marino, a public agency, having its principal office at _____________ ________________________________________________________________. §102. Representatives of the Parties and Service of Notices A. The representatives of the respective parties who are authorized to administer this Agreement and to whom formal notices, demands and communications must be given are as follows:

1. The representative of the County of Los Angeles is, unless otherwise stated in this Agreement:

Craig Hirakawa
County of Los Angeles - Chief Executive Office
500 West Temple Street, Room 796
Los Angeles, CA 90012
Phone: (213) 974-1127
[email protected]
Ana Vazquez
County of Los Angeles - Chief Executive Office
500 West Temple Street, Room 796
Los Angeles, CA 90012
Phone: (213) 974-1178
[email protected]
2200 Huntington
Drive, San Marino, CA 91108
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2. The representative of Subrecipient is:

Name and Title:

Organizational UEI #:

Address:

City/State/Zip:

Phone:

Email:

With a copy to:

Name and Title:

Organization:

Address:

City/State/Zip:

Phone:

Email:

B. Formal notices, demands and communications to be given hereunder by either party must be made in writing and may be affected by personal delivery, regular U.S. Postal mail service and/or e-mail. In the event of personal delivery or email, the message will be deemed communicated upon receipt by the County of Los Angeles. In the event of mail service, the message will be deemed communicated as of the date of mailing.

C. If the name and/or title of the person designated to receive the notices, demands or communications or the address of such person is changed, written notice must be given, in accord with this section, within five (5) business days of said change.
§103. Independent Party
Subrecipient is acting hereunder as an independent party, and not as an agent or employee of the County of Los Angeles. An employee of Subrecipient is not, and Philippe Eskandar, City Manager
QDM5CHK63KL3
2200 Huntington Drive
San Marino, CA 91108
(626) 300-0700
[email protected]
Mario Rueda, Fire Chief
San Marino Fire Department
2200 Huntington Drive
San Marino, CA 91108
(626) 300-0735
[email protected]
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will not be deemed, an employee of the County of Los Angeles by virtue of this Agreement, and Subrecipient must so inform each employee organization and each employee who is hired or retained under this Agreement. Subrecipient must not represent or otherwise hold out itself or any of its directors, officers, partners, employees, or agents to be an agent or employee of the County of Los Angeles by virtue of this Agreement.
§104. Conditions Precedent to Execution of This Agreement Subrecipient must provide the following signed documents to the County of Los Angeles, unless otherwise exempted:

A. Certification and Disclosure Regarding Lobbying, attached hereto as Exhibit A and made a part hereof, in accordance with §411.A.14 of this Agreement.

Subrecipient must also file a Disclosure Form at the end of each calendar quarter in which there occurs any event requiring disclosure or which materially affects the accuracy of the information contained in any Disclosure Form previously filed by Subrecipient.

B. Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions, attached hereto as Exhibit B and made a part hereof, as required by Executive Order 12549 in accordance with §411.A.12 of this Agreement.

C. Certification Regarding Drug-Free Workplace, attached hereto as Exhibit C and made a part hereof, in accordance with §411.A.13 of this Agreement.

D. Certification of Grant Assurances, attached hereto as Exhibit D and made a part hereof, in accordance with §411.C of this Agreement.

SECTION II

TERM AND SERVICES TO BE PROVIDED
§201. Performance Period
The performance period of this Agreement is from September 1, 2024 to February 28, 2027, unless the County of Los Angeles, with Cal OES approval, provides written notification to the Subrecipient that the performance period has been extended, in which case the performance period will be so extended by such written notification, as provided in §503, below.

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§202. Use of Grant Funds
A. Subrecipient and the County of Los Angeles have previously completed a mutually approved budget/expenditure plan, hereinafter "Budget," for the 2024 SHSP, which has been approved by Cal OES. This information is contained in a copy of the Final Grant Award Letter and Project Worksheet, attached hereto as Exhibit E.

Any request by Subrecipient to modify the Budget must be made in writing with the appropriate justification and submitted to CEO for approval. If during the County of Los Angeles review process, additional information or documentation is required, the Subrecipient will have ten (10) business days to comply with the request. If the Subrecipient does not comply with the request, CEO will issue written notification indicating that the requested modification will not be processed. Modifications must be approved in writing by the County of Los Angeles and Cal OES during the term of this Agreement. Upon approval, all other terms of this Agreement will remain in effect.

Subrecipient must utilize grant funds in accordance with all Federal regulations and State Guidelines.

B. Subrecipient agrees that grant funds awarded will be used to supplement existing funds for program activities, and will not supplant (replace) non-Federal funds.

C. Subrecipient must review the Federal Debarment Listing at https://www.sam.gov/search/ prior to the purchase of equipment or services to ensure the intended vendor is not listed and also maintain documentation that the list was verified.

D. Prior to the purchase of equipment or services utilizing a sole source contract or the receipt of single bid response of $250,000.00 or more, justification must be presented to CEO, who upon review will request approval from Cal OES. Such approval in writing must be obtained prior to the commitment of funds.

E. Subrecipient must provide any certifications or reports requested by the County of Los Angeles to the CEO indicating Subrecipient's performance under this Agreement, including progress on meeting program goals. Reports must be in the form requested by the County of Los Angeles, and must be provided by the fifteenth (15th) of the following month. Subrecipient is required to complete any survey requests requested by the County of Los Angeles. Subrecipient must also submit completed Project Claims for reimbursement immediately or a minimum on a quarterly basis, and no later than the date stated in §201, above.

F. Subrecipient must provide an electronic copy of their Annual Single Audit Report, as required by Title 2 Code of Federal Regulations (C.F.R) Part 200, to the County of Los Angeles within 30 calendar days after receipt of the auditor's PAGE 283 of 704

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report(s). In the event the Subrecipient does not meet the Single Audit Threshold expenditure amount in a fiscal year, the Subrecipient must provide the County of Los Angeles a copy of a letter sent to State Controller's Office noting the Single Audit Threshold was not met, and its exempt status within nine months after the end of the Subrecipient's fiscal year, unless otherwise approved by the County of Los Angeles.

G. Subrecipient may be monitored by the County of Los Angeles on an annual basis to ensure compliance with Cal OES grant program requirements. The County of Los Angeles anticipates that said monitoring may include, at a minimum, one onsite visit during the term of this Agreement. Monitoring will utilize a Review Instrument (sample attached hereto as Exhibit H, and subject to periodic revisions) to evaluate compliance.

H. Subrecipient must provide Corrective Action Plan(s) to CEO within thirty (30) days of any audit finding.

I. Subrecipient use of the Los Angeles Regional Interoperable Communication System's Motorola Solutions, Incorporated Land Mobile Radio System Contract to purchase equipment is unallowable unless the Subrecipient can clearly demonstrate to CEO it meets one of the four federal exceptions to necessitate a noncompetitive procurement before issuance of any contract, amendment, or purchase order.

J. Subrecipient shall not use grant funds to purchase, extend, or renew any Telecommunications and Video Surveillance services and equipment as substantial or essential component of any system, or as critical technology as part of any system which the Secretary of Defense, in consultation with Director of National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an owned, controlled by, or connected to the People's Republic of China such as and not limited to Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities); or Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).

K. Any equipment acquired pursuant to this Agreement must be authorized in the G&T Authorized Equipment List (AEL) available online at https://www.fema.gov/authorized-equipment-list and the Funding Guidelines of the 2024 SHSP Notice of Funding Opportunity, incorporated by reference, and attached hereto as Exhibit F. Subrecipient must provide the CEO a copy of its most current procurement guidelines and follow its own procurement requirements as long as they meet or exceed the minimum Federal requirements and any added Cal OES requirements. Federal procurement requirements for the 2024 SHSP can be found at Title 2 CFR Part 200.313.

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Any equipment acquired or obtained with Grant Funds:

1. Will be made available under the California Disaster and Civil Defense Master Mutual Aid Agreement in consultation with representatives of the various fire, emergency medical, hazardous materials response services, and law enforcement agencies within the jurisdiction of the applicant;

2. Will be consistent with needs as identified in the State Homeland Security Strategy and will be deployed in conformance with that plan;

3. Will be made available pursuant to applicable terms of the California Disaster and Civil Defense Master Mutual Aid Agreement and deployed with personnel trained in the use of such equipment in a manner consistent with the California Law Enforcement Mutual Aid Plan or the California Fire Services and Rescue Mutual Aid Plan.

L. Equipment acquired pursuant to this Agreement will be subject to the requirements of Title 2 CFR Part 200.313. For the purposes of this subsection, "Equipment" is defined as tangible nonexpendable property, having a useful life of more than one year which costs $5,000.00 or more per unit. Items costing less than $5,000.00, but acquired under the "Equipment" category of the Grant must also be listed on any required Equipment Listing.

1. Equipment must be used by Subrecipient in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by Federal funds. When no longer needed for the original program or project, the Equipment may be used in other activities currently or previously supported by a Federal agency.

2. Subrecipient must make Equipment available for use on other like projects or programs currently or previously supported by the Federal Government, providing such use will not interfere with the work on the projects or program for which it was originally acquired. First preference for other use must be given to other programs or projects supported by the awarding agency.

3. An Equipment Listing must be maintained listing each item of Equipment acquired with SHSP funds. The Equipment Listing must be kept up to date at all times. Any changes must be recorded in the Listing within ten (10) business days and the updated Listing is to be forwarded to the County of Los Angeles Auditor-Controller (A-C) Shared Services Division. The Equipment Property Records must be maintained that include: (a) a description of the property, (b) a serial number or other identification number, (c) the source of property, (d) who holds title, (e) the acquisition date, (f) and cost of the property, (g) percentage of Federal participation in the cost of the property, (h) the location, (i) use and condition of the PAGE 285 of 704

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property, (j) and any ultimate disposition data including the date of disposal and sale price of the property. Records must be retained by the subrecipient pursuant to Title 2, Part 200.313 (d) (1) of the CFR.

4. All Equipment obtained under this Agreement must have an appropriate identification decal affixed to it, and, when practical, must be affixed where it is readily visible.

5. A physical inventory of the Equipment must be taken by the Subrecipient and the results reconciled with the Equipment Listing at least once every two years or prior to any site visit by State or Federal auditors or County of Los Angeles monitors. The Subrecipient is required to have on file a letter certifying as to the accuracy of the Equipment Listing in the frequency as above, and provide to the CEO when requested.

M. Any Planning paid pursuant to this Agreement must conform to the guidelines as listed in Exhibit F or subsequent grant year programs.

N. Any Organization activities paid pursuant to this Agreement must conform to the guidelines as listed in Exhibit F.

O. Any Training paid pursuant to this Agreement must conform to the guidelines as listed in Exhibit F, and must be first submitted to CEO and then pre-authorized by Cal OES. A catalog of federally approved and sponsored training courses is available at https://www.firstrespondertraining.gov/frts/.

P. Any Exercise paid pursuant to this Agreement must conform to the guidelines as listed in Exhibit F. Detailed Homeland Security Exercise and Evaluation Program Guidance is available at https://www.fema.gov/hseep.

Q. Any Personnel activities paid pursuant to this Agreement must conform to the guidelines as listed in Exhibit F.

R. Subrecipient must provide to CEO a spending plan detailing the required steps and timeframes required to complete the approved projects within the grant timeframe. Subrecipient must submit the spending plan to CEO prior to final execution of this Agreement.

S. Pursuant to this Agreement, indirect costs are not reimbursable.

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SECTION Ill

PAYMENT
§301. Payment of Grant Funds and Method of Payment
A. The County of Los Angeles will reimburse Subrecipient up to the maximum grant amount of $30,000 as expenditures are incurred and paid by Subrecipient and all documentation is reviewed and approved by County of Los Angeles. All expenditures must be for the purchase of equipment, exercises, training, organization, and planning as described in Section II of this Agreement. The grant amount represents the amount allocated to Subrecipient in the 2024 SHSP Grant Award Letter from Cal OES.

B. Subrecipient must submit reimbursement requests to the County of Los Angeles A-C Shared Services Division requesting payment as soon as a Project is completed and expenses are incurred and paid with the required supporting documentation; submission can be sent immediately or at a minimum on a quarterly basis, and no later than the date stated in §201, above. Each reimbursement request must be accompanied by the Reimbursement Form (sample attached hereto as Exhibit G, and subject to periodic revisions). All appropriate back-up documentation must be attached to the reimbursement form, including the method of procurement, bid documentation, purchase orders, invoices, report of goods received, and proof of payment.

For Training reimbursements, Subrecipient must include a copy of the class roster verifying training attendees, proof that prior approval was obtained from Cal OES and that a Cal OES Feedback number has been assigned to the course, and timesheets and payroll registers for all training attendees.

For Exercise reimbursements, Subrecipient must enter the After Action Report (AAR) and Improvement Plan on the State Office of Domestic Preparedness secure portal within sixty (60) days following completion of the exercise and submit proof of prior State approval of the AAR with the reimbursement request.

For Planning reimbursements, Subrecipient must include a copy of the final tangible product.

C. The County of Los Angeles may, at its discretion, reallocate unexpended grant funds to another subrecipient. Said reallocation may occur upon approval by the County of Los Angeles of a Subrecipient reimbursement submission, inquiry from the County of Los Angeles to the Subrecipient regarding fund utilization, or by written notification from the Subrecipient to the County of Los Angeles that a portion of the grant funds identified in PAGE 287 of 704

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§301.A., above, will not be utilized. As provided in §503, below, any increase or decrease in the grant amount specified in §301.A., above, may be effectuated by a written notification by the County of Los Angeles to the Subrecipient.

D. Payment of reimbursement request will be withheld by the County of Los Angeles until the County of Los Angeles has determined that Subrecipient has turned in all supporting documentation and completed the requirements of this Agreement.

E. It is understood that the County of Los Angeles makes no commitment to fund this Agreement beyond the terms set forth herein.

F. Funding for all periods of this Agreement is subject to continuing Federal appropriation of grant funds for this program. In the event of a loss or reduction of Federal appropriation of grant funds for this program, the Agreement may be terminated, or appropriately amended, immediately upon notice to Subrecipient of such loss or reduction of Federal grant funds.

County of Los Angeles will make a good-faith effort to notify Subrecipient, in writing, of such non-appropriation at the earliest time.

SECTION IV

STANDARD PROVISIONS
§401. Construction of Provisions and Titles Herein
All titles or subtitles appearing herein have been inserted for convenience and do not, and will not be deemed to, affect the meaning or construction of any of the terms or provisions hereof. The language of this Agreement will be construed according to its fair meaning and not strictly for or against either party. §402. Applicable Law, Interpretation and Enforcement
Each party's performance hereunder must comply with all applicable laws of the United States of America, the State of California, and the County of Los Angeles.

This Agreement will be enforced and interpreted, as applicable, under the laws of the United States of America, the State of California and the County of Los Angeles.

If any part, term or provision of this Agreement is held void, illegal, unenforceable, or in conflict with any law of a Federal, State or Local Government having jurisdiction over this Agreement, the validity of the remainder of the Agreement will not be affected thereby.

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Applicable Federal or State requirements that are more restrictive will be followed.
§403. Integrated Agreement
This Agreement sets forth all of the rights and duties of the parties with respect to the subject matter hereof, and replaces any and all previous agreements or understandings, whether written or oral, relating thereto. This Agreement may be amended only as provided for herein.
§404. Breach
If any party fails to perform, in whole or in part, any promise, covenant, or agreement set forth herein, or should any representation made by it be untrue, any aggrieved party may avail itself of all rights and remedies, at law or equity, in the courts of law. Said rights and remedies are cumulative of those provided for herein except that in all events, no party may recover more than once, suffer a penalty or forfeiture, or be unjustly compensated.
§405. Prohibition Against Assignment or Delegation
Subrecipient may not do any of the following, unless it has first obtained the written permission of the County of Los Angeles:

A. Assign or otherwise alienate any of its rights hereunder, including the right to payment; or
B. Delegate, subcontract, or otherwise transfer any of its duties hereunder. §406. Permits
Subrecipient and its officers, agents and employees must obtain and maintain all permits and licenses necessary for Subrecipient's performance hereunder and must pay any fees required therefor. Subrecipient further certifies that it will immediately notify the County of Los Angeles of any suspension, termination, lapse, non-renewal or restriction of licenses, certificates, or other documents. §407. Nondiscrimination and Affirmative Action
Subrecipient must comply with the applicable nondiscrimination and affirmative action provisions of the laws of the United States of America, the State of California, and the County of Los Angeles. In performing this Agreement, Subrecipient must not discriminate in its employment practices against any employee or applicant for employment because of such person's race, religion, PAGE 289 of 704

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national origin, ancestry, sex, sexual orientation, age, physical handicap, mental disability, marital status, domestic partner status or medical condition.

Subrecipient must comply with Executive Order 11246, entitled "Equal Employment Opportunity," as amended by Executive Order 11375, and as supplemented in Department of Labor regulations (41 CFR Part 60).

If required, Subrecipient must submit an Equal Employment Opportunity Plan to the Department of Justice Office of Civil Rights in accordance with guidelines listed at https://www.justice.gov/crt.

Any subcontract entered into by the Subrecipient relating to this Agreement, to the extent allowed hereunder, will be subject to the provisions of this §407 of this Agreement.
§408. Indemnification
Each of the parties to this Agreement is a public entity. This indemnity provision is written in contemplation of the provisions of Section 895.2 of the Government Code of the State of California, which impose certain tort liability jointly upon public entities, solely by reason of such entities being parties to an agreement, and the parties agree that this indemnity provision will apply and will be enforceable regardless of whether Section 895 et seq. is deemed to apply to this Agreement. The parties hereto, as between themselves, consistent with the authorization contained in Government Code Sections 895.4 and 895.6 agree to each assume the full liability imposed upon it or upon any of its officers, agents, or employees by law, for injury caused by a negligent or wrongful act or omission occurring in the performance of this Agreement, to the same extent that such liability would be imposed in the absence of Government Code Section 895.2.

To achieve the above-stated purpose, each party agrees to indemnify and hold harmless the other party for any liability arising out of its own negligent acts or omissions in the performance of this Agreement (i.e., the Subrecipient agrees to indemnify and hold harmless the County of Los Angeles for liability arising out of the Subrecipient's negligent or wrongful acts or omissions and the County of Los Angeles agrees to indemnify and hold harmless the Subrecipient for liability arising out of the County of Los Angeles' negligent or wrongful acts or omissions). Each party further agrees to indemnify and hold harmless the other party for liability that is imposed on the other party solely by virtue of Government Code Section 895.2. The provisions of Section 2778 of the California Civil Code are made a part hereof as if fully set forth herein. Subrecipient certifies that it has adequate self-insured retention of funds to meet any obligation arising from this Agreement.

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§409. Conflict of Interest
A. The Subrecipient covenants that none of its directors, officers, employees, or agents may participate in selecting, or administrating, any subcontract supported (in whole or in part) by Federal funds where such person is a director, officer, employee or agent of the subcontractor; or where the selection of subcontractors is or has the appearance of being motivated by a desire for personal gain for themselves or others such as family business, etc.; or where such person knows or should have known that:

1. A member of such person's immediate family, or domestic partner or organization has a financial interest in the subcontract;

2. The subcontractor is someone with whom such person has or is negotiating any prospective employment; or

3. The participation of such person would be prohibited by the California Political Reform Act, California Government Code §87100 et seq. if such person were a public officer, because such person would have a "financial or other interest" in the subcontract.

B. Definitions:

1. The term "immediate family" means domestic partner and/or those persons related by blood or marriage, such as husband, wife, father, mother, brother, sister, son, daughter, father in law, mother in law, brother in law, sister in law, son in law, daughter in law.

2. The term "financial or other interest" means:
a. Any direct or indirect financial interest in the specific contract, including but not limited to, a commission or fee, a share of the proceeds, prospect of a promotion or of future employment, a profit, or any other form of financial reward.
b. Any of the following interests in the subcontractor ownership:
partnership interest or other beneficial interest of five percent or more; ownership of five percent or more of the stock; employment in a managerial capacity; or membership on the board of directors or governing body.

C. The Subrecipient further covenants that no officer, director, employee, or agent may solicit or accept gratuities, favors, or anything of monetary value from any actual or potential subcontractor, supplier, a party to a sub agreement, (or persons who are otherwise in a position to benefit from the actions of any officer, employee, or agent).

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D. The Subrecipient may not subcontract with a former director, officer, or employee within a one-year period following the termination of the relationship between said person and the Subrecipient.

E. Prior to obtaining the County of Los Angeles' approval of any subcontract, the Subrecipient must disclose to the County of Los Angeles any relationship, financial or otherwise, direct or indirect, of the Subrecipient or any of its officers, directors or employees or their immediate family with the proposed subcontractor and its officers, directors or employees.

F. For further clarification of the meaning of any of the terms used herein, the parties agree that references are made to the guidelines, rules, and laws of the County of Los Angeles, State of California, and Federal regulations regarding conflict of interest.

G. The Subrecipient warrants that it has not paid or given and will not pay or give to any third person any money or other consideration for obtaining this Agreement.

H. The Subrecipient covenants that no member, officer or employee of Subrecipient may have interest, direct or indirect, in any contract or subcontract or the proceeds thereof for work to be performed in connection with this project during his/her tenure as such employee, member or officer or for one year thereafter.

I. The Subrecipient must incorporate the foregoing subsections of this Section into every agreement that it enters into in connection with this grant and must substitute the term "subcontractor" for the term "Subrecipient" and "sub subcontractor" for "Subcontractor".
§410. Restriction on Disclosures
Any reports, analyses, studies, drawings, information, or data generated as a result of this Agreement are to be governed by the California Public Records Act (California Government Code Sec. 6250 et seq.).
§411. Statutes and Regulations Applicable To All Grant Contracts A. Subrecipient must comply with all applicable requirements of State, Federal, and County of Los Angeles laws, executive orders, regulations, program and administrative requirements, policies and any other requirements governing this Agreement. Subrecipient must comply with applicable State and Federal laws and regulations pertaining to labor, wages, hours, and other conditions of employment. Subrecipient must comply with new, amended, or revised laws, regulations, and/or procedures that apply to the performance of this Agreement.

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These requirements include, but are not limited to:

1. CFR
Subrecipient must comply with Title 2 CFR Part 200.

2. Single Audit Act
Since Federal funds are used in the performance of this Agreement, Subrecipient must, as applicable, adhere to the rules and regulations of the Single Audit Act (31 USC Sec. 7501 et seq.), 2 CFR Part 200 and any administrative regulation or field memos implementing the Act.

3. Americans with Disabilities Act
Subrecipient hereby certifies that, as applicable, it will comply with the Americans with Disabilities Act 42, USC §§12101 et seq., and its implementing regulations. Subrecipient will provide reasonable accommodations to allow qualified individuals with disabilities to have access to and to participate in its programs, services and activities in accordance with the provisions of the Americans with Disabilities Act. Subrecipient will not discriminate against persons with disabilities nor against persons due to their relationship to or association with a person with a disability. Any subcontract entered into by Subrecipient, relating to this Agreement, to the extent allowed hereunder, will be subject to the provisions of this paragraph.

4. Political and Sectarian Activity Prohibited
None of the funds, materials, property or services provided directly or indirectly under this Agreement may be used for any partisan political activity, or to further the election or defeat of any candidate for public office. Neither may any funds provided under this Agreement be used for any purpose designed to support or defeat any pending legislation or administrative regulation. None of the funds provided pursuant to this Agreement may be used for any sectarian purpose or to support or benefit any sectarian activity.

Subrecipient must file a Disclosure Form at the end of each calendar quarter in which there occurs any event requiring disclosure or which materially affects the accuracy of any of the information contained in any Disclosure Form previously filed by Subrecipient. Subrecipient must require that the language of this Certification be included in the award documents for all subawards at all tiers and that all subcontractors certify and disclose accordingly.

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5. Records Inspection
At any time during normal business hours and as often as either the County of Los Angeles, the U.S. Comptroller General or the Auditor General of the State of California may deem necessary, Subrecipient must make available for examination all of its records with respect to all matters covered by this Agreement. The County of Los Angeles, the U.S. Comptroller General and the Auditor General of the State of California have the authority to audit, examine and make excerpts or transcripts from records, including all Subrecipient's method of procurement, invoices, materials, payrolls, records of personnel, conditions of employment and other data relating to all matters covered by this Agreement.

Subrecipient agrees to provide any reports requested by the County of Los Angeles regarding performance of this Agreement.

6. Records Maintenance
Records, in their original form, must be maintained in accordance with requirements prescribed by the County of Los Angeles with respect to all matters specified in this Agreement. Original forms are to be maintained on file for all documents specified in this Agreement. Such records must be retained for a period five (5) years after termination of this Agreement and after final disposition of all pending matters. "Pending matters" include, but are not limited to, an audit, litigation or other actions involving records. The County of Los Angeles may, at its discretion, take possession of, retain and audit said records. Records, in their original form pertaining to matters covered by this Agreement, must at all times be retained within the County of Los Angeles unless authorization to remove them is granted in writing by the County of Los Angeles.

7. Subcontracts and Procurement
Subrecipient must, as applicable, comply with the Federal, State and County of Los Angeles standards in the award of any subcontracts. For purposes of this Agreement, subcontracts include but are not limited to purchase agreements, rental or lease agreements, third party agreements, consultant service contracts and construction subcontracts.

Subrecipient must, as applicable, ensure that the terms of this Agreement with the County of Los Angeles are incorporated into all Subcontractor agreements. The Subrecipient must submit all Subcontractor agreements to the County of Los Angeles for review prior to the release of any funds to the Subcontractor. The Subrecipient must withhold funds to any Subcontractor agency that fails to comply with the terms and conditions of this Agreement and their respective Subcontractor agreement.

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8. Labor
Subrecipient must, as applicable, comply with the Intergovernmental Personnel Act of 1970 (42 U.S.C. §§4728-4763) relating to prescribed requirements for merit systems for programs funded under one of the 19 statutes or regulations specified in Appendix A of OPM's Standards for a Merit System Personnel Administration (5 CFR 900, Subpart F).

Subrecipient must, as applicable, comply with the provisions of the DavisBacon Act (40 U.S.C. §§276a to 276a-7); the Copeland Act (40 U.S.C. §276c and 18 U.S.C. §874); the Contract Work Hours and Safety Standards Act (40 U.S.C. §§327-333), regarding labor standards for federally-assisted construction subagreements; and the Hatch Act (5 USC §§1501-1508 and 7324-7328).

Subrecipient must, as applicable, comply with the Federal Fair Labor Standards Act (29 U.S.C. §201) regarding wages and hours of employment.

None of the funds may be used to promote or deter union/labor organizing activities. CA Gov't Code Sec. 16645 et seq.

9. Civil Rights
Subrecipient must, as applicable, comply with all Federal statutes relating to nondiscrimination. These include but are not limited to: (a) Title VI of the Civil Rights Act of 1964 (P.L. 88-352), which prohibits discrimination on the basis of race, color or national origin; (b) Title IX of the Education Amendments of 1972, as amended (20 U.S.C. §§1681- 1683, and 1685- 1686), which prohibits discrimination on the basis of sex; (c) Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. §794), which prohibits discrimination on the basis of disabilities; (d) the Age Discrimination Act of 1975, as amended (42 U.S.C. §§6101-6107), which prohibits discrimination on the basis of age; (e) the Drug Abuse Office and Treatment Act of 1972 (P.L. 92-255), as amended, relating to nondiscrimination on the basis of drug abuse; (f) the Comprehensive Alcohol Abuse and Alcoholism Prevention, Treatment and Rehabilitation Act of 1970 (P.L. 91-616), as amended, relating to nondiscrimination on the basis of alcohol abuse or alcoholism; (g) §§523 and 527 of the Public Health Service Act of 1912 (42 U.S.C. §§290 dd-3 and 290 ee 3), as amended, relating to confidentiality of alcohol and drug abuse patient records; (h) Title VIII of the Civil Rights Act of 1968 (42 U.S.C. §§3601 et seq.), as amended, relating to non-discrimination in the sale, rental or financing of housing; (i) any other nondiscrimination provisions in the specific statute(s) under which application for Federal assistance is being made; 0) the requirements of any other nondiscrimination statute(s) that may apply to the application; and (k) P.L. 93-348 regarding the protection of human PAGE 295 of 704

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subjects involved in research, development, and related activities supported by this award of assistance.

10.Environmental
Subrecipient must, as applicable, comply, or has already complied, with the requirements of Titles II and Ill of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (P.L. 91-646), which provide for fair and equitable treatment of persons displaced or whose property is acquired as a result of Federal or federally-assisted programs. These requirements apply to all interests in real property acquired for project purposes regardless of Federal participation in purchases.

Subrecipient must, as applicable, comply with environmental standards which may be prescribed pursuant to the following: (a) institution of environmental quality control measures under the National Environmental Policy Act of 1969 (P.L. 91-190) and Executive Order (EO) 11514; (b) notification of violating facilities pursuant to EO 11738; (c) protection of wetlands pursuant to EO 11990; (d) evaluation of flood hazards in floodplains in accordance with EO 11988; (e) assurance of project consistency with the approved State management program developed under the Coastal Zone Management Act of 1972 (16 U.S.C. §§1451 et seq.); (f) conformity of Federal actions to State (Clean Air) Implementation Plans under Section 176(c) of the Clean Air Act of 1955, as amended (42 U.S.C. §§7401 et seq.); (g) protection of underground sources of drinking water under the Safe Drinking Water Act of 1974, as amended (P.L. 93- 523); (h) protection of endangered species under the Endangered Species Act of 1973, as amended (P.L. 93205); and (i) Flood Disaster Protection Act of 1973 §102(a) (P.L. 93-234).

Subrecipient must, as applicable, comply with the Wild and Scenic Rivers Act of 1968 (16 U.S.C. §§1271 et seq.) related to protecting components or potential components of the national wild and scenic rivers system.

Subrecipient must, as applicable, comply with the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. §§4801 et seq.), which prohibits the use of lead-based paint in construction or rehabilitation of residence structures.

Subrecipient must, as applicable, comply with the Federal Water Pollution Control Act (33 U.S.C. §1251 et seq.), which restores and maintains the chemical, physical and biological integrity of the Nation's waters.

Subrecipient must, as applicable, ensure that the facilities under its ownership, lease or supervision that are utilized in the accomplishment of this project are not listed in the Environmental Protection Agency's (EPA) list of Violating Facilities and that it will notify the Federal Granter agency of the receipt of any communication from the Director of the EPA Office of Federal PAGE 296 of 704

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Activities indicating that a facility to be used in the project is under consideration for listing by the EPA.

By signing this Agreement, Subrecipient warrants and represents that it will, as applicable, comply with the California Environmental Quality Act (CEQA), Public Resources Code §21000 et seq.

Subrecipient must, as applicable, comply with the Energy Policy and Conservation Act (P.L. 94-163, 89 Stat. 871).

Subrecipient must, as applicable, comply with the provision of the Coastal Barrier Resources Act (P.L. 97-348) dated October 19, 1982 (16 U.S.C. 3501 et. seq.) which prohibits the expenditure of most new Federal funds within the units of the Coastal Barrier Resources System.

11.Preservation
Subrecipient must, as applicable, comply with Section 106 of the National Historic Preservation Act of 1966, as amended (16 U.S.C. §470), EO 11593 (identification and protection of historic properties), and the Archaeological and Historic Preservation Act of 1974 (16 U.S.C. §§469a-1 et seq.).

12.Suspension, Debarment, Ineligibility and Voluntary Exclusion Subrecipient must, as applicable, comply with Title 2 CFR Part §3000, regarding Suspension and Debarment, and Subrecipient must submit a Certification Regarding Debarment, attached hereto as Exhibit B, required by Executive Order 12549 and any amendment thereto. Said Certification must be submitted to the County of Los Angeles concurrent with the execution of this Agreement and must certify that neither Subrecipient nor its principals are presently debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from participation in this transaction by any Federal department head or agency. Subrecipient must require that the language of this Certification be included in the award documents for all sub-award at all tiers and that all subcontractors certify accordingly.

13.Drug-Free Workplace
Subrecipient must, as applicable, comply with the federal Drug-Free Workplace Act of 1988, 41 USC §701, Title 44 Code of Federal Regulations (CFR) Part §17; the California Drug-Free Workplace Act of 1990, CA Gov't Code §§8350-8357, and Subrecipient must complete the Certification Regarding Drug-Free Workplace Requirements, attached hereto as Exhibit C, and incorporated herein by reference. Subrecipient must require that the language of this Certification be included in the award documents for all subaward at all tiers and that all subcontractors certify accordingly.

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14.Lobbying Activities
Subrecipient must, as applicable, comply with 31 U.S.C.1352 and complete the Disclosure of Lobbying Activities, (OMB 0038-0046), attached hereto as Exhibit A, and incorporated herein by reference.

15.Miscellaneous
Subrecipient must, as applicable, comply with the Laboratory Animal Welfare Act of 1966, as amended (P.L. 89-544, 7 USC §§2131 et seq.).

B. Statutes and Regulations Applicable To This Particular Grant Agreement Subrecipient must comply with all applicable requirements of State and Federal laws, executive orders, regulations, program and administrative requirements, policies and any other requirements governing this particular grant program.

Subrecipient must, as applicable, comply with new, amended, or revised laws, regulations, and/or procedures that apply to the performance of this Agreement.

These requirements include, but are not limited to:

Title 2 CFR Part 200; EO 12372; U.S. Department of Homeland Security, Office of State and Local Government Coordination and Preparedness, Office for Domestic Preparedness, ODP WMD Training Course Catalogue; and DOJ Office for Civil Rights.

Standardized Emergency Management System (SEMS) requirements as stated in the California Emergency Services Act, Government Code Chapter 7 of Division 1 of Title 2, §8607.1(e) and CCR Title 19, §§2445-2448.

Provisions of Title 2, 6, 28, 44 CFR applicable to grants and cooperative agreements, including Part 18, Administrative Review Procedures; Part 20, Criminal Justice Information Systems; Part 22, Confidentiality of Identifiable Research and Statistical Information; Part 23, Criminal Intelligence Systems Operating Policies; Part 30, Intergovernmental Review of Department of Justice Programs and Activities; Part 35, Nondiscrimination on the Basis of Disability in State and Local Government Services; Part 38, Equal Treatment of Faith-based Organizations; Part 42, Nondiscrimination/Equal Employment Opportunities Policies and Procedures; Part 61, Procedures for Implementing the National Environmental Policy Act; Part 63, Floodplain Management and Wetland Protection Procedures; Part 64, Floodplain Management and Wetland Protection Procedures; Federal laws or regulations applicable to Federal Assistance Programs; Part 69, New Restrictions on Lobbying; Part 70, Uniform Administrative Requirements for Grants and Cooperative Agreements (including sub-awards) with Institutions of Higher Learning, Hospitals and other Non-Profit PAGE 298 of 704

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Organizations; and Part 83, Government-Wide Requirements for a Drug Free Workplace (grants).

Nondiscrimination requirements of the Omnibus Crime Control and Safe Streets Act of 1968, as amended, 42 USC 3789(d), or the Juvenile Justice and Delinquency Prevention Act, or the Victims of Crime Act, as appropriate; the provisions of the current edition of the Office of Justice Programs Financial and Administrative Guide for Grants, M7100.1, and all other applicable Federal laws, orders, circulars, or regulations.

1. Travel Expenses
Subrecipient, as provided herein, will be compensated for Subrecipient's reasonable travel expenses incurred in the performance of this Agreement, to include travel and per diem, unless otherwise expressed. Subrecipient's total travel for in-State and/or out-of-State and per diem costs must be included in the contract budget(s). All travel, including out- of-State travel, that is not included in the budget(s) will not be reimbursed without prior written authorization from the County of Los Angeles.

Subrecipient's administrative-related travel and per diem reimbursement costs will not be reimbursed. For programmatic-related travel costs, Subrecipient's reimbursement rates may not exceed the amounts established under the grant.

C. Compliance With Grant Requirements
To obtain the grant funds, the State required an authorized representative of the County of Los Angeles to sign certain promises regarding the way the grant funds would be spent. These requirements are included in Exhibit F and in the State's "Grant Assurances". By signing these Grant Assurances and accepting Exhibit F, the County of Los Angeles became liable to the State for any funds that are used in violation of the grant requirements. The State's Grant Assurances are incorporated into this Agreement through Exhibit D. Subrecipient will be liable to the Granter for any funds the State determines the Subrecipient used in violation of these Grant Assurances.

Pursuant to this Agreement, Subrecipient shall execute the 2024 Certification of Grant Assurances in Exhibit D, accepting and agreeing to abide by all provisions, assurances, and requirements therein. Subrecipient agrees to indemnify and hold harmless the County of Los Angeles for any sums the State or Federal government determines Subrecipient used in violation of the Grant Assurances.

To the extent Exhibit D conflicts with language or provisions contained in this Agreement, or contains more restrictive requirements under Federal and State law, Exhibit D shall control.

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D. Noncompliance With Grant Requirements
Subrecipient understands that failure to comply with any of the above assurances and requirements, including Exhibit D, may result in suspension, termination or reduction of grant funds, and repayment by the Subrecipient to the County of Los Angeles of any unauthorized expenditures.
§412. Federal, State and Local Taxes
Federal, State and local taxes are the responsibility of the Subrecipient as an independent party and not of the County of Los Angeles and must be paid prior to requesting reimbursement. However, these taxes are an allowable expense under the grant program.
§413. Inventions, Patents and Copyrights
A. Reporting Procedure for Inventions
If any project produces any invention or discovery ("Invention") patentable or otherwise under Title 35 of the U.S. Code, including, without limitation, processes and business methods made in the course of work under this Agreement, the Subrecipient must report the fact and disclose the Invention promptly and fully to the County of Los Angeles. The County of Los Angeles will report the fact and disclose the Invention to the State. Unless there is a prior agreement between the County of Los Angeles and the State, the State will determine whether to seek protection on the Invention. The State will determine how the rights in the Invention, including rights under any patent issued thereon, will be allocated and administered in order to protect the public interest consistent with the policy ("Policy") embodied in the Federal Acquisition Regulations System, which is based on Ch. 18 of Title 35 U.S.C. Sections 200 et seq. (Pub. L. 95-517, Pub. L. 98-620, Title 37 CFR Part 401); Presidential Memorandum on Government Patent Policy to the Heads of the Executive Departments and Agencies, dated 2/18/1983); and Executive Order 12591, 4/10/87, 52 FR 13414, Title 3 CFR, 1987 Comp., p. 220 (as amended by Executive Order 12618, 12/22/87, 52 FR 48661, Title 3 CFR, 1987 Comp., p. 262). Subrecipient hereby agrees to be bound by the Policy, and will contractually require its personnel to be bound by the Policy.

B. Rights to Use Inventions
As applicable, County of Los Angeles will have an unencumbered right, and a non-exclusive, irrevocable, royalty-free license to use, manufacture, improve upon, and allow others to do so for all government purposes, any Invention developed under this Agreement.

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C. Copyright Policy

1. Unless otherwise provided by the State or the terms of this Agreement, when copyrightable material ("Material") is developed under this Agreement, the County of Los Angeles, at its discretion, may copyright the Material. If the County of Los Angeles declines to copyright the Material, the County of Los Angeles will have an unencumbered right, and a non-exclusive, irrevocable, royalty-free license, to use, manufacture, improve upon, and allow others to do so for all government purposes, any Material developed under this Agreement.

2. The State will have an unencumbered right, and a non-exclusive, irrevocable, royalty-free license, to use, manufacture, improve upon, and allow others to do so for all government purposes, any Material developed under this Agreement or any Copyright purchased under this Agreement.

3. Subrecipient must comply with Title 24 CFR 85.34.

D. Rights to Data
The State and the County of Los Angeles will have unlimited rights or copyright license to any data first produced or delivered under this Agreement. "Unlimited rights" means the right to use, disclose, reproduce, prepare derivative works, distribute copies to the public, and perform and display publicly, or permit others to do so; as required by Title 48 CFR 27.401. Where the data are not first produced under this Agreement or are published copyrighted data with the notice of 17 U.S.C. Section 401 or 402, the State acquires the data under a copyright license as set forth in Title 48 CFR 27.404(f)(2) instead of unlimited rights. (Title 48 CFR 27.404(a)).

E. Obligations Binding on Subcontractors
Subrecipient must require all subcontractors to comply with the obligations of this section by incorporating the terms of this section into all subcontracts. §414. Child Support Assignment Orders
Under the terms of this Agreement, Subrecipient must, as applicable, comply with California Family Code Section 5230 et seq.
§415. Minority, Women, And Other Business Enterprise Outreach Program It is the policy of the County of Los Angeles to provide Minority Business Enterprises, Women Business Enterprises and all other business enterprises an equal opportunity to participate in the performance of all Subrecipient's contracts, PAGE 301 of 704

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including procurement, construction and personal services. This policy applies to all of the Subrecipient's contractors and sub-contractors. §416. Compliance with Fair Chance Employment Practices
Subrecipient shall comply with fair chance employment hiring practices set forth in California Government Code Section 12952, Employment Discrimination:

Conviction History. Subrecipient's violation of this paragraph of the Agreement may constitute a material breach of the Agreement. In the event of such material breach, County of Los Angeles may, in its sole discretion, terminate the Agreement.
§417. Method of Payment and Required Information
The County of Los Angeles may, at its sole discretion, determine the most appropriate, efficient, secure, and timely form of payment provided under this Agreement. Subrecipient further agrees that the default form of payment shall be Electronic Funds Transfer (EFT) or Direct Deposit, unless an alternative method of payment is deemed appropriate by the A-C.

Subrecipient shall provide the A-C with electronic banking and related information for the Subrecipient and/or any other payee that the Subrecipient designates to receive payment pursuant to this Agreement at
https://directdeposit.lacounty.gov/. Such electronic banking and related information includes, but is not limited to: bank account number and routing number, legal business name, valid taxpayer identification number or TIN, a working e-mail address capable of receiving remittance advices and other payment related correspondence, and any other information that the A-C determines is reasonably necessary to process the payment and comply with all accounting, record keeping, and tax reporting requirements.

Any provision of law, grant, or funding agreement requiring a specific form or method of payment other than EFT or Direct Deposit shall supersede this requirement with respect to those payments. At any time during the duration of this Agreement, the Subrecipient may submit a written request for an exemption to this requirement and must be based on specific legal, business or operational needs and explain why the payment method designated by the A-C is not feasible and an alternative is necessary. The A-C, in consultation with CEO, shall decide whether to approve exemption requests.

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SECTION V

DEFAULTS, SUSPENSION, TERMINATION, AND AMENDMENTS
§501. Defaults
Should either party fail for any reason to comply with the contractual obligations of this Agreement within the time specified by this Agreement, the non-breaching party reserves the right to terminate the Agreement, reserving all rights under State and Federal law.
§502. Termination
This Agreement may be terminated, in whole or in part, from time to time, when such action is deemed by the County of Los Angeles, in its sole discretion, to be in its best interest. Termination of work hereunder shall be effected by notice of termination to the Subrecipient specifying the extent to which performance of work is terminated and the date upon which such termination becomes effective.

The date upon which such termination becomes effective shall be no less than ten (10) days after the notice is sent.
§503. Amendments
Except as otherwise provided in this paragraph, any change in the terms of this Agreement, including changes in the services to be performed by Subrecipient, that are agreed to by the Subrecipient and the County of Los Angeles must be incorporated into this Agreement by a written amendment properly signed by persons who are authorized to bind the parties. Notwithstanding the foregoing, any increase or decrease of the grant amount specified in §301.A., above, or any extension of the performance period specified in §201, above, does not require a written amendment, but may be effectuated by a written notification by the County of Los Angeles to the Subrecipient.

SECTION VI

ENTIRE AGREEMENT
§601. Complete Agreement
This Agreement contains the full and complete Agreement between the two parties. Neither verbal agreement nor conversation or other communication with any officer or employee of either party will affect or modify any of the terms and conditions of this Agreement.

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§602. Number of Pages and Attachments
This Agreement may be executed utilizing wet, scanned digital, and electronic signatures, each of which is deemed to be an original. This Agreement includes (27) pages and (8) Exhibits which constitute the entire understanding and agreement of the parties.
[Remainder of this page intentionally left blank]
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IN WITNESS WHEREOF, the Subrecipient and the County of Los Angeles have caused this Agreement to be executed by their duly authorized representatives.

COUNTY OF LOS ANGELES
BY
FESIA A. DAVENPORT Date
Chief Executive Officer
BY ______________________________

EDWARD YEN
Executive Officer, Board of Supervisors
BY ______________________________

OSCAR VALDEZ
Auditor-Controller

APPROVED AS TO FORM
DAWYN R. HARRISON
County Counsel
BY
Deputy County Counsel

CITY OF SAN MARINO
BY ___________________________________________________ _________________ City Representative/Title (Signature) (Print Name) Date

APPROVED AS TO FORM
BY ___________________________________________________ _________________ City Attorney (Signature – If Needed) (Print Name) Date ATTEST
BY ___________________________________________________ _________________ City Clerk (Signature – If Needed) (Print Name) Date
PAGE 305 of 704

EXHIBITS
Exhibit A Certification and Disclosure Regarding Lobbying Exhibit B Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions
Exhibit C Certification Regarding Drug Free Workplace
Exhibit D Certification of Grant Assurances
Exhibit E Final Grant Award Letter and Project Worksheet Exhibit F 2024 Notice of Funding Opportunity & 2024 Cal OES Supplemental to Federal Notice of Funding Opportunity
Exhibit G Reimbursement Form and Instructions
Exhibit H Monitoring Instrument
PAGE 306 of 704
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PAGE 308 of 704

CERTIFICATION REGARDING

DEBARMENT, SUSPENSION, INELIGIBILITY AND VOLUNTARY EXCLUSION

LOWER TIER COVERED TRANSACTIONS
This certification is required by the regulations Implementing Executive Order 12549, Debarment and Suspension, 24 CFR Part 24 Section 24.510, Participants' responsibilities.
(READ ATTACHED INSTRUCTIONS FOR CERTIFICATION BEFORE

COMPLETING)

1. The prospective recipient of Federal assistance funds certifies that neither it nor its principals are presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from participation in this transaction by any Federal department or agency.

2. Where the prospective recipient of Federal assistance funds is unable to certify to any of the statements in this certification, such prospective participant shall attach an explanation to this proposal.

AGREEMENT NUMBER

CONTRACTOR/BORROWER/AGENCY

NAME AND TITLE OF AUTHORIZED REPRESENTATIVE

SIGNATURE DATE

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EXHIBIT B
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PAGE 310 of 704

STATE OF CALIFORNIA

DRUG-FREE WORKPLACE CERTIFICATION
STD. 21
COMPANY/ORGANIZATION NAME:

The contractor or grant recipient named above hereby certifies compliance with Government Code Section 8355 in matters relating to providing a drug-free workplace. The above-named contractor or recipient will:

1. Publish a statement notifying employees that unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance is prohibited and specifying actions to be taken against employees for violations, as required by Government Code Section 8355(a). 2. Establish a Drug-Free Awareness Program as required by Government Code Section 8355(b), to inform employees about all of the following:
(a) The dangers of drug abuse in the workplace,
(b) The person’s or organization’s policy of maintaining a drug-free workplace, (c) Any available counseling, rehabilitation and employee assistance programs, and (d) Penalties that may be imposed upon employees for drug abuse violations.

3. Provide as required by Government Code Section 8355(c), that every employee who works on the proposed contract or subgrant:
(a) Will receive a copy of the company’s drug-free policy statement, and (b) Will agree to abide by the terms of the company’s statement as a condition of employment on the contract or subgrant.

CERTIFICATION
I, the official named below, hereby swear that I am duly authorized legally to bind the contractor or Recipient to the above described certification. I am fully aware that this certification, executed on the date and in the county below, is made under penalty of perjury under the laws of the State of California.

OFFICAL’S NAME DATE EXECUTED

EXECUTED IN THE COUNTY OF
CONTRACTOR or RECEIPEINT SIGNATURE
TITLE
FEDERAL I.D. NUMBER
PAGE 311 of 704

STATEMENT ON THE DRUG-FREE WORKPLACE
To comply with the enactment of Senate Bill 1120, (Chapter 1170, Statutes of 1990), which established the Drug-Free Workplace Act of 1990, the
(your agency)
accordingly provides this statement of compliance.

In order to maintain funding eligibility, state agencies, along with those in receipt of grant and contractual awards, must certify that they provide drug-free workplaces and have issued drug-free workplace statements to their employees [Section 8355(a) of the Government Code]. Consequently, in accordance with this directive, this statement is issued to meet this requirement.

The (your agency), an agency within the State of California has adopted this statement in compliance with legislation which addresses issues to avoid the dangers arising from drug and alcohol abuse in the workplace. These dangers include death and injury to the employee, co-workers, or the public resulting from accidents, dereliction of duty, poor judgment and carelessness. Substance abuse also results in lost productivity, reduced efficiency, and increased absenteeism by the substance abuser and interferes with the job performance of employees who do not use illegal or unauthorized substances. [Section 8355(b)(1)]
California law prohibits the unlawful manufacture, dispensation, possession, or illegal use of a controlled substance. That prohibition extends to all places and includes the worksite of California state employees. [Section 8355(a)]
Employees convicted of a violation of criminal drug statute, when the violation occurred at an employee’s worksite, shall report the conviction to the granting and monitoring State agency upon conviction. [Section 8356(a)(1)(2)]
In the event of the unlawful manufacture, distribution, dispensation, possession or illegal use of a controlled substance at a State worksite, the State may take disciplinary action pursuant to the law and/or require the satisfactory completion of a drug abuse assistance or rehabilitation program. [Section 8355(b)(4)] The Employee Assistance Program (EAP) provides drug problem assessment and referral to appropriate counseling and rehabilitation services. The EAP is available to all agency employees. Procedures exist to ensure the confidentiality of EAP records. Contact your personnel office for further information.

It is the intent of the (your agency) to ensure by execution of this statement of compliance that each employee shall abide by the terms of this drug-free workplace statement. [Section 8355(c)]
PAGE 312 of 704
FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
As the duly authorized representative of the Applicant, I hereby certify that the Applicant has the legal authority to apply for federal assistance and the institutional, managerial, and financial capability (including funds sufficient to pay any non-federal share of project cost) to ensure proper planning, management, and completion of the project described in this application, within prescribed timelines.

The requirements outlined in these assurances apply to Applicant and any of its subrecipients.

I further acknowledge that the Applicant is responsible for reviewing and adhering to all requirements within the:
(a) Applicable Federal Regulations (see below);
(b) Federal Program Notice of Funding Opportunity (NOFO); (c) Federal Preparedness Grants Manual;
(d) California Supplement to the NOFO; and
(e) Federal and State Grant Program Guidelines.

Federal Regulations
Government cost principles, uniform administrative requirements, and audit requirements for federal grant programs are set forth in Title 2, Part 200 of the Code of Federal Regulations (C.F.R.) and adopted by the Department of Homeland Security (DHS) at 2 C.F.R. Part 3002.10. Updates are issued by the Office of Management and Budget (OMB) and can be found at http://www.whitehouse.gov/omb/.

In the event Cal OES determines that changes are necessary to the subaward after a subaward has been made, including changes to period of performance or terms and conditions, Applicants will be notified of the changes in writing. Once notification has been made, any subsequent request for funds will indicate Applicant acceptance of the changes to the subaward.

State and federal grant award requirements are set forth below. The Applicant hereby agrees to comply with the following:

1. Proof of Authority
The Applicant will obtain proof of authority from the city council, governing board, or authorized body in support of this project. This written authorization must specify that the Applicant and the city council, governing board, or authorized body agree:

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Non-Disaster Preparedness Grant Programs
(a) To provide all matching funds required for the grant project and that any cash match will be appropriated as required;
(b) Any liability arising out of the performance of this agreement shall be the responsibility of the Applicant and the city council, governing board, or authorized body;
(c) Grant funds shall not be used to supplant expenditures controlled by the city council, governing board, or authorized body;
(d) The Applicant is authorized by the city council, governing board, or authorized body to apply for federal assistance, and the institutional, managerial and financial capability (including funds sufficient to pay the non-federal share of project cost, if any) to ensure proper planning, management and completion of the project described in this application; and
(e) The official executing this agreement is authorized by the Applicant.

This Proof of Authority must be maintained on file and readily available upon request.

2. Period of Performance
The period of performance is specified in the Award. The Applicant is only authorized to perform allowable activities approved under the award, within the period of performance.

3. Lobbying and Political Activities
As required by Section 1352, Title 31 of the United States Code (U.S.C.), for persons entering into a contract, grant, loan, or cooperative agreement from an agency or requests or receives from an agency a commitment providing for the United States to insure or guarantee a loan, the Applicant certifies that:
(a) No federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of an 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.

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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
(b) If any funds other than federal 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.
(c) The Applicant shall require that the language of this certification be included in the award documents for all subawards at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly.

The Applicant will also comply with provisions of the Hatch Act (5 U.S.C. §§ 1501- 1508 and §§ 7324-7328) which limit the political activities of employees whose principal employment activities are funded in whole or in part with federal funds.

Finally, the Applicant agrees that federal funds will not be used, directly or indirectly, to support the enactment, repeal, modification or adoption of any law, regulation, or policy without the express written approval from the California Governor’s Office of Emergency Services (Cal OES) or the federal awarding agency.

4. Debarment and Suspension
As required by Executive Orders 12549 and 12689, and 2 C.F.R. § 200.214 and codified in 2 C.F.R. Part 180, Debarment and Suspension, the Applicant will provide protection against waste, fraud, and abuse by debarring or suspending those persons deemed irresponsible in their dealings with the federal government. The Applicant certifies that it and its subrecipients:
(a) Are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by any federal department or agency;
(b) Have not within a three-year period preceding this application been convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (federal, state, or local) transaction or contract under a public transaction; violation of federal or state antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property;

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Non-Disaster Preparedness Grant Programs
(c) Are not presently indicted for or otherwise criminally or civilly charged by a governmental entity (federal, state, or local) with commission of any of the offenses enumerated in paragraph (4)(b) of this certification; and (d) Have not within a three-year period preceding this application had one or more public transaction (federal, state, or local) terminated for cause or default.

Where the Applicant is unable to certify to any of the statements in this certification, he or she shall attach an explanation to this application.

5. Non-Discrimination and Equal Employment Opportunity
The Applicant will comply with all state and federal statutes relating to nondiscrimination, including:
(a) Title VI of the Civil Rights Act of 1964 (Public Law (P.L.) 88-352 and 42 U.S.C. § 2000d et. seq.) which prohibits discrimination on the basis of race, color, or national origin and requires that recipients of federal financial assistance take reasonable steps to provide meaningful access to persons with limited English proficiency (LEP) to their programs and services; (b) Title IX of the Education Amendments of 1972, (20 U.S.C. §§ 1681-1683, and 1685-1686), which prohibits discrimination on the basis of sex in any federally funded educational program or activity;
(c) Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794), which prohibits discrimination against those with disabilities or access and functional needs; (d) Americans with Disabilities Act (ADA) of 1990 (42 U.S.C. § 12101et seq.), which prohibits discrimination on the basis of disability and requires buildings and structures be accessible to those with disabilities and access and functional needs;
(e) Age Discrimination Act of 1975, (42 U.S.C. §§ 6101-6107), whichprohibits discrimination on the basis of age;
(f) Public Health Service Act of 1912 (42 U.S.C. §§ 290 dd—2), relating to confidentiality of patient records regarding substance abuse treatment; (g) Title VIII of the Civil Rights Act of 1968 (42 U.S.C. § 3601 et seq.), relating to nondiscrimination in the sale, rental or financing of housing as implemented by the Department of Housing and Urban Development at 24 C.F.R. Part100. The prohibition on disability discrimination includes the requirement that new multifamily housing with four or more dwelling units — i.e., the public and common use areas and individual apartment units (all units in buildings with elevators and ground-floor units in buildings without elevators) — be designed and constructed with certain accessible features (See 24 C.F.R. § 100.201);

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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
(h) Executive Order 11246, which prohibits federal contractors and federally assisted construction contractors and subcontractors, who do over $10,000 in Government business in one year from discriminating in employment decisions on the basis of race, color, religion, sex, sexual orientation, gender identification or national origin;
(i) Executive Order 11375, which bans discrimination on the basis of race, color, religion, sex, sexual orientation, gender identification, or national origin in hiring and employment in both the United States federal workforce and on the part of government contractors;
(j) California Public Contract Code § 10295.3, which prohibits discrimination based on domestic partnerships and those in same sex marriages; (k) DHS policy to ensure the equal treatment of faith-based organizations, under which the Applicant must comply with equal treatment policies and requirements contained in
6 C.F.R. Part 19;
(l) The California’s Fair Employment and Housing Act (FEHA) (California Government Code §§12940-12957), as applicable. FEHA prohibits harassment and discrimination in employment because of ancestry, familial status, race, color, religious creed (including religious dress and grooming practices), sex (which includes pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy, childbirth or breastfeeding), gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, mental and physical disability, genetic information, medical condition, age, pregnancy, denial of medical and family care leave, or pregnancy disability leave, military and veteran status, and/or retaliation for protesting illegal discrimination related to one of these categories, or for reporting patient abuse in tax supported institutions;
(m)Any other nondiscrimination provisions in the specific statute(s) under which application for federal assistance is being made; and
(n) The requirements of any other nondiscrimination statute(s) that may apply to this application.

Civil Rights Policies for Program Beneficiaries and Subrecipients of DHS funding, pertaining to the following are available on the Cal OES website:
• Non-discrimination in Programs & Services
• Reasonable Accommodation for Program Beneficiaries
• Language Access Policy

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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs

6. Drug-Free Workplace
As required by the Drug-Free Workplace Act of 1988 (41 U.S.C. § 701 et seq.),the Applicant certifies that it will maintain a drug-free workplace and a drug-free awareness program as outlined in the Act.

7. Environmental Standards
The Applicant will comply with state and federal environmental standards, including:
(a) The California Environmental Quality Act (CEQA) (California Public Resources Code §§ 21000-21177), to include coordination with the city or county planning agency;
(b) CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3, §§ 15000-15387);
(c) The Federal Clean Water Act (CWA) (33 U.S.C. § 1251 et seq.), which establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters; (d) The Federal Clean Air Act of 1955 (42 U.S.C. § 7401) which regulates air emissions from stationary and mobile sources;
(e) Institution of environmental quality control measures under the National Environmental Policy Act (NEPA) of 1969 (P.L. 91-190); the Council on Environmental Quality Regulations for Implementing the Procedural Provisions of NEPA; and Executive Order 12898 which focuses on the environmentaland human health effects of federal actions on minority and low-income populations with the goal of achieving environmental protection for all communities;
(f) Evaluation of flood hazards in floodplains in accordance with Executive Order 11988;
(g) Executive Order 11514 which sets forth national environmental standards; (h) Executive Order 11738 instituted to assure that each federal agency empowered to enter into contracts for the procurement of goods, materials, or services and each federal agency empowered to extend federal assistance by way of grant, loan, or contract shall undertake such procurement and assistance activities in a manner that will result in effective enforcement of the Clean Air Act and the Federal Water Pollution Control Act Executive Order 11990 which requires preservation of wetlands;
(i) The Safe Drinking Water Act of 1974, (P.L. 93-523); (j) The Endangered Species Act of 1973, (P.L. 93-205);

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Non-Disaster Preparedness Grant Programs
(k) Assurance of project consistency with the approved state management program developed under the Coastal Zone Management Act of 1972 (16 U.S.C. §§1451 et seq.);
(l) Conformity of Federal Actions to State (Clear Air) Implementation Plans under Section 176(c) of the Clean Air Act of 1955, as amended (42 U.S.C. §§7401 et seq.); and
(m)The Wild and Scenic Rivers Act of 1968 (16 U.S.C. § 1271 et seq.) related to protecting components or potential components of the national wild and scenic rivers system.

The Applicant shall not be: 1) in violation of any order or resolution promulgated by the State Air Resources Board or an air pollution district; 2) subject to a cease-anddesist order pursuant to section 13301 of the California Water Code for violation of waste discharge requirements or discharge prohibitions; or 3) determined to be in violation of federal law relating to air or water pollution.

8. Audits
For subrecipients expending $1,000,000 or more in federal grant funds annually, the Applicant will perform the required financial and compliance audits in accordance with the Single Audit Act Amendments of 1996 and C.F.R., Part 200, Subpart F Audit Requirements.

9. Cooperation and Access to Records
The Applicant must cooperate with any compliance reviews or investigations conducted by DHS. In accordance with 2 C.F.R. § 200.337, the Applicant will give the awarding agency, the Comptroller General of the United States and, if appropriate, the state, through any authorized representative, access to and the right to examine all records, books, papers, or documents related to the award. The Applicant will require any subrecipients, contractors, successors, transferees and assignees to acknowledge and agree to comply with this provision.

10. Conflict of Interest
The Applicant will establish safeguards to prohibit the Applicant’s employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain.

11. Financial Management
False Claims for Payment - The Applicant will comply with 31 U.S.C §§ 3729-3733 which provides that Applicant shall not submit a false claim for payment, reimbursement, or advance.

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Non-Disaster Preparedness Grant Programs

12. Reporting - Accountability
The Applicant agrees to comply with applicable provisions of the Federal Funding Accountability and Transparency Act (FFATA) (P.L. 109-282), including but not limited to (a) the reporting of subawards obligating $30,000 or more in federal funds, and (b) executive compensation data for first-tier subawards as set forth in 2 C.F.R. Part 170, Appendix A. The Applicant also agrees to comply with the requirements set forth in the government-wide financial assistance award term regarding the System for Award Management and Universal Identifier Requirements located at 2 C.F.R.

Part 25, Appendix A.

13. Whistleblower Protections
The Applicant must comply with statutory requirements for whistleblower protections at 10 U.S.C. § 2409, 41 U.S.C. § 4712, and 10 U.S.C. § 2324, 41 U.S.C. § 4304 and § 4310.

14. Human Trafficking
The Applicant will comply with the requirements of Section 106(g) of the Trafficking Victims Protection Act of 2000, as amended (22 U.S.C. § 7104) which prohibits the Applicant or its subrecipients from: (1) engaging in trafficking in persons during the period of time that the award is in effect; (2) procuring a commercial sex act during the period of time that the award is in effect; or (3) using forced labor in the performance of the award or subawards under the award.

15. Labor Standards
The Applicant will comply with the following federal labor standards:
(a) The Davis-Bacon Act (40 U.S.C. §§ 276a to 276a-7), as applicable, and the Copeland Act (40 U.S.C. § 3145 and 18 U.S.C. § 874) and the Contract Work Hours and Safety Standards Act (40 U.S.C. §§ 327-333), regarding labor standards for federally-assisted construction contracts or subcontracts, and (b) The Federal Fair Labor Standards Act (29 U.S.C. § 201 et seq.) as they apply to employees of institutes of higher learning (IHE), hospitals and other nonprofit organizations.

16. Worker’s Compensation
The Applicant must comply with provisions which require every employer to be insured to protect workers who may be injured on the job at all times during the performance of the work of this Agreement, as per the workers compensation laws set forth in California Labor Code §§ 3700 et seq.

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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs

17. Property-Related
If applicable to the type of project funded by this federal award, the Applicant will:
(a) Comply with the requirements of Titles II and III of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (P.L. 91-646) which provide for fair and equitable treatment of persons displaced or whose property is acquired as a result of federal or federally-assisted programs. These requirements apply to all interests in real property acquired for project purposes regardless of federal participation in purchase;
(b) Comply with flood insurance purchase requirements of Section 102(a) of the Flood Disaster Protection Act of 1973 (P.L. 93-234) which requires federal award subrecipients in a special flood hazard area to participate in the program and to purchase flood insurance if the total cost of insurable construction and acquisition is $10,000 or more;
(c) Assist the awarding agency in assuring compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (16 U.S.C. § 470), Executive Order 11593 (identification and protection of historic properties), and the Archaeological and Historic Preservation Act of 1974 (16 U.S.C. § 469a-1 et seq.); and
(d) Comply with the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. § 4831 and 24 CFR Part 35) which prohibits the use of lead-based paint in construction or rehabilitation of residence structures.

18. Certifications Applicable Only to Federally-Funded Construction Projects For all construction projects, the Applicant will:
(a) Not dispose of, modify the use of, or change the terms of the real property title or other interest in the site and facilities without permission and instructions from the awarding agency. Will record the federal awarding agency directives and will include a covenant in the title of real property acquired in whole or in part with federal assistance funds to assure nondiscrimination during the useful life of the project;
(b) Comply with the requirements of the awarding agency with regard to the drafting, review and approval of construction plans and specifications; and (c) Provide and maintain competent and adequate engineering supervision at the construction site to ensure that the complete work conforms with the approved plans and specifications and will furnish progressive reports and such other information as may be required by the assistance awarding agency or State.

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Non-Disaster Preparedness Grant Programs

19. Use of Cellular Device While Driving is Prohibited
The Applicant is required to comply with California Vehicle Code sections 23123 and 23123.5. These laws prohibit driving motor vehicle while using an electronic wireless communications device to write, send, or read a text-based communication. Drivers are also prohibited from the use of a wireless telephone without hands-free listening and talking, unless to make an emergency call to 911, law enforcement, or similar services.

20. California Public Records Act and Freedom of Information Act The Applicant acknowledges that all information submitted in the course of applying for funding under this program, or provided in the course of an entity’s grant management activities that are under Federal control, is subject to the Freedom of Information Act (FOIA), 5 U.S.C. § 552, and the California Public Records Act, California Government Code §7920.000 et seq. The Applicant should consider these laws and consult its own State and local laws and regulations regarding the release of information when reporting sensitive matters in the grant application, needs assessment, and strategic planning process.

21. Acknowledgment of Federal Funding from DHS
The Applicant must acknowledge its use of federal funding when issuing statements, press releases, requests for proposals, bid invitations, and other documents describing projects or programs funded in whole or in part with federal funds.

22. Activities Conducted Abroad
The Applicant must coordinate with appropriate government authorities when performing project activities outside the United States and obtain all appropriate licenses, permits, or approvals.

23. Best Practices for Collection and Use of Personally Identifiable Information (PII) DHS defines PII as any information that permits the identity of an individual to be directly or indirectly inferred, including any information that is linked or linkable to that individual. If the Applicant collects PII, the Applicant is required to have a publicly-available privacy policy that describes standards on the usage and maintenance of the PII they collect. The Applicant may refer to the DHS Privacy Impact Assessments: Privacy Guidance and Privacy Template as a useful resource.

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Non-Disaster Preparedness Grant Programs

24. Copyright
Recipients must affix the applicable copyright notices of 17 U.S.C. §§ 401 or 402 to any work first produced under federal awards and also include an acknowledgement that the work was produced under a federal award (including the federal award number and federal awarding agency). As detailed in 2 C.F.R. § 200.315, a federal awarding agency reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes and to authorize others to do so.

25. Duplicative Costs
Applicants are prohibited from charging any cost to this federal award that will be included as a cost or used to meet cost sharing or matching requirements of any other federal award in either the current or a prior budget period. (See 2 C.F.R. § 200.403(f)).

However, recipients may shift costs that are allowable under two or more federal awards where otherwise permitted by federal statutes, regulations, or the federal financial assistance award terms and conditions.

26. Energy Policy and Conservation Act
The Applicant must comply with the requirements of 42 U.S.C. § 6201 which contain policies relating to energy efficiency that are defined in the state energy conservation plan issued in compliance with this Act.

27. Federal Debt Status
The Applicant is required to be non-delinquent in its repayment of any federal debt.

Examples of relevant debt include delinquent payroll and other taxes, audit disallowances, and benefit overpayments. See OMB Circular A-129.

28. Fly America Act of 1974
The Applicant must comply with Preference for United States Flag Air Carriers:
(a list of certified air carriers can be found at: Certificated Air Carriers List | US Department of Transportation, https://www.transportation.gov/policy/aviationpolicy/certificated-air-carriers-list) for international air transportation of people and property to the extent that such service is available, in accordance with the International Air Transportation Fair Competitive Practices Act of 1974 (49 U.S.C. § 40118) and the interpretative guidelines issued by the Comptroller General of the United States in the March 31, 1981, amendment to Comptroller General Decision B-138942.

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EXHIBIT D
PAGE 323 of 704
FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs

29. Hotel and Motel Fire Safety Act of 1990
In accordance with Section 6 of the Hotel and Motel Fire Safety Act of 1990, the Applicant must ensure that all conference, meeting, convention, or training space funded in whole or in part with federal funds complies with the fire prevention and control guidelines of the Federal Fire Prevention and Control Act of 1974, as amended, 15 U.S.C. § 2225a.

30. Non-supplanting Requirement
If the Applicant receives federal financial assistance awards made under programs that prohibit supplanting by law, the Applicant must ensure that federal funds do not replace (supplant) funds that have been budgeted for the same purpose through non- federal sources.

31. Patents and Intellectual Property Rights
Recipients are subject to the Bayh-Dole Act, 35 U.S.C. § 200 et seq. and applicable regulations governing inventions and patents, including the regulations issued by the Department of Commerce at 37 C.F.R. Part 401 (Rights to Inventions Made by Nonprofit Organizations and Small Business Firms under Government Awards, Contracts, and Cooperative Agreements) and the standard patent rights clause set forth at 37 C.F.R. § 401.14.

32. SAFECOM
If the Applicant receives federal financial assistance awards made under programs that provide emergency communication equipment and its related activities, the Applicant must comply with the SAFECOM Guidance for Emergency Communication Grants, including provisions on technical standards that ensure and enhance interoperable communications.

33. Terrorist Financing
The Applicant must comply with Executive Order 13224 and United States law that prohibit transactions with, and the provisions of resources and support to, individuals and organizations associated with terrorism. The Applicant is legally responsible for ensuring compliance with the Order and laws.

34. Reporting of Matters Related to Recipient Integrity andPerformance If the total value of the Applicant’s currently active grants, cooperative agreements, and procurement contracts from all federal assistance offices exceeds $10,000,000 for any period of time during the period of performance of this federal financial assistance award, the Applicant must comply with the requirements set forth in the

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EXHIBIT D
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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
government-wide Award Term and Condition for Recipient Integrity and Performance Matters located at 2 C.F.R. Part 200, Appendix XII, the full text of which is incorporated here by reference in the award terms and conditions.

35. USA Patriot Act of 2001
The Applicant must comply with requirements of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act), which amends 18 U.S.C. §§ 175–175c.

36. Use of DHS Seal, Logo, and Flags
The Applicant must obtain written permission from DHS prior to using the DHS seals, logos, crests, or reproductions of flags, or likenesses of DHS agency officials. This includes use of DHS component (e.g., FEMA, CISA, etc.) seals, logos, crests, or reproductions of flags, or likenesses of component officials.

37. Performance Goals (HSGP and NSGP)
In addition to the Biannual Strategy Implementation Report submission requirements outlined in the Preparedness Grants Manual, the Applicant must demonstrate how the grant-funded project addresses the core capability gap associated with each project. The capability gap reduction must be addressed in the Project Description of the BSIR for each project.

38. Applicability of DHS Standard Terms and Conditions to Tribes The DHS Standard Terms and Conditions are a restatement of general requirements imposed upon the Applicant and flow down to any of its subrecipients as a matter of law, regulation, or executive order. If the requirement does not apply to Indian tribes or there is a federal law or regulation exempting its application to Indian tribes, then the acceptance by Tribes of, or acquiescence to, DHS Standard Terms and Conditions does not change or alter its inapplicability to an Indian tribe. The execution of grant documents is not intended to change, alter, amend, or impose additional liability or responsibility upon the Tribe where it does not already exist.

39. Required Use of American Iron, Steel, Manufactured Products, and Construction Materials
The Applicant must comply with the “Build America, Buy America” Act (BABAA), enacted as part of the Infrastructure Investment and Jobs Act and Executive Order 14005. Applicants receiving a federal award subject to BABAA requirements may not use federal financial assistance funds for infrastructure projects unless:

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EXHIBIT D
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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
(a) All iron and steel used in the project are produced in the United States – this means all manufacturing processes, from the initial melting stage through the application of coatings, occurred in the United States; (b) All manufactured products used in the project are produced in the United States – this means the manufactured product was manufactured in the United States; and the cost of the components of the manufactured product that are mined, produced, or manufactured in the United States is greater than 55 percent of the total cost of all components of the manufactured product, unless another standard for determining the minimum amount of domestic content of the manufactured product has been established under applicable law or regulation; and (c) All construction materials are manufactured in the United States – this means that all manufacturing processes for the construction material occurred 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. It 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.

Per section 70914(c) of BABAA, FEMA may waive the application of a Buy America preference under an infrastructure program in certain cases.

40. E.O. 14074 – Advancing Effective, Accountable Policing and Criminal Justice Practices to Enhance Public Trust and Public Safety
Recipient State, Tribal, local, or territorial law enforcement agencies must comply with the requirements of section 12(c) of E.O. 14074. Recipient State, Tribal, local, or territorial law enforcement agencies are also encouraged to adopt and enforce policies consistent with E.O. 14074 to support safe and effective policing.

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EXHIBIT D
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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs

IMPORTANT
The purpose of these assurances is to obtain federal and state financial assistance, including any and all federal and state grants, loans, reimbursement, contracts, etc.

Applicant recognizes and agrees that state financial assistance will be extended based on the representations made in these assurances. These assurances are binding on Applicant, its successors, transferees, assignees, etc. as well as any of its subrecipients.

Failure to comply with any of the above assurances may result in suspension, termination, or reduction of grant funds.

All appropriate documentation, as outlined above, must be maintained on file by the Applicant and available for Cal OES or public scrutiny upon request. Failure to comply with these requirements may result in suspension of payments under the grant or termination of the grant or both and the Applicant may be ineligible for award of any future grants if Cal OES determines that the Applicant: (1) has made false certification, or (2) violates the certification by failing to carry out the requirements as noted above.

All of the language contained within this document must be included in the award documents for all subawards at all tiers. Applicants are bound by the DHS Standard Terms and Conditions 2024, Version 2, hereby incorporated by reference, which can be found at: https://www.dhs.gov/publication/fy15-dhs- standard-terms-and-conditions.

The undersigned represents that he/she is authorized to enter into this agreement for and on behalf of the Applicant.

Applicant:

Signature of Authorized Agent:

Printed Name of Authorized Agent:

Title: Date:

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EXHIBIT D
PAGE 327 of 704

GAVIN NEWSOM

GOVERNOR

NANCY WARD

DIRECTOR
3650 SCHRIEVER AVENUE, MATHER, CA 95655
(916) 845-8506 TELEPHONE (916) 845-8511 FAX
www.CalOES.ca.gov
October 28, 2024
Fesia A. Davenport DELIVERED VIA E-MAIL: [email protected] Chief Executive Officer
Los Angeles County
500 West Temple Street, Room 713
Los Angeles, CA 90012
SUBJECT: NOTIFICATION OF SUBRECIPIENT ALLOCATION
Fiscal Year (FY) 2024 Homeland Security Grant Program (HSGP) Grant Subaward Period of Performance: 09/01/2024-05/31/2027 Dear Ms. Davenport:

We are pleased to announce the approval of your FY 2024 HSGP subaward in the amount of $8,300,952.

This subaward is subject to requirements in 2 CFR, Part 200, including the Notice of Funding Opportunity (NOFO), the Preparedness Grants Manual, the California Supplement to the NOFO, reporting requirements, and all applicable federal, state, and local requirements. All activities funded with this subaward must be completed within the subaward period of performance.

Your organization will be required to prepare and submit the Biannual Strategy Implementation Report (BSIR) to Cal OES semi-annually for the duration of the subaward period of performance or until all activities are completed and the subaward is formally closed. Throughout the subaward cycle, milestones set in the BSIR will be used as indicators of project feasibility, performance, and grant management capacity.

This information may also be used in assessing proposals in future grant opportunities.

Failure to submit required reports could result in subaward reduction, suspension, or termination.

Subrecipients must obtain additional approval prior to incurring costs for

EXHIBIT E
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Fesia A. Davenport
October 28, 2024

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__________________________________ __________________
Fesia A. Davenport Date
Los Angeles County
activities such as aviation, watercraft, allowability request logs, noncompetitive procurement, and projects requiring Environmental Planning and Historic Preservation review.

Next Steps:
x Your signature is required on this letter. Please sign and return this letter via email to your Cal OES Grants Analyst (GA) within 20 calendar days of receipt and keep a copy for your records.
x If you have not already, please visit the Grants Central System (GCS) webpage to register your organization.
x You will be notified to complete your application as soon as it is available in GCS – we anticipate mid-January 2025.
x Once the completed application is submitted and approved in GCS, you will be able to request reimbursement of eligible subaward expenditures in the system.

Please contact your GA if you have questions or need further assistance.

Sincerely,

NANCY WARD
Director
Fesia Davenport (Nov 6, 2024 11:40 PST)
Fesia Davenport

EXHIBIT E
PAGE 329 of 704
City of San Marino Ledger Type Initial Application
FY 2024 State Homeland Security Program (SHSP) Projects Date 3/12/2025 Cal OES ID: 037-00000 Request # 0
Grant #: 2024-0088 POP Start Date 9/1/2024
POP End Date 5/31/2027
IJ State Goals Direct /
Subaward
Project
Number Project Title Funding Source Discipline Solution Area Core Capability Capability Building Deployable /
Shareable
Supports Previous
Awarded Investment? Total Budgeted Cost
IJ.05 Goal #6 Subaward 032 FS URVI Equipment 2 HSGP-SHSP FS Equipment Threats and Hazards Identification Build Deployable No $ 30,000
National Priority Area (NPA) Total $ 30,000

PROJECT LEDGER

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EXHIBIT E
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City of San Marino Ledger Type Initial Application
FY 2024 State Homeland Security Program (SHSP) Projects Date 3/12/2025 Cal OES ID: 037-00000 Request # 0
Grant #: 2024-0088 POP Start Date 9/1/2024
POP End Date 5/31/2027
Project
Number
Equipment Description
(Include Quantity) AEL # AEL Title Funding
Source Discipline Solution Area
Sub-Category
Deployable /
Shareable
Invoice
Number Vendor ID Tag
Number
Condition/
Disposition
Deployed
Location
Acquisition
Date
Noncompetitive
Procurement over
$250K
Hold Trigger Approval Date Budgeted Cost
$ 30,000.00
32 Invictus PTT wired for Motorola APX Radio (18)
and Invictus Lo Vis R23 Single Comm
Ruggedized Earpiece (18); Hurst SC 758 E2
Combi Tool (2); Stream light Helmet Lights (18);
06CP-03-PRAC
03SR-02-TPEL
03OE-04-LTHE
Accessories, Portable Radio;
Tools, Power, Electric;
Light, Personal, Intrinsically Safe
HSGP-SHSP FS 04 - Information
Technology Deployable No N/A $ 30,000
National Priority Area (NPA)

EQUIPMENT

EXHIBIT E
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1 FY 2024 HSGP NOFO
The U. S. Department of Homeland Security (DHS)
Notice of Funding Opportunity (NOFO)
Fiscal Year 2024 Homeland Security Grant Program
All entities wishing to do business with the federal government must have a unique entity identifier (UEI). The UEI number is issued by the system. Requesting a UEI using System for Award Management (SAM.gov) can be found at: https://sam.gov/content/entityregistration.

Updates in Grant Application Forms:

The Data Universal Numbering System (DUNS) Number was replaced by a new, nonproprietary identifier requested in, and assigned by SAM.gov. This new identifier is the Unique Entity Identifier.

Additional Information can be found on Grants.gov: https://www.grants.gov/forms/formsdevelopment/planned-uei-updates

EXHIBIT F
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2 FY 2024 HSGP NOFO
Table of Contents
Updates in Grant Application Forms: ..................................................................................... 1 A. Program Description ................................................................................................................ 5

1. Issued By .......................................................................................................................... 5

2. Assistance Listings Number ............................................................................................ 5

3. Assistance Listings Title .................................................................................................. 5

4. Funding Opportunity Title ............................................................................................... 5

5. Funding Opportunity Number.......................................................................................... 5

6. Authorizing Authority for Program ................................................................................. 5

7. Appropriation Authority for Program .............................................................................. 5

8. Announcement Type ........................................................................................................ 5

9. Program Category ............................................................................................................ 5

10. Program Overview, Objectives, and Priorities ................................................................ 5

11. Performance Measures ................................................................................................... 13 B. Federal Award Information ................................................................................................... 13

1. Available Funding for the NOFO: $1,008,000,000 ..................................................... 13

2. Projected Number of Awards 56................................................................................ 17

3. Period of Performance: 36 months ........................................................................... 17

4. Projected Period of Performance Start Date(s): 09/01/2024 ......................................... 17

5. Projected Period of Performance End Date(s): 08/31/2027 .......................................... 17

6. Projected Budget Period(s) ............................................................................................ 17

7. Funding Instrument Type: Grant ............................................................................... 17 C. Eligibility Information ........................................................................................................... 17

1. Eligible Applicants......................................................................................................... 17

2. Applicant Eligibility Criteria ......................................................................................... 18

3. Subawards and Beneficiaries ......................................................................................... 18 a. Subaward Allowability .............................................................................................. 18 b. Subrecipient Eligibility .............................................................................................. 18 c. Other Subaward Information ..................................................................................... 19 d. Beneficiaries or Participants ...................................................................................... 19

4. Other Eligibility Criteria/Restrictions ............................................................................ 19 a. National Incident Management System (NIMS) Implementation ............................ 19 b. Emergency Management Assistance Compact (EMAC) Membership ..................... 20 c. Law Enforcement Terrorism Prevention Activities (LETPA) .................................. 20

5. Cost Share or Match....................................................................................................... 21 D. Application and Submission Information .............................................................................. 21

1. Key Dates and Times..................................................................................................... 21 a. Application Start Date: 04/16/2024 .......................................................................... 21 b. Application Submission Deadline: 06/24/2024 at 5 p.m. ET .................................... 21 c. Anticipated Funding Selection Date: No later than August 23, 2024 ...................... 21 d. Anticipated Award Date: No later than September 30, 2024 .................................. 21 e. Other Key Dates: ....................................................................................................... 22

2. Agreeing to Terms and Conditions of the Award .......................................................... 22

3. Address to Request Application Package ...................................................................... 22

4. Requirements: Obtain a Unique Entity Identifier (UEI) and Register in the System for Award Management (SAM.gov) ................................................................................... 22

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3 FY 2024 HSGP NOFO

5. Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award Management (SAM), and Submit an Application ......................................................... 22

6. Electronic Delivery ........................................................................................................ 24

7. How to Register to Apply .............................................................................................. 24 a. General Instructions: ................................................................................................. 24 b. Obtain an UEI Number: ............................................................................................ 24 c. Obtain Employer Identification Number ................................................................... 24 d. Create a login.gov account: ....................................................................................... 24 e. Register with SAM: ................................................................................................... 25 f. Register in FEMA GO, Add the Organization to the System, and Establish the AOR:
................................................................................................................................... 26

8. Submitting the Application ............................................................................................ 26

9. Timely Receipt Requirements and Proof of Timely Submission .................................. 26

10. Content and Form of Application Submission ............................................................... 27 a. Standard Required Application Forms and Information ........................................... 27 b. Program-Specific Required Forms and Information ................................................. 27

11. Other Submission Requirements .................................................................................... 37 a. Fusion Center Investments ........................................................................................ 37 b. Emergency Communications Investments ................................................................ 37

12. Intergovernmental Review ............................................................................................. 38

13. Funding Restrictions and Allowable Costs .................................................................... 38 a. Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services ................................................................................................... 38 b. Pre-Award Costs ........................................................................................................ 38 c. Management and Administration (M&A) Costs ....................................................... 39 d. Indirect Facilities & Administrative (F&A) Costs .................................................... 40 e. Funds Transfer Restrictions ....................................................................................... 41 f. Evaluation Costs ........................................................................................................ 41 g. Allowable Cost Matrix for SHSP, UASI, and OPSG ................................................ 41 h. SHSP and UASI Other Direct Costs ......................................................................... 44 i. OPSG Other Direct Costs .......................................................................................... 55 j. Unallowable Costs for SHSP, UASI, and OPSG ...................................................... 62 E. Application Review Information ........................................................................................... 63

1. Application Evaluation Criteria ..................................................................................... 63 a. Programmatic Criteria ............................................................................................... 63 b. Financial Integrity Criteria ........................................................................................ 64 c. Supplemental Financial Integrity Criteria and Review ............................................. 65

2. Review and Selection Process ....................................................................................... 65 a. SHSP and UASI ........................................................................................................ 65 b. OPSG ......................................................................................................................... 68 F. Federal Award Administration Information .......................................................................... 68

1. Notice of Award ............................................................................................................. 68

2. Pass-Through Requirements .......................................................................................... 69

3. Administrative and National Policy Requirements ........................................................ 71 a. DHS Standard Terms and Conditions ....................................................................... 71 b. Ensuring the Protection of Civil Rights .................................................................... 71

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4 FY 2024 HSGP NOFO
c. Environmental Planning and Historic Preservation (EHP) Compliance ................... 72 d. National Incident Management System (NIMS) Implementation ............................ 72 e. Emergency Communication Investments .................................................................. 72 f. Mandatory Disclosures .............................................................................................. 73

4. Reporting........................................................................................................................ 73

5. Monitoring and Oversight .............................................................................................. 74 G. DHS Awarding Agency Contact Information ....................................................................... 74

1. Contact and Resource Information ................................................................................ 74 a. Program Office Contact ............................................................................................. 74 b. FEMA Grants News .................................................................................................. 74 c. Grant Programs Directorate (GPD) Award Administration Division ....................... 74 d. FEMA Regional Offices ............................................................................................ 74 e. Equal Rights .............................................................................................................. 75 f. Environmental Planning and Historic Preservation .................................................. 75

2. Systems Information ...................................................................................................... 75 a. FEMA GO ................................................................................................................. 75 b. FEMA Preparedness Toolkit ..................................................................................... 75 H. Additional Information .......................................................................................................... 75

1. Termination Provisions .................................................................................................. 76 a. Noncompliance .......................................................................................................... 76 b. With the Consent of the Recipient ............................................................................ 76 c. Notification by the Recipient .................................................................................... 76

2. Program Evaluation ....................................................................................................... 77

3. Financial Assistance Programs for Infrastructure.......................................................... 77 a. Build America, Buy America Act ............................................................................. 77 b. Waivers ...................................................................................................................... 78 c. Definitions ................................................................................................................. 78

4. Report issues of fraud, waste, abuse .............................................................................. 79

5. National Threat Evaluation and Reporting (NTER) Program Office ............................ 79 a. Behavioral Threat Assessment Integration ................................................................ 79 b. Nationwide Suspicious Activity Reporting Initiative ............................................... 79

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5 FY 2024 HSGP NOFO
A. Program Description

1. Issued By
U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA)/Grant Programs Directorate (GPD)

2. Assistance Listings Number

97.067

3. Assistance Listings Title
Homeland Security Grant Program

4. Funding Opportunity Title
Fiscal Year 2024 Homeland Security Grant Program (HSGP)  State Homeland Security Grant Program (SHSP)
 Urban Area Security Initiative (UASI)
 Operation Stonegarden (OPSG)

5. Funding Opportunity Number
DHS-24-GPD-067-00-98

6. Authorizing Authority for Program
Section 2002 of the Homeland Security Act of 2002 (Pub. L. No. 107-296, as amended) (6 U.S.C. § 603)

7. Appropriation Authority for Program
Department of Homeland Security Appropriations Act, 2024, Pub. L. No. 118-47, Title III, Protection, Preparedness, Response, and Recovery (2024 DHS Appropriations Act)

8. Announcement Type
Initial

9. Program Category
Preparedness: Community Security

10. Program Overview, Objectives, and Priorities
a. Overview
The Fiscal Year (FY) 2024 Homeland Security Grant Program (HSGP) is one of the three grant programs that constitute the DHS/FEMA focus on enhancing the ability of state, local, tribal, and territorial governments, as well as nonprofits, to prevent, protect against, and respond to terrorist attacks. These grant programs are part of a comprehensive set of measures authorized by Congress and implemented by DHS to help strengthen the Nation’s communities against potential terrorist attacks.

In FY 2024, there are three components of the HSGP:

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6 FY 2024 HSGP NOFO
1) State Homeland Security Program (SHSP): SHSP assists state, local, tribal, and territorial (SLTT) efforts to build, sustain, and deliver the capabilities necessary to prevent, prepare for, protect against, and respond to acts of terrorism.
2) Urban Area Security Initiative (UASI): UASI assists high-threat, high-density Urban Area efforts to build, sustain, and deliver the capabilities necessary to prevent, prepare for, protect against, and respond to acts of terrorism. 3) Operation Stonegarden (OPSG): OPSG supports enhanced cooperation and coordination among Customs and Border Protection (CBP), United States Border Patrol (USBP), and federal, state, local, tribal, and territorial law enforcement agencies to improve overall border security. OPSG provides funding to support joint efforts to secure the United States’ borders along routes of ingress/egress to and from international borders, to include travel corridors in states bordering Mexico and Canada, as well as states and territories with international water borders. SLTT law enforcement agencies utilize their inherent law enforcement authorities to support the border security mission and do not receive any additional authority by participating in OPSG.

Finally, for FY 2024, DHS is focused on the criticality of information sharing and collaboration to building a national culture of preparedness and protecting against terrorism and other threats to our national security. The threats to our nation have evolved during the past two decades. We now face continuous cyber threats by sophisticated actors, threats to soft targets and crowded places, and threats from domestic violent extremists, who represent one of the most persistent threats to the nation1
. Therefore, for FY 2024, DHS has identified six priority areas (see Section A.10.b) related to the most serious threats to the nation, as well as required minimum funding allocations.

For a full list of SHSP and UASI recipients and a breakdown of OPSG funding by state for FY 2023, please refer to Information Bulletin (IB) 490a. b. Goals, Objectives, and Priorities
Goal: The HSGP will fund SLTT efforts and strengthen capabilities of SLTT governments to prevent, prepare for, protect against, and respond to terrorist attacks and other threats and hazards that pose the greatest risk to the security of the United States.

Objectives: HSGP provides resources that support eligible SLTT governments; highdensity urban areas, and SLTT law enforcement along international land/water borders and travel corridors in meeting the following objectives:
• Build and sustain core capabilities, including Law Enforcement and Terrorism Prevention Activities and the National Priority Areas (see priorities below); 1 Strategic Intelligence Assessment and Data on Domestic Terrorism, Federal Bureau of Investigation and Department of Homeland Security, June 2023.

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7 FY 2024 HSGP NOFO
• Address capability gaps identified in their Threat and Hazard Identification and Risk Assessment (THIRA) and Stakeholder Preparedness Review (SPR) process; and
• Implement a comprehensive and coordinated approach to address enduring security needs of communities that includes planning, training and awareness campaigns, equipment and capital projects, and exercises.

SHSP and UASI Funding Priorities: Given the evolving national security threat landscape, DHS/FEMA has evaluated the national risk profile and set priorities that help inform appropriate allocation of scarce security dollars. In assessing the national risk profile for FY 2024, six National Priority Areas pose the most concern. Due to the unique threats that the nation faces in 2024, DHS/FEMA has determined that recipients should allocate a total of 30% of their SHSP and UASI award funds across these six priority areas. As indicated below, one of the priorities has a minimum spend requirement totaling 3% of SHSP and UASI awards. Recipients will have the flexibility to allocate the remaining 27% across the priorities. The following are the six priority areas for FY 2024, along with the minimum corresponding percentage of SHSP and UASI funds that each recipient will be required to allocate:
1) Enhancing the protection of soft targets/crowded places – no minimum percent
2) Enhancing information and intelligence sharing and analysis – no minimum percent
3) Combating domestic violent extremism – no minimum percent 4) Enhancing cybersecurity – no minimum percent
5) Enhancing community preparedness and resilience – no minimum percent 6) Enhancing election security – 3%
Additional information about these priority areas and how they relate to achieving anti-terrorism capabilities is included in Section D of this NOFO. Failure by a recipient to propose investments and projects that align with the priority areas and spending requirements will result in a recipient having a portion of their SHSP and UASI funds (up to 30%) placed on hold until they provide projects that sufficiently align to the National Priority Areas, and total at least the minimum percentages per National Priority Area (as applicable) and overall 30% of total SHSP and UASI funds.

A state or high-risk urban area must allocate the remaining 70% of their funding to addressing capability gaps (e.g., building/sustaining capability and/or closing capability gaps) identified through their THIRA/SPR process.

Likewise, there are several enduring security needs that crosscut the homeland security enterprise to which recipients should consider allocating funding across core capability gaps and national priorities. The following are enduring needs that help recipients implement a comprehensive approach to securing communities:

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8 FY 2024 HSGP NOFO
1) Effective planning2
;
2) Training and awareness campaigns;
3) Equipment and capital projects; and
4) Exercises.

The table below provides a breakdown of the FY 2024 SHSP and UASI priorities (the focus of OPSG remains unique to border security), showing the core capabilities enhanced and lifelines supported, as well as examples of eligible project types for each area. More information on allowable investments can be found in the Section D.13 “Funding Restrictions and Allowable Costs” below and in the Preparedness Grants Manual (FM-207-23-001). DHS/FEMA anticipates that in future years, national priorities will continue to be included and will be updated as the threats evolve and as capability gaps are closed. Applicants are strongly encouraged to begin planning to sustain existing capabilities through funding mechanisms other than DHS preparedness grants. The example project types in the table below are allowable to prepare for disasters unrelated to acts of terrorism as long as they also help achieve target capabilities related to preventing, preparing for, protecting against, or responding to acts of terrorism.

FY 2024 SHSP and UASI Funding Priorities
All priorities in this table concern the Safety and Security Lifelines.

Priority Areas Core Capabilities Example Project Types
National Priorities
Enhancing
Cybersecurity
• Cybersecurity
• Intelligence and information
sharing
• Planning
• Public information and warning
• Operational coordination
• Screening, search, and detection
• Access control and identity
verification
• Supply chain integrity and
security
• Risk management for protection
programs and activities
• Long-term vulnerability
reduction
• Situational assessment
• Infrastructure systems
• Operational communications
• Cybersecurity risk assessments
• Migrating online services to the “.gov” internet domain • Projects that address vulnerabilities identified in
cybersecurity risk assessments
o Improving cybersecurity of critical infrastructure to meet minimum levels identified by the Cybersecurity
and Infrastructure Security Agency and the National
Institute of Standards and Technology Cybersecurity
Framework (Version 1.1)
o Adoption of cybersecurity performance goals
(CISA's Cross-Sector Cybersecurity Performance
Goals)
• Cybersecurity training and planning
Enhancing the
Protection of
Soft Targets/
Crowded Places
• Operational coordination
• Public information and warning
• Intelligence and information
sharing
• Interdiction and disruption
• Operational overtime. For more information on
operational overtime, see Section D of this NOFO.
• Physical security enhancements
o Security cameras (closed-circuit television [CCTV])
o Security screening equipment for people and baggage
2 Including assessment of critical infrastructure system vulnerabilities and plans to reduce consequences of disruptions, using the Infrastructure Resilience Planning Framework and Regional Resiliency Assessment Methodology produced by the Cybersecurity and Infrastructure Security Agency.

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Priority Areas Core Capabilities Example Project Types
• Screening, search, and detection
• Access control and identity
verification
• Physical protective measures
• Risk management for protection
programs and activities
o Lighting
o Access controls
o Fencing, gates, barriers, etc.
• Unmanned Aircraft Systems and detection technologies
Enhancing
information and
intelligence
sharing and
analysis
• Intelligence and information
sharing
• Interdiction and disruption
• Planning
• Public information and warning
• Operational coordination
• Risk management for protection
programs and activities
• Fusion Center projects
• Information sharing with all DHS components; fusion
centers; other operational, investigative, and analytic entities; and other federal law enforcement and
intelligence entities
• Cooperation with DHS officials and other entities
designated by DHS in intelligence, threat recognition,
assessment, analysis, and mitigation
• Identification, assessment, and reporting of threats of violence
• Intelligence analysis training and planning
• Coordinating the intake, triage, analysis, and reporting of tips/ leads and suspicious activity, to include
coordination with the Nationwide Suspicious Activity
Reporting (SAR) Initiative (NSI)
Combating
Domestic
Violent
Extremism
• Interdiction and disruption
• Intelligence and information
sharing
• Planning
• Public information and warning
• Operational coordination
• Risk management for protection
programs and activities
• Open-source analysis of disinformation and
misinformation campaigns, targeted violence and threats to life, including tips/leads, and online/social mediabased threats • Sharing and leveraging intelligence and information,
including open-source analysis
• Development, implementation, and execution of threat
assessment and management programs to identify,
evaluate, and analyze indicators and behaviors indicative of terrorism and targeted violence
• Training, awareness, and outreach programs to help
identify and prevent radicalization, and report potential instances of terrorism and targeted violence
Enhancing
Community
Preparedness and
Resilience
• Planning
• Public Information and
Warning
• Community Resilience
• Risk Management for
Protection Programs and
Activities
• Mass Care Services
• Intelligence and Information
Sharing
• Risk and Disaster Resilience
Assessment
• Long Term Vulnerability
Reduction
• Establish, train, and maintain Community Emergency
Response Teams (CERT) and Teen CERT, with a focus
on historically undeserved communities, including
procurement of appropriate tools, equipment, and
training aides
o Local delivery of CERT Train-the-Trainer and CERT
Program Manager to build local program training and
maintenance capacity
• Provide continuity training, such as FEMA’s
Organizations Preparing for Emergency Needs training,
to faith-based organizations, local businesses, and
community-based organizations, such as homeless
shelters, food pantries, nonprofit medical providers, and senior care facilities to bolster their resilience
• Partner with local school districts to deliver the Student Tools for Emergency Planning curriculum or other
educational programming to guide students on how to
create emergency kits and family communications plans

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Priority Areas Core Capabilities Example Project Types
• Partner with key stakeholders to assist with completing the Emergency Financial First Aid Kit or a similar tool to bolster the disaster centric financial resilience of individuals and households
• Execute You are the Help Until the Help Arrives
workshops in concert with community-based
organizations to bolster individual preparedness
• Target youth preparedness using FEMA programing
such as Prepare with Pedro resources and Ready2Help
• Promote community planning, coordination, and
integration of children’s needs during emergencies
through workshops like FEMA’s Integrating the Needs
of Children
• Community Mapping: identify community resources and
characteristics in order to identify gaps in resources, identify hazards and vulnerabilities, and inform action to promote resilience
• Provide training and awareness programs with key
stakeholders (e.g., through social media, community and civic organizations, etc.) to educate the public on
misinformation and disinformation campaigns to
increase individual and community resilience
• Support integrated and cross-jurisdictional preparedness planning that considers how the community develops
networks of information-sharing and collaboration
among community-based organizations and government
institutions to enable a quicker recovery from multiple threats, including terrorist actions
Enhancing
Election Security
• Cybersecurity
• Intelligence and information
sharing
• Planning
• Long-term vulnerability
reduction
• Situational assessment
• Infrastructure systems
• Operational coordination
• Community resilience
• Physical security planning support
• Physical/site security measures – e.g., locks, shatter proof glass, alarms, access controls, etc.
• General election security navigator support
• Cyber navigator support
• Cybersecurity risk assessments, training, and planning • Projects that address vulnerabilities identified in
cybersecurity risk assessments
• Iterative backups, encrypted backups, network
segmentation, software to monitor/scan, and endpoint
protection
• Distributed Denial of Service protection
• Migrating online services to the “.gov” internet domain • Online harassment and targeting prevention services
• Public awareness/preparedness campaigns discussing
election security and integrity measures
Enduring Needs
Planning • Planning
• Risk management for protection
programs and activities
• Risk and disaster resilience
assessment
• Threats and hazards
identification
• Operational coordination
• Development of:
o Security Risk Management Plans
o Threat Mitigation Plans
o Continuity of Operations Plans
o Response Plans
o Vulnerability Assessments

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Priority Areas Core Capabilities Example Project Types
• Community resilience  Assessments should consider the impacts of climate change on investments to close identified
security gaps3
• Efforts to strengthen governance integration
between/among regional partners
• Joint training and planning with DHS officials and other entities designated by DHS
• Cybersecurity training and planning
• Revision of existing plans to strengthen community
resilience in underserved communities
Training and
Awareness
• Long-term vulnerability
reduction
• Public information and warning
• Operational coordination
• Situational assessment
• Community resilience
• Active shooter training, including integrating the needs of persons with disabilities
• Intelligence analyst training
• SAR and terrorism indicators/behaviors training
• Security training for employees
• Public awareness/preparedness campaigns
• Cybersecurity training and planning
• Sharing and leveraging intelligence and information
• Targeted outreach and preparedness training for
underserved communities in conjunction with
community-based organizations
Equipment and
Capital Projects
• Long-term vulnerability
reduction
• Infrastructure systems
• Operational communications
• Interdiction and disruption
• Screening, search and detection
• Access control and identity
verification
• Physical protective measures
• Protection of high-risk, high-consequence areas or
systems that have been identified through risk
assessments
• Physical security enhancements
o Security cameras (CCTV)
o Security screening equipment for people and baggage
o Lighting
o Access Controls
 Fencing, gates, barriers, etc.
• Enhancing Weapons of Mass Destruction and/or
improvised explosive device prevention, detection, and
response capabilities
o Chemical/Biological/Radiological/
Nuclear/Explosive detection, prevention, and
response equipment
Exercises • Long-term vulnerability
reduction
• Operational coordination
• Operational communications
• Community resilience
• Response exercises, including exercise planning with
community-based organizations
For FY 2024, each SHSP and UASI recipient is required to submit an Investment Justification (IJ) for the National Priority Area with a minimum spend requirement (Enhancing Election Security). The investment must also account for at least the relevant minimum percentage (totaling 3%) of the applicant’s SHSP and UASI allocation. State Administrative Agencies (SAAs) may submit complete project-level information at the time of application, including the National Priority Area IJs, but 3 For more information on considering the impacts of climate change, please see Executive Order 14008, Tackling the Climate Crisis at Home and Abroad and Executive Order 14030, Climate-Related Financial Risk

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are not required to do so. As a reminder, all SHSP- and UASI-funded projects must have a demonstrated nexus to achieving target capabilities related to preventing, preparing for, protecting against, and responding to acts of terrorism. However, such projects may simultaneously support enhanced preparedness for disasters unrelated to acts of terrorism.

DHS/FEMA also requires SHSP and UASI recipients (states, territories, and high-risk urban areas) to complete a THIRA/SPR and prioritize grant funding to support building capability and/or closing capability gaps or sustaining capabilities that address national priorities and/or support enduring needs. Additional information on the THIRA/SPR process, including other National Preparedness System tools and resources, can be found at National Preparedness System | FEMA.gov. Detailed information on THIRA/SPR timelines and deadlines can be found in the Preparedness Grants Manual.

OPSG Funding Priorities: The table below provides a breakdown of the FY 2024 OPSG funding priority, which remains focused on and unique to border security.

FY 2024 OPSG Funding Priority
Priority Areas Core Capabilities Lifelines Example Project Types National Priorities
Enhancing
information and
intelligence
sharing and
analysis, and
cooperation with
federal agencies,
including DHS
• Intelligence and
information sharing
• Safety and
Security
• Participation in the DHS/ICE 287(g) training
program
• Information sharing with all DHS components;
fusion centers; other operational, investigative, and
analytic entities; and other federal law enforcement
and intelligence entities
• Cooperation with DHS officials and other entities
designated by DHS in intelligence, threat
recognition, assessment, analysis, and mitigation
• Identification, assessment, and reporting of threats of violence
• Joint intelligence analysis training and planning with DHS officials and other entities designated by DHS
For FY 2024, each OPSG applicant is required to clearly articulate and identify how the Concept of Operations addresses the national priority identified above. c. Alignment to Program Purpose and the DHS and FEMA Strategic Plan Among the five basic homeland security missions noted in the DHS Strategic Plan for Fiscal Years 2020-2024, the HSGP supports the goal to Strengthen National Preparedness and Resilience.

The 2022-2026 FEMA Strategic Plan outlines three goals designed to position FEMA to address the increasing range and complexity of disasters, support the diversity of communities we serve, and complement the nation’s growing expectations of the emergency management community. The HSGP supports FEMA’s efforts to achieve

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equitable outcomes for those we serve (Goal 1) and to promote and sustain a prepared nation (Goal 3). We invite our stakeholders and partners to also adopt these priorities and join us in building a more prepared and resilient nation.

11. Performance Measures
Performance metrics for this program:

SHSP and UASI:
• Percentage of funding allocated by the recipient to core capabilities to build or sustain national priorities identified in the section above
• Percentage of funding and projects allocated by the recipient that align to capability gaps identified through the THIRA/SPR process
• Percentage of projects identified by the recipient that address a capability gap in a core capability that has a target(s) rated as high
FEMA will calculate and analyze the above metrics through a review of state/territory and urban area SPR submissions and required programmatic reports.

OPSG:
• Number of contacts that occurred as a result of OPSG deployments o Number of arrests that resulted from OPSG contacts
o Value of drug seizures that resulted from OPSG contacts B. Federal Award Information

1. Available Funding for the NOFO: $1,008,000,000
HSGP Programs FY 2024 Allocation
SHSP $373,500,000
UASI $553,500,000
OPSG $81,000,000
Total $1,008,000,000
SHSP Allocations
For FY 2024, DHS/FEMA will award SHSP funds based on DHS/FEMA’s relative risk methodology and statutory minimums pursuant to the Homeland Security Act of 2002, as amended. THIRA/SPR results do not impact grant allocations or awards.

Each state and territory will receive a minimum allocation under the SHSP using thresholds established in the Homeland Security Act of 2002, as amended. All 50 States, the District of Columbia, and the Commonwealth of Puerto Rico will receive 0.35% of the total funds allocated for grants under Section 2003 and Section 2004 of the Homeland Security Act of 2002, as amended. Each of the four territories (American Samoa, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands) will receive a minimum allocation of 0.08% of the total funds allocated for grants under Sections 2003 and 2004 of the Homeland Security Act of 2002, as amended.

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Each state must include a separate IJ for the National Priority Area with a minimum spend requirement (Enhancing Election Security). All projects related to the minimum spend for the National Priority Area must be included in the IJ. For this National Priority Area with a minimum spend percentage requirement, the funding level in that National Priority Area investment must equal or exceed 3%, calculated as a percentage of the state’s SHSP allocation in the table below. The funding levels across all six National Priority Areas must equal or exceed 30% of the total SHSP allocation.

FY 2024 SHSP Allocations
State/Territory FY 2024
Allocation State/Territory FY 2024 Allocation
Alabama $4,362,750 Montana $4,362,750
Alaska $4,362,750 Nebraska $4,362,750
American Samoa $997,200 Nevada $4,362,750
Arizona $4,362,750 New Hampshire $4,362,750
Arkansas $4,362,750 New Jersey $6,367,357
California $51,332,060 New Mexico $4,362,750
Colorado $4,362,750 New York $61,229,940
Connecticut $4,362,750 North Carolina $4,576,849
Delaware $4,362,750 North Dakota $4,362,750
District of Columbia $4,576,849 Northern Mariana
Islands $997,200
Florida $8,409,514 Ohio $5,571,852
Georgia $4,759,790 Oklahoma $4,362,750
Guam $997,200 Oregon $4,362,750
Hawaii $4,362,750 Pennsylvania $7,322,627
Idaho $4,362,750 Puerto Rico $4,362,750
Illinois $12,505,419 Rhode Island $4,362,750
Indiana $4,362,750 South Carolina $4,362,750
Iowa $4,362,750 South Dakota $4,362,750
Kansas $4,362,750 Tennessee $4,362,750
Kentucky $4,362,750 Texas $16,389,406
Louisiana $4,362,750 U.S. Virgin Islands $997,200
Maine $4,362,750 Utah $4,362,750
Maryland $6,367,357 Vermont $4,362,750
Massachusetts $5,571,852 Virginia $7,322,627
Michigan $4,576,849 Washington $5,571,852
Minnesota $4,362,750 West Virginia $4,362,750
Mississippi $4,362,750 Wisconsin $4,362,750
Missouri $4,362,750 Wyoming $4,362,750
Total $373,500,000

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UASI Allocations
Eligible candidates for the FY 2024 UASI program are identified in the table below.

Eligibility has been determined through an analysis of relative risk of terrorism faced by the 100 most populous Metropolitan Statistical Areas (MSA) in the United States, in accordance with the Homeland Security Act of 2002, as amended. Detailed information on MSAs is publicly available from the United States Census Bureau at Metropolitan and Micropolitan (census.gov). THIRA/SPR results do not impact grant allocations or awards.

The Metropolitan Areas Standardization and Protection (MAPS) Act of 2021 (P.L. 117-219) prohibits automatically updating core-based statistical areas, which are used to delineate MSAs, for grantmaking. The MAPS Act requires that FEMA issue notice-and-comment rulemaking to make any changes. Should changes be necessary in FY 2024, FEMA will issue notice-and-comment rulemaking within the statutorily defined guidelines.

The following table identifies the UASI allocations for each high-risk urban area based on DHS/FEMA’s relative risk methodology pursuant to the Homeland Security Act of 2002, as amended.

In its application, each high-risk urban area, through the state, must include a separate IJ for the National Priority Area with a minimum spend requirement (Enhancing Election Security). All projects related to the minimum spend for the National Priority Area must be included in the IJ. For the National Priority Area with a minimum spend percentage requirement, the funding level in that National Priority Area investment must equal or exceed 3%, calculated as a percentage of the urban area’s UASI allocation in the table below.

The funding levels across all six National Priority Areas must equal or exceed 30% of the total UASI allocation.

FY 2024 UASI Allocations
State/Territory Funded Urban Area FY 2024 UASI
Allocation
Arizona Phoenix Area $4,712,190
California
Anaheim/Santa Ana Area $4,712,190
Bay Area $32,754,895
Los Angeles/Long Beach Area $59,395,378
Riverside Area $3,500,484
Sacramento Area $3,410,728
San Diego Area $14,760,877
Colorado Denver Area $3,500,484
District of Columbia National Capital Region $45,201,207 Florida
Jacksonville Area $1,346,340
Miami/Fort Lauderdale Area $13,040,425
Orlando Area $3,410,728
Tampa Area $3,410,728
Georgia Atlanta Area $6,911,212

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State/Territory Funded Urban Area FY 2024 UASI
Allocation
Hawaii Honolulu Area $1,346,340
Illinois Chicago Area $59,395,378
Indiana Indianapolis Area $1,476,785
Louisiana New Orleans Area $1,476,785
Maryland Baltimore Area $3,410,728
Massachusetts Boston Area $14,941,233
Michigan Detroit Area $4,712,190
Minnesota Twin Cities Area $4,712,190
Missouri Kansas City Area $1,476,785
St. Louis Area $3,410,728
Nevada Las Vegas Area $4,712,190
New Jersey Jersey City/Newark Area $16,722,687
New York New York City Area $156,131,176
North Carolina Charlotte Area $3,410,728
Ohio
Cincinnati Area $1,476,785
Cleveland Area $1,476,785
Columbus Area $1,346,340
Oregon Portland Area $3,410,728
Pennsylvania Philadelphia Area $14,941,233
Pittsburgh Area $1,476,785
Tennessee Nashville Area $1,346,340
Texas
Austin Area $1,500,000
Dallas/Fort Worth/Arlington
Area $14,941,233
Houston Area $21,748,776
San Antonio Area $3,410,728
Virginia Hampton Roads Area $3,410,728
Washington Seattle Area $5,609,750
Total $553,500,000
OPSG Allocations
For FY 2024, DHS/FEMA will award OPSG funds based on risk and the anticipated effectiveness of the proposed use of grant funds upon completion of the application review process. The FY 2024 OPSG risk assessment is designed to identify the risk to border security and to assist with the distribution of funds for the grant program. Funding under OPSG is distributed based on the risk to the security of the border and the effectiveness of the proposed projects. Entities eligible for funding are the state, local, and tribal law enforcement agencies that are located along the border of the United States. DHS/FEMA will make final award determinations based upon a review of the anticipated effectiveness of the

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state’s application as described in Section D, below. The THIRA/SPR process is not required for OPSG.

For the purposes of OPSG, the risk is defined as the potential for an adverse outcome assessed as a function of threats, vulnerabilities, and consequences associated with an incident, event, or occurrence.

Based upon ongoing intelligence analysis and extensive security reviews, DHS/CBP continues to focus the bulk of OPSG funds based upon risk analyses. The risk model used to allocate OPSG funds considers the potential risk that certain threats pose to border security and estimates the relative risk faced by a given area. In evaluating risk, DHS/CBP considers intelligence, situational awareness, criminal trends, and statistical data specific to each of the border sectors, and the potential impacts that these threats pose to the security of the border area. For vulnerability and consequence, DHS/CBP considers the expected impact and consequences of successful border events occurring in specific areas.

Threat and vulnerability are evaluated based on specific operational data from DHS/CBP.

Threat components present in each of the sectors are used to determine the overall threat score. These components are terrorism, criminal aliens, drug trafficking organizations, and alien smuggling organizations.

Effectiveness of the proposed investments will be evaluated based on the recipient’s investment strategy, budget, collaboration, and past performance.

2. Projected Number of Awards 56

3. Period of Performance: 36 months
Extensions to the period of performance are allowed. For additional information on period of performance extensions, please refer to the Preparedness Grants Manual.

4. Projected Period of Performance Start Date(s): 09/01/2024

5. Projected Period of Performance End Date(s): 08/31/2027

6. Projected Budget Period(s)
There will be only a single budget period with the same start and end dates as the period of performance.

7. Funding Instrument Type: Grant
C. Eligibility Information

1. Eligible Applicants
The SAA is the only entity eligible to submit HSGP applications to DHS/FEMA, including those applications submitted on behalf of UASI and OPSG applicants. All 56 states and territories, including any state of the United States, the District of Columbia, the

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Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands, are eligible to apply for SHSP funds. Tribal governments may not apply directly for HSGP funding; however, funding may be available to tribes through the SAA.

2. Applicant Eligibility Criteria
The SAA is the only eligible applicant.

An application submitted by an otherwise eligible non-federal entity (i.e., the applicant) may be deemed ineligible when the person that submitted the application is not: 1) a current employee, personnel, official, staff, or leadership of the non-federal entity; and 2) duly authorized to apply for an award on behalf of the non-federal entity at the time of application.

Further, the Authorized Organization Representative (AOR) must be a duly authorized current employee, personnel, official, staff, or leadership of the recipient and provide an email address unique to the recipient at the time of application and upon any change in assignment during the period of performance. Consultants or contractors of the recipient are not permitted to be the AOR of the recipient.

3. Subawards and Beneficiaries
a. Subaward Allowability
Subawards are allowed under the HSGP. The recipient (the SAA) is awarded, and then any funds passed through to other state or local entities (subrecipients) are considered subawards.
b. Subrecipient Eligibility
Eligible high-risk urban areas for the FY 2024 UASI program have been determined through an analysis of relative risk of terrorism faced by the 100 most populous MSAs in the United States. Subawards will be made by the SAAs to the designated high-risk urban areas.

For 2024, each SAA is strongly encouraged to re-evaluate its process for collecting and evaluating subaward applications. FEMA encourages each SAA to minimize the type and quantity of information that it collects as part of the subaward application process, in order to decrease the overall financial and time burden associated with applying for subawards under this grant program. Each SAA should review its subaward application and reduce or eliminate the request for any information that is not needed for legal, financial, or oversight purposes.

In FY 2024, OPSG eligible subrecipients are local units of government at the county level or equivalent level of government and federally recognized tribal governments in states bordering Canada or Mexico and states and territories with international water borders. All applicants must have active ongoing USBP operations coordinated through a CBP sector office to be eligible for OPSG funding.

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In FY 2024, OPSG subrecipients eligible to apply for and receive a subaward directly from the SAAs are divided into three Tiers. Tier 1 entities are local units of government at the county level or equivalent and federally recognized tribal governments that are on a physical border in states bordering Canada, states bordering Mexico, and states and territories with international water borders. Tier 2 eligible subrecipients are those not located on the physical border or international water but are contiguous to a Tier 1 county. Tier 3 eligible subrecipients are those not located on the physical border or international water but are contiguous to a Tier 2 eligible subrecipient. The tier structure is only applicable with regard to eligibility.

OPSG funding allocations are based on the assessed border security risks as determined by the USBP.
c. Other Subaward Information
Please see the following sections for additional information on requirements or restrictions related to subawards/subrecipients:
• Section D.4 “Requirements: Obtain a Unique Entity Identifier (UEI) and Register in the System for Award Management”;
• Section D.10.b “Program-Specific Required Forms and Information”; • Section D.13 “Funding Restrictions and Allowable Costs”; • Section F.2 “Pass-Through Requirements”;
• Section F.3.b “Ensuring the Protection of Civil Rights”; • Section F.5 “Monitoring and Oversight”;
• Section G.1.f “Environmental Planning and Historic Preservation”; • Section H.1 “Terminations Provisions”;
• Section H.2 “Program Evaluation”; and
• Section H.3 “Financial Assistance Programs for Infrastructure.” Additionally, please see the Preparedness Grants Manual for further information on requirements or restrictions related to subawards/subrecipients. d. Beneficiaries or Participants
This NOFO and any subsequent federal awards create no rights or causes of action for any participant or beneficiary.

4. Other Eligibility Criteria/Restrictions
a. National Incident Management System (NIMS) Implementation Prior to allocation of any federal preparedness awards, recipients must ensure and maintain adoption and implementation of NIMS, including implementation of important operational systems defined under NIMS, such as the Incident Command System (ICS). The list of objectives used for progress and achievement reporting is on FEMA’s website at https://www.fema.gov/emergencymanagers/nims/implementation-training.

Please see the Preparedness Grants Manual for more information on NIMS.

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b. Emergency Management Assistance Compact (EMAC) Membership In support of the National Preparedness Goal (the Goal), SHSP recipients must belong to, be in, or act as a temporary member of the EMAC, except for the American Samoa and the Commonwealth of the Northern Mariana Islands, which are not required to belong to the EMAC at this time. All assets supported in part or entirely with FY 2024 HSGP funding must be readily deployable and NIMS-typed, when possible, to support emergency or disaster operations per existing EMAC agreements. In addition, funding may be used for the sustainment of core capabilities that, while they may not be physically deployable, support national response capabilities, such as Geographic/Geospatial Information Systems, interoperable communications systems, capabilities as defined under the Mitigation Mission Area of the Goal, and fusion centers.
c. Law Enforcement Terrorism Prevention Activities (LETPA) Per section 2006 of the Homeland Security Act of 2002, as amended (6 U.S.C. § 607), DHS/FEMA is required to ensure that at least 25% of grant funding appropriated for grants awarded under HSGP’s authorizing statute are used for LETPAs. For FY 2024, DHS/FEMA is requiring that at least 35% of grant funding appropriated under HSGP is used for LETPA. DHS/FEMA meets this requirement, in part, by requiring all recipients allocate at least 35% of the combined HSGP funds allocated under SHSP and UASI towards LETPAs, as defined in 6 U.S.C. § 607. The LETPA allocation can be from SHSP, UASI, or both. The 35% LETPA allocation may be met by funding projects in any combination of the six National Priority Areas identified above and any other investments. The 35% LETPA allocation requirement is in addition to the 80% pass-through requirement to local units of government and tribes, referenced below. Information Bulletin (IB) 485 includes the most up-to-date information on project selection considerations and allowable activities for LETPA investments and compliments IB 473. Both IBs are applicable to the FY 2024 HSGP NOFO. More information on allowable investments can also be found in the Allowable Costs Matrix section below.

The National Prevention Framework describes those activities that should be executed upon the discovery of intelligence or information regarding an imminent threat to the homeland, to thwart an initial or follow-on terrorist attack and provides guidance to ensure the Nation is prepared to identify, prevent, avoid, or stop a threatened or actual act of terrorism. Activities outlined in the National Prevention Framework are eligible for use as LETPA-focused funds. Also, where capabilities are shared with the protection mission area, the National Protection Framework activities are also eligible. All other terrorism prevention activities proposed for funding under LETPA must be approved by the FEMA Administrator.

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

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high-profile events. More information about operational overtime costs can be found in Section D.13 “Funding Restrictions and Allowable Costs” below.

5. Cost Share or Match
There is no cost share or match requirements for the FY 2024 HSGP.

D. Application and Submission Information

1. Key Dates and Times
a. Application Start Date: 04/16/2024
b. Application Submission Deadline: 06/24/2024 at 5 p.m. ET All applications must be received by the established deadline.

FEMA’s Grants Outcomes System (FEMA GO) automatically records proof of timely submission and the system generates an electronic date/time stamp when FEMA GO successfully receives the application. The individual with the AOR role that submitted the application will also receive the official date/time stamp and a FEMA GO tracking number in an email serving as proof of their timely submission. For additional information on how an applicant will be notified of application receipt, see the subsection titled “Timely Receipt Requirements and Proof of Timely Submission” in Section D of this NOFO.

FEMA will not review applications that are received after the deadline or consider these late applications for funding. FEMA may, however, extend the application deadline on request for any applicant who can demonstrate that good cause exists to justify extending the deadline. Good cause for an extension may include technical problems outside of the applicant’s control that prevent submission of the application by the deadline, other exigent or emergency circumstances, or statutory requirements for FEMA to make an award.

Applicants experiencing technical problems outside of their control must notify FEMA as soon as possible and before the application deadline. Failure to timely notify FEMA of the issue that prevented the timely filing of the application may preclude consideration of the award. “Timely notification” of FEMA means the following: prior to the application deadline and within 48 hours after the applicant became aware of the issue.

A list of FEMA contacts can be found in Section G of this NOFO, “DHS Awarding Agency Contact Information.” For technical assistance with the FEMA GO system, please contact the FEMA GO Helpdesk at [email protected] or (877) 585-3242, Monday through Friday, 9:00 AM – 6:00 PM Eastern Time (ET). For programmatic or grants management questions, please contact your Preparedness Officer or Grants Management Specialist. If applicants do not know who to contact or if there are programmatic questions or concerns, please contact [email protected], Monday through Friday, 9:00 AM – 5:00 PM ET. c. Anticipated Funding Selection Date: No later than August 23, 2024 d. Anticipated Award Date: No later than September 30, 2024

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e. Other Key Dates:

2. Agreeing to Terms and Conditions of the Award
By submitting an application, applicants agree to comply with the requirements of this NOFO and the terms and conditions of the award, should they receive an award.

3. Address to Request Application Package
Applications are processed through the FEMA GO system. To access the system, go to https://go.fema.gov/.

4. Requirements: Obtain a Unique Entity Identifier (UEI) and Register in the System for Award Management (SAM.gov)
Each applicant, unless they have a valid exception under 2 CFR §25.110, must:
a. Be registered in Sam.Gov before application submission. b. Provide a valid UEI in its application.
c. Continue to always maintain an active SAM registration with current information during the federal award process. Note: Per 2 C.F.R. § 25.300, subrecipients are NOT required to go through the full SAM registration process. First-tier subrecipients (meaning entities receiving funds directly from the recipient) are only required to obtain a UEI through SAM, but they are not required to complete the full SAM registration in order to obtain a UEI. Recipients may not make subawards unless the subrecipient has obtained and provided the UEI.

Lower-tier subrecipients (meaning entities receiving funds passed through by a higher-tier subrecipient) are not required to have a UEI and are not required to register in SAM.

Applicants are also not permitted to require subrecipients to complete a full registration in SAM beyond obtaining the UEI.

5. Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award Management (SAM), and Submit an Application
Applying for an award under this program is a multi-step process and requires time to complete. Applicants are encouraged to register early as the registration process can take four weeks or more to complete. Therefore, registration should be done in sufficient time to Event Suggested Deadline for Completion
Obtaining Unique Entity Identifier
(UEI) number
Four weeks before actual submission deadline
Obtaining a valid Employer
Identification Number (EIN) Four weeks before actual submission deadline Creating an account with login.gov Four weeks before actual submission deadline Registering in SAM or updating SAM
registration Four weeks before actual submission deadline Registering Organization in FEMA
GO Prior to beginning application
Submitting complete application in
FEMA GO One week before actual submission deadline

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ensure it does not impact your ability to meet required submission deadlines. Please review the table above for estimated deadlines to complete each of the steps listed. Failure of an applicant to comply with any of the required steps before the deadline for submitting an application may disqualify that application from funding.

To apply for an award under this program, all applicants must:
a. Apply for, update, or verify their UEI number and Employer Identification Number (EIN) from the Internal Revenue Service;
b. In the application, provide an UEI number;
c. Have an account with login.gov;
d. Register for, update, or verify their SAM account and ensure the account is active before submitting the application;
e. Register in FEMA GO, add the organization to the system, and establish the AOR.

The organization’s electronic business point of contact (EBiz POC) from the SAM registration may need to be involved in this step. For step-by-step instructions, see https://www.fema.gov/grants/guidance-tools/fema-go/startup f. Submit the complete application in FEMA GO; and
g. Continue to maintain an active SAM registration with current information at all times during which it has an active federal award or an application or plan under consideration by a federal awarding agency. As part of this, applicants must also provide information on an applicant’s immediate and highest-level owner and subsidiaries, as well as on all predecessors that have been awarded federal contracts or federal financial assistance within the last three years, if applicable.

Applicants are advised that FEMA may not make a federal award until the applicant has complied with all applicable SAM requirements. Therefore, an applicant’s SAM registration must be active not only at the time of application, but also during the application review period and when FEMA is ready to make a federal award. Further, as noted above, an applicant’s or recipient’s SAM registration must remain active for the duration of an active federal award. If an applicant’s SAM registration is expired at the time of application, expires during application review, or expires any other time before award, FEMA may determine that the applicant is not qualified to receive a federal award and use that determination as a basis for making a federal award to another applicant.

Per 2 C.F.R. § 25.110(c)(2)(iii), if an applicant is experiencing exigent circumstances that prevents it from obtaining an UEI number and completing SAM registration prior to receiving a federal award, the applicant must notify FEMA as soon as possible by contacting [email protected] and providing the details of the circumstances that prevent completion of these requirements. If FEMA determines that there are exigent circumstances and FEMA has decided to make an award, the applicant will be required to obtain an UEI number, if applicable, and complete SAM registration within 30 days of the federal award date.

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6. Electronic Delivery
DHS is participating in the Grants.gov initiative to provide the grant community with a single site to find and apply for grant funding opportunities. DHS encourages or requires applicants to submit their applications online through Grants.gov, depending on the funding opportunity.

For this funding opportunity, FEMA requires applicants to submit applications through FEMA GO.

7. How to Register to Apply
a. General Instructions:

Registering and applying for an award under this program is a multi-step process and requires time to complete. Read the instructions below about registering to apply for FEMA funds. Applicants should read the registration instructions carefully and prepare the information requested before beginning the registration process.

Reviewing and assembling the required information before beginning the registration process will alleviate last-minute searches for required information.

The registration process can take up to four weeks to complete. To ensure an application meets the deadline, applicants are advised to start the required steps well in advance of their submission.

Organizations must have an UEI number, an EIN, and an active SAM registration to apply for a federal award under this funding opportunity. b. Obtain an UEI Number:

All entities applying for funding, including renewal funding, must have a UEI number. Applicants must enter the UEI number in the applicable data entry field on the SF-424 form.

For more detailed instructions for obtaining a UEI number, refer to: SAM.gov c. Obtain Employer Identification Number
All entities applying for funding must provide an Employer Identification Number (EIN). The EIN can be obtained from the IRS by visiting:
https://www.irs.gov/businesses/small-businesses-self-employed/apply-for-anemployer-identification-number-ein-online. d. Create a login.gov account:

Applicants must have a login.gov account in order to register with SAM or update their SAM registration. Applicants can create a login.gov account here:
https://secure.login.gov/sign_up/enter_email?request_id=34f19fa8-14a2-438c-8323- a62b99571fd3.

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Applicants only have to create a login.gov account once. For applicants that are existing SAM users, use the same email address for the login.gov account as with SAM.gov so that the two accounts can be linked.

For more information on the login.gov requirements for SAM registration, refer to:
https://www.sam.gov/SAM/pages/public/loginFAQ.jsf.
e. Register with SAM:

All applicants applying online through FEMA GO must register with SAM. Failure to register with SAM will prevent an applicant from completing the application in FEMA GO. SAM registration must be renewed annually. Organizations will be issued a UEI number with the completed SAM registration.

For more detailed instructions for registering with SAM, refer to https://apply07.grants.gov/help/html/help/Register/RegisterWithSAM.htm Note: Per 2 C.F.R. § 25.200, applicants must also provide the applicant’s immediate and highest-level owner, subsidiaries, and predecessors that have been awarded federal contracts or federal financial assistance within the last three years, if applicable.

I. ADDITIONAL SAM REMINDERS
Existing SAM.gov account holders should check their account to make sure it is “ACTIVE.” SAM registration should be completed at the very beginning of the application period and should be renewed annually to avoid being “INACTIVE.” Please allow plenty of time before the grant application submission deadline to obtain an UEI number and then to register in SAM. It may be four weeks or more after an applicant submits the SAM registration before the registration is active in SAM, and then it may be an additional 24 hours before FEMA’s system recognizes the information.

It is imperative that the information applicants provide is correct and current.

Please ensure that your organization’s name, address, and EIN are up to date in SAM and that the UEI number used in SAM is the same one used to apply for all other FEMA awards. Payment under any FEMA award is contingent on the recipient’s having a current SAM registration.

II. HELP WITH SAM
The SAM quick start guide for new recipient registration and SAM video tutorial for new applicants are tools created by the General Services Administration (GSA) to assist those registering with SAM. If applicants have questions or concerns about a SAM registration, please contact the Federal Support Desk at https://www.fsd.gov/fsd-gov/home.do or call toll free (866) 606-8220.

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f. Register in FEMA GO, Add the Organization to the System, and Establish the AOR:

Applicants must register in FEMA GO and add their organization to the system. The organization’s electronic business point of contact (EBiz POC) from the SAM registration may need to be involved in this step. For step-by-step instructions, see https://www.fema.gov/grants/guidance-tools/fema-go/startup Note: FEMA GO will support only the most recent major release of the following browsers:
• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Apple Safari
• Microsoft Edge
Users who attempt to use tablet type devices or other browsers may encounter issues with using FEMA GO.

8. Submitting the Application
Applicants will be prompted to submit the standard application information and any program-specific information required as described in Section D.10 of this NOFO, “Content and Form of Application Submission.” The Standard Forms (SF) may be accessed in the Forms tab under the https://grants.gov/forms/forms-repository/sf-424-family Applicants should review these forms before applying to ensure they have all the information required.

After submitting the final application, FEMA GO will provide either an error message or a successfully received transmission in the form of an email sent to the AOR that submitted the application. Applicants using slow internet connections, such as dial-up connections, should be aware that transmission can take some time before FEMA GO receives your application.

For additional application submission requirements, including program-specific requirements, please refer to the subsection titled “Content and Form of Application Submission” under Section D of this NOFO.

9. Timely Receipt Requirements and Proof of Timely Submission All applications must be completed in FEMA GO by the application deadline. FEMA GO automatically records proof of timely submission and the system generates an electronic date/time stamp when FEMA GO successfully receives the application. The individual with the AOR role that submitted the application will also receive the official date/time stamp and a FEMA GO tracking number in an email serving as proof of their timely submission on the date and time that FEMA GO received the application.

Applicants who experience system-related issues will be addressed until 3:00 PM ET on the date applications are due. No new system-related issues will be addressed after this deadline. Applications not received by the application submission deadline will not be accepted.

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10. Content and Form of Application Submission
a. Standard Required Application Forms and Information
Generally, applicants have to submit either the non-construction forms (i.e., SF-424A and SF-424B) or construction forms (i.e., SF-424C and SF-424D), meaning that applicants that only have construction work and do not have any non-construction work need only submit the construction forms (i.e., SF-424C and SF-424D) and not the non-construction forms (i.e., SF-424A and SF-424B), and vice versa. However, applicants who have both construction and non-construction work under this program need to submit both the construction and non-construction forms.

The following forms or information are required to be submitted via FEMA GO. The Standard Forms (SF) are also available at https://grants.gov/forms/formsrepository/sf-424-family • SF-424, Application for Federal Assistance
• Grants.gov Lobbying Form, Certification Regarding Lobbying • SF-424A, Budget Information (Non-Construction)
o For construction under an award, submit SF-424C, Budget Information (Construction), in addition to or instead of SF-424A • SF-424B, Standard Assurances (Non-Construction)
o For construction under an award, submit SF-424D, Standard Assurances (Construction), in addition to or instead of SF-424B • SF-LLL, Disclosure of Lobbying Activities
b. Program-Specific Required Forms and Information
The following program-specific forms or information are required to be submitted in FEMA GO:
• Investment Justification (SHSP and UASI)
• Concept of Operations (OPSG)
• Operations Orders (OPSG)
• Detailed Budgets
I. IJ DEVELOPMENT: SHSP AND UASI
As part of the FY 2024 HSGP application process for SHSP and UASI funds, applicants must develop formal IJs that address the proposed investments. Failure to fulfill all of the terms contained in this section will be considered by DHS/FEMA in its evaluation of the effectiveness of the IJs submitted to meet the minimum percent spend requirement for the National Priority Areas. Failure to sufficiently align projects to the National Priority Areas and meet the minimum percent spend requirement will result in funds being placed on hold until those issues are addressed.

FY 2024 SHSP and UASI applications must include one (1) IJ and at least one (1) respective project for the one National Priority Area with a minimum spend requirement (Enhancing Election Security) identified in this NOFO. This IJ must also meet or exceed the minimum percent spend requirement based on the

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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: SHSP AND 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: SHSP AND 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

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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

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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

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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.

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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: SHSP AND 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

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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)

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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

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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

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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
Developing and implementing homeland security support programs and adopting 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
Hiring of full- or part-time staff or contract/consultantsto assist with planning, 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 N N Activitiesto achieve planning inclusive of people with disabilities and others with access and functional needs 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

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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 are permitted under this grant only 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, and activitiesthat facilitate shared situational awareness between the public and private sectors 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 Overtime for information, investigative, and intelligence sharing activities(up to 50% of the allocation) Y Y Y
Hiring of new staff positions/contractors/consultants for participation in information/intelligence analysis and sharing groups or fusion center activities(up to 50% of the allocation).

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

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Allowable Program Activities SHSP UASI OPSG
Critical emergency supplies Y Y N
General use vehicle acquisition, lease, and rental N N Y Specialized vehicle acquisition, lease, and rental Y Y Y Other Authorized Equipment Y Y Y
Allowable Training Costs
Overtime and backfill for emergency preparedness and response personnel attending DHS/FEMA-sponsored and approved training 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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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.

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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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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

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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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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 EMAC4 and 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 and vehicles;
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").
4 Except for American Samoa and the Commonwealth of the Northern Mariana Islands, which are not required to belong to EMAC at this time.
5 This 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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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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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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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

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occurred for reasons other than the receipt or expected receipt of federal funds.

Operational Overtime Costs
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:
• SEAR 1: A significant event with national and/or
international importance that may require extensive federal interagency support.
• SEAR 2: A significant event with national and/or
international importance that may require some level of federal interagency support.
• SEAR 3: An event of national and/or international
importance that requires only limited federal support.
• 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.

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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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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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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

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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 EMAC7 and 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 and vehicles;
o Fire service equipment and vehicles, to include hose, pump accessories, and foam concentrate for specialized
7 Except 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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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 staff8 engaged in homeland security program activity.

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 8 This 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.

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

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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.

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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.

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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:

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• 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 • 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 OPSG ONLY
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

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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:
• Aligns with at least one core capability identified in the Goal; • Demonstrates how investments support building capability and/or closing capability gaps or sustaining capabilities identified in the THIRA/SPR process; and
• 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:
• 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; • A summary of the status of planning and design efforts accomplished to date (e.g., included in a capital improvement plan); and • 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

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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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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

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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:
• How the proposed investment addresses the National Priority Area; • 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 • 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:
• 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.
• 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.

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• 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.
• 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.

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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:
• 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.
• An Indian tribe or authorized tribal organization, or in Alaska a Native village or Alaska Regional Native Corporation.
• A rural community, unincorporated town or village, or other public entity.

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

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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.

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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:
• Environmental Planning and Historic Preservation (EHP) Compliance • FirstNet
• National Incident Management System (NIMS) Implementation • 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

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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:
• 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. • 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. • 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

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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.

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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 [email protected], 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 [email protected] 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.

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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 [email protected] 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:
• Actions to Address Noncompliance
• Audits
• Case Studies and Use of Grant-Funded Resources During Real-World Incident Operations
• Community Lifelines
• Conflicts of Interest in the Administration of Federal Awards and Subawards • Disability Integration
• National Incident Management System
• Payment Information

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• Period of Performance Extensions
• Procurement Integrity
• Record Retention
• Termination Provisions
• Whole Community Preparedness
• Report Issues of Fraud, Waste, and Abuse
• Hazard Resistant Building Codes
• 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.

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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

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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:
• Applying the domestic content procurement preference would be inconsistent with the public interest.
• 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.
• 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.

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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. • 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. ·
• 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.
• SAR Standardized Technical Assistance Consultation Guide: This document provides an overview of the technical assistance and training services.

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80 FY 2024 HSGP NOFO
• 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.
• 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.

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

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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

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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

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1 Section 1 ‒ Overview | 2024
Federal Program
Announcement
On 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 follow the programmatic requirements in the NOFO, FEMA Preparedness Grants Manual, and the
applicable provisions of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards located in Title 2, Code of Federal
Regulations (C.F.R.), Part 200.

Information
Bulletins
DHS issues Information Bulletins (IBs) to provide updates, clarification, and new requirements throughout the life of the grant.

Grant
Management
Memoranda
Cal OES issues Grant Management Memoranda (GMMs)
which provide additional information and requirements
regarding HSGP funds.

Purpose of the
California
Supplement
The FY 2024 HSGP California Supplement to the NOFO
(State Supplement) is intended to complement, rather than replace, the NOFO and the FEMA Preparedness Grants
Manual. Applicants are highly encouraged to thoroughly
read the NOFO and the Preparedness Grants Manual
before referring to the State Supplement. The State
Supplement will emphasize differences between the
FY 2023 and FY 2024 HSGP and highlight additional
California policies and requirements applicable to FY 2024 HSGP.

Eligible
Subrecipients
Eligible Applicants, referred to as 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.

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2 Section 1 ‒ Overview | 2024
Tribal
Allocations
The NOFO strongly encourages Cal OES to provide HSGP
funds directly to tribes in California. To implement this requirement, a special Competitive Funding Opportunity
(CFO) will be issued to California’s federally recognized tribes. All Subrecipients are encouraged to coordinate with tribal governments to ensure that tribal needs are
considered in their grant applications.

Subrecipient
Allocations
FY 2024 HSGP Subrecipient final allocations are provided in Attachment A and reflect reductions to Subrecipients who did not submit minimum thresholds for National Priority Areas, including Subrecipients opting out of the award
altogether, and increases to Subrecipients that are helping meet statewide minimum level National Priority Area
requirements.

Supplanting Grant funds must be used to supplement existing funds, not replace (supplant) funds that have been appropriated for the same purpose. Subrecipients may be required to
provide supporting documentation that certifies a
reduction in non-federal resources that occurred for
reasons other than the receipt or expected receipt of
federal funds. Supplanting will result in the disallowance of the activity associated with this improper use of federal grant funds.

Public/Private
Organizations
Subrecipients may contract with other public or private organizations to perform eligible activities on approved 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 in federal assistance programs.

Subrecipients must obtain documentation of eligibility
before making any subaward or contract using HSGP funds and must be prepared to present supporting
documentation to monitors/auditors.

Before entering into a Grant Subaward, the Subrecipient must notify Cal OES if it knows if any of the principals under the subaward fall under one or more of the four criteria listed at 2 C.F.R. § 180.335.

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

The rule also applies to Subrecipients who pass through funding to other local entities.

If at any time after accepting a subaward, Subrecipients learn that any of its principals fall under one or more of the criteria listed at 2 C.F.R. § 180.335, immediate written notice must be provided to Cal OES and all grant activities halted until further instructions are received from Cal OES. The rule also applies to subawards passed through by Subrecipients to local entities.

Key Changes to
the FY 2024
HSGP
National Priority Areas: There are six National Priority Areas (NPAs) for FY 2024. The primary change for FY 2024 is that only the Enhancing Election Security NPA maintains a 3% minimum spend. SHSP and UASI applicants must include
one Investment Justification (IJ) for each NPA that has a minimum spend requirement, where applicable. For the
NPAs with no minimum spend requirement, the Department
of Homeland Security strongly encourages recipients to
make investments in those 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 for those NPAs must be included in the
same IJ.

The six NPAs, along with the relevant minimum spend
requirement, are:
• Enhancing information and intelligence sharing and
cooperation with federal agencies, including the
Department of Homeland Security – NEW: no minimum
spend;
• Enhancing the protection of soft targets/crowded
places –NEW: no minimum spend;
• Enhancing cybersecurity – no minimum spend;
• Enhancing community preparedness and resilience –
NEW: no minimum spend;
• Combating domestic violent extremism – NEW: no
minimum spend ;
• Enhancing election security – 3% minimum.

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4 Section 1 ‒ Overview | 2024
Key Changes to
the FY 2024
HSGP
Cont.

Purchasing Under a FEMA Award: 2024 OMB Revisions:

The Office of Management and Budget (OMB) has updated
parts of the OMB Guidance for Grants and Agreements in Title 2 of the Code of Federal Regulations. These updates will apply to FEMA awards with an award date on or after October 1, 2024.

Key changes include updates to the federal procurement
standards at 2 C.F.R. §§ 200.317 – 200.327, which govern how FEMA award recipients and subrecipients must conduct
purchases under a FEMA award.

FEMA will update its policy and guidance documents to
incorporate these revisions, but for now, please refer to the Purchasing Under a FEMA Award: 2024 OMB Revisions Fact
Sheet for more information.

Details on all the 2 C.F.R. revisions can be found on the Federal Register’s Guidance for Federal Financial Assistance webpage.

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

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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 in building,
sustaining, and delivering the core capabilities outlined in the goal of a secure and resilient nation. This analysis provides a national perspective on critical preparedness trends for whole community partners to use to inform
program priorities, allocate resources, and communicate with stakeholders about issues of concern.

HSGP Subrecipients are required to prioritize grant funding to demonstrate how investments support closing capability gaps or sustaining capabilities identified in the Threat Hazard Identification and Risk Assessment
(THIRA)/Stakeholder Preparedness Review (SPR) process.

DHS/FEMA continually assesses changes to the threat
landscape to further the National Preparedness Goal
(NPG) of a secure and resilient nation. The following are national priority areas for FY 2024, including the
corresponding percentage of funds required in each area:
• Enhancing information and intelligence sharing and
cooperation with federal agencies, including DHS – no
minimum;
• Enhancing the protection of soft targets/crowded
places – no minimum;
• Enhancing cybersecurity – no minimum;
• Enhancing community preparedness and resilience – no
minimum;
• Combating domestic violent extremism through
enhanced intelligence collection & analysis, training,
and community resilience – no minimum; and
• Enhancing election security – 3% minimum.

Subrecipients must spend a minimum of 30% of their SHSP and UASI awards across the six NPAs but have flexibility on how that funding is allocated. Only the Enhancing Election Security NPA has a minimum spend requirement of 3%. The remaining 27% can be allocated across any of the NPAs.

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6 Section 2 ‒ Federal Changes and Initiatives | 2024
FY 2024 National
Priorities Cont.

National Priority projects will be reviewed for effectiveness by DHS/FEMA and must be deemed effective prior to the
obligation or expenditure of funds.

Projects requiring additional information for DHS/FEMA to determine effectiveness of the project, or projects
deemed ineffective, will have a hold placed on their
subaward pending submission of requested information
and DHS/FEMA approval. Once a project is approved by
DHS/FEMA, modifications to the project have special
restrictions regarding modifications as indicated below:

Modifications which do not change the project scope and do not decrease the overall project budget can be
processed via regular modification request.

Modifications which change the project scope or
decrease the overall project budget will require DHS/FEMA approval and must be requested on the National Priority Project Modification Form.

Effectiveness will be evaluated by DHS/FEMA,
Cybersecurity and Infrastructure Security Agency,
DHS Office of Intelligence and Analysis, DHS Center for Prevention Programs and Partnerships, and/or other
DHS components, as appropriate. 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, based on the following four factors:
• Investment Strategy (40%): Projects will be evaluated based on the quality and extent to which the strategy
effectively demonstrates supporting 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.
• Budget (20%): Projects will be evaluated based on the extent to which a budget plan for each investment
demonstrates how grant expenditures maximize cost
effectiveness.

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7 Section 2 ‒ Federal Changes and Initiatives | 2024
FY 2024 National
Priorities Cont.
• Impact/Outcomes (40%): Projects will be evaluated on
how this investment helps the jurisdiction close
capability gaps identified in its Stakeholder
Preparedness Review and addresses NPs outlined in the
FY 2024 NOFO. Further, projects 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 improvements are measured and/or
evaluated.
• Past Performance (additional consideration): Projects will be evaluated based on the Subrecipient’s
demonstrated capability to execute the proposed
investments. Under this factor, FEMA will consider the
information provided by the Subrecipient and may also
consider relevant information from other sources.

A detailed description of allowable investments for each NP is included in the FY 2024 HSGP NOFO (Section A).

National
Campaigns and
Programs
Whole Community Preparedness – Subrecipients should
engage with the whole community to advance individual
and community preparedness and to work as a nation to
build and sustain resilience. In doing so, Subrecipients are encouraged to consider the needs of individuals with
access and functional needs and limited English
proficiency in the activities and projects funded by the grant.

Subrecipients should utilize established best practices for whole community inclusion and engage with stakeholders
to advance individual and jurisdictional preparedness and resilience. Subrecipients are encouraged to consider the necessities of all Californians in the activities and projects funded by the grant, including children, seniors, individuals with disabilities or 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 and resilience is available through
Individuals and Communities.

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8 Section 2 ‒ Federal Changes and Initiatives | 2024
National
Campaigns and
Programs Cont.

Active Shooter Preparedness – DHS developed a
comprehensive Active Shooter Preparedness website,
which strives to enhance national preparedness through a whole-community approach by providing the necessary
products, tools, and resources to help all stakeholders prepare for and respond to an active shooter incident.

Subrecipients are encouraged to review the referenced
active shooter resources and evaluate their preparedness needs.

Soft Targets and Crowded Places – States, territories, UAs, and public and private sector partners are encouraged to identify security gaps and build capabilities that address security needs and challenges related to protecting
locations or environments that are easily accessible to large numbers of people on a predictable or semipredictable basis that have limited security or protective measures in place, including town centers, shopping malls, open-air 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 and unity of effort to enable the integration of preparedness efforts, existing plans, and identifies unmet needs to better anticipate response requirements.

Additional information may be found at the 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 the
country from foreign terrorist organizations to address the evolving challenges of today.

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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 or inspire Westerners to carry out attacks against western and U.S. targets, including individuals living in communities 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 is not a phenomenon restricted solely to one community and
that any effort to counter violent extremism must be
applicable to all ideologically motivated violence. Efforts to provide information and training regarding CVE should emphasize the strength of local communities’ approach.

National
Cybersecurity
Review
The National Cybersecurity Review (NCSR) is a required
assessment for all Subrecipients of State Homeland Security Program (SHSP) and Urban Areas Security Initiative (UASI) funding to be completed between October 2024 and
February 2025.

The NCSR is a no-cost, anonymous, and annual selfassessment designed to measure gaps and capabilities of 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 will be required to complete the first 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. If there is no CIO or CISO, the most senior
cybersecurity professional should complete the
assessment. Additional information may be found in IB 439 and 429a.

NIMS
Implementation
Prior to the allocation of any federal preparedness awards, Subrecipients must ensure and maintain the adoption and implementation of the National Incident Management
System (NIMS).

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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 to Law Enforcement Terrorism Prevention
Activities (LETPA). This required LETPA allocation can be from SHSP, UASI, or both and may be met by funding
projects in any combination of the six NPAs and any other investments.

Allowable expenditures can be found in the 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 to be counted towards the LETPA
requirement, it must have a law enforcement terrorism
prevention nexus. If an activity is listed in the authorizing legislation or can be directly tied to a capability in the National Prevention Framework or shared capability in the National Protection Framework, then it is presumed to have law enforcement nexus and be a LETPA. For all other
claimed activities, nexus to law enforcement and terrorism prevention must be clearly explained.

Refer to IB 485 - FY23 LETPA Supplemental Guidance to the NOFO for further direction on how to account for LETPA
activities, best practices for submitting LETPA investments, and information on how to distinguish LETPA from other
activities .

Management
and
Administration
The Management and Administration (M&A) allowance for
Subrecipients is set at a maximum of 5% for FY 2024 HSGP.

Indirect Costs Indirect costs are allowable under the FY 2024 HSGP Grant Award.

Subrecipients with an indirect cost rate approved by their cognizant federal agency may claim indirect costs based on the established rate. Indirect costs claimed must be calculated using the base approved in the indirect cost negotiation agreement. A copy of the approved
negotiation agreement is required at the time of
application.

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

Indirect costs are in addition to the M&A allowance and must be included in the Grant Award application as a
“Project” and reflected in the 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’s fiscal year. An exception to this rule applies if there is a mid-year change to the approved indirect cost rate; in this case, costs incurred to date must be claimed. At that time, a Grant Subaward Modification reflecting the rate change
must also be submitted to Cal OES, along with a copy of the new Indirect Cost Rate Agreement.

The FEMA Preparedness Grants Manual, published by
FEMA, states that State and local governments are not
permitted to use the de minimis rate. These costs are
allowable only when an exception is granted to the SAA
by FEMA per 2 C.F.R. Part 200, Appendix VII, paragraph
D.1.b. Subrecipients should not include these costs in their future applications until further notice. If necessary, subrecipients may work with their Grants Analyst to modify their existing projects to remove these costs that were included in their advanced application.

Organization
Costs – Overtime
Operational overtime costs are allowable for increased
security measures at critical infrastructure sites if associated with detecting, deterring, disrupting, and preventing acts of terrorism and other catastrophic events.

Pursuant to page 52 of 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 as it relates to the event or activity requiring operational overtime support and explains how the overtime activity is
responsive to the threat.

Post-event operational overtime requests will only be
considered on a case-by-case basis, where it is
demonstrated exigent circumstances prevented

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12 Section 2 ‒ Federal Changes and Initiatives | 2024
Organization
Costs – Overtime
Cont.
submission of a request in advance of the event or activity.

Requests for overtime costs must be submitted to Cal OES via Allowability Request Log (ARL) Form at the time of
application, if the activity will occur within one year of the final application submission. All subsequent requests must be submitted at least 60 days in advance of the activity.

All operational overtime costs must be formally preapproved in writing by DHS/FEMA.

Personnel Cap Pursuant to 6 U.S.C. § 609(b), SHSP and UASI funds may be used for personnel costs, totaling up to 50 percent of each fund source. A Subrecipient may request 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 on official letterhead, with the following information:
• Documentation explaining why the cap should be
waived;
• Conditions under which the request is being submitted; and
• A budget and method of calculation of personnel costs both in percentages of the Grant Award and in total
dollar amount (waivers must be calculated separately
for SHSP and UASI, outlining salary, fringe benefits, and any M&A costs).

Subrecipient requests to exceed the personnel cap must
be received by Cal OES at the time of application.

Subaward modifications impacting the personnel cap will be reviewed on a case-by-case basis and may require the submittal of the above-mentioned information.

Please see IB 421b for more information on the waiver
process.

Allowable HSGP equipment is listed on the FEMA
Authorized Equipment List (AEL) website.

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

Per FEMA policy, the purchase of weapons and weapon
accessories are not allowed with HSGP funds. Special rules apply to pharmaceutical purchases, medical
countermeasures, and critical emergency supplies; refer to page A-10 of the FEMA Preparedness Grants Manual for
additional information.

Expenditures for general purpose equipment are allowable if they align to and support one or more core capabilities identified in the NPG, and in addition, are
deployable/sharable through the Emergency
Management Assistance Compact and allowable under
6 U.S.C. § 609. Refer to the NOFO and Preparedness Grants Manual for examples of allowable general-purpose
equipment.

Equipment
Maintenance/
Sustainment
Use of HSGP funds for maintenance contracts, warranties, repair or replacement 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 in their FMFW how
such activities align with the goals of the 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 Authorization Act for FY 2019 (NDAA) and 2 C.F.R. § 200.216, 200.471, and Appendix II to 2 C.F.R. Part 200 prohibit DHS/FEMA Recipients and
Subrecipients (including their contractors and
subcontractors) from using any FEMA funds under open or new awards for the following telecommunications
equipment or services:

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14 Section 2 ‒ Federal Changes and Initiatives | 2024
Telecom
Equipment and
Services
Prohibitions Cont.
1) Telecommunications equipment produced by Huawei
Technologies Company or 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 and telecommunications equipment
produced by Hytera Communications Corporation,
Hangzhou Hikvision Digital Technology Company, or
Dahua Technology Company (or any subsidiary or
affiliate of such entities);
3) Telecommunications or video surveillance services
provided by such entities or using such equipment; or
4) Telecommunications or video surveillance equipment or services produced or provided by an entity that the
Secretary of Defense, in consultation with the Director of National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be 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 Equipment or 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 Department of
Homeland Security (DHS) to review its grant programs and, consistent with applicable law, prohibits the use of grant funding to purchase certain types of military equipment by state, local, tribal, and territorial law enforcement
agencies (LEAs).

For all awards issued on or after January 1, 2023, the policy directly prohibits certain types of equipment outright
(prohibited equipment), whereas other types of equipment may be controlled, or LEAs are required to submit
certifications prior to purchase.

Even if equipment is listed as controlled equipment and is not outright prohibited, that does not automatically

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15 Section 2 ‒ Federal Changes and Initiatives | 2024
Prohibited and
Controlled
Equipment Cont.
make it allowable under a particular FEMA program.

Subrecipients should refer to applicable program
guidance or contact your Grants Analyst to determine if a 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 to purchase Small Unmanned Aircraft Systems (SUAS) with FEMA grant funding must comply with FEMA
Policy 207-22-0002 and include copies of the policies and procedures in place to safeguard individuals’ privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to, or otherwise use the SUAS equipment. The Authorized Equipment Listing for 03OE-07-SUAS details
questions that must be included in the 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 Equipment Self-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 is required 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 to remain
compliant with the Comprehensive Preparedness Guide
101 version 2.0.

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16 Section 2 ‒ Federal Changes and Initiatives | 2024
Conflict of
Interest
To eliminate and reduce the impact of conflicts of interest in the subaward process, Subrecipients and pass-through entities must follow their own policies and procedures
regarding the elimination or reduction of conflicts of
interest when making subawards. Subrecipients and passthrough entities are also required to follow any applicable federal, state, local, and tribal statutes or regulations governing conflicts of interest in the making of subawards.

Subrecipients must disclose to their Grants Analyst, in writing, any real or potential conflict of interest as defined by the federal, state, local, or tribal statutes or regulations, which may arise during the administration of the HSGP
subaward within five days of learning of the conflict of interest.

Build America,
Buy America Act
(BABAA)
Under FEMA financial assistance programs, the BABAA
requirements apply to:
• New awards made on or after January 2, 2023,
• New funding that FEMA obligates to existing awards or through renewal awards on or after January 2, 2023;
and
• Infrastructure projects.

Funds provided under this program may not 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 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. Additionally, the Buy America
preference does not 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.

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17 Section 2 ‒ Federal Changes and Initiatives | 2024
Build America,
Buy America Act
(BABAA) Cont.

When necessary, Subrecipients may apply for a waiver
from these requirements. Additional information regarding the BABAA can be found on FEMA’s website under
Buy America Preference Buy America Preference.

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18 Section 3 ‒ State Changes and Initiatives | 2024
FY 2024
Investments
The State prioritized the following investment strategies for the 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, Governance, Technology, and
Equipment;

7. Enhance Medical and Public Health Preparedness;

8. Strengthen Information Sharing and Collaboration (nonFusion Center);

9. Enhance Multi-Jurisdictional/Inter-Jurisdictional AllHazards/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).

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19 Section 3 ‒ State Changes and Initiatives | 2024
California
Homeland
Security Strategy
Goals
The State prioritized the following California Homeland Security Strategy Goals for the 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 and Preparedness Across
Cyberspace;

4. Strengthen Communications Capabilities through
Planning, Governance, Technology, and Equipment;

5. Enhance Community Preparedness;

6. Enhance Multi-Jurisdictional/Inter-Jurisdictional AllHazards 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% of the 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 to decline or fail to utilize their subaward in a timely manner.

Public Alert and
Warning
Cal OES encourages Subrecipients to consider the use of this funding to assist their jurisdiction’s alignment with the State of California Alert and Warning Guidelines,
developed pursuant to Senate Bill 833 of the 2018
Legislative Session.

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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 to apply for grant programs. The Grant Subaward Face Sheet must be signed and submitted in portrait format. An active UEI# (Formerly DUNS#) is required. UEI registration information is available sam.gov.

Authorized Body of 5 – Provide the contact information of Authorized Agents (AA), delegated via the Governing Body Resolution (GBR) or Signature Authorization Form, including staff related to grant activities. More than one person is
recommended for designation as the AA; in the absence of an AA, an alternate AA can sign requests.

Project Ledger – The project ledger is used in the application process to submit funding information and is used for submitting cash requests, Grant Subaward Modifications, and assists with the completion of the Biannual Strategy Implementation Report (BSIR).

Planning Tab – Provides detailed information on grant-funded planning activities with a final product identified.

Organization Tab – Provides detailed information on grant-funded organizational activities.

Equipment Tab – Detailed information must be provided under the equipment description for all grant-funded equipment. AEL numbers must be included for all items of equipment. Always refer to the AEL for a list of allowable equipment and conditions, if any.

Training Tab – Provides detailed information on grant-funded training activities. All training activities must receive Cal OES approval prior to starting the event, including a Training Feedback number. The Training Request Form must be submitted and approved to obtain a Training Feedback number and should be submitted at least 30 days in advance.

Exercise Tab – Provides detailed information on grant-funded exercises.

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

M&A Tab – Provides information on grant-funded M&A activities.

Indirect Costs Tab – Provides information on indirect costs.

Consultant-Contractor Tab – Provides detailed information on grant-funded consultants and contractors.

Authorized Agent Page – The AA Page must be submitted with the application, all cash requests, and Grant Subaward
Modifications. The AA Page must include a valid signature on file with Cal OES and the date.

Subrecipient
Grants
Management
Assessment
Per 2 C.F.R. § 200.332, Cal OES is required to evaluate the risk of non-compliance with federal statutes, regulations, and grant terms and conditions posed by each Subrecipient of passthrough funding. The Subrecipient Grants Management Assessment Form contains questions related to an organization’s experience in the management of federal grant awards. It is used to determine and provide an appropriate level of technical assistance, training, and grant oversight to Subrecipients during the subaward. The questionnaire must be completed and
returned with the grant application.

Application
Attachments
Federal Funding Accountability and Transparency Act (FFATA) Financial Disclosure – Use the FFATA Financial Disclosure Form to provide the information required by the Federal Funding Accountability and Transparency Act of 2006.

Intelligence Analysts Certificates – Pursuant to the Preparedness Grants Manual, Cal OES must have certificates for completion of training for fusion 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 or list defining the footprint must be included with the application.

UAWG Member Roster (UASIs Only) – A list of all current UAWG members with positions or titles.

Indirect Cost Rate Agreement – If claiming indirect costs at a federally-approved rate, please provide a copy of the approved indirect cost rate agreement.

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22 Section 4 ‒ Required State Application Components | 2024 Standard
Assurances
The Standard Assurances list the requirements to which the Subrecipients will be held accountable. All Applicants will be required to submit an electronic signed, copy of the FY 2024 Standard Assurances as part of their FY 2024 HSGP application.

The required Standard Assurances can be found only in PDF format on the 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 an electronic signed Program Standard Assurances Addendum as part of the FY 2024 HSGP application. The required Program Standard Assurances
Addendum can be found only in PDF format on the Cal OES website.

Operational
Areas and
Urban Areas
Governing Body Resolution – The GBR appoints AAs (identified by the individual’s name or by a position title) to act on behalf of the governing body and the Applicant by executing any actions necessary for each application and subaward. All Applicants are required to submit a copy of an approved GBR with their grant application. Resolutions may be valid for up to three grant years given the following:
• The resolution identifies the applicable grant program (e.g., EMPG and/or HSGP);
• The resolution identifies the applicable grant years, (e.g., FY 2024, FY 2025, FY 2026; and
• Adheres to any necessary elements required by local
protocols, rules, etc., if applicable.

Resolutions that only identify a single grant program will only be valid for that single program. Resolutions that do not identify applicable grant years will only be valid for the grant year in which the resolution was submitted.

Authorized Agent Information – For each person or position appointed by the governing body, identify the individual in the All changes in AA and contact information must be provided to Cal OES in writing. If the GBR identifies the AA by name, a new Resolution is needed when changes are made. If the GBR
identifies the AA by position and/or title, changes may be made

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23 Section 4 ‒ Required State Application Components | 2024 Operational
Areas and
Urban Areas
Cont.
by submitting a request on the entity’s letterhead, signed by an existing AA. Cal OES will not accept signatures of an AA’s designee, unless authorized by the GBR. A change to an AA's designee must be submitted on agency letterhead and signed by the AA, announcing the change to their designee.

Operational
Areas Only
Approval Authority Body – OAs must appoint an Anti-Terrorism Approval Body (Approval Authority) to have final approval of the OA’s application for HSGP funds. Each member of the Approval Authority must provide written agreement with the OA’s
application for HSGP funds. The Approval Authority shall consist of the following representatives, and additional voting members may be added by a simple majority vote of the following standing members:
• County Public Health Officer or designee responsible for Emergency Medical Services
• County Fire Chief or Chief of Fire Authority
• Municipal Fire Chief (selected by the OA Fire Chiefs) • County Sheriff
• Chief of Police (selected by the OA Police Chiefs)
Urban Areas
Only
Urban Area Working Groups – Membership in the UAWG must provide either direct or indirect representation for all relevant jurisdictions and response disciplines (including law enforcement, fire service, EMS, hospitals, public health, and emergency management) that comprise the defined UA. It also must be inclusive of local Citizen Corps Council and tribal representatives.

The UAWG should also ensure the integration of local emergency management, public health, and health care systems into a coordinated sustained local capability to respond effectively to a mass casualty incident. Additional group composition criteria are found in the FEMA Preparedness Grants Manual.

Threat Hazard Identification and Risk Assessment – Subrecipients are required to submit a THIRA for all 32 core capabilities.

Beginning in 2019, UAs are required to submit a THIRA every three years. An annual capability assessment will still be required.

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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 to reach the targets set in their THIRA.

Fusion
Centers Only
All fusion center investments must align to, and reference, specific performance areas of the assessment that the funding is intended to support.

Fusion Centers are also required to follow all Reporting and Administrative Metrics for California Fusion Centers, as set forth in the Governor’s Homeland Security Advisor/Cal OES Director’s letter dated March 16, 2016. These operational and administrative metrics set forth an integrated and coordinated approach for regular and proactive information and intelligence sharing between all fusion centers in the California State Threat Assessment System (STAS).

State
Agencies and
Tribes Only
State Agencies, and federally recognized tribes may submit the Signature Authorization Form in lieu of a GBR, signed by the most senior ranking official, such as the Secretary, Director, President, Chancellor, or Chairperson.

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25 Section 5 ‒ State Application Process | 2024
Application
Submission
Subrecipients must submit an electronic copy of their completed FMFW to their Grants Analyst for review. After the application is approved, a completed copy of the FMFW, along with all other application components must be submitted, with official signatures, by the application due date. During the application process, if it is determined not all allocated funds can be expended by the end of the period of performance, please inform a Grants Analyst as soon as possible. The completed application should be received by Cal OES no later than the date provided in the FY 2024 HSGP Timeline, referenced as Attachment B.

Late or
Incomplete
Application
Late or incomplete applications may be denied. If an application is incomplete, the Grants Analyst may request additional information. Requests for late submission of applications must be made in writing to the Grants Analyst prior to the application due date. Cal OES has sole discretion to accept or reject a late or incomplete grant application.

HSGP Contact
Information
The Grants Analyst Regional Assignments Map is linked and available on the Cal OES website under “Regional Assignments”.

Subaward
Approval
Subrecipients will receive a formal notification of award no later than 45 days after Cal OES accepts the federal grant award. The award letter must be signed, dated, and returned to Cal OES within 20 calendar days. Once the completed application, along with the signed award letter, is received and approved, reimbursement of eligible subaward expenditures may be
requested using the Cal OES FMFW.

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26 Section 6 ‒ Post Award Requirements | 2024
Payment Request
Process
To request an advance or cash reimbursement of HSGP
funds, Subrecipients must first complete a payment request using the Cal OES HSGP FMFW, returning it to the appropriate Grants Analyst. Subrecipients who fail to follow the workbook instructions may experience delays in processing the
payment request.

Payments can only be made if the Subrecipient has an
approved application.

Advances and
Interest Earned on
Advances
An Advance payment is a payment that is requested before Subrecipients have disbursed the funds for program purposes.

Subrecipients may be paid an advance, provided they
maintain a willingness and ability to maintain procedures to minimize the time elapsing between the receipt of funds and their disbursement. The timing and amount of advance
payments must be as close as administratively feasible to the actual disbursements by the Subrecipient for project costs.

Federal rules require advances to be deposited in interestbearing accounts. Interest earned in amounts up to $500 per year may be retained by Subrecipients for administrative expenses; any additional interest earned on federal advance payments must be returned annually to Cal OES.

Semi-Annual
Drawdown
Requirements
All Subrecipients must report expenditures and request funds at least semi-annually throughout the period of performance.

Semi-annual drawdowns should occur by March and
October of each calendar year following final approval of the subaward application, except for the final cash request, which must be submitted within 20 calendar days after the end of the period of performance.

Modifications Post-award budget and scope modifications must be requested using the Cal OES HSGP FMFW v1.24, signed by the Subrecipient’s AA, and submitted to the Grants Analyst.

The Subrecipient may implement grant modification
activities, and incur associated expenses, only after receiving written final approval of the modification from Cal OES.

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27 Section 6 ‒ Post Award Requirements | 2024
Modifications
Cont.

Subrecipients must provide a written justification with all modification requests. The justification may be included in the body of the e-mail transmitting the request, or in a document attached to the transmittal e-mail. Please reference GMM 2018-17 for additional information regarding modification requests.

Modifications to NP Projects have additional restrictions as indicated below:

Modifications which do not change the project scope and do not decrease the overall project budget can be
processed via regular modification request.

Modifications which change the project scope or decrease the overall project budget will require DHS/FEMA approval and must be requested on the National Priority Project
Modification Form.

Training
Requirements
All grant-funded training activities must receive Cal OES approval prior to starting the training event. Cal OES shall allow Subrecipients to develop a “placeholder” for future training conferences when an agenda has not been
established at the time Subrecipient applications are due.

Please work with a Grants Analyst and the Training Branch to identify a possible “placeholder” for these types of training activities.

When seeking approval of non-DHS/FEMA developed
courses, course materials must be submitted with the
approval requests. Conditional approvals are not offered.

Subrecipients must complete a Training Request Form and submit it electronically to the Cal OES Training Branch to be approved with a Training Feedback Number before
beginning any training activities. This includes project components like travel to, materials for, or attendance in training courses. Training Feedback Numbers should be
obtained no later than 30 days before the first day of the training or related activities. Requests that are submitted with less than 30 days prior to the start of the training or activity are not guaranteed to be approved in time and run the risk of training being unallowable. Training Feedback numbers must

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28 Section 6 ‒ Post Award Requirements | 2024
Training
Requirements
Cont.
be included on the FMFW Training Ledger to be considered for reimbursement.

For more information on this or other training-related inquiries, contact the Cal OES Training Branch at (916) 845-8745 or [email protected].

Exercises,
Improvement
Plans, and AfterAction Reporting
Subrecipients should engage stakeholders to identify longterm 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 for improvement identified in the NPR.

Subrecipients must report on all exercises conducted with HSGP grant funds. An After-Action Report
(AAR)/Improvement Plan (IP) or Summary Report (for
Seminars and Workshops) must be completed and submitted to Cal OES within 90 days after exercise/seminars/workshops are conducted. It is acceptable to submit an Exercise
Summary Report for Seminars and Workshops in lieu of a full AAR/IP.

Please e-mail AAR/IPs and Summary Reports to:
• [email protected]
• [email protected]
• [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 for reimbursement until an AAR/IP is received by Cal OES.

Procurement
Standards and
Written
Procedures
Subrecipients are required to conduct procurement activities in with documented procurement procedures that align with federal procurement standards outlined in 2 C.F.R. Part 200. In cases where there is a conflict between the local procedures and federal standards, the more stringent requirements must be followed. Additionally, subrecipients must implement written conflict of interest policies that govern the actions of employees involved in the selection, award, and
administration of contracts. These policies should include provisions for disciplinary actions in the event of violations.

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29 Section 6 ‒ Post Award Requirements | 2024
Procurement
Thresholds
Under 2 C.F.R. Part 200, procurement thresholds are defined as follows:
• Micro-purchase threshold: This is the maximum amount for which purchases can be made without requiring
competitive quotes or formal procurement processes,
provided the price is reasonable. The micro-purchase
threshold is set at $10,000.
• Simplified acquisition threshold: This sets the maximum amount for which federal procurement procedures may be
simplified. The threshold is $250,000. For purchases at or below this amount, subrecipients may use streamlined
methods, such as obtaining competitive price or rate
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 to these thresholds and, in cases of conflict between local procurement procedures and
federal requirements, must apply the more stringent
threshold.

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

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30 Section 6 ‒ Post Award Requirements | 2024
Noncompetitive
Procurement
All noncompetitive procurements exceeding the simplified acquisition threshold requires Cal OES prior written approval to be eligible for reimbursement. This method of procurement must be approved by the local Purchasing Agent prior to submitting a request for Cal OES approval. A copy of the 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 of the cost of the training. Exceptions to this policy may be approved in limited circumstances, e.g., related to a procurement effort that has resulted in
inadequate competition. Please refer to GMM2017-01A and GMM2021-05 for additional guidance.

Performance
Bond
Due to the risks associated with delays in vendor delivery of large equipment procurements, DHS/FEMA allows
Subrecipients to obtain a “performance bond” for items that are paid for up front to ensure delivery of the equipment within the grant period of performance.

Cal OES requires Subrecipients to obtain a performance bond when procuring any equipment item over $250,000, or for any vehicle, aircraft, or watercraft that requires full or partial payment prior to receiving the final product(s).

Performance Bond Waivers may be granted on a case-bycase basis and must be submitted to Cal OES prior to procurement.

Environmental
Planning and
Historic
Preservation (EHP)
DHS/FEMA is required to ensure all activities and programs that are funded by the 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 or renovation projects) that have the potential to impact the environment, or a historic structure must participate in the EHP screening process. EHP Screening Memos must include detailed project information, explain the goals and objectives of the proposed

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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 Subrecipient to provide a confidential California Historical Resources Information System (CHRIS) report in addition to the EHP Screening Form.

Determination on the necessity of a CHRIS report is based upon information disclosed on the form. GrantAnalysts will provide additional instructions should this report be required.

EHP Screening Requests should be submitted to Cal OES as early as possible. All projects/activities triggering EHP must receive DHS/FEMA written approval prior to commencement of the funded activity.

Updated information may be referenced in the FEMA GPD
EHP Policy Guidance.

Construction and
Renovation
When applying for construction activity at the time of
application, including communication towers, Subrecipients must submit evidence of approved zoning ordinances,
architectural plans, any other locally required planning permits, and a notice of federal interest. Additionally, Subrecipients are required to submit an SF-424C Budget and Budget Detail that cites project costs. Communication tower construction requests also require evidence that the Federal Communications Commission’s Section 106 review process
was completed.

Subrecipients using funds for construction projects must comply with the Davis-Bacon Act. Subrecipients must ensure that their contractors or subcontractors for construction projects pay workers no less than the prevailing wages for laborers and mechanics employed on projects of a
character like the contract work in the civil subdivision of the state in which the work is to be performed.

Project construction using SHSP and UASI funds may not
exceed $1,000,000 or 15% of the grant subaward (for the purposes of limitations on funding levels, communications towers are not considered construction).

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32 Section 6 ‒ Post Award Requirements | 2024
Construction and
Renovation Cont.

Written approval for construction must be provided by
DHS/FEMA prior to the use of any HSGP funds for construction or renovation. No construction activities (including site preparation, utility installations, and any groundbreaking activities) or equipment installations on existing structures, may begin until the EHP review process is complete.

Inventory Control
and Property
Management
Subrecipients must use standardized resource management concepts for resource typing and credentialing, in addition to maintaining an inventory by which to facilitate the effective identification, dispatch, deployment, tracking, and recovery of resources.

Subrecipients must have an effective inventory management system, to include:
• Property records that document description, serial/ID number, fund source, title information, acquisition date, cost, federal cost share, location, use, condition, and ultimate disposition;
• A physical inventory conducted at least every two years; • A control system to prevent loss, damage, and theft of grant purchased equipment and supplies; and
• Adequate maintenance procedures to keep the property
in good condition.

Equipment
Disposition
When original or replacement equipment acquired under the HSGP is no longer needed for program activities, the
Subrecipient must contact the Grants Analyst to request disposition instructions. See 2 C.F.R. § 200.313€.

Performance
Reporting
Subrecipients must complete a BSIR 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 for the
duration of each subaward period of performance or until all grant activities are completed and the subaward is formally closed by Cal OES. Failure to submit a BSIR could result in subaward reduction, suspension, or termination.

Access to the BSIR for all awards prior to FY 2024 may be obtained through the GRT. To create a new account, please click the link that reads, “Register for an account” and follow the instructions provided. The Subrecipient will be required to

EXHIBIT F
PAGE 446 of 704
33 Section 6 ‒ Post Award Requirements | 2024
Performance
Reporting Cont.
ensure up-to-date project information is entered. The Project Ledger in the FMFW may assist with the BSIR data entry
process. For additional assistance with the GRT, please contact your Grants Analyst.

Extension
Requests
Extensions to the initial period of performance identified in the subaward will only be considered through formal, written requests to your Grants Analyst. Upon receipt of the extension request, Cal OES will:

1. Verify compliance with performance reporting
requirements by confirming the Subrecipient has
submitted all necessary performance reports;

2. Confirm the Subrecipient has provided sufficient
justification for the request; and

3. If applicable, confirm the Subrecipient has demonstrated sufficient progress in past situations where an extension was authorized by Cal OES.

Extension requests will be granted only due to compelling legal, policy, or operational challenges, must be projectspecific and will only be considered for the following reasons:

1. Contractual commitments with vendors that prevent
completion of the project within the period of
performance;

2. The project must undergo a complex environmental
review which cannot be completed 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 no later than 60 days prior to the end of the Subrecipient’s period of performance and must contain specific and
compelling justifications as to why an extension is required. All extension requests must address the following:

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

2. Reason for delay;

3. Current status of the activity/activities;

4. Approved period of performance termination date and
new project completion date;

EXHIBIT F
PAGE 447 of 704
34 Section 6 ‒ Post Award Requirements | 2024
Extension
Requests
Cont.

5. Amount of funds drawn down to date;

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 for implementing the plan for completion; and

9. Certification the activity/activities will be completed within the extended period of performance without any
modification to the original Project Scope.

General questions regarding extension requirements and the extension request form, should be directed to your Grants Analyst. For additional information, please see IB 379.

Extension requests for personnel and salaries do not meet the requirements of IB 379 and will not be granted. Subrecipients are expected to complete all grant-funded personnel
activities by the end of the subaward period of performance.

Progress Reports
on Grant
Extensions
All Subrecipients that receive Cal OES approval to extend their FY 2024 Grant Subaward period of performance may be required to submit progress reports indicating completed and future project milestones on all extended projects. Progress reports must be submitted electronically to the Subrecipient’s Grants Analyst. Deadlines for the submission of progress reports will be established at the time of extension approval.

Monitoring Cal OES Grants Monitoring actively monitors Subrecipients, through day-to-day communications, programmatic site
visits, desk, and on-site compliance assessments. The purpose of the compliance assessment is to ensure Subrecipients are in compliance with applicable state and federal regulations, grant guidelines, and programmatic requirements.

Monitoring activities may include, but are not limited to:
• Verifying entries recorded on the FMFW categories are properly supported with source documentation;
• Eligibility of and support for expenditures, typically covering two to three years of data;
• Comparing actual Subrecipient activities to those
approved in the grant application and subsequent

EXHIBIT F
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35 Section 6 ‒ Post Award Requirements | 2024
Monitoring
Cont.
modifications, including the review of timesheets and
invoices as applicable;
• Procurements and contracts;
• Ensuring equipment lists are properly maintained and
physical inventories are conducted;
• Ensuring advances have been disbursed in accordance
with applicable guidelines; and
• Confirming compliance with Standard Assurances; and
• Information provided on performance reports and
payment requests
NOTE: It is the responsibility of all Subrecipients that pass down grant funds to other entities, to maintain and utilize a formal process to monitor the grant activities of their subawards. This requirement includes, but is not limited to, on-site verification of grant activities, as required. It is common for Subrecipients to receive findings in a programmatic site visit or compliance assessment, which require a Corrective Action Plan (CAP) to be submitted by Subrecipients. Those Subrecipients who fail to submit a CAP, as required, shall have a “hold” placed on any future reimbursements until the “finding” is resolved.

Failure to Submit
Required Reports
Periodic reporting is required by the grant. Subrecipients who miss a single reporting deadline may receive a letter
addressed to their Board of Supervisors informing them of the failure to report. County OAs and tribes who fail to report twice consecutively may have subsequent awards reduced
by 10% until timely reporting is reestablished; UASIs may have a “hold” placed on any future reimbursements.

Suspension/
Termination
Cal OES may suspend or terminate grant funding, in whole or in part, or other measures may be imposed for any of the following reasons:
• Failure to submit required reports.
• Failure to expend funds in a timely manner consistent with the grant milestones, guidance, and assurances.
• Failure to comply with the requirements or statutory
progress toward the goals or objectives of federal or state law.
• Failure to make satisfactory progress toward the goals or objectives set forth in the Subrecipient application.
• Failure to follow Grant Subaward requirements or Special

EXHIBIT F
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36 Section 6 ‒ Post Award Requirements | 2024
Suspension/
Termination Cont.

Conditions.
• Proposing or implementing substantial plan changes to the extent that, if originally submitted, the application would not have been selected for funding.
• False certification in the application or document.
• Failure to adequately manage, monitor, or direct the
grant funding activities of their Subrecipients.

Before taking action, Cal OES will provide the Subrecipient reasonable notice of intent to impose corrective measures and will make every effort to informally resolve the problem.

Closeout
Cal OES will close-out Subrecipient awards when it
determines all applicable administrative actions and all required work of the federal award have been completed.

Subawards will be closed after:
• All funds have been requested and reimbursed, or
disencumbered;
• Receiving all applicable Subrecipient reports indicating all approved work has been completed, and all funds have
been distributed;
• Completing a review to confirm the accuracy of reported information;
• Reconciling actual costs to subawards, modifications, and payments; and
• Verifying the Subrecipient has submitted a final BSIR showing all grant funds have been expended.

Records Retention The records retention period is three years from the date of the Cal OES Grant Closeout letter, or until any pending litigation, claim, or audit started before the expiration of the three-year retention period has been resolved and final action is taken.

For indirect cost rate proposals, cost allocation plans, or other rate computation records, the start of the record retention period is dependent on whether the proposal, plan, or other computation is required to be submitted to the federal
government (or to the pass-through entity) for negotiation purposes. See 2 C.F.R. § 200.334(f).

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

In order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g).

The Cal OES Grant Closeout Letter will notify the Subrecipient of the start of the records retention period for all
programmatic and financial grant-related records.

If the State Administrative Agency’s award remains open after the Subrecipient’s submission of the final BSIR, Cal OES will complete any additional BSIR reporting required under the award on behalf of the Subrecipient.

Closed grants may still be monitored and audited. Failure to maintain all grant records for the required retention period could result in a reduction of grant funds, and an invoice to return costs associated with the unsupported activities.

If documents are retained longer than the required retention period, FEMA, the DHS Office of Inspector General,
Government Accountability Office, and pass-through entity have the right to access these records as well. See 2 C.F.R. §§ 200.334, 200.336.

EXHIBIT F
PAGE 451 of 704
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

EXHIBIT F
PAGE 452 of 704
39 Attachment A ‒ FY 2024 HSGP Allocations | 2024
Fusion Centers
Region Total Award
SAN FRANCISCO BAY AREA 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 to
State
Allocation to
UASI 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 AREA 3,410,728 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

EXHIBIT F
PAGE 453 of 704
40 Attachment B ‒ FY 2024 HSGP Timeline | 2024
DHS/FEMA Announcement of 2024 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

EXHIBIT F
PAGE 454 of 704
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 Body of 5
☐ 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 Counter-Signed 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 (If Applicable)
☐ Intelligence Analyst(s) Certificates (If Applicable)
UASI Only:
☐ UASI Footprint
☐ UAWG Roster
State Agencies and Tribes Only:
☐ Signature Authority Form (in lieu of Governing Body Resolution) For Cal OES Use Only
Reviewed by: Date:

Management Approval: Date:

EXHIBIT F
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TO: Mayor and City Council
FROM: Philippe Eskandar, City Manager
BY: Hillary Guirola-Leon, Finance Director
DATE: December 10, 2025
SUBJECT: RECEIVE AND FILE ANNUAL COMPREHENSIVE

FINANCIAL REPORT (ANNUAL AUDIT) FOR THE FISCAL
YEAR ENDED JUNE 30, 2025

STRATEGIC PLAN CRITICAL SUCCESS FACTORS
Efficient, Responsive, and Effective City Services
Fiscally Responsible and Transparent City Government

BACKGROUND
The Annual Comprehensive Financial Report (ACFR) is used to communicate the City’s financial condition and activity in a transparent and organized manner. The ACFR presents historical and comparative information that can be useful to City Staff, elected officials, and external users, such as businesses, other public agencies and the City’s residents. As required by the Citywide Financial Policies, the ACFR is prepared by the City and audited by independent auditors who are contracted through a competitive procurement process.

LSL conducted the audit in accordance with the Generally Accepted Auditing Standards, whereby an audit plan was prepared and followed to obtain reasonable assurance that the City’s financial statements were free from material misstatements. The audit included a review, on a test basis, of documents supporting the amounts and disclosures in the financial statements. The audit also assessed the accounting principles used and significant estimates made by management, as well as evaluated the overall general-purpose financial statement presentation. Fiscal Year 2024-25 represents the fifth year that the City has created an ACFR in accordance with standards prescribed by the Government Finance Officers Association (GFOA).

Gretchen Shepherd Romey, Mayor
Tony Chou, Vice Mayor
Hunter Chang, Council Member
John Chou, Council Member
Calvin Lo, Council Member
PAGE 479 of 704
This was an objective that the Finance Department previously disclosed as one of its goals during the FY 2021-22 budget process and continues to be one of the Department’s core goals moving forward. In addition to the financial statements and required supplementary information which were provided in the past, the ACFR also provides a letter of transmittal and a statistical section detailing information about the City that external users can use to see tenyear trends of the City. The FY 2023-24 ACFR received the City’s third Certificate of Achievement for Excellence in Financial Reporting. This year’s ACFR will be submitted once again to the GFOA as part of their Certificate of Achievement for Excellence in Financial Reporting awards programs.

The City Council’s Alternate Finance Liaison, Council Member John Chou also participated in the auditor’s exit interview along with City staff. The exit interview provided an opportunity for Council Member Chou, City staff, and LSL discuss the audit at a high level and answer any questions.

DISCUSSION
The attached ACFR (Attachment 1) for the fiscal year ended June 30, 2025, received an unqualified/unmodified “clean” audit opinion letter. A clean opinion communicates to users that the financial statements are fairly presented and that the information used in the statements is reliable. The recent history of findings is displayed below:

Fiscal Year
(FY)
Number of Material
Weaknesses
Number of Significant
Deficiencies
FY 2015 6 1
FY 2016 2 1
FY 2017 0 1
FY 2018 1 1
FY 2019 0 0
FY 2020 0 0
FY 2021 0 0
FY 2022 0 0
FY 2023 0 0
FY 2024 0 0
FY 2025 0 0
In the Statement of Auditing Standards Statement (SAS) 114 letter (Attachment 2), the letter details the scope of audit procedures performed, significant findings, and other information, such as disagreements with management, audit adjustments and significant estimates, that are not communicated in the audited financial statements.

PAGE 480 of 704
In the past, the City had a history of material weaknesses and significant deficiencies that suggested fundamental operational problems that were reported by the auditors. In the Statement of Auditing Standards Statement (SAS) 115 letter (Attachment 3), LSL did not identify any deficiencies in internal controls that they consider as material weaknesses or significant deficiencies that require corrective action by the City.

The City’s General Fund had a net change of $1,533,064 for the year ended June 30, 2025. The General Fund’s unassigned fund balance as of June 30, 2025, is $19.07 million. This represents a reserve ratio of 52% measured against annual General Fund revenues. The City’s Financial Policies specify that the General Fund unassigned fund balance shall be approximately 40% of General Fund revenues. On November 12, 2025, Council approved a transfer from the General Fund to the Capital Projects Fund in the amount of $2,300,000 for FY 2025-26.

Management’s Discussion and Analysis section (MD&A) of this report (pages 5 through 11) provides an overview and analysis of the financial activities of the City for the fiscal year ended June 30, 2025. The MD&A also provides an overview of each major section of the report and provides a comparison to prior year.

The format and content of the ACFR are largely prescribed in order to meet governmental accounting standards. The City’s ACFR includes the following major sections and information:

Introductory Section
● Letter of Transmittal
● Organizational Chart
● List of Elected and Administrative Officials
● Certificate of Achievement for Excellence in Financial Reporting for Fiscal Year Ended June 30, 2024
Financial Section
● Independent Auditors’ Report: the City’s report card on the content of the Financial Statements
● Management’s Discussion and Analysis (MD&A): provides an analytical overview of the City’s financial status
● Governmental-Wide Financial Statements: show finances at a point in time (assets – liabilities) and throughout the year (revenues – expenditures), budget to actual revenues and expenditures, and cash flows PAGE 481 of 704
● Fund Financial Statements: a detailed look at funds, showing Balance Sheet and Statement of Revenues, Expenditures, Changes in Fund Balance, and Net Position
● Notes to the Financial Statements: a narrative explanation that accompanies the Basic Financial Statements
● Budget to Actual Comparisons: General Fund and other select major funds ● Pension Information: 10 years of pension funding information ● Other Post-Employment Benefits (OPEB) Information: 7 years of OPEB funding information
● Breakout of Individual Funds: presented in a cumulative manner in the Financial Section
Statistical Section
● Financial Trends
● Revenue Capacity
● Debt Capacity
● Demographic and Economic Information
● Operating Information

FISCAL IMPACT & PROCUREMENT REVIEW
The receiving and filing of the City’s financial statements possesses no fiscal impact and requires no procurement review.

LEGAL REVIEW
The City Attorney's office has reviewed and approved as to form.

RECOMMENDATION
Staff recommends that this annual financial statement be received and filed.

If the City Council concurs with staff’s recommendation, an appropriate motion would be:
“I move to receive and file the audited financial statements for the fiscal year ended June 30, 2025.”

ATTACHMENTS

1. City of San Marino Annual Comprehensive Financial Report for the Fiscal Year Ended June 30, 2025

2. Auditor’s Communication Letter (SAS 114) for the Fiscal Year Ended June 30, 2025
PAGE 482 of 704

3. Auditor’s Report on Internal Controls (SAS 115) for the Fiscal Year Ended June 30, 2025
PAGE 483 of 704

CITY OF SAN MARINO
Annual
Comprehensive
Financial Report
For the Fiscal Year Ended June 30, 202
PAGE 484 of 704

CITY OF SAN MARINO, CALIFORNIA
Annual Comprehensive Financial Report
For the Year Ended June 30, 2025
PREPARED BY:

FINANCE DEPARTMENT
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CITY OF SAN MARINO, CALIFORNIA
Annual Comprehensive Financial Report
For the Year Ended June 30, 2025
Table of Contents
Page
Number

INTRODUCTORY SECTION
Letter of Transmittal ..................................................................................................................................................... i Organizational Chart ................................................................................................................................................ vii List of Elected and Administrative Officials ............................................................................................................. viii Certificate of Achievement for Excellence in Financial Reporting ........................................................................... vix

FINANCIAL SECTION
INDEPENDENT AUDITORS’ REPORT ..................................................................................................................... 1 MANAGEMENT'S DISCUSSION AND ANALYSIS .................................................................................................... 5

BASIC FINANCIAL STATEMENTS
Government-Wide Financial Statements:

Statement of Net Position ........................................................................................................................... 13 Statement of Activities ................................................................................................................................ 15 Fund Financial Statements:

Balance Sheet – Governmental Funds ....................................................................................................... 16 Reconciliation of the Balance Sheet of Governmental Funds to the Statement of Net Position ................................................................................................................. 17 Statement of Revenues, Expenditures and Changes in Fund Balances – Governmental Funds ................................................................................................................ 18 Reconciliation of the Statement of Revenues, Expenditures and Changes in Fund Balances of Governmental Funds to the
Statement of Activities ................................................................................................................................ 19 Statement of Net Position – Proprietary Fund ............................................................................................ 20 Statement of Revenues, Expenses and Changes in
Net Position – Proprietary Fund ................................................................................................................. 21 Statement of Cash Flows – Proprietary Fund ............................................................................................ 22 Notes to the Financial Statements ..................................................................................................................... 23

REQUIRED SUPPLEMENTARY INFORMATION
General Fund Schedule of Revenues, Expenditures, and Changes in Fund Balance - Budget and Actual .................................................................................................................... 53 PAGE 487 of 704

CITY OF SAN MARINO, CALIFORNIA
Annual Comprehensive Financial Report
For the Year Ended June 30, 2025
Table of Contents
Page
Number
Schedule of Proportionate Share of the Net Pension Liability ........................................................................... 54 Schedules of Plan Contributions ........................................................................................................................ 55 Schedule of Changes in the Net OPEB Liability and Related Ratios ................................................................ 56 Notes to Required Supplementary Information .................................................................................................. 59

COMBINING AND INDIVIDUAL FUND STATEMENTS AND SCHEDULES
Combining Balance Sheet – Nonmajor Governmental Funds ........................................................................... 60 Combining Statement of Revenues, Expenditures and Changes in Fund Balances – Nonmajor Governmental Funds ........................................................................................ 66 Budgetary Comparison Schedules – Special Revenue Funds:

State Gas Tax ............................................................................................................................................. 72 Community Development Block Grant ....................................................................................................... 73 Prop. A Transit ............................................................................................................................................. 74 Air Quality .................................................................................................................................................... 75 TDA Article 3 ................................................................................................................................................ 76 Prop. C Transit ............................................................................................................................................. 77 Asset Seizure ............................................................................................................................................... 78 California Recycling Grant ........................................................................................................................... 79 COPS Grant ................................................................................................................................................. 80 STPL ............................................................................................................................................................ 81 Measure W Clean Water ............................................................................................................................ 82 Measure R .................................................................................................................................................. 83 OTS Grant Fund .......................................................................................................................................... 84 PEG Fund .................................................................................................................................................... 85 SB 1383 and Used Oil Grant ....................................................................................................................... 86 Drought Education Fund .............................................................................................................................. 87 Measure M ................................................................................................................................................... 88 Bodyworn Camera Grant Fund .................................................................................................................... 89 Budgetary Comparison Schedule – Capital Projects Fund ............................................................................... 90 Budgetary Comparison Schedule – City Debt Service Fund ............................................................................. 91 PAGE 488 of 704

CITY OF SAN MARINO, CALIFORNIA
Annual Comprehensive Financial Report
For the Year Ended June 30, 2025
Table of Contents
Page
Number

STATISTICAL SECTION
Financial Trends:

Net Position by Component – Last Ten Fiscal Years ......................................................................................... 97 Changes in Net Position – Last Ten Fiscal Years .............................................................................................. 98 Fund Balances of Governmental Funds – Last Ten Fiscal Years .................................................................... 100 Changes in Fund Balances of Governmental Funds – Last Ten Fiscal Years ................................................. 102 Revenue Capacity:

Property Tax Dollar Breakdown ....................................................................................................................... 104 Direct and Overlapping Property Tax Rates – Last Ten Fiscal Years .............................................................. 105 Assessed and Estimated Actual Values of Taxable Property – Last Ten Fiscal Years .................................... 106 Top Ten Property Taxpayers – Current Year and Nine Years Ago .................................................................. 107 Assessed Value of Taxable Property by Category – Last Ten Fiscal Years .................................................... 108 Property Tax Levies and Collections – Last Ten Fiscal Years ......................................................................... 109 Debt Capacity:

Outstanding Debt by Type ................................................................................................................................ 110 Direct and Overlapping Debt ............................................................................................................................. 111 Demographic and Economic Information:

Demographic and Economic Statistics – Last Ten Calendar Years ................................................................. 112 Taxable Sales by Category ............................................................................................................................... 114 Operating Information:

Full-Time Equivalent City Employees by Function – Last Ten Fiscal Years .................................................... 115 Operating Indicators by Function – Last Ten Fiscal Years ............................................................................... 116 Capital Asset Statistics by Function – Last Ten Fiscal Years ........................................................................... 117 PAGE 489 of 704

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CITY OF SAN MARINO
2200 Huntington Drive
San Marino, CA 91108-2639
www.cityofsanmarino.org
November 4, 2025
Honorable Mayor, Vice Mayor, City Councilmembers, and Citizens of San Marino:

The Finance Department is excited to present to the City Council the City of San Marino’s (City) fourth Annual Comprehensive Financial Report (ACFR), formally known as the Comprehensive Annual Financial Report for the fiscal year ended June 30, 2025. The ACFR is intended to provide readers with a clearly articulated, user-friendly reporting of the City’s financial affairs. Within the ACFR, readers will find reporting on all funds and account groups for the City. This report consists of management’s representations concerning the finances of the City. As such, management assumes full responsibility for the completeness and reliability of the information contained in this report, based upon a comprehensive internal control framework it established for this purpose. Because the cost of internal controls should not exceed anticipated benefits, the objective is to provide reasonable assurance, rather than absolute assurance, that the financial statements are free of any material misstatements.

State Law requires the City to prepare an annual financial report. This report fulfills that obligation.

LSL, LLP, an independent firm of certified public accountants, has issued an unmodified opinion on the financial statements of the City for the year ended June 30, 2025. This will be the seventh year in a row that the City was able to achieve a clean opinion from the auditors with no material weaknesses or significant deficiencies. The independent auditors’ report is located at the front of the financial section of this ACFR. The ACFR has been prepared in conformity with Generally Accepted Accounting Principles (GAAP) and the financial reporting requirements prescribed by the Governmental Accounting Standards Board (GASB). These reporting requirements specify that management provide a narrative introduction, overview and analysis to accompany the financial statements in the form of a Management’s Discussion and Analysis (MD&A). The MD&A, which immediately follows the independent auditors’ report, complements this letter of transmittal and should be read in conjunction with it.

THE PRIMARY GOVERNMENT
The City is a General Law city and operates under a Council/Manager form of government. The City Council consists of five members that are elected at-large and typically serve staggered, four-year terms. The Mayor and Vice Mayor seats typically are one-year in duration and are selected by the Council Members. The City Council serves as the City’s primary governing body. The City Council additionally appoints the City Manager, the City Attorney and the City Treasurer. The City Manager oversees daily functions and ensures that directions of the City Council are carried out. The City provides Public Safety (Police and Fire), Community Development, Planning, Building and Safety, Parks and Public Works, Code Enforcement, Recreation Programs, Library Services, Financial Management, and Administrative Services mostly with City employees.
i
PAGE 491 of 704

THE CITY OF SAN MARINO
Situated 12 miles from the majestic foothill mountains, the beautiful City of San Marino, California (population 12,330 as of January 1, 2025 California State Department of Finance) is located northeast of Los Angeles in the San Gabriel Valley. Incorporated in 1913, this uniquely residential community is known for expansive properties surrounded by beautiful gardens, wide streets, well-maintained parkways, and top performing schools.

A city of 3.77 square miles, San Marino is home to the renowned Huntington Library, Art Collections, and Botanical Gardens. With a focus on resident services and community, the City is recognized for its police and fire services, library, parks and community amenities, and planning and zoning that distinguish and maintain the community’s high-quality residential character. The intention of the City’s founding fathers was a high-quality, crime-free residential area that provides great schools, parks, and an exclusive lifestyle; the City’s physical form today reflects those early values and development patterns.

ACCOUNTING SYSTEM AND BUDGETARY CONTROL
Accurate accounting of the City’s assets is essential to safeguard against loss and misrepresentation. The City’s system of accounting establishes solid control of the City’s financial assets and allows for budgeting and reliable performance reporting. It provides for the proper recording of financial transactions and lends itself to the establishment of accurate financial statements.

The City’s adopted financial policy states an annual budget needs to be adopted by the City Council by at least June 30 of each fiscal year. The City Council is presented each year with a new annual operating and capital improvement project budget. Part of the financial policy also requires the City to publish quarterly financial reports and a present a 30-Year Long-Range Financial Projection to the City Council annually.

CAPITAL IMPROVEMENT PROJECTS
The City’s Capital Improvement Program (CIP) is a component of the budget process and addresses the City’s short and long-term capital needs. The CIP includes a plan to effectively maintain existing infrastructure as well as provide new facilities to support population growth and replace older assets that are no longer useful or are unsafe.

The City has over 119.5 lane miles and 100 sidewalk miles covering the 3.77 square miles, as well as over 2,300 streetlights, 13 Civic Facilities, 1 Community Center, and 1 park.

During this reporting period, the City focused its resources on: Lift Station Improvements, Street Rehabilitation, Street Striping/Marking Program, Citywide Sidewalk Replacement, Culvert Replacement Program, Street Tree Management Program, and other projects which benefited the citizens of San Marino.

LOCAL ECONOMIC CONDITION AND OUTLOOK
San Marino remains one of America’s wealthiest communities. San Marino is an elegant community that benefits from a strong property tax base. The median age of San Marino residents in 2023 is 45.5, while the median age in the State of California as a whole is reported at 38.2 years (2023 US Census Bureau).

The operating budget is funded almost entirely from the General Fund, with some additional funding from restricted transportation, public safety funds, and other special revenue funds. The City’s General Fund has an unassigned fund balance of $19.0M as of June 30, 2025 and is projected to decrease by $41 thousand by June 30, 2026, which will be equal to 52% of FY 2025-26 General Fund Group estimated revenues. The property tax and public safety parcel tax together make up approximately 68% of the City’s General Fund revenues. The assumption for property tax growth in Fiscal Year 2025-26 is 4%.
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The adopted capital budget consists of $3.1 million for new projects, $5.7 million for unfinished projects from the prior year, and approximately $932 thousand for new equipment. While funding for capital equipment comes from the General Fund, funding for capital improvements comes primarily from our Capital Projects Fund reserves, along with some external funding sources.

The budget for the year ended June 30, 2026, includes an assumed growth rate of 4% for property taxes, which has been the trend for property taxes in the past two years. A conservative approach was used during the budget process as the local economy recovers from impacts due to the COVID-19 pandemic, and the continuation of a slowly growing economy. The adopted budget includes total revenues of $39.2 million and total expenditures of $47.1 million ($37.4 million in operating expenditures and $9.7 million of capital expenditures). Please see the following graph for a breakdown of our revenue sources and expenditure categories:

LONG-TERM FINANCIAL PLANNING
Property tax, Public Safety Parcel Tax and Utility Users Taxes are the three major contributors to the increase and current estimates indicate a continued, modest amount of growth for the upcoming years. A Five-Year Forecast is prepared during every budget year for the General and Public Safety Funds. The results of the projections during the budget FY 2025-26 preparation indicate that expenditure growth will outpace revenue growth during the next five years. The annual budget process also includes a long-range, 5-year plan for the spending of money on the City’s CIP.

The City has a reserve policy that maintains a general fund balance of at least forty percent (40%) of fiscal year (FY) budgeted revenues. The purpose for this allowance is to provide for various identified contingencies as well as allow for normal operation of regular city services. The City’s reserve balance is strong and meets the minimum required by the City-wide financial policies.
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MAJOR MILSTONES IN FISCAL YEAR 2024-25
During FY 2024-25, the City had various accomplishments and a relational by-product of clearly defined, consistent management practices, and responsible stewardship of the City’s assets. The following are undertakings that have helped to strengthen the City’s financial stability.

1. Continuation of the Public Safety Parcel Tax
Educated the community on Measure SM, leading to a successful passing of the Public Safety Parcel Tax

2. Implementation of Sewer Service Charges
The city hired a consultant to perform a Sewer Rate Study, leading to successful implementation of annual sewer service charges starting FY 2025-26. The Sewer service charges will provide funding to fund 25% of Sewer System capital needs.

3. Continued to prefund employer pension contributions through the CalPERS’ California Employers’ Retiree Benefit Trust (CERBT) program.

The City opened up a Section 115 Trust with CalPERS’s CERBT program in Fiscal Year 2020-21 with an initial contribution of $500,000. In Fiscal Year 2024-25, an additional contribution of $100,000 was made with the purpose of prefunding future employer medical pension contributions. The City has made $900,000 in contributions over the past five fiscal years.

4. FY 2023-24 ACFR awarded the Certificate of Achievement for Excellence in Financial Reporting by Government Finance Officers Association’s (GFOA).

This was the third time the City received the Certificate of Achievement for Excellence in Financial Reporting by Government Finance Officers Association’s (GFOA).

5. Continued Delivery of Accurate and Comprehensible Financial Reports The Department of Finance prepares and presents the Quarterly Financial Reports to the City Council per the City’s Financial Policies. The Department continues to distribute monthly budget to actuals financial reports to management for the purpose of identifying areas of spending patterns not in keeping with the approved budget. As such, management is easily able to identify problems, understand the financial impact of the problems, and establish corrective action plans for meeting organizational and citywide goals. iv
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INDEPENDENT AUDIT
For the fiscal year ended June 30, 2025, the City’s financial statements were audited by the certified public accounting firm of LSL, LLP to ensure that the financial statements of the City were free of material misstatement.

The audit a) examined activities, documents, and disclosures used to create the financial statements, b) assessed the accounting principles used by management, and c) evaluated the overall financial statement presentation. The results of the audit are as follows:
• The City’s financial statements have no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards; and
• Internal control over financial reporting and its operations was considered free from material weaknesses and significant deficiencies; and
• Financial statements present fairly, in all material respects, the respective financial position of the governmental activities, the business-type activities, each major fund, and the aggregate remaining fund information of the City of San Marino, California, as of June 30, 2025.

In this, it is my goal to provide readers and citizens an accurate depiction of the financial standing and activities regarding the City. Please reference the MD&A section of this report for a more complete and detailed accounting of financial performance for the fiscal year ended June 30, 2025.

AWARDS & ACKNOWLEDGEMENTS
The Government Finance Officers Association’s (GFOA) awarded the Certificate of Achievement for Excellence in Financial Reporting for the FY 2023-24 ACFR. This was the third year the City was recognized by the GFOA. The City will be submitting this year’s ACFR to the GFOA to determine its eligibility for the FY 2024-25 Certificate.

The GFOA awarded a Distinguished Budget Presentation Award to the City on August 12, 2025 for its operating and capital budget for fiscal year 2025-26. The award represents a significant achievement by the entity. It reflects the commitment of the governing body and staff to meeting the highest principles of governmental budgeting. In order to receive the budget award, the entity had to satisfy nationally recognized guidelines for effective budget presentation. These guidelines are designed to assess how well an entity's budget serves as a policy document, a financial plan, an operations guide and a communications device. The GFOA Distinguished Budget Presentation Award is valid for only one year.

The California Society of Municipal Finance Officers (CSMFO) awarded the Certificate for Excellence in Budgeting to the City on February 7, 2025 for its operating and capital budget for fiscal year 2024-25. The CSMFO Certificate of Excellence in Budgeting is valid for only one year. We believe our adopted operating and capital budget continues to meet the requirements of the CSMFO Certificate of Excellence in Budgeting and have submitted it for recognition for the fiscal year ended June 30, 2026.
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This report is a joint effort by all city departments. The preparation of this report could not have been accomplished without the hard work and team effort of the staff of the Finance Department, in particular, Account Clerks Mishalai Reed and Lisa Carlson. I want to express my appreciation to all members of the various City Departments who assisted and contributed to its preparation. I would also like to thank the Mayor; Vice Mayor, Councilmembers; and the Executive Team for their continuing efforts in administering the financial operations of the City responsibly and prudently.

Respectfully submitted,

Hillary Guirola-Leon
Finance Director
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City of San Marino
Organizational Chart
Residents
City Council
City Attorney City Manager
City Manager’s Office Community
Development
Community Services Finance
Fire Police Human Resources
Parks & Public Works Police
City Treasurer
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City Council
Mayor
Gretchen Shepherd Romey
Vice-Mayor
Tony Chou
Council Member
Hunter Chang
Council Member
John Chou
Council Member
Calvin Lo
Appointed Officials
Interim City Treasurer
Hillary Guirola-Leon
City Attorney
Joseph Montes
Executive Team
City Manager
Philippe Eskandar
Finance Director
Hillary Guirola-Leon
Human Resources Director
Lizette Guerrero
Community Development Director
Isidro Figueroa
Police Chief
John Incontro
Fire Chief
Mario Rueda
Parks & Public Works Director
Amber Shah
Community Services Director
Cathi Johnson
Community Engagement Manager
Nicole Tibbet
City Clerk
Alison Walker
City Leaders
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Government Finance Officers Association
Certificate of
Achievement
for Excellence
in Financial
Reporting
Presented to
City of San Marino
California
For its Annual Comprehensive
Financial Report
For the Fiscal Year Ended
June 30, 2024
Executive Director/CEO
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LSLCPAS.COM
INDEPENDENT AUDITORS’ REPORT
To the Honorable Mayor and Members of the City Council
City of San Marino, California
Report on the Audit of the Financial Statements
Opinions
We have audited the accompanying financial statements of the governmental activities, each major fund, and the aggregate remaining fund information of the City of San Marino, California, (hereafter, the City) as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the City’s basic financial statements as listed in the table of contents.

In our opinion, the financial statements referred to above present fairly, in all material respects, the respective financial position of the governmental activities, each major fund, and the aggregate remaining fund information of the City as of June 30, 2025, and the respective changes in financial position for the year then ended in accordance with accounting principles generally accepted in the United States of America.

Basis for Opinions
We conducted our audit in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States. Our responsibilities under those standards are further described in the Auditors’ Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of the City and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.

Responsibilities of Management for the Financial Statements Management is responsible for the preparation and fair presentation of the financial statements in accordance with accounting principles generally accepted in the United States of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about the City’s ability to continue as a going concern for twelve months beyond the financial statement date, including any currently known information that may raise substantial doubt shortly thereafter.

Auditors’ Responsibilities for the Audit of the Financial Statements Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinions.

Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with generally accepted auditing standards and Government Auditing Standards will always detect a material misstatement when it exists. The risk of not detecting a material PAGE 501 of 704
To the Honorable Mayor and Members of the City Council
City of San Marino, California
misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if there is a substantial likelihood that, individually or in the aggregate, they would influence the judgment made by a reasonable user based on the financial statements.

In performing an audit in accordance with generally accepted auditing standards and Government Auditing Standards, we:
• Exercise professional judgment and maintain professional skepticism throughout the audit. • Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. • Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the City’s internal control. Accordingly, no such opinion is expressed. • Evaluate the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluate the overall presentation of the financial statements. • Conclude whether, in our judgment, there are conditions or events, considered in the aggregate, that raise substantial doubt about the City’s ability to continue as a going concern for a reasonable period of time.

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control-related matters that we identified during the audit.

Required Supplementary Information
Accounting principles generally accepted in the United States of America require that the management’s discussion and analysis, budgetary comparison information, and required pension and other post-employment benefits schedules as listed on the table of contents be presented to supplement the basic financial statements. Such information is the responsibility of management and, although not a part of the basic financial statements, is required by the Governmental Accounting Standards Board who considers it to be an essential part of financial reporting for placing the basic financial statements in an appropriate operational, economic, or historical context. We have applied certain limited procedures to the required supplementary information in accordance with auditing standards generally accepted in the United States of America, which consisted of inquiries of management about the methods of preparing the information and comparing the information for consistency with management’s responses to our inquiries, the basic financial statements, and other knowledge we obtained during our audit of the basic financial statements. We do not express an opinion or provide any assurance on the information because the limited procedures do not provide us with sufficient evidence to express an opinion or provide any assurance. 2 PAGE 502 of 704
To the Honorable Mayor and Members of the City Council
City of San Marino, California
Supplementary Information
Our audit was conducted for the purpose of forming opinions on the financial statements that collectively comprise the City’s basic financial statements. The accompanying combining and individual fund financial statements and schedules (supplementary information) are presented for purposes of additional analysis and are not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements.

The information has been subjected to the auditing procedures applied in the audit of the basic financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the supplementary information is fairly stated, in all material respects, in relation to the basic financial statements as a whole.

Other Information
Management is responsible for the other information included in the annual report. The other information comprises the introductory and statistical sections but does not include the basic financial statements and our auditors’ report thereon. Our opinions on the basic financial statements do not cover the other information, and we do not express an opinion or any form of assurance thereon.

In connection with our audit of the basic financial statements, our responsibility is to read the other information and consider whether a material inconsistency exists between the other information and the basic financial statements, or the other information otherwise appears to be materially misstated. If, based on the work performed, we conclude that an uncorrected material misstatement of the other information exists, we are required to describe it in our report.

Other Reporting Required by Government Auditing Standards In accordance with Government Auditing Standards, we have also issued our report dated November 4, 2025, on our consideration of the City’s internal control over financial reporting and on our tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements and other matters. The purpose of that report is solely to describe the scope of our testing of internal control over financial reporting and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the City’s internal control over financial reporting or on compliance. That report is an integral part of an audit performed in accordance with Government Auditing Standards in considering City’s internal control over financial reporting and compliance.

Irvine, California
November 4, 2025
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MANAGEMENT’S DISCUSSION AND ANALYSIS
As management of the City of San Marino, we offer readers of the City’s basic financial statements this narrative overview and analysis of the financial activities of the City for the fiscal year ended June 30, 2025. We encourage readers to consider the information presented here in conjunction with additional information that we have furnished in the City’s basic financial statements.

FINANCIAL HIGHLIGHTS
• The aggregate net pension liability reported in the Statement of Net Position is $44.3 million. The net pension liability increased by $480 thousand, or 1%, this year. The aggregate net OPEB liability reported in the Statement of Net Position is $6.8 million. The City’s OPEB liability increased by $185 thousand this year. The increase is due to updates in valuation assumptions and a change in benefit terms. • The General Fund’s unassigned fund balance as of June 30, 2025 is $19.1 million. This represents a reserve ratio of 52% measured against annual General Fund operating revenue. The City’s Financial Policies specify that the General Fund unassigned fund balance shall be approximately 40% of General Fund revenues.
• The General Fund had a positive change in Fund balance of $1.5 million for FY 2024-25. This was due to one-time revenues received during the year related to expenditure reimbursement of $295,000 and the sale of Proposition A funds for $750,000 General Funds.

OVERVIEW OF THE FINANCIAL STATEMENTS
This discussion and analysis are intended to serve as an introduction to the City’s basic financial statements.

The basic financial statements consist of three components: 1) Government-wide Financial Statements, 2) Fund Financial Statements – both Governmental and Proprietary, and 3) Notes to Basic Financial Statements.

This report also contains required supplementary information in addition to the basic financial statements.

Government-wide Financial Statements. The government-wide financial statements are designed to provide readers with a broad overview of the City’s finances, in a manner similar to a private-sector business. There are two government-wide financial statements: the Statement of Net Position and the Statement of Activities.

The Statement of Net Position presents financial information about all of the City’s assets, deferred outflows of resources, liabilities, and deferred inflows of resources with the difference reported as net position. Over time, increases or decreases in net position may serve as a useful indicator of whether the financial position of the City is improving or deteriorating.

The Statement of Activities presents information showing how the City’s net position changed during the most recent fiscal year. All changes in net position are reported as soon as the underlying event giving rise to the change occurs, regardless of the timing of related cash flows. Thus, revenues and expenses are reported for some items that will only result in cash flows in future fiscal periods (e.g., uncollected taxes and earned but unused vacation leave).

Government-wide financial statements distinguish functions of an organization that are principally supported by taxes and intergovernmental revenues (“governmental activities”) from other functions that are intended to recover all or a significant portion of their costs through user fees and charges (“business-type activities”). The governmental activities of the City include general government, public safety, community development, recreation, parks and public works, library and interest on long-term debt. The City has no business-type activities as of June 30, 2025. Starting FY 2025-26, the City will have a Sewer fund where Sewer Service Charges will be accounted for.

Fund Financial Statements. A fund is a grouping of related accounts that is used to maintain control over resources that have been segregated for specific activities or objectives. The City, like other state and local governments, uses fund accounting to ensure and demonstrate compliance with finance-related legal requirements. All of the funds of the City can be divided into two categories: governmental funds and proprietary funds.
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Governmental Funds. Governmental funds are used to account for essentially the same functions reported as governmental activities in the government-wide financial statements. However, unlike the government-wide financial statements, governmental fund financial statements focus on near-term inflows and outflows of spendable resources, as well as on balances of spendable resources available at the end of the fiscal year. Such information may be useful in assessing a government’s near-term financing requirements.

Because the focus of governmental funds is narrower than that of the government-wide financial statements, it is useful to compare the information presented for governmental funds with similar information presented for governmental activities in the government-wide financial statements. By doing so, readers may better understand the long-term impact of the government’s near-term financing decisions. Both the governmental fund balance sheet and the governmental fund statement of revenues, expenditures and changes in fund balances provide a reconciliation to facilitate this comparison between governmental funds and governmental activities.

The City maintains twenty-three (23) individual governmental funds. Information is presented separately in the governmental fund balance sheet and in the governmental fund statement of revenues, expenditures and changes in fund balances for the General Fund and the City’s Capital Projects Fund; each is considered to be a major fund. Data from the other twenty-one (21) governmental funds are combined into a single aggregated presentation. Individual fund data for each of these nonmajor governmental funds is provided in the form of combining statements in the combining and individual fund statements and schedules section of this report.

The City adopted an annual appropriated budget for all the funds. A budgetary comparison statement has been provided for each of the governmental funds that adopted a budget to demonstrate compliance with its own budget.

Proprietary Funds. The City maintains one internal service fund, one type of proprietary fund.

Internal service funds are an accounting device used to accumulate and allocate costs internally among the City’s various functions. The City uses an internal service fund to account for capitalized equipment. Because this service benefits governmental functions, it is included within governmental activities in the government-wide financial statements.

Proprietary funds provide the same type of information as the government-wide financial statements, only in more detail. The proprietary fund financial statements provide information for the City’s one internal service fund.

Notes to the Financial Statements. The notes provide additional information that is necessary to acquire a full understanding of the data provided in the government-wide and fund financial statements.

Other Information. In addition to the basic financial statements and accompanying notes, this report also presents Required Supplementary Information (RSI). RSI can be found immediately following the Notes to the Financial Statements, and includes a budgetary comparison schedule for the General Fund and supplemental information on the City’s pension and OPEB plans.

The combining statements, referred to earlier in connection with nonmajor governmental funds, are presented immediately following the RSI on pensions and OPEB.

THE CITY AS A WHOLE
The analysis below focuses on the net position and changes in net position presented in Table 1 and Table 2, respectively.

Net Position. The City’s net position can serve as a useful indicator of the City’s financial position. As of June 30, 2025, the City’s net position is $202 million, which was up $2.7 million for the year. Net Position consists of three categories: net investment in capital assets, restricted, and unrestricted. The largest portion of the City’s net position, approximately $212 million at June 30, 2025, is the City’s net investment in capital assets (i.e., land, buildings, machinery, equipment, and infrastructure). Because capital assets are used to provide service to citizens, they are not available to fund the City’s day-to-day activities. Net investment in capital assets increased by $7.7 million for the year as additions to capital assets exceeded depreciation on capital assets.

Capital assets are further discussed later in this analysis. 6 PAGE 506 of 704
The restricted net position totaled $5.6 million at June 30, 2025. These are resources subject to external restrictions on how they can be used. Restricted net position decreased by $2.5 million this year, due primarily to using transportation-related special revenues reserves during the year. The remaining unrestricted net position was a negative $15.8 million. The negative net position is primarily caused by the reporting of the net pension liability and other postemployment benefits (OPEB) liability as required under GASB Statements No. 68 and No. 75, respectively.

Changes in Net Position. During the year, the net position for the City decreased by $2.7 million, or -330.9%. Revenues increased by $1.3 million, or 3.3%, and expenses increased by $5.2 million, or 13.7%, over the prior year amounts.

Program revenues decreased by $1.3 million and general revenues increased by $2 million. The general revenue increase was due to growth in property taxes and Utility Users Taxes. General revenues also increased due to other revenues that were one-time in nature. During the fiscal year, the city sold $1,000,000 in Proposition A funds in exchange for $750,000 in General funds. During the fiscal year, the city also received reimbursement from Valley vista Services in the amount of $225,000 for costs incurred with the RFP and evaluation services.

Other revenues also increased due to changes in market value of the city investments.

The overall $5.2 million increase in expenses was driven by an increase in expenses for the Public Safety and General Government divisions.
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2025 2024 Change in $ Change in %
Current and Other Assets $ 37,681,051 $ 43,676,518 $ (5,995,467) -13.7% Capital Assets 213,693,612 205,623,529 8,070,083 3.9%
Total Assets 251,374,663 249,300,047 2,074,616 0.8%
Deferred Outflows of Resources
Deferred Pension-Related Items 13,527,836 18,056,225 (4,528,389) -25.1% Deferred Other Post-Employment
Benefits-Related Items 1,661,454 2,014,981 (353,527) -17.5% Total Deferred Outflows of Resources 15,189,290 20,071,206 (4,881,916) -24.3% Current Liabilities 5,795,115 4,288,979 1,506,136 35.1% Long-term Liabilities 55,337,516 55,948,831 (611,315) -1.1% Total Liabilities 61,132,631 60,237,810 894,821 1.5%
Deferred Inflows of Resources
Deferred Pension-Related Items 998,720 1,811,014 (812,294) -44.9% Deferred Other Post-Employment
Benefits-Related Items 2,144,090 2,294,962 (150,872) -6.6% Total Deferred Inflows of Resources 3,142,810 4,105,976 (963,166) -23.5% Net Position:

Net Investment in Capital Assets 212,512,065 204,744,294 7,767,771 3.8% Restricted 5,627,837 8,168,361 (2,540,524) -31.1%
Unrestricted (15,851,390) (7,885,188) (7,966,202) 101.0% Total Net Position $ 202,288,512 $ 205,027,467 $ (2,738,955) -1.3% Table 1
Condensed Statement of Net Position
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2025 2024 Change in $ Change in %
Revenues:

Program Revenues
Charges for Services & Special Taxes $ 8,194,284 $ 7,644,721 $ 549,563 7.2% Operating Grants & Contributions 1,905,155 3,220,385 (1,315,230) -40.8% Capital Grants & Contributions 678,250 685,392 (7,142) -1.0% Total program revenues 10,777,689 11,550,498 (772,809) -6.7% General Revenues
Property Taxes 20,341,950 19,651,443 690,507 3.5%
Property Taxes in Lieu of Motor Vehicle Fees 2,110,856 2,480,578 (369,722) -14.9% Utility Users Taxes 2,363,550 2,124,689 238,861 11.2%
Business License Taxes 443,305 425,418 17,887 4.2%
Sales Taxes 694,873 648,547 46,326 7.1%
Franchise Taxes 718,933 757,649 (38,716) -5.1%
Use of Money & Property 1,662,088 1,726,871 (64,783) -3.8% Other Revenues 1,609,276 52,799 1,556,477 2947.9%
Total general revenues 29,944,831 27,867,994 2,076,837 7.5% Total revenues 40,722,520 39,418,492 1,304,028 3.3%
Expenses:

General Government 7,495,254 6,029,243 1,466,011 24.3%
Public Safety 23,256,896 20,134,246 3,122,650 15.5%
Community Development 2,260,848 2,127,253 133,595 6.3%
Recreation 2,254,453 2,250,933 3,520 0.2%
Parks & Public Works 6,396,864 5,683,009 713,855 12.6%
Library 1,793,161 1,953,966 (160,805) -8.2%
Interest on Long-Term Debt 3,999 53,780 (49,781) -92.6% Total expenses 43,461,475 38,232,430 5,229,045 13.7%
Changes in net position (2,738,955) 1,186,062 (3,925,017) -330.9% Net Position:

Beginning of year 205,027,467 203,841,405 1,186,062 0.6% Net Position at End of Year $ 202,288,512 $ 205,027,467 $ (2,738,955) -1.3% Table 2
Condensed Changes in Net Position
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THE CITY’S FUNDS
The governmental funds balance sheet is shown on page 16 of this report. The combined fund balance of $33.4 million decreased during Fiscal Year 2025 by $7.2 million. The combined fund balance in the prior year was $40.5 million. The increase is due mostly to the use of existing Capital Projects Reserves to fund capital projects for the fiscal year. The Capital Projects net change in fund balance decreased by $6.0 million during the fiscal year, making up about 83% of the total change in combined fund balance.

The General Fund is the main operating fund of the City. As of June 30, 2025, the total fund balance of the General Fund is $21.3 million, an increase of $1.5 million from the prior year. General Fund revenues increased by $1.3 million, or 3.6%, compared to FY 2023-24. The overall increase in General Fund revenues was driven by an increase in property taxes of 4% and is in line with projections. Expenditures increased by $5 million, or

15.6%. The primary reason for the increase was the salary related expense increases that are part of the Memorandum of Understandings with the various City employee associations as well as due to inflationary pressures related to materials and supplies expenses. There was also an increase in the City’s required Unfunded Accrued Liability (UAL) contribution during Fy 2024-25 of 19.5%.

General Fund revenues less expenditures were $782 thousand before other financing sources (uses).

The City’s Capital Projects Fund began the year with accumulated reserves (assigned fund balance) of $14.2 million. During the year, the fund balance decreased by $6.0 million. This is due to the City’s investment in the Sewer Lift Station Improvements Of $1.2 million and $3.8 million in street rehabilitation. The city also started the Lacy Park Playground Replacement Project during the Fiscal year. In previous years, the City Council has approved transfers from the General fund to the Capital Projects fund to provide funding for capital improvement needs citywide.

The City has one proprietary fund, its Capitalized Equipment Internal Service Fund. The fund accumulates resources through internal charges based on depreciation for equipment replacement.

General Fund Budgetary Highlights
During the year, with the recommendation from the City’s staff, the City Council revised the City budget several times which is normal business practice. Adjustments were made as the City’s staff requested additional appropriations to cover the cost of projects that either had change orders for additional work, or the cost at the beginning of the project was underestimated. Adjustments were also made as department heads requested increases or decreases to their budgets to maintain their current level of services. By policy, all amendments modifying the adopted budget are approved by the City Council.

The budgetary comparison schedule for the General Fund is shown on page 53 of this report. Actual General Fund revenues came in $1.3 million higher than the final budget amount this year and is due to fluctuations in the market value of investments.

Actual General Fund expenditures were $48 thousand less than final appropriations for the year. The largest savings were in the areas of community development and general government.

CAPITAL ASSET AND DEBT ADMINISTRATION
Capital Assets
At the end of FY 2024-25, the City had $213 million invested in the range of capital assets shown in Table 3 below. This amount represents a net increase (including additions and deductions) of $8.1 million over the prior year due to completed infrastructure projects.
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2025 2024
Land $ 149,584,512 $ 149,584,512
Construction in Progress 9,332,322 107,444
Structures & Improvements 20,011,280 20,501,032
Furniture & Equipment 2,317,991 2,471,690
Lease Assets 846,775 197,392
Subscription Assets 378,548 693,909
Infrastructure 31,222,184 32,067,550
Total $ 213,693,612 $ 205,623,529
Governmental
Activities
Net of Depreciation
Capital Assets
Table 3
More detailed information related to the City’s capital asset activity including discussion regarding relevant disclosures related to changes in balances during the year and depreciation expense charged to function/programs of the primary government may be found at Note 4 in the Notes to the Financial Statements.

Debt
As of June 30, 2025, the City had no outstanding debt. The City had liabilities related to Leases, Subscription Based Information Technology Arrangements (SBITAs), Claims Payable, and Compensated Absences.

More detailed information related to the City’s long-term liabilities including discussion regarding future annual required payments and relevant disclosures may be found at Note 6 in the Notes to the Financial Statements.

CONTACTING THE CITY’S FINANCIAL MANAGEMENT
This financial report is designed to provide our citizens, taxpayers, customers, investors, and creditors with a general overview of the City’s finances and to show the City’s accountability for the money it receives. Questions concerning any of the information provided in this report or requests for additional financial information should be addressed to the Finance Department, at the City of San Marino, 2200 Huntington Drive, San Marino, California 91108. The telephone number is (626) 300-0708. 11 PAGE 511 of 704

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12 PAGE 512 of 704

CITY OF SAN MARINO, CALIFORNIA
Statement of Net Position
Governmental
Activities
ASSETS
Cash and investments $ 34,306,598
Receivables (net of uncollectibles):

Accounts 369,279
Taxes 1,023,124
Accrued interest 141,564
Due from other governments 4,985
Notes and loans 3,674
Inventories 111,292
Prepaid costs 16,389
Restricted assets:

Cash and investments 1,704,146
Capital assets (not being depreciated/amortized) 158,916,834 Capital assets (net of accumulated depreciation/amortization) 54,776,778 Total assets 251,374,663

DEFERRED OUTFLOWS OF RESOURCES
Pension-related 13,527,836
OPEB-related 1,661,454
Total deferred outflows of resources 15,189,290

LIABILITIES
Accounts payable 2,475,352
Pass-through payable 1,236
Due to other governments 191,202
Accrued liabilities 1,504,600
Accrued interest 12,674
Deposits payable 66,551
Noncurrent liabilities:

Due within one year: leases, SBITA, claims, and
compensated absences 1,543,500
Due in more than one year:

Net pension liability 44,291,953
Net OPEB liability 6,756,138
Leases, SBITA, claims, and compensated absences 4,289,425 Total liabilities 61,132,631

DEFERRED INFLOWS OF RESOURCES
Pension-related 998,720
OPEB-related 2,144,090
Total deferred inflows of resources 3,142,810

NET POSITION
Net investment in capital assets 212,512,065
Restricted:

Public safety 589,086
Community development 728,845
Parks and recreation 1,217
Public works 2,604,543
CEPPT Investments Trust 1,704,146
Unrestricted (15,851,390)
Total net position $ 202,288,512
June 30, 2025
Primary
Government
See Notes to Financial Statements.
13 PAGE 513 of 704

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14 PAGE 514 of 704

CITY OF SAN MARINO, CALIFORNIA
Statement of Activities
For the Year Ended June 30, 2025
Operating Capital
Charges for Contributions Contributions Governmental
Expenses Services and Grants and Grants Activities
Functions/Programs:

Primary government:

Governmental activities:

General government $ 7,495,254 $ 269,664 $ 890,207 $ - $ (6,335,383) Public safety 23,256,896 4,738,504 263,263 - (18,255,129) Community development 2,260,848 1,994,101 27,735 - (239,012) Parks and recreation 2,254,453 895,043 3,022 - (1,356,388) Parks and public works 6,396,864 129,412 649,443 678,250 (4,939,759) Library 1,793,161 7 167,560 - 1,485 (1,554,116)
Interest on long-term debt - 3,999 - - (3,999)
Total governmental activities 43,461,475 8,194,284 1,905,155 678,250 (32,683,786) Total primary government $ 43,461,475 $ 8,194,284 $ 1,905,155 $ 678,250 (32,683,786) General revenues:

Property taxes 20,341,950
Sales taxes 694,873
Franchise taxes 718,933
Business licenses taxes 443,304
Utility users tax 2,363,550
Other taxes 2,598,292
Use of money and property 1,662,088
Other 1,076,170
Gain on sale of capital asset 45,671
Total general revenues 29,944,831
Change in net position (2,738,955)
Net position-beginning 205,027,467
Net position-ending $ 202,288,512
Program Revenues
Net
(Expenses)
Primary
Government
See Notes to Financial Statements.
15 PAGE 515 of 704

CITY OF SAN MARINO, CALIFORNIA
Balance Sheet
Governmental Funds
June 30, 2025
Capital
Projects Funds
Total Total
Nonmajor Governmental
General Funds Funds
ASSETS
Cash and investments $ 20,954,070 $ 9,515,222 $ 3,823,838 $ 34,293,130 Receivables (net of uncollectibles):

Accounts 339,845 - 8,195 348,040
Taxes 926,895 - 96,229 1,023,124
Accrued interest 107,815 - 32,804 140,619
Due from other governments - - 4,985 4,985
Notes and loans 3,674 - - 3,674
Due from other funds 16,804 - 5 16,809
Inventories 111,292 - - 111,292
Prepaid items 16,389 - - 16,389
Restricted assets:

Cash and investments 1,704,146 - - 1,704,146
Total assets $ 24,180,930 $ 9,515,222 $ 3,966,056 $ 37,662,208

LIABILITIES
Accounts payable $ 1,598,590 $ 1,247,077 $ 22,461 $ 2,868,128 Pass-through payables 1,236 - - 1,236
Due to other governments 191,202 - - 191,202
Due to other funds - - 16,809 16,809
Accrued liabilities 1,105,837 - - 1,105,837
Deposits payable 34,599 31,952 - 66,551
Total liabilities 2,931,464 1,279,029 39,270 4,249,763

DEFERRED INFLOWS OF RESOURCES
Unavailable revenues - - 13,039 13,039
Total deferred inflows of resources - - 13,039 13,039

FUND BALANCES (DEFICITS)
Non-spendable 131,355 - - 131,355
Restricted 1,704,146 - 3,923,691 5,627,837
Committed 342,895 - - 342,895
Assigned - 8,236,193 - 8,236,193
Unassigned 19,071,070 - (9,944) 19,061,126
Total fund balances (deficits) 21,249,466 8,236,193 3,913,747 33,399,406 Total liabilities, deferred inflows of resources,
and fund balances (deficits) $ 24,180,930 $ 9,515,222 $ 3,966,056 $ 37,662,208 Capital
Projects Fund
See Notes to Financial Statements.
16 PAGE 516 of 704
Reconciliation of the Balance Sheet of Governmental Funds to the Statement of Net Position
June 30, 2025
Amounts reported for governmental activities in the Statement of Net Position are different because:

Total fund balances - governmental funds $ 33,399,406
211,325,708
Deferred outflows-pension-related 13,527,836
Deferred outflows-OPEB-related 1,661,454
Deferred inflows-pension-related (998,720)
Deferred inflows-OPEB-related (2,144,090)
Total deferred outflows and inflows related to postemployment benefits 12,046,480 13,039
2,397,569
Leases and subscriptions payable (1,181,547)
Compensated absences (1,783,013)
Claims payable (2,868,365)
Accrued interest payable on long-term debt (12,674)
Net pension liability (44,291,953)
Net OPEB liability (6,756,138)
Total long-term liabilities (56,893,690)
Net position of governmental activities $ 202,288,512
Long-term liabilities that are not due and payable in the current period, and therefore, are not reported in the funds.

CITY OF SAN MARINO, CALIFORNIA
Capital assets, net of accumulated depreciation/amortization, used in governmental activities are not financial resources and, therefore, are not reported in the funds.

Differences between expected and actual experiences, assumption changes and net differences between projected and actual earnings, and contributions subsequent to the measurement date for the postretirement benefits (pension and OPEB) are recognized as deferred outflows of resources and deferred inflows of resources on the Statement of Net Position.

Revenues reported as unavailable revenue in the governmental funds are recognized in the Statement of Activities.

Internal service funds provide services to other funds on a cost-reimbursement basis.

The assets, deferred outflows of resources, liabilities, and deferred inflows of resources of the internal service funds are included in governmental activities in the Statement of Activities.

See Notes to Financial Statements.
17 PAGE 517 of 704

CITY OF SAN MARINO, CALIFORNIA
Statement of Revenues, Expenditures and Changes in Fund Balances Governmental Funds
For the Year Ended June 30, 2025
Capital
Projects Funds
Total Total
Nonmajor Governmental
General Funds Funds

REVENUES
Taxes $ 30,408,896 $ 721,223 - $ $ 31,130,119
Licenses and permits 1,431,113 - - 1,431,113
Intergovernmental 560,876 - 1,671,951 2,232,827
Charges for services 2,870,983 - - 2,870,983
Use of money and property 1,176,330 69,692 413,004 1,659,026 Fines and forfeitures 133,868 - - 133,868
Contributions 154,206 - - 154,206
Miscellaneous 1,001,242 - - 1,001,242
Total revenues 37,737,514 69,692 2,806,178 40,613,384

EXPENDITURES
Current:

General government 5,538,703 - 1,165,419 6,704,122
Public safety 19,453,298 - 139,693 19,592,991
Community development 2,203,756 - - 2,203,756
Parks and recreation 2,149,925 - 68,504 2,218,429
Public works 4,666,059 8,026 47,072 4,721,157
Library 1,506,174 - - 1,506,174
Capital outlay 902,405 6,080,471 3,807,308 10,790,184
Debt service:

Lease and subscription payments 518,995 - - 518,995
Interest - leases and subscriptions 16,008 - - 16,008
Total expenditures 36,955,323 6,088,497 5,227,996 48,271,816 Excess (deficiency) of revenues
over (under) expenditures 782,191 (6,018,805) (2,421,818) (7,658,432)

OTHER FINANCING SOURCES (USES)
Transfers in 44,129 - - 44,129
Transfers out (114,561) - (263,908) (378,469)
Subscription and lease financing 821,305 - - 821,305
Total other financing sources (uses) 750,873 (263,908) - 486,965 Net change in fund balances 1,533,064 (6,018,805) (2,685,726) (7,171,467) Fund balances (deficit)-beginning 14,254,998 19,716,402 6,599,473 40,570,873 Fund balances (deficit)-ending $ 21,249,466 $ 8,236,193 $ 3,913,747 $ 33,399,406 Capital
Projects Fund
See Notes to Financial Statements.
18 PAGE 518 of 704
Reconciliation of the Statement of Revenues, Expenses and Changes in Fund Balances of Governmental Funds to the Statement of Activities For the Year Ended June 30, 2025
Amounts reported for governmental activities in the Statement of Activities are different because:

Net change in fund balances - total governmental funds: $ (7,171,467) Capital outlay 10,708,807
Depreciation/amortization expense (2,534,938)
Total adjustment 8,173,869
Earned but unavailable grant revenues (9,597)
Subscription payments 371,550
Subscription financing (34,525)
Lease payments 147,445
Leases financing (786,780)
Total adjustment (302,310)
Accrued interest for long-term liabilities. This is the net change in accrued interest for the current period. 12,009
(86,346)
Compensated absences (187,801)
Changes in insurance liabilities 85,257
Changes in pension liabilities and related deferred outflows and inflows of resources (3,235,563) Changes in OPEB liabilities and related deferred outflows and inflows of resources (17,006) Total adjustment (3,355,113)
Change in net position of governmental activities $ (2,738,955) Internal service funds provide services to other funds on a cost-reimbursement basis. The net revenue of certain activities of internal service funds is reported with governmental activities.

Some expenses reported in the Statement of Activities do not require the use of current financial resources and, therefore, are not reported as expenditures in the governmental funds.

CITY OF SAN MARINO, CALIFORNIA
Governmental funds report capital outlays are expenditures. However, in the Statement of Activities, the cost of these assets is allocated over their estimated useful lives and reported as depreciation/amortization expense. This is the amount by which capital outlays exceeded depreciation/amortization expense in the current period.

Revenues in the Statement of Activities that do not provide current financial resources are not reported as revenues in the funds.

Bond and other debt proceeds provide current financial resources to governmental funds, but issuing debt increases long-term liabilities in the Statement of Net Position. Repayment of bond and other debt principal is an expenditure in the governmental funds, but repayment reduces long-term liabilities in the Statement of Net Position. Also, governmental funds report the effect of premiums, discounts, and similar items when debt is first issued, whereas these amounts are deferred and amortized in the Statement of Activities.

See Notes to Financial Statements.
19 PAGE 519 of 704

CITY OF SAN MARINO, CALIFORNIA
Statement of Net Position
Proprietary Fund
June 30, 2025
Governmental
Activities -
Internal Service
Fund
ASSETS
Current assets:

Cash and investments $ 13,468
Receivables (net of uncollectibles):

Accounts 21,239
Accrued interest 945
Total current assets 35,652
Noncurrent:

Capital assets, net 2,367,904
Total noncurrent assets 2,367,904
Total assets 2,403,556

LIABILITIES
Current liabilities:

Accounts payable 5,987
Total current liabilities 5,987
Total liabilities 5,987

NET POSITION
Invested in capital assets 2,367,904
Unrestricted 29,665
Total net position $ 2,397,569
Capitalized
Equipment
See Notes to Financial Statements.
20 PAGE 520 of 704

CITY OF SAN MARINO, CALIFORNIA
Statement of Revenues, Expenses and
Changes in Net Position
Proprietary Fund
For the Year Ended June 30, 2025
Governmental
Activities -
Internal Service
Fund

OPERATING REVENUES
Charges for services $ 218,317
Total operating revenues 218,317

OPERATING EXPENSES
Administrative expenses 17,828
Repairs and maintenance 51,289
Depreciation/amortization 688,619
Total operating expenses 757,736
Operating income (loss) (539,419)

NONOPERATING REVENUES (EXPENSES)
Other revenue 70,000
Interest revenue 3,062
Gain on sale of capital asset 45,671
Total nonoperating revenues (expenses) 118,733
Income (loss) before transfers (420,686)
Transfers in 334,340
Change in net position (86,346)
Net position-beginning 2,483,915
Net position-ending $ 2,397,569
Capitalized
Equipment
See Notes to Financial Statements.
21 PAGE 521 of 704

CITY OF SAN MARINO, CALIFORNIA
Statement of Cash Flows
Proprietary Fund
For the Year Ended June 30, 2025
Governmental
Activities -
Internal Service
Fund

CASH FLOWS FROM OPERATING ACTIVITIES
Receipts from customers $ 197,078
Payments to suppliers and service providers (63,327)
Net cash provided by (used for)
operating activities 133,751

CASH FLOWS FROM NONCAPITAL

FINANCING ACTIVITIES
Transfers from other funds 334,340
Net cash provided by (used for)
noncapital financing activities 334,340

CASH FLOWS FROM CAPITAL AND RELATED

FINANCING ACTIVITIES
Capital grants and contributions 70,000
Acquisition and construction of capital assets (585,741) Proceeds from sales of assets 46,579
Net cash provided by (used for)
capital and related financing activities (469,162)

CASH FLOWS FROM INVESTING ACTIVITIES
Interest on investments 6,189
Net cash provided by (used for)
investing activities 6,189
Net increase (decrease) in
cash and cash equivalents 5,118
Cash and cash equivalents-beginning 8,350
Cash and cash equivalents-ending $ 13,468

RECONCILIATION OF CASH AND CASH EQUIVALENTS

TO THE STATEMENT OF NET POSITION
Cash and investments $ 13,468
Total cash and cash equivalents $ 13,468

RECONCILIATION OF OPERATING INCOME (LOSS)

TO NET CASH PROVIDED BY (USED FOR)

OPERATING ACTIVITIES
Operating income (loss) $ (539,419)
Adjustments to reconcile operating income (loss) to
net cash provided by (used for) operating activities:

Depreciation/amortization expense 688,619
(Increase) decrease in accounts receivable (21,239)
Increase (decrease) in accounts payable 5,790
Total adjustments 673,170
Net cash provided by (used for)
operating activities $ 133,751
Capitalized
Equipment
See Notes to Financial Statements.
22 PAGE 522 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
The basic financial statements of the City of San Marino (the “City”) have been prepared in conformity with Generally Accepted Accounting Principles (GAAP) applicable to government units. The Governmental Accounting Standards Board (GASB) is the accepted standard-setting body for establishing governmental accounting and financial reporting principles. More significant accounting policies of the City are described below.

A. Description of Entity
The City was incorporated on April 13, 1913, under the laws of the State of California and enjoys all the rights and privileges applicable to a General Law City. The City operates under a Council-Manager form of government and provides basic local government services including public safety (police, fire and emergency operations), maintenance and construction of public improvements, recreation, planning, zoning, library and general administration.

The accompanying financial statements contain information for the total reporting entity, which includes the City (the primary government). There are no component units as defined by GAAP.

B. Government-Wide and Fund Financial Statements
The government-wide financial statements (i.e., the statement of net position and the statement of activities) report information on all of the nonfiduciary activities of the primary government and its component units. For the most part, the effect of interfund activity has been removed from these statements. Governmental activities, which normally are supported by taxes and intergovernmental revenues, are reported separately from business-type activities, which rely to a significant extent on fees and charges for support.

The statement of activities demonstrates the degree to which the direct expenses of a given function or segment is offset by program revenues. Direct expenses are those that are clearly identifiable with a specific function or segment. Program revenues include: 1) charges to customers or applicants who purchase, use or directly benefit from goods, services or privileges provided by a given function or segment, and 2) grants and contributions that are restricted to meeting the operational or capital requirements of a particular function or segment. Taxes and other items not properly included among program revenues are reported instead as general revenues.

Separate financial statements are provided for governmental funds. Major individual governmental funds are reported as separate columns in the fund financial statements.

C. Measurement Focus, Basis of Accounting and Financial Statement Presentation The government-wide financial statements are reported using the economic resources measurement focus and the accrual basis of accounting, as are the proprietary fund financial statements. Revenues are recorded when earned and expenses are recorded when a liability is incurred, regardless of the timing of related cash flows. Property taxes are recognized as revenues in the year for which they are levied.

Grants and similar items are recognized as revenue as soon as all eligibility requirements imposed by the provider have been met.

Governmental fund financial statements are reported using the current financial resources measurement focus and the modified accrual basis of accounting. Revenues are recognized as soon as they are both measurable and available. Revenues are considered to be available when they are collectible within the current period or soon enough thereafter to pay liabilities of the current period. For this purpose, the government considers revenues to be available if they are collected within 60 days of the end of the current fiscal period. Expenditures generally are recorded when a liability is incurred, as under accrual accounting. However, debt service expenditures, as well as expenditures related to compensated absences and claims and judgments, are recorded only when payment is due.
23 PAGE 523 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) Property taxes, franchise taxes, licenses and interest associated with the current fiscal period are all considered to be susceptible to accrual and so have been recognized as revenues of the current fiscal period. Only the portion of special assessments receivable due within the current fiscal period is considered to be susceptible to accrual as revenue of the current period. All other revenue items are considered to be measurable and available only when cash is received by the government.

The City reports the following major governmental funds:
• The General Fund is used to account for all financial resources of the general government, except those required to be accounted for in another fund.
• The Capital Projects Fund is used to track the investment of City funds for capital projects that have a cost greater than $5,000 per unit and a useful life of two or more years.

Additionally, the City reports the following fund types:
• Special Revenue Funds are used to account for financial resources which are restricted for specific purposes. • The Debt Service Fund is used to account for the accumulation of resources for and the payment of general long-term debt principal and interest.
• The Internal Service Fund is used to account for equipment purchases and capital assets of the City and the replacement of equipment to other departments of the City.

D. Assets, Deferred Outflows, Liabilities, Deferred Inflows and Net Position or Equity

1. Cash and Investments
The City's cash and cash equivalents are considered to be cash on hand, demand deposits and short-term investments with original maturities of three months or less from the date of acquisition.

Investments for the City are reported at fair value, which is the determined using observable inputs at June 30, 2025. The City's policy is generally to hold investments until maturity or until market values equal or exceed cost.

2. Receivables and Payables
Activity between funds that is representative of lending/borrowing arrangements outstanding at the end of the fiscal year are referred to as either "due to/from other funds" (i.e., the current portion of interfund loans) or "advances to/from other funds" (i.e., the non-current portion of interfund loans). All other outstanding balances between funds are reported as "due to/from other funds." Any residual balances outstanding between the governmental activities and business-type activities are reported in the government-wide financial statements as "internal balances." Advances between funds, as reported in the fund financial statements, are offset by a fund balance reserve account in applicable governmental funds to indicate that they are not available for appropriation and are not expendable available financial resources.

All trade and property tax receivables are shown net of an allowance for uncollectibles. 24 PAGE 524 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

3. Functional Classifications
Expenditures of the Governmental Funds are classified by function. Functional classifications are defined as follows:
• General Government includes legislative activities that have a primary objective of providing legal and policy guidelines for the City. Also included in this classification are those activities that provide management or support services across more than one functional area.
• Public Safety includes those activities that involve the protection of people and property. • Community Development includes those activities that involve the enhancing of the general quality of life. • Parks and Recreation includes activities for children, adults and senior citizens. • Public Works includes those activities that involve the maintenance and improvement of City streets, roads and park department development and maintenance.
• Library includes those activities related to the provision of library services to the community.

4. Inventories
All inventories are valued at cost using the first-in/first-out (FIFO) method. Inventories in the General Fund consist of gasoline and garage items. Inventory costs are recorded as expenditures when used.

The General Fund inventory is accounted for on the consumption method and is equally offset by a reservation of fund balance in the fund-level statements, which indicates that it does not constitute "available spendable resources."

5. Capital Assets
Capital assets, which include property, plant, equipment, right-to-use lease assets (lease assets), right-to-use subscription assets (subscription assets), and infrastructure assets (e.g., roads, bridges, sidewalks and similar items), are reported in the governmental activities column in the government-wide financial statements. Capital assets are defined by the City as assets with an initial, individual cost of more than $5,000 (amount not rounded) and an estimated useful life in excess of two years. Such assets are recorded at historical cost or estimated historical cost if purchased or constructed. Donated capital assets, donated works of art and similar items, and assets received in a service concession arrangement are recorded at acquisition value at the time of acquisition.

In accordance with GASB Statement No. 34, the City has reported general infrastructure assets acquired in the current and prior fiscal years.

The costs of normal maintenance and repairs that do not add to the value of the asset or materially extend assets’ lives are not capitalized.

Major outlays for capital assets and improvements are capitalized as projects are constructed. 25 PAGE 525 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) Property, plant and equipment of the primary government is depreciated using the straight-line method over the following estimated useful lives:

6. Leases
Lease assets are reported in the governmental activities column in the governmental-wide financial statements.

These assets are defined by the City as assets with an initial, individual cost of more than $5,000 (amount not rounded) and an estimated useful life in excess of two years. Such assets are recorded at the present value of the lease liability including expenses to place the asset into service.

At the commencement of a lease, the City initially measures the lease liability at the present value of payments expected to be made during the lease term. Subsequently, the lease liability is reduced by the principal portion of lease payments made. The lease asset is initially measured as the initial amount of the lease liability, adjusted for lease payments made at or before the lease commencement date, plus certain initial direct costs. Subsequently, the lease asset is amortized on a straight‐line basis over its useful life. Key estimates and judgments related to leases include how the City determines (1) the discount rate it uses to discount the expected lease payments to present value, (2) lease term, and (3) lease payments.
• The City uses the interest rate charged by the lessor as the discount rate. When the interest rate charged by the lessor is not provided, the City generally uses its estimated incremental borrowing rate as the discount rate for leases.
• The lease term includes the noncancellable period of the lease. Lease payments included in the measurement of the lease liability are composed of fixed payments and the purchase option price that the City is reasonably certain to exercise.

The City monitors changes in circumstances that would require a remeasurement of its lease and will remeasure the lease asset and liability if certain changes occur that are expected to significantly affect the amount of the lease liability.

Lease assets are reported with other capital assets and lease liabilities are reported with long-term debt on the statement of net position.

7. Subscription-Based Information Technology Arrangements The City is a subscriber for noncancellable subscriptions of information technology services. The City recognizes a subscription liability and subscription asset in the government‐wide financial statements. The City recognizes subscription liabilities with an initial, individual value of $5,000 or more.

At the commencement of a subscription, the City initially measures the subscription liability at the present value of payments expected to be made during the subscription term. Subsequently, the subscription liability is reduced by the principal portion of subscription payments made. The subscription asset is initially measured as the initial amount of the subscription liability, adjusted for subscription payments made at or before the subscription commencement date, plus certain initial direct costs. Subsequently, the subscription asset is amortized on a straight‐line basis over its useful life. Key estimates and judgments related to subscriptions include how the City determines (1) the discount rate it uses to discount the expected subscription payments to present value, (2) lease term, and (3) subscription payments.

Assets Years
Structures and improvements 7-50
Furniture and equipment 3-20
Infrastructure 10-25
Leased assets 2-5
Subscription assets 2-5
26 PAGE 526 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) • The City uses the interest rate charged by the vendor as the discount rate. When the interest rate charged by the vendor is not provided, the City generally uses its estimated incremental borrowing rate as the discount rate for subscriptions.
• The subscription term includes the noncancellable period of the subscription. Subscription payments included in the measurement of the subscription liability are composed of fixed payments that the City is reasonably certain to exercise.

The City monitors changes in circumstances that would require a remeasurement of its subscriptions and will remeasure the subscription asset and liability if certain changes occur that are expected to significantly affect the amount of the subscription liability.

Subscription assets are reported with other capital assets and subscription liabilities are reported with long-term debt on the statement of net position.

8. Deferred Outflows/Inflows of Resources
In addition to assets, the statement of financial position and governmental fund balance sheet will sometimes report a separate section for deferred outflows of resources. This separate financial statement element, deferred outflows of resources, represents a consumption of net assets that applies to future periods. The City only has two items that qualify for reporting in this category. The deferred outflows relating to the net pension obligation and to the total other post-employment benefit (OPEB) obligation reported in the government-wide statement of net position. These outflows are the results of contributions made after the measurement period, which are recognized in the following year, and of adjustments due to difference in proportions, changes in assumptions, and differences between expected and actual experiences. These amounts are deferred and amortized over the expected average remaining service lifetime.

In addition to liabilities, the statement of financial position will sometimes report a separate section for deferred inflows of resources. This separate financial statement element, deferred inflows of resources, represents an acquisition of net assets that applies to future periods. The City has three items reported in this category. One arises only under a modified accrual basis of accounting. Accordingly, the item, unavailable revenues, is reported only in the governmental fund balance sheet. These amounts are deferred and recognized as an inflow of resources in the period that the amounts become available. The second and third items are the deferred inflows relating to the net pension obligation and to the net OPEB obligation reported in the government-wide statement of net position. These inflows are the result of changes in employees’ proportion differences in proportionate share of contributions, changes in assumptions, differences between projected and actual experiences, adjustments due to differences in proportions, and the net difference between projected and actual earnings on plan investments. These items, with the exception of the difference between projected and actual earnings on plan investments, are deferred and recognized over the remaining service life. The difference between projected and actual earnings on plan investments is amortized over five years.

9. Pension Plans
For purposes of measuring the net pension liability, deferred outflows and inflows of resources related to pensions, and pension expense, information about the fiduciary net position and additions to/deductions from the fiduciary net position have been determined on the same basis as they are reported by the California Public Employees’ Retirement System (“CalPERS”) Financial Office. For this purpose, benefit payments (including refunds of employee contributions) are recognized when currently due and payable in accordance with the benefit terms.

Investments are reported at fair value. CalPERS’ audited financial statements are publicly available reports that can be obtained at CalPERS’ website under Forms and Publications. GAAP requires that the reported results must pertain to liability and asset information within certain defined timeframes. 27 PAGE 527 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) For this report, the following timeframes are used.

Valuation Date (VD): June 30, 2023
Measurement Date (MD): June 30, 2024
Measurement Period (MP): July 1, 2023 to June 30, 2024

10. Other Postemployment Benefits (OPEB)
For purposes of measuring the net OPEB liability, deferred outflows and inflows of resources related to OPEB, and OPEB expense, and information about the City’s OPEB plan have been determined by an independent actuary.

For this purpose, benefit payments are recognized when currently due and payable in accordance with the benefit terms.

GAAP require that the reported results must pertain to liability and asset information within certain defined timeframes. For this report, the following timeframes are used.

Valuation Date (VD): June 30, 2023
Measurement Date (MD): June 30, 2024
Measurement Period (MP): July 1, 2023 to June 30, 2024

11. Compensated Absences
It is the government's policy to permit employees to accumulate earned but unused vacation and sick pay benefits.

Vacation time accrued is transferable from one year to the next with the exception that no more than 180 through 624 hours of vacation time may be carried over to the next year, depending on the job classification. An employee accruing the maximum number of hours for vacation time shall be compensated at the employee’s regular hourly rate on a monthly basis for the number of vacation hours the employee would have accrued, until the number of accrued hours drops below the maximum number of accruable hours.

Employees are entitled to accrue sick leave, depending on job classification, from 240 up to 340 hours. Upon reaching the maximum accrual allowed, the employee shall cease to accrue sick leave time until such time as the total accrued hours are less than the maximum permitted. Employees have no vested rights in the accrued sick leave time.

12. Proprietary Funds Operating and Nonoperating Revenues and Expenses Proprietary funds distinguish operating revenues and expenses from nonoperating items. Operating revenues and expenses generally result from providing services and producing and delivering goods in connection with a proprietary fund’s principal ongoing operations. The principal operating revenues of the internal service fund is charges to customers for sales and services. Operating expenses for the internal service fund include contractual services and depreciation/amortization on capital assets. All revenues and expenses not meeting this definition are reported as nonoperating revenues and expenses.
28 PAGE 528 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

13. Long-Term Obligations
In the government-wide financial statements, long-term debt and other long-term obligations are reported as liabilities in the applicable governmental activities in the statement of net position.

14. Fund Balance
In the fund financial statements, government funds report the following fund balance classification:

Non-spendable includes amounts that cannot be spent because they are either (a) not in spendable form or (b) legally or contractually required to be maintained intact. The City reports $131,355 in non-spendable balance as of June 30, 2025.

Restricted includes amounts that are constrained on the use of resources by either (a) external creditors, grantors, contributors, or laws of regulations of other governments or (b) by law through constitutional provisions or enabling legislation. The City reports $5,627,837 in restricted balance as of June 30, 2025.

Committed includes amounts that can only be used for specific purposes pursuant to constraints imposed by formal action of the government’s highest authority, the City Council. The formal action that is required to be taken to establish, modify, or rescind a fund balance commitment is through resolution. The City reports $342,895 in committed balance as of June 30, 2025.

Assigned includes amounts that are constrained by the government’s intent to be used for specific purposes but are neither restricted nor committed. The Finance Director is authorized to assign amounts to a specific purpose, which was established by the governing body in resolution. The City reports $8,236,193 in assigned balance as of June 30, 2025.

Unassigned include the residual amounts that have not been restricted, committed, or assigned to specific purposes. The City reports $19,061,126 in unassigned balance as of June 30, 2025.

An individual governmental fund could include non-spendable resources and amounts that are restricted or unrestricted (committed, assigned, or unassigned) or any combination of those classifications. Restricted and unrestricted amounts are to be considered spent when an expenditure is incurred for purposes for which both restricted and unrestricted fund balance is available and committed, assigned, then unassigned amounts are considered to have been spent when an expenditure is incurred for purposes for which amounts in any of those unrestricted fund balance classifications can be used.

15. Net Position Flow Assumption
Sometimes the government will fund outlays for a particular purpose from both restricted (e.g., restricted bond or grant proceeds) and unrestricted resources. In order to calculate the amounts to report as restricted net position and unrestricted net position in the government-wide and proprietary fund financial statements, a flow assumption must be made about the order in which the resources are considered to be applied. It is the government’s policy to consider restricted net position to have been depleted before unrestricted – net position is applied.

16. Fund Balance Flow Assumptions
Sometimes the government will fund outlays for a particular purpose from both restricted and unrestricted resources (the total of committed, assigned, and unassigned fund balance). In order to calculate the amounts to report as restricted, committed, assigned, and unassigned fund balance in the governmental fund financial statements a flow assumption must be made about the order in which the resources are considered to be applied. It is the government’s policy to consider restricted fund balance to have been depleted before using any of the components of unrestricted fund balance. Further, when the components of unrestricted fund balance can be used for the same purpose, committed fund balance is depleted first, followed by assigned fund balance. Unassigned fund balance is applied last.
29 PAGE 529 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

17. Property Tax Revenue
Property tax revenue is recognized on the basis of National Committee on Governmental Accounting Interpretation No. 3, (adopted by GASB) that is, in the fiscal year for which the taxes have been levied providing they become available. Available means then due, or past due and receivable within the current period and collected within the current period or expected to be collected soon enough thereafter to be used to pay liabilities of the current period.

The County of Los Angeles collects property taxes for the City. Tax liens attach annually as of 12:01 A.M. on the first day in January preceding the fiscal year for which the taxes are levied. The tax levy is made July 1 and covers the fiscal period July 1 to June 30. All secured personal property taxes and one-half of the taxes on real property are due November 1; the second installment is due February 1. All taxes are delinquent, if unpaid, on December 10 and April 10, respectively. Unsecured personal property taxes become due on the first of March each year and are delinquent, if unpaid, on August 31.

NOTE 2: STEWARDSHIP, COMPLIANCE, AND ACCOUNTABILITY
A. Compliance with Budgetary Limitations
The County Park Bond, Homeland Security Grant, and Prop 1B Street special revenue funds did not adopt a budget for the year ended June 30, 2025.

B. Deficit Fund Balances
The following governmental fund had a deficit fund balance as of June 30, 2025:

The deficit fund balances will be resolved with future grant revenue.

NOTE 3: CASH AND INVESTMENTS
As of June 30, 2025, the City reported $36,010,744 in cash and investments. The City follows the practice of pooling cash and investments of all funds, except for funds required to be held by fiscal agents under provisions of bond indentures. Interest income earned on pooled cash and investments is allocated quarterly to the various funds based on quarterly cash and investment balances. Interest income from cash and investments with fiscal agents is credited directly to the related fund.

A. Deposits
As of June 30, 2025, the carrying amount of the City’s deposits was $3,575,792 and the bank balance was $3,860,832. The $285,040 difference represents outstanding checks and other reconciling items.

The California Government Code requires California banks and savings and loan associations to secure City’s deposits by pledging securities as collateral. This Code states that collateral pledged in this manner shall have the effect of perfecting a security interest in such collateral superior to those of a general creditor. Thus, collateral for cash deposits is considered to be held in the City’s name.

Fund Name Fund Type Deficit
Community Development Block Grant Nonmajor Special Revenue Fund 8,089 $ County Park Bond Nonmajor Special Revenue Fund 9
Air Quality Nonmajor Special Revenue Fund 1,730
OTS Grant Fund Nonmajor Special Revenue Fund 116
30 PAGE 530 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 3: CASH AND INVESTMENTS (CONTINUED)
The market value of pledged securities must equal at least 110% of the City’s cash deposits. California law also allows institutions to secure City deposits by pledging first trust deed mortgage notes having a value of 150% of the City’s total cash deposits. The City invests in a money market account with their bank that is collateralized with a letter of credit with a value of 105% of the City’s total cash deposit which is in accordance with the California Government Code. The City may waive collateral requirements for cash deposits, that are fully insured up to $250,000 by the Federal Deposit Insurance Corporation. The City, however, has not waived the collateralization requirements.

B. Investments
Under provision of the City’s investment policy and in accordance with the California Government Code, the following investments are authorized:
• United States Treasury Bills, Bonds and Notes
• Federal Agency Securities
• State of California Local Agency Investment Fund (LAIF) and other local government investment pools • Money Market Mutual Funds in compliance with California Government Code Section 53601(L) • Certificates of Deposit placed through a private placement service in compliance with California Government Code Sections 53601.8 and 53635.8 C. Investments Authorized by Debt Agreements
The above investments do not address investment of debt proceeds held by a bond trustee. Investments of debt proceeds held by a bond trustee are governed by provisions of the debt agreements rather than the general provisions of the California Government Code or the City’s investment policy.

D. Investments in State Investment Pool
The City is a voluntary participant in the State of California Local Agency Investment Fund (LAIF) that is regulated by the California Government Code under the oversight of the Treasurer of the State of California. The fair value of the City’s investment in the pool is reported in the accompanying financial statements at amounts based on the City’s pro rata share of the fair value provided by LAIF for the entire LAIF portfolio (in relation to the amortized cost of that portfolio). The balance available for withdrawal is based on accounting records maintained by LAIF, which are recorded on an amortized cost basis. LAIF is not registered with the Securities and Exchange Commission and is not rated. Deposits and withdrawals in LAIF are made on the basis of $1 and not fair value. Accordingly, the City’s investment in this pool is measured on uncategorized inputs not defined as Level 1, 2, or 3.

E. Fair Value Hierarchy
The City categorizes its fair value measurements within the fair value hierarchy established by GAAP. The hierarchy is based on the valuation inputs used to measure the fair value of the asset. Level 1 inputs are quoted prices in active markets for identical assets; Level 2 inputs are significant other observable inputs; Level 3 inputs are significant unobservable inputs. As of June 30, 2025, all the City’s investments, with the exception of LAIF, are valued using Level 2 inputs. The City's Level 2 inputs were obtained from the City's third-party investment manager based on identical or comparable assets or liabilities or through the use of valuation methodologies using observable market inputs. Prices from the City's third-party investment manager are validated through analytical reviews and assessment of current market activity.

F. Custodial Credit Risk
Custodial credit risk for deposits is the risk that in the event of the failure of a depository financial institution, a government will not be able to recover deposits or will not be able to recover collateral securities that are in the possession of an outside party. The custodial credit risk for investments is the risk that in the event of the failure of the counterparty to a transaction, a government will not be able to recover the value of investment or collateral securities that are in the possession of an outside party. 31 PAGE 531 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 3: CASH AND INVESTMENTS (CONTINUED)
The California Government Code and the City’s investment policy do not contain legal or policy requirements that would limit the exposure to custodial credit risk for deposits or investments, other than as follows. The California Government Code requires that a financial institution secure deposits made by state or local governmental units by pledging securities in an undivided collateral pool held by a depository regulated under state law (unless so waived by the governmental unit). The market value of the pledged securities in the collateral pool must equal at least 110% of the total amount deposited by the City. California law also allows financial institutions to secure City deposits by pledging a letter of credit having a value of 105% of the City’s deposits for the money market account. The City’s investment policy requires delivery versus payment procedures and that all securities be held in third-party safekeeping by a custodial financial institution.

As of June 30, 2025, all of the City’s deposits with financial institutions in excess of Federal depository insurance limits were collateralized by an interest in an undivided collateral pool as required by State law. In addition, all investments were held by a third-party safekeeping institution.

G. Concentration of Credit Risk
The City’s investment policy contains a limitation on the maximum percentage of total portfolio investments in certain types of investments. The City limits total portfolio investments in mortgage-backed securities and negotiable certificates of deposit to 20% and 30%, respectively. Total investment in money market mutual funds shall not exceed 20% of the City’s total portfolio. The City was in compliance with these limitations at June 30, 2025.

GASB Statement No. 40 requires that the City disclose investments in any one issuer that represents 5% or more of the total investments. At June 30, 2025, the following investment exceeded 5% of total investments, with the exception of the Local Agency Investment Fund (which is exempt from this restriction):

H. Credit Risk
Generally, credit risk is the risk that an issuer of an investment will not fulfill its obligation to the holder of the investment. This is measured by the assignment of a rating by a nationally recognized statistical rating organization.

Presented below is the minimum rating required by (where applicable) the California Government Code or the City’s investment policy, and the actual rating as of the fiscal year end for each investment type:

Fair Value Percentage
Federal Farm Credit Bank $ 1,716,060 5.29%
Less Than
Investment Type Total 1 Year 1 - 3 Years 3 - 5 Years
Local Agency Investment Fund $ 13,315,853 $ 13,315,853 $ - $ - Certificates of Deposit 5,140,535 2,449,123 2,442,095 249,317 Federal Home Loan Bank 1,501,655 998,330 503,325
Federal Farm Credit Bank 1,716,060 1,231,975 484,085 -
Municipal Securities 494,490 494,490 - -
Money Market Deposit Account 8,562,213 8,562,213 - -
Held by Trustee
CEPPT Investments Trust 1,704,146 1,704,146 - -
Total $ 32,434,952 $ 28,756,130 $ 3,429,505 $ 249,317
Remaining Maturity (in Months)
32 PAGE 532 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 3: CASH AND INVESTMENTS (CONTINUED)
I. Interest Rate Risk
The City’s investment policy limits investment maturities as a means of managing its exposure to fair value losses arising from increasing interest rates. The City’s investment policy states that all investments shall mature in five years or less. The City has elected to use the segmented time distribution method of disclosure for its interest rate risk.

As of June 30, 2025, the City had the following investments and remaining maturities:

Total as of Minimum
Investment Type June 30, 2025 Legal Rating Aaa Aa Exempt Not Rated Local Agency Investment Fund 13,315,853 $ N/A - $ - $ - $ 13, $ 315,853 Certificates of Deposit 5,140,535 N/A - - - 5, 140,535
Federal Home Loan Bank 1,501,655 N/A - - 1, - 501,655
Federal Farm Credit Bank 1,716,060 N/A - - 1, - 716,060 Municipal Securities 494,490 N/A - - - 494,490
Money Market Deposit Account 8,562,213 N/A - - - 8, 562,213 Held by Trustee
CEPPT Investments Trust 1,704,146 N/A - - - 1, 704,146
$ 32,434,952 $ - $ 3, - $ 217,715 $ 29,217,237
Moody's Rating as of Fiscal Year End
33 PAGE 533 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 4: CAPITAL ASSETS
Capital asset activity for the year ended June 30, 2025, was as follows:

Balance Balance
June 30, 2024 Additions Deletions Transfers June 30, 2025 Governmental activities:

Capital assets,
not being depreciated/amortized
Land $ 149,584,512 $ - $ - $ 149,584,512 - $
Construction-in-progress 107,444 9,224,878 - 9,332,322 - Total capital assets,
not being depreciated/amortized 149,691,956 9,224,878 - 158,916,834 - Capital assets,
being depreciated/amortized
Structures and improvements 27,254,620 86,377 - 27,340,997 - Furniture and equipment 8,045,432 535,828 (197,842) 8,383,418 - Infrastructure 84,407,722 640,672 - 85,048,394 -
Lease assets - equipment 529,763 772,268 (129,320) 1,172,711 - Subscription assets 1,336,558 34,525 - 1,371,083 -
Total capital assets,
being depreciated/amortized 121,574,095 2,069,670 (327,162) 123,316,603 - Less accumulated
depreciation/amortization
Structures and improvement (6,753,588) (576,129) - (7,329,717) - Furniture and equipment (5,573,742) (688,619) 196,934 (6,065,427) - Infrastructure (52,340,172) (1,486,038) - (53,826,210) - Lease assets - equipment (332,371) (122,885) 129,320 (325,936) - Subscription assets (642,649) (349,886) - (992,535) -
Total accumulated
depreciation/amortization (65,642,522) (3,223,557) 326,254 (68,539,825) - Total capital assets
being depreciated/amortized, net 55,931,573 (1,153,887) (908) 54,776,778 - Total governmental activities capital assets $ 205,623,529 $ 8,070,991 $ (908) $ 213,693,612 - $ 34 PAGE 534 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 4: CAPITAL ASSETS
Depreciation/amortization expense was charged to functions/programs of the primary government as follows:

NOTE 5: INTERFUND RECEIVABLE, PAYABLE AND TRANSFERS
The composition of interfund balances as of June 30, 2025, was as follows:

A. Due To/From Other Funds
The General Fund made short term loans to various nonmajor funds in the amount of $16,804 to cover various temporary cash deficits during the year.

B. Interfund Transfers
Transfers into the Internal Service Fund from the General Fund and Nonmajor Funds are to fund equipment purchases, respectively. The transfer in the General Fund from the Nonmajor Funds is to close out the Debt Service Fund.

General government $ 535,519
Public safety 116,865
Community development 42,153
Public works 1,529,024
Library 311,377
Internal service funds 688,619
Total depreciation/amortization expense $ 3,223,557
General Internal
Transfers out Fund Service Fund Total
General Fund - $ $ 114,561 $ 114,561
Nonmajor Funds 44,129 219,779 263,908
$ 44,129 $ 334,340 $ 378,469
Transfers In
35 PAGE 535 of 704

CITY OF SAN MARINO, CALIFORNIA
Notes to the Financial Statements
For the Year Ended June 30, 2025
NOTE 6: NONCURRENT LIABILITIES
NOTE 7: LEASES AND SUBSCRIPTION-BASED INFORMATION TECHNOLOGY ARRANGEMENTS A. Leases
The City has entered into various lease agreements as lessee for the acquisition and use of:

1. Postage Machine
In May 2024, the City entered into a noninterest bearing lease agreement with Pitney Bowes to obtain a postage machine. The lease term is five years with base monthly payments of $72 per month beginning on May 26, 2024.

As of June 30, 2025, the lease liability outstanding is $2,372.

2. Copiers
Between September 2016 and February 2022, the City entered into eleven noninterest bearing lease agreements with CopyFree to obtain photocopiers and a printer for different City departments. The lease term for each lease is five years with base monthly payments ranging between $114 and $398 per month. As of June 30, 2025, the total outstanding lease liability for these copiers is $47,227.

3. Facilities
The City has entered into two noninterest bearing facility use lease agreements with the San Marino Unified School District for use of a swimming pool and parking lot. The lease term for the swimming pool is five years with annual payments of $12,875 per year beginning July 1, 2019. The rent amount will be adjusted annually by the lesser of the Los Angeles Statistical Area Consumer Price Index or 3%. The lease term for the parking lot is ten years beginning with a lump sum payment of $61,600 in which $30,800 represents back-rent for the City’s use of the parking spaces. The remaining $30,800 is the initial annual rent payment beginning October 13, 2019. For the parking lot lease, the rent amount will increase by 2% from the preceding lease year. In addition to the annual rent, an additional annual payment of $2,000 will be paid to anticipate slurry seal repairs and needs. As of June 30, 2025, the total lease liability outstanding for these facilities is $141,872.

4. Vehicles
Between August 2024 and March 2025, the City entered into fifteen interest bearing lease agreements with Enterprise to obtain vehicles for different City departments. The lease term for each lease is five years with base monthly payments ranging between $620 and $1,216 per month. As of June 30, 2025, the total outstanding lease liability for these copiers is $634,465.

San Marino City CouncilDecember 10, 2025

San Marino City Council
December 10, 2025