Agenda, regular meeting, first session — Sierra Madre City Council, December 9, 2025 (part 1 of 2)

CITY COUNCIL

MEETING AGENDA PACKET
Tuesday, December 9, 2025
5:30 pm
Sierra Madre City Council Chambers
232 W. Sierra Madre Boulevard
Sierra Madre, California 91024
Mayor Robert Parkhurst, Mayor Pro Tempore Kristine Lowe Council Members: Edward Garcia, Gene Goss, and Kelly Kriebs

CITY OF

SIERRA MADRE CITY COUNCIL

REGULAR MEETING AGENDA
Mayor Robert Parkhurst | Mayor Pro Tem Kristine Lowe
Council Member Edward Garcia | Council Member Gene Goss | Council Member Kelly Kriebs

AMENDED AGENDA
Tuesday, December 9, 2025, 5:30 P.M.

City Council Chambers, 232 W. Sierra Madre Blvd.

AMERICANS WITH DISABILITIES ACT
Pursuant to the Americans with Disabilities Act, persons with a disability who require a disability related modification or accommodation in order to participate in a meeting, including auxiliary aids or services, may request such modification or accommodation from the City Clerk at (626) 355-7135. Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to assure accessibility to the meeting.

PUBLIC COMMENT & ACCESS
The Brown Act provides the public with an opportunity to make public comments at any public meeting. As an alternative, public comment may be submitted by e-mail to [email protected] by 3:00PM on the day of the meeting. Emails will be acknowledged at the City Council meeting, filed into public record, and scanned onto the City website for public review.

A copy of the posted agenda and a live video stream of the meeting can be found on the City’s website at sierramadreca.gov , on Foothills Media website at foothillsmedia.org/sierramadre, and broadcast on Government Access Channel 3 (Spectrum).

If you require special assistance to participate in this meeting, please contact the City Clerk’s Office at (626) 355-7135 at least 48 hours prior to the meeting.

CODE OF CONDUCT
The purpose of a City Council meeting is to conduct City business. Members of the public that behave in a manner that interrupts or obstructs the City Council’s ability to conduct City business may be asked to leave the meeting. Any and all demonstrations which disrupt, interrupt, or obstruct the City Council’s ability to conduct City business are prohibited. No signs, posters, or other large objects shall be brought into the Council Chambers or other meeting place if doing so would disrupt, disturb, or otherwise impede the orderly course of the meeting.

1. CALL TO ORDER

2. PLEDGE OF ALLEGIANCE AND INSPIRATION
Mayor Robert Parkhurst

3. ROLL CALL OF CITY COUNCIL MEMBERS
Robert Parkhurst, Mayor
Kristine Lowe, Mayor Pro Tem
Edward Garcia, Council Member
Gene Goss, Council Member
Kelly Kriebs, Council Member

4. SUPPLEMENTAL INFORMATION FROM CITY CLERK REGARDING AGENDA ITEMS

5. REPORTS FROM MAYOR AND CITY COUNCIL (including reports from City Council related to meetings attended at City expense per AB 1234)

6. REPORTS FROM CITY STAFF

7. PRESENTATIONS
a. Presentation by Sierra Madre Rose Float Association
b. Presentation to Troop 110 & 373 Eagle Scouts
c. Presentation by Ruben Lubowski of Lombard Odier Asset Management

8. PUBLIC COMMENT FOR ITEMS NOT ON THE AGENDA
Any person wishing to speak before the City Council is asked to complete a Speaker Card and provide it to the City Clerk prior to the start of the meeting. Speakers are generally limited to three (3) minutes per person and time may not be delegated; any changes to the allotted time will be announced prior to the Public Comment period. Under the Brown Act, the City Council is prohibited from discussing or taking action on any item not listed on the posted agenda.

Addressing the City Council from the audience is not permitted; all comments addressing the Council must be made from the podium. Only public comment made from the podium will be recognized by the City Council and entered into public record.

9. CONSENT CALENDAR
All matters listed under the Consent Calendar are considered to be routine and can be acted on by one roll call vote. There will be no separate discussion of these items unless a member of the City Council requests that a specific item be removed from the Consent Calendar for separate discussion and action.
a. City Council Meeting Minutes of November 18, 2025
CEQA: Not a Project
Recommended Action: Approve
b. Second Reading of Ordinance 1486 Amending Chapter 15.24 (Fire Code) and Adding Chapter 15.25 (California Wildland Urban Interface Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code CEQA: Not a Project
Recommended Action: Adopt
c. Second Reading of Ordinance 1488 Approving a Municipal Code Text Amendment (MCTA 25-03) and Recommending the City Council Adopt an Ordinance Amending Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) of the Sierra Madre Municipal Code
CEQA: Not a Project
Recommended Action: Adopt
d. Resolution 25-63 Accepting the State Homeland Security Program (SHSP) Sub recipient Agreement Grant Year 2024 of $50,000, Authorizing the City Manager or designee, to Execute all Related Grant Documents, Plus Approving a Fiscal Year 2025-2026 Budget Appropriation of $140,577 Representing Previously Accepted Grants from Fiscal Year 2022-2023, and the said 2024 Grant CEQA: Not a Project
Recommended Action: Approve
e. Resolution 25-69 Amending the Fiscal Year 2025-2026 Budget, Authorizing a Supplemental Appropriation of $250,000 in the Internal Service Fund – Personnel and Risk Management Division for Personnel Legal Expenditures CEQA: Not a Project
Recommended Action: Approve
f. Resolution 25-71 Approving Certain Demands
CEQA: Exempt
Recommended Action: Approve
g. Resolution 25-72 Approving a Fiscal Year 2025-2026 Budget Appropriation of $15,241 Sierra Madre Police Department Evidence Funds
CEQA: Exempt
Recommended Action: Approve
h. Resolution 25-73 Approving a Grant of Easement to Southern California Edison Company
CEQA: Exempt
Recommended Action: Approve

10. DISCUSSION ITEMS
a. Report, Discussion, and Direction on Sierra Madre Local Transportation Program Options
CEQA: Not a Project
Recommended Action: Deny

11. ITEMS FOR FUTURE AGENDAS

12. ADJOURNMENT
The City Council will adjourn to its next meeting on Tuesday, December 16, 2025.

CITY OF

SIERRA MADRE CITY COUNCIL

SPECIAL MEETING MINUTES
Mayor Robert Parkhurst | Mayor Pro Tem Kristine Lowe
Council Member Edward Garcia | Council Member Gene Goss | Council Member Kelly Kriebs Tuesday, November 18, 2025, 5:30 P.M.

City Council Chambers, 232 W. Sierra Madre Blvd.

AMERICANS WITH DISABILITIES ACT
Pursuant to the Americans with Disabilities Act, persons with a disability who require a disability related modification or accommodation in order to participate in a meeting, including auxiliary aids or services, may request such modification or accommodation from the City Clerk at (626) 574-5455. Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to assure accessibility to the meeting.

If you require special assistance to participate in this meeting, please contact the City Clerk’s Office at (626) 355-7135 at least 48 hours prior to the meeting.

1. CALL TO ORDER
Mayor Parkhurst called the meeting to order at 5:31 p.m. City Clerk Aguilar called the roll.

2. ROLL CALL OF CITY COUNCIL MEMBERS
Robert Parkhurst, Mayor
Kristine Lowe, Mayor Pro Tem
Edward Garcia, Council Member
Gene Goss, Council Member
Kelly Kriebs, Council Member

Absent: None.

Also Present: Michael Bruckner, City Manager
Aleks Giragosian, City Attorney
Laura Aguilar, City Clerk
Leila Regan, City Librarian
Katelyn Huang, Assistant Planner
James Carlson, Senior Analyst
Oscar Millan, IT Manager

3. PLEDGE OF ALLEGIANCE AND INSPIRATION
Council Member Kriebs led the audience in the Pledge of Allegiance. Afterwards she shared the last stanza of the Ella Wheeler Wilcox poem, titled Thanksgiving.

4. REPORT FROM CITY ATTORNEY REGARDING CLOSED SESSION
The City Council did not meet in Closed Session since they last adjourned on October 28, 2025

5. SUPPLEMENTAL INFORMATION FROM CITY CLERK REGARDING AGENDA ITEMS None.

6. REPORTS FROM MAYOR AND CITY COUNCIL (including reports from City Council related to meetings attended at City expense per AB 1234)

7. Council Member Kriebs:

Reported that she attended the Principal for a Day luncheon at Pasadena Unified School District. She also reported that she attended the November 5th State of the City Address and the Car Show on November 8.

Council Member Goss
Reported that he attended the November 4th meeting of the Library Project Ad-Hoc Committee. He also attended the November 5th State of the City Address and a discussion on November 13, led by former Library Trustee Richard Proctor.

Council Member Garcia
Reported that he attended the Senior Community Commission meeting on November 6 and the Car Show on November 8.

Mayor Pro Tem Lowe:

Reported that she attended Halloween Happening events on October 31. She also reported attending the November 5th State of the City Address, the Car Show on November 8, and Sierra Madre Historical Preservation Society Cemetery Tour on November 8.

Mayor Parkhurst
Reported that he attended the following events since the last Council meeting:

Revenue Ad-Hoc Committee meetings on October 29 and November 13 Halloween Happenings on October 31
State of the City on November 5
Clean Power Alliance Board meeting on November 6
Car Show on November 8
Sierra Madre Historical Preservation Society Cemetery Tour on November 8 Eagle Scout ceremony for Mark Garcia on November 8; and Los Angeles County Sanitation District meeting on November 17.

8. REPORTS FROM CITY STAFF
City Librarian Regan announced upcoming library events and programming.

9. PRESENTATIONS
a) Presentation on State Bill 707 Open Meetings: Meetings and Teleconference Requirements
City Attorney Giragosian presented

10. PUBLIC COMMENT FOR ITEMS NOT ON THE AGENDA
Any person wishing to speak before the City Council is asked to complete a Speaker Card and provide it to the City Clerk prior to the start of the meeting. Speakers are generally limited to three (3) minutes per person and time may not be delegated; any changes to the allotted time will be announced prior to the Public Comment period. Under the Brown Act, the City Council is prohibited from discussing or taking action on any item not listed on the posted agenda.

Mayor Parkhurst opened the podium for public comment on items not on the agenda.

City Clerk Aguilar announced that no speaker cards had been submitted for items not on the agenda.

Seeing no one come forward, Mayor Parkhurst closed public comment.

11. PUBLIC HEARING
Any person wishing to speak before the City Council on a public hearing item is asked to complete a Speaker Card noting the agenda item number and provide it to the City Clerk prior to the start of the public hearing. Separate and apart from the applicant (who may speak longer in the discretion of the City Council) speakers are generally limited to three (3) minutes per person; any changes to the allotted time will be announced prior to the Public Comment period. Under the Brown Act, the City Council is prohibited from discussing or acting on any item not listed on the posted agenda. The applicant may additionally submit rebuttal comments, at the discretion of the City Council.

12. CONSENT CALENDAR
All matters listed under the Consent Calendar are considered to be routine and can be acted on by one roll call vote. There will be no separate discussion of these items unless a member of the City Council requests that a specific item be removed from the Consent Calendar for separate discussion and action.
a) Regular Meeting Minutes of October 28, 2025
CEQA: Not a Project
Recommended Action: Approve
b) First Amendment to the Professional Services Agreement with Hue C. Quach CEQA: Not a Project
Recommended Action: Approve
c) First Amendment to the Professional Services Agreement with King Office Services extending the contract term and increasing the Not-to-Exceed amount to $146,045
CEQA: Not a Project
Recommended Action: Approve
d) Quarterly Treasurer’s Report
CEQA: Not a Project
Recommended Action: Receive and File
e) Resolution No. 25-62 accepting $30,000 in grant funds from the State of California Department of Alcoholic Beverage Control Grant Assistance Program, approving the grant budget, appropriating said funds to the Sierra Madre Police Department and authorizing the City Manager or designee to execute all related records.

CEQA: Not a Project
Recommended Action: Adopt
f) Resolution No. 25-67 Approving Certain Demands
CEQA: Not a Project
Recommended Action: Adopt
g) Resolution No. 25-68 amending the Classification Plan and Salary Matrix for Executive Management.

CEQA: Not a Project
Recommended Action: Approve
h) Resolution 25-70 amending the Fiscal Year 2025-2026 budget approving a supplemental budget appropriation from the Public Education and Government Fund Reserve
CEQA: Not a Project
Recommended Action: Adopt
At the conclusion of City Clerk Aguilar’s report, Mayor Parkhurst brought the matter to the City Council for questions. The City Council asked questions for clarification, staff provided responses for clarity.

Council Member Goss asked to have Consent Item H pulled for additional discussion.

Mayor Parkhurst opened the podium for public comment and asked if any e-mails had been received prior to the meeting. City Clerk Aguilar noted for the record that no e-mails had been received prior to the City Council meeting.

Seeing no one come forward, Mayor Parkhurst closed Public Comment and brought the matter back to the City Council.

Mayor Parkhurst asked the Council for a motion.

Council Member Kriebs made a motion to approve Consent a-g.

Mayor Pro Tem Lowe seconded the motion.

Mayor Parkhurst called for a vote of the Council:

Ayes: Mayor Parkhurst, Mayor Pro Tem Lowe, Council Members Garcia, Goss and Kriebs Noes: None.

Absent: None.

Abstain: None.

Consent Items a-g were approved by majority voice vote.

The Mayor moved onto a discussion of Consent h
h) Resolution 25-70 amending the Fiscal Year 2025-2026 budget approving a supplemental budget appropriation from the Public Education and Government Fund Reserve
CEQA: Not a Project
Recommended Action: Adopt
IT Manger Millan presented the report to the City Council.

Council Member Garcia made a motion to approve Consent h.

Mayor Pro Tem Lowe seconded the motion.

Mayor Parkhurst called for a vote of the Council:

Ayes: Mayor Parkhurst, Mayor Pro Tem Lowe, Council Members Garcia, Goss and Kriebs Noes: None.

Absent: None.

Abstain: None.

Consent Item H was approved by majority voice vote.

13. ITEMS FOR FUTURE AGENDAS
Mayor Pro Tem Lowe: An update on the Yucca Trail Debris Structure Hearing no other requests from Council, Mayor Parkhurst asked for a motion to adjourn the meeting.

Council Member Garcia made a motion to adjourn the meeting.

Council Member Kriebs seconded the motion to adjourn.

Mayor Parkhurst called for a vote of the Council:

Ayes: Mayor Parkhurst, Mayor Pro Tem Lowe, Council Members Garcia, Goss, and Kriebs Noes: None.

Absent: None.

Abstain: None.

The motion to adjourn the Special meeting was approved by all Members at 7:13 pm.

14. ADJOURNMENT
The City Council will adjourn to a regular meeting on Tuesday, December 9, 2025.

Minutes taken and typed by: Approved by Council Action:
_____________________ _______________________________
Laura M. Aguilar Robert Parkhurst
City Clerk Mayor

CITY OF

SIERRA MADRE STAFF REPORT

FIRE DEPARTMENT
DATE: December 9, 2025
TO: Honorable Mayor and City Council
FROM: Brent Bartlett, Fire Chief
SUBJECT: Ordinance No. 1486 Relating to the Adoption and Amendments to the 2025 California Fire Code and 2025 California Wildland Urban Interface Code

RECOMMENDATION
It is recommended that the City Council conduct the second reading and adopt Ordinance No. 1486 amending various sections of the Sierra Madre Municipal Code pursuant to the 2025 California Fire Code and 2025 California Wildland Urban Interface Code amendments.

SUMMARY
At its regular meeting of October 28, 2025, the City Council held a public hearing introducing the first reading of Ordinance No. 1486. The second reading of Ordinance No. 1486 is hereby presented before the City Council for consideration and adoption.

For additional information about Ordinance No. 1486, please see Attachments 2 and 3.

ENVIRONMENTAL ANALYSIS
It is recommended that City Council find that this Ordinance be determined exempt from the California Environmental Quality Act pursuant to State Guidelines §15061(b)(3) as a project that has no potential for causing a significant effect on the environment.

FISCAL IMPACT
There is no impact to the General Fund as a result of the recommended action.

Adoption of Ordinance No. 1486 Amending the Sierra Madre Municipal Code for California Fire Code and Wildland Urban Interface Code Amendments
December 9, 2025

Page 2 of 2 ends

Approved by:
___________________________
Michael Bruckner
City Manager
Attachment(s):

1. Ordinance No. 1486

2. October 14, 2025 Agenda Report – Ordinance No. 1486

3. October 28, 2025 Agenda Report – Ordinance No. 1486
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ORDINANCE NO. 1486

AN ORDINANCE OF THE CITY OF SIERRA MADRE
AMENDING CHAPTER 15.24 (FIRE CODE) AND
ADDING CHAPTER 15.25 (CALIFORNIA WILDLAND
URBAN INTERFACE CODE) OF TITLE 15 (BUILDINGS

AND CONSTRUCTION) OF THE SIERRA MADRE

MUNICIPAL CODE

THEREFORE, THE CITY COUNCIL OF THE CITY OF SIERRA MADRE, CALIFORNIA, DOES ORDAIN AS FOLLOWS:

SECTION 1. Municipal Code Amendment. Section 15.24.010 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

SECTION 15.24.010 Adoption of the California Fire Code
There is hereby adopted by the City Council of the City of Sierra Madre for the purpose of prescribing regulations governing conditions hazardous to life and property from fire or explosion, that certain Code known as the 2025 Edition of the California Fire Code based on the 2024 Edition of the International Fire Code published by the International Code Council except such portions as are hereinafter deleted, modified or amended by Section 15.24.070 of the Sierra Madre Municipal Code and portions of the International Fire Code. From the date on which this ordinance shall take effect, the provisions of the 2025 California Fire Code shall be controlling within the limits of the City of Sierra Madre.

SECTION 2. Municipal Code Amendment. Section 15.24.020 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

SECTION 15.24.020 - Establishment and duties of the bureau of fire prevention.

The California Fire Code shall be enforced by the bureau of fire prevention in the fire department of the city which is established and which shall be operated under the supervision of the chief of the fire department.

SECTION 3. Municipal Code Amendment. Section 15.24.070 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

SECTION 15.24.070 Amendments to the 2025 California Fire Code A. Section 101.1 is amended to read as follows:
101.1 Title. These regulations shall be known as the Fire Code of the City of Sierra Madre, hereinafter referred to as “this code”.
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B. Section 113.4 is amended to read as follows:
113.4 Violation penalties. Persons who shall violate a provision of this code or shall fail to comply with any of the requirements thereof or who shall erect, install alter, repair or do work in violation of the approved construction documents or directive of the fire code official, or of a permit or certificate used under provisions of this code, shall be guilty of a misdemeanor, and may be punishable by administrative, civil, or criminal action. An administrative, civil, or criminal action may be brought concurrently with any other process regarding the same violation. Each day such violation is committed or permitted is to constitute a separate offense and shall be punishable as such.

C. Section 114.4 is amended to read as follows:
114.4 Failure to comply. Any person who shall continue any work after having been served with a stop work order, except such work as that person is directed to perform to remove a violation or unsafe condition, shall be guilty of a misdemeanor, and may be punishable by administrative, civil, or criminal action. An administrative, civil, or criminal action may be brought concurrently with any other process regarding the same violation. Each day such violation is committed or permitted is to constitute a separate offense and shall be punishable as such.

D. Section 307.4.2 is amended to read as follows:
307.4.2 Recreational fires. Recreational fires shall not be conducted within 25 feet (760mm) of a structure or combustible material. Conditions which could cause a fire to spread within 25 feet (7620 mm) of a structure shall be eliminated.

Discontinuance. The fire code official or his representative is authorized to require that recreational fires be immediately discontinued if such fires are determined by the chief to constitute a hazardous condition or if atmospheric conditions reach critical levels as specified in the policies and procedures of the fire prevention bureau.

E. Section 503.2.1 is amended to read as follows due to local topographical conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
503.2.1 Dimensions. Fire apparatus access roads shall have an unobstructed width of not less than 20 feet (6096 mm), except for approved security gates in accordance with section 503.6, and an unobstructed vertical clearance of not less than 13 feet 6 inches (4115mm).

When fire hydrants are required, fire apparatus access roads shall have an unobstructed width of not less than 26 feet (4114 mm) within a linear distance of 25 feet (7620 mm) each side of the hydrant.
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F. Section 903.2.1.1 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.1.1 Group A-1. An automatic sprinkler system shall be provided for Group A-1 occupancies in accordance with Code section 15.24.120.

G. Section 903.2.1.2 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.1.2 Group A-2. An automatic sprinkler system shall be provided for Group A-2 occupancies in accordance with Code section 15.24.120.

H. Section 903.2.1.3 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.1.3 Group A-3. An automatic sprinkler system shall be provided for Group A-3 occupancies in accordance with Code section 15.24.120.

I. Section 903.2.1.4 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.1.4 Group A-4. An automatic sprinkler system shall be provided for Group A-4 occupancies in accordance with Code section 15.24.120.

J. Section 903.2.1.5 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.1.5 Group A-5. An automatic sprinkler system shall be provided for Group A-5 occupancies in the following areas: concession stands, retail areas, press boxes, and other accessory use areas in accordance with Code section 15.24.120.

K. Section 903.2.2 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
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903.2.2 Group B. An automatic sprinkler system shall be provided throughout all buildings containing a Group B occupancy in accordance with Code section

15.24.120.

L. Section 903.2.3 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.3 Group E. An automatic sprinkler system shall be provided throughout all buildings containing a Group E occupancy in accordance with Code section

15.24.120. (exception: For public school state-funded construction projects see Section 903.2.19)
M. Section 903.2.4 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.4 Group F-1. An automatic sprinkler system shall be provided throughout all buildings containing a Group F-1 occupancy in accordance with Code section

15.24.120.

N. Section 903.2.5 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.5 Group H. Automatic sprinkler systems shall be provided in high-hazard occupancies as required in Sections 903.2.5.1 through 903.2.5.3. 903.2.5.1 General, An automatic sprinkler system shall be installed in Group H occupancies. in accordance with Code section 15.24.120.

O. Section 903.2.6 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.6 Group I. An automatic sprinkler system shall be provided throughout buildings with a Group I in accordance with Code section 15.24.120.

P. Section 903.2.7 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire 411714.3
Code Findings of Fact as filed with the California Building Standards Commission:
903.2.7 Group M. An automatic sprinkler system shall be provided throughout buildings containing a Group M occupancy in accordance with Code section

15.24.120.

Q. Section 903.2.8 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.8 Group R. An automatic sprinkler system installed in accordance with Section 903.3 shall be provided throughout all buildings with a Group R fire area and in accordance with Code section 15.24.110.

R. Section 903.2.9 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.9 Group S-1. An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 in accordance with Code section 15.24.120.

S. Section 903.2.9.1 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.9.1 Repair garages. An automatic sprinkler system shall be provided throughout all buildings used as repair garages in accordance with Code section

15.24.120.

T. Section 903.2.9.2 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.9.2 Bulk storage of tires. Buildings and structures with an area for the storage of tires shall be equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1.

U. Section 903.2.10 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
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903.2.10 Group S-2. An automatic sprinkler system shall be provided throughout buildings classified as enclosed parking garages in accordance with Section 406.6 of the California Building Code or where located beneath other groups.

V. Section 903.2.10.1 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.10.1 Commercial parking garages. An automatic sprinkler system shall be provided throughout buildings used for storage of commercial motor vehicles in accordance with Code section 15.24.120
W. APPENDIX D-Fire Apparatus Access Roads is adopted and amended to read as follows due to local topographical conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:

D103.1 Access road width with a fire hydrant. Where a fire hydrant is located on a fire apparatus access road, the minimum road width shall be 26 feet (7925 mm), within a linear distance of 25 feet (7620 mm) each side of the hydrant, exclusive of shoulders.

SECTION 4. Municipal Code Amendment. Section 15.24.090 of the Sierra Madre Municipal Code is hereby amended to read as follows:

The sale possession or discharge of all fireworks is prohibited within the city. The provisions of this section will not apply to public displays of fireworks conducted by a licensed pyrotechnic engineer.

SECTION 5. Municipal Code Amendment. Section 15.24.110 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

15.24.110 - Automatic life safety support sprinkler system.

An approved automatic life safety support sprinkler system shall be installed in all occupancies and locations as set forth in this section and shall meet all designated National Fire Protection Association (NFPA) code requirements, or Section R309 of the California Residential Code as adopted by the State of California and the policies and procedures of the Sierra Madre Fire Prevention Bureau as currently specified and amended by the Sierra Madre Municipal Code:

A. All newly constructed residential occupancies shall install an automatic life safety support sprinkler system as an integral aspect of their new construction. 411714.3
B. All residential occupancies being renovated over seventy percent of their existing square footage in a twelve-month period shall install a life safety support sprinkler system throughout the entire occupancy.

C. All residential occupancies where an addition of fifty percent or more of the existing square footage is being accomplished in a twelve-month period shall install a life safety support sprinkler system throughout the entire occupancy.

SECTION 6. Municipal Code Amendment. Section 15.24.120 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

15.24.120 - Automatic fire extinguishing systems.

An automatic fire sprinkler systems shall be installed in the following occupancies:

A. In all new buildings within the City of Sierra Madre except group U.

B. All new Group U as classified in the International Fire Code, which are located within thirty five (35) feet of any exposure.

C. All buildings classified as a Group A, B, E, F, H, I, M, S when renovated over seventy five percent (75%) of their existing square footage.

D. All buildings classified as a Group A, B, E, F, H, I, M, S when an addition of fifty percent of their existing square footage is being accomplished.

E. All Group R occupancies shall install an automatic life safety fire sprinkler system in accordance with Code Section 15.24.110.

SECTION 7. Municipal Code Amendment. Chapter 15.25 (California Wildland Urban Interface Code) is added to Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code to read as follows:

CHAPTER 15.25 – CALIFORNIA WILDLAND URBAN INTERFACE CODE SECTION 15.25.010 Adoption of the California Wildland Urban Interface Code There is hereby adopted by the City Council of the City of Sierra Madre for the purpose of prescribing regulations governing conditions hazardous to life and property from wildfire or conflagration, that certain Code known as the 2025 Edition of the California Wildland Urban Interface Code based on the 2024 Edition of the International Wildland Urban Interface Code published by the International Code Council, from the date on which this ordinance shall take effect, the provisions of the 2025 California Wildland Urban Interface Code shall be controlling within the limits of the City of Sierra Madre.
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SECTION 8. Repeal of Conflicting Ordinances. All existing ordinances or parts thereof conflicting or inconsistent with the provisions of this ordinance or the California Fire Code adopted are hereby repealed.

SECTION 9. References in Documents and Continuing Legal Effect. References to prior versions of the California Fire Code, or of the Sierra Madre Municipal Code that are amended or renumbered in this Municipal Code, that are cited on notices issued by the City or other documents of ongoing or continuing legal effect, including resolutions adopting or imposing fees or charges, until converted, are deemed to be references to the new counterpart 2025 Fire Code, 2025 Wildland Urban Interface Code, or amended Municipal Code sections for the purposes of notice and enforcement. The provisions adopted hereby shall not in any manner affect deposits, established fees or other matters of record which refer to, or are otherwise connected with, ordinances which are specifically designated by number, code section or otherwise, but such references shall be deemed to apply to the corresponding provisions set forth in the code sections adopted or amended hereby.

SECTION 10. Continuity. To the extent the provisions of this Ordinance are substantially the same as previous provisions of the Sierra Madre Municipal Code, these provisions shall be construed as continuations of those provisions and not as amendments of the earlier provisions.

SECTION 11. No Effect on Enforceability. The repeal of any sections of the Municipal Code, shall not affect or impair any act done, or right vested or approved, or any proceeding, suit or prosecution had or commenced in any cause before such repeal shall take effect; but every such act, vested right, proceeding, suit, or prosecution shall remain in full force and effect for all purposes as if the applicable provisions of the Municipal Code, or part thereof, had remained in force and effect.

No offense committed and no liability, penalty, or forfeiture, either civil or criminal, incurred prior to the repeal or alteration of any applicable provision of the 2022 Code as amended, shall be discharged or affected by such repeal or alteration but prosecutions and suits for such offenses, liabilities, penalties or forfeitures shall be instituted and proceed in all respects as if the applicable provisions of the 2022 Code, as amended, had not been repealed or altered.

SECTION 12. Supplementary of Existing Law. The City Council intends this Ordinance to supplement, not to duplicate or contradict, applicable state and federal law and this Ordinance shall be construed in light of that intent.

SECTION 13. Modifications to California Fire Code. All inconsistencies between the Municipal Fire Code, as adopted by this ordinance, and Parts 7 & 9 of Title 24 the California Code of Regulations are changes, modifications, amendments, additions or deletions thereto authorized by California Health and Safety Code Sections 17858 and 17858.7.

SECTION 14. Findings. The City Council hereby adopts the findings attached hereto as Exhibit A by this reference fully incorporated herein. These modifications to the 2025 California Fire Code, incorporating the 2024 International Fire Codes are 411714.3
reasonably necessary due to the local climatic, geological, and topographical reasons set forth in Exhibit A.

SECTION 15. Severability. Should any section, subsection, clause, or provision of this Ordinance for any reason be held to be invalid or unconstitutional, such invalidity or unconstitutionality shall not affect the validity or constitutionality of the remaining portions of this Ordinance; it being hereby expressly declared that this Ordinance, and each section, subsection, sentence, clause, and phrase hereof would have been prepared, proposed, approved, and ratified irrespective of the fact that any one or more sections, subsections, sentences, clauses, or phrases be declared invalid or unconstitutional.

SECTION 16. Effective Date. Pursuant to Government Code Section 36937, this Ordinance shall take effect thirty days after its adoption, or January 1, 2026, whichever is later.

SECTION 17. Records. Pursuant to Government Code Section 40801, proof of certification and publication shall be entered in the book of Ordinances of the City Council.

SECTION 18. CEQA. This Ordinance has been determined to be exempt from the California Environmental Quality Act pursuant to State Guidelines §15061 (b) (3) as a project that has no potential for causing a significant effect on the environment.

SECTION 19. Certification. Pursuant to Government Code Section 36932, the City Clerk shall certify the passage, approval, and adoption of this Ordinance by the City Council.

SECTION 20. Filing with State. The City Clerk shall file a certified copy of this Ordinance with the California Building Standards Commission.

PASSED, APPROVED AND ADOPTED, this 28th day of October, 2025 ___________________________
Robert Parkhurst, Mayor
I HEREBY CERTIFY that the foregoing Ordinance was introduced by first reading on the 14th day of October, 2025, and duly adopted at a regular meeting held on the 28th day of October 2025, by the City Council of the City of Sierra Madre, California, by the following vote:
411714.3
AYES:

NOES
ABSTAIN:

ABSENT:
___________________________
Laura Aguilar, City

City of Sierra Madre

AGENDA REPORT
TO: Honorable Mayor Parkhurst and Members of the City Council FROM: Brent Bartlett, Fire Chief
REVIEWED BY: Michael Bruckner, City Manager
DATE: October 14, 2025
SUBJECT: ORDINANCE NO. 1486 RELATING TO THE ADOPTION AND AMENDMENTS TO THE 2025 INTERNATIONAL FIRE CODE
AND THE 2025 CALIFORNIA FIRE CODE UPDATES

STAFF RECOMMENDATION
It is recommended that the City Council introduce for first reading Ordinance No. 1486 amending various sections of the Sierra Madre Municipal Code (SMMC) pursuant to the 2025 California Fire Code and 2025 California Wildland Urban Interface Code amendments.

ALTERNATIVES

1. Introduce Ordinance No. 1486 for first reading by title only.

2. Direct staff to revise Ordinance No. 1486 and conduct first reading as amended by title only.

SUMMARY
On January 1, 2026, the state of California will be adopting a new fire code.

Subsequently, the City of Sierra Madre is required to adopt and enforce the same code with local amendments. Currently, the City is enforcing the 2022 California Fire Code with local amendments. There are no proposed new local amendments to the California Fire Code.

The state has also adopted a new code, known as Title 24, Part 7 California Wildland Urban Interface Code, through the California Building Standards Commission. There are no new state or local amendments in the 2025 California Wildland Urban Interface Code, as this new statewide code is merely a reorganization and consolidation of existing statutes, codes, and standards into a single document for ease of use by the authority having jurisdiction, as well as property owners or developers.

Ordinance No. 1486 amends Title 15.24 of the Sierra Madre Municipal Code relating to Robert Parkhurst, Mayor
Kristine Lowe, Mayor Pro Tem
Edward Garcia, Council Member
Gene Goss, Council Member
Kelly Kriebs, Council Member
Sue Spears, City Treasurer

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the adoption and amendment of the 2025 California Fire Code and 2025 California Wildland Urban Interface Code to meet with State requirements. Additionally, this Ordinance continues all previous amendments from 2022 with no additional changes.

ANALYSIS
Ordinance No. 1486 amends Title15.24 as follows:

Section 1. Section 15.24.010 is amended to adopt the 2025 California Fire Code.

Section 2. Section 15.24.020 is amended to replace the words “International Fire Code” with “California Fire Code”
Section 3. Section 15.24.070 Amendments to the California Fire Code.

Section 101.1 of the California Fire Code is amended to identify “this code” as the Sierra Madre Fire Code.

Section 113.4 identifies fire code violations and penalties as misdemeanors, and may be punishable by administrative, civil, or criminal action.

Section 114.4 identifies failure to comply penalties as misdemeanors, and may be punishable by administrative, civil, or criminal action.

Section 307.4.2 of the California Fire Code is amended to allow the Fire Code Official to order recreational fires to be discontinued if such fires constitute a hazardous condition or if atmospheric conditions reach critical levels.

Section 503.2.1 of the California Fire Code is amended to require new fire access roads to have a minimum width of 26 feet within 25 feet of each side of a fire hydrant. This requirement will prevent the problem of an access road being blocked when a fire engine is utilizing a fire hydrant.

Sections 903.2.1.1, 903.2.1.2, 903.2.1.3, 903.2.1.4, 903.2.1.5, 903.2.2, 903.2.3, 903.2.4, 903.2.5, 903.2.6, 903.2.7, 903.2.8, 903.2.9, 903.2.9.1, 903.2.9.2, 903.2.10 and 903.2.10.1 of the fire code are amended in order to maintain the current fire sprinkler requirements as set forth in Section 15.24.120 of the Sierra Madre Municipal Code.

APPENDIX D-Fire Apparatus Access Roads is adopted and amended to continue to require new fire access roads to have a minimum width of 26 feet within 25 feet of each side of a fire hydrant. This requirement will help prevent the problem of an access road being blocked when a fire engine is utilizing a fire hydrant.

Section 4. Section 15.24.110 is amended to include additional design options for residential fire sprinklers by adding “Section R309 of the California Residential Code”, and continue existing requirements for residential buildings being renovated based on

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square footage percentages.

Section 5. Section 15.24.120 is amended to continue to require automatic fire sprinklers in buildings being renovated based on square footage percentages.

Section 6. Section 15.25.010 is established to adopt the 2025 California Wildland Urban Interface Code as published with no amendments.

Sections 7-19. Repeal of Conflicting Ordinances and other legal Code Adoption language.

ENVIRONMENTAL (CEQA)
The proposed action does not constitute as a project under the California Environmental Quality Act (“CEQA”), based on Section 15061(b)(3) of the CEQA Guidelines, as it can be determined with certainty that it will have no impact on the environment.

STRATEGIC PLAN CORRELATION
Ordinance No. 1486 and enforcement of the 2025 California Fire Code and 2025 California Wildland Urban Interface Code is aligned with Goal 2: Public Safety.

PUBLIC NOTICE PROCESS
This item has been noticed though the regular agenda notification process. Notice of the hearing was published consistent with the requirements of Government Code Sections 65090 and 50022.2, including publication of a summary notice of public hearing in the local adjudicated newspaper. Copies of this report can be accessed on the City’s website at sierramadreca.gov.

FINANCIAL REVIEW/SOURCE OF FUNDING
There is no impact to the General Fund. The adoption of Ordinance No. 1486 to enforce the 2025 California Fire Code and the 2025 California Wildland Urban Interface Code, along with local amendments, will not result in any direct fiscal impact to the City of Sierra Madre. The ordinance involves the continuation of the current code enforcement practices and does not introduce any new local amendments or operational costs. Staff time has already been incurred in preparing the report and draft ordinance; however, no additional funds or expenditures are required for implementation beyond normal administrative duties. Therefore, the proposed action is considered fiscally neutral for the City.

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Attachments
Attachment 1: City Council Ordinance No. 1486 - 2025 Fire Code & California Wildland Urban Interface Code Adoption
Exhibit A: Sierra Madre Fire Department 2025 Fire Code & California Wildland Urban Interface Code Findings
[Omitted for the October 28, 2025 Agenda Report]

City of Sierra Madre

AGENDA REPORT
TO: Honorable Mayor and Members of the City Council
FROM: Brent Bartlett, Fire Chief
REVIEWED BY: Michael Bruckner, City Manager
DATE: October 28, 2025
SUBJECT: ORDINANCE NO. 1486 RELATING TO THE ADOPTION AND AMENDMENTS TO THE 2025 CALIFORNIA FIRE CODE AND
2025 CALIFORNIA WILDLAND URBAN INTERFACE CODE

EXECUTIVE SUMMARY
At its regular meeting of October 14, 2025, the City Council received a report and presentation of Ordinance No. 1486 relating to the adoption and amendments of the 2025 California Fire Code and 2025 California Wildland Urban Interface Code; however, official public notice of that meeting was provided in error through reference of amendments to the “2025 International Fire Code”. Notice of the October 28, 2025, public hearing for first reading of Ordinance No. 1486 was provided through a publication in the Mountain Views News with a correction of the aforementioned reference. Additionally, the Fire Marshal recommends including, for the avoidance of doubt, an existing local amendment related to the prohibition of the sale, possession or discharge of all fireworks within the City.

ANALYSIS
The 2025 California Fire Code (CFC) and California Wildland Urban Interface (WUI) Code provide updated minimum standards for fire prevention, building construction, and life safety.

Ordinance No. 1486 adopts these codes with local amendments specific to Sierra Madre’s unique topographic, climatic, and geological conditions. The amendments are designed to enhance the City’s capacity to mitigate fire risks and strengthen overall community resilience.

Notable local amendments include:
x Enhanced sprinkler system requirements for both new and substantially renovated residential and commercial occupancies.
x Access road width standards to ensure unobstructed routes for fire apparatus, particularly in hillside and canyon areas where steep grades and narrow roads constrain emergency response.
x Local prohibitions on fireworks, reaffirming an existing ordinance to reduce ignition risks during high fire danger periods.
x Integration of WUI standards to improve structure hardening and defensible space in areas adjacent to the Angeles National Forest.

Robert Parkhurst, Mayor
Kristine Lowe, Mayor Pro Tem
Edward Garcia, Council Member
Gene Goss, Council Member
Kelly Kriebs, Council Member
Sue Spears, City Treasurer

Page 2 of 3 ends

These provisions are supported by the 2025 Fire Code & Wildland Urban Interface Code Findings (Exhibit A to Ordinance No. 1486), which document Sierra Madre’s elevated fire risk due to steep terrain, dry vegetation, and limited egress routes. Together, the adoption and amendments ensure regulatory consistency with state law while maintaining the City’s higher local standards for fire and life safety protection.

ENVIRONMENTAL (CEQA)
Pursuant to Section 15061(b)(3) of the California Environmental Quality Act (CEQA) Guidelines, adoption of Ordinance No. 1486 is exempt from environmental review. The ordinance constitutes a regulatory update that establishes administrative and procedural standards for fire and building safety. It does not authorize or require any specific development or activity that may cause a direct or reasonably foreseeable indirect impact on the physical environment. Therefore, it can be seen with certainty that the proposed action will not have a significant effect on the environment.

STRATETGIC PLAN CORRELATION
Adoption of the 2025 Fire Code and WUI Code directly supports several strategic priorities outlined in the City of Sierra Madre Strategic Plan 2025–2026, particularly under Goal 2: Public Safety and Goal 3: Infrastructure & Growth Management x Objective 2.1 – Sustaining Sierra Madre’s Fire Services: Enhances the City’s readiness and resiliency through code-based prevention and community risk reduction, supporting projects such as pre-fire planning, home-hardening, and Firewise/Wildfire Interface initiatives.
x Objective 2.3 – Environmental Management & Code Enforcement: Advances riskreduction strategies that promote defensible space and sustainable construction practices in the WUI.
x Objective 3.3 – Municipal Facilities Modernization & Resilience: Reinforces lifesafety standards for critical public infrastructure and ensures that all facilities meet contemporary fire and seismic safety requirements.

By adopting these codes, Sierra Madre continues to advance its commitment to exceptional public services that enhance quality of life, honor community character, and maintain fiscal and environmental sustainability—as stated in the City’s Mission Statement.

FISCAL IMPACT
Publication and noticing costs related to the ordinance are routine and have been budgeted within the City Clerk’s operating expenses. No new positions, capital improvements, or equipment purchases are required to implement the updated fire and building code standards.

Adoption of Ordinance No. 1486 amending the Sierra Madre Municipal Code to incorporate the 2025 California Fire Code and 2025 California Wildland Urban Interface Code will have minimal direct fiscal impact on the City’s operating budget. Implementation will primarily involve staff time associated with training, interdepartmental coordination, and public outreach, which will be absorbed within existing appropriations for the Fire Department and Planning & Community Preservation Department in Fiscal Year 2025–2026.

Page 3 of 3 ends

PUBLIC NOTICE PROCESS
Pursuant to Government Code Sections 6066 and 50022.3, notice of the public hearing for the first reading of Ordinance No. 1486 was published in the Mountain Views News on October 18, 2025. The corrected notice clarified the reference to the 2025 California Fire Code and 2025 California Wildland Urban Interface Code, superseding an earlier notice that inadvertently referenced the International Fire Code. Copies of the proposed ordinance and supporting findings were made available for public review on the City’s website prior to the hearing, in accordance with the Sierra Madre Municipal Code and the City’s standard noticing procedures.

ATTACHMENTS
Attachment 1: Ordinance No. 1486
Attachment 2: October 14, 2025 Agenda Report re: Ordinance No. 1486

411714.3
ORDINANCE NO. 1486

AN ORDINANCE OF THE CITY OF SIERRA MADRE
AMENDING CHAPTER 15.24 (FIRE CODE) AND
ADDING CHAPTER 15.25 (CALIFORNIA WILDLAND
URBAN INTERFACE CODE) OF TITLE 15 (BUILDINGS

AND CONSTRUCTION) OF THE SIERRA MADRE

MUNICIPAL CODE

THEREFORE, THE CITY COUNCIL OF THE CITY OF SIERRA MADRE, CALIFORNIA, DOES ORDAIN AS FOLLOWS:

SECTION 1. Municipal Code Amendment. Section 15.24.010 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

SECTION 2. Municipal Code Amendment. Section 15.24.020 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

SECTION 15.24.020 - Establishment and duties of the bureau of fire prevention.

SECTION 3. Municipal Code Amendment. Section 15.24.070 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

411714.3
B. Section 113.4 is amended to read as follows:
113.4 Violation penalties. Persons who shall violate a provision of this code or shall fail to comply with any of the requirements thereof or who shall erect, install alter, repair or do work in violation of the approved construction documents or directive of the fire code official, or of a permit or certificate used under provisions of this code, shall be guilty of a misdemeanor, and may be punishable by administrative, civil, or criminal action. An administrative, civil, or criminal action may be brought concurrently with any other process regarding the same violation. Each day such violation is committed or permitted is to constitute a separate offense and shall be punishable as such.

411714.3
F. Section 903.2.1.1 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire Code Findings of Fact as filed with the California Building Standards Commission:
903.2.1.1 Group A-1. An automatic sprinkler system shall be provided for Group A-1 occupancies in accordance with Code section 15.24.120.

411714.3
903.2.2 Group B. An automatic sprinkler system shall be provided throughout all buildings containing a Group B occupancy in accordance with Code section

15.24.120.

903.2.5.1 General, An automatic sprinkler system shall be installed in Group H occupancies. in accordance with Code section 15.24.120.

P. Section 903.2.7 is amended to read as follows due to local topographical, geological and climatic conditions as identified in the 2025 Fire

411714.3
Code Findings of Fact as filed with the California Building Standards Commission:
903.2.7 Group M. An automatic sprinkler system shall be provided throughout buildings containing a Group M occupancy in accordance with Code section

15.24.120.

411714.3
903.2.10 Group S-2. An automatic sprinkler system shall be provided throughout buildings classified as enclosed parking garages in accordance with Section 406.6 of the California Building Code or where located beneath other groups.

SECTION 4. Municipal Code Amendment. Section 15.24.090 of the Sierra Madre Municipal Code is hereby amended to read as follows:

SECTION 5. Municipal Code Amendment. Section 15.24.110 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

15.24.110 - Automatic life safety support sprinkler system.

A. All newly constructed residential occupancies shall install an automatic life safety support sprinkler system as an integral aspect of their new construction.

411714.3
B. All residential occupancies being renovated over seventy percent of their existing square footage in a twelve-month period shall install a life safety support sprinkler system throughout the entire occupancy.

SECTION 6. Municipal Code Amendment. Section 15.24.120 of Chapter 15.24 (Fire Code) of Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code is hereby amended to read as follows:

15.24.120 - Automatic fire extinguishing systems.

An automatic fire sprinkler systems shall be installed in the following occupancies:

A. In all new buildings within the City of Sierra Madre except group U.

B. All new Group U as classified in the International Fire Code, which are located within thirty five (35) feet of any exposure.

C. All buildings classified as a Group A, B, E, F, H, I, M, S when renovated over seventy five percent (75%) of their existing square footage.

D. All buildings classified as a Group A, B, E, F, H, I, M, S when an addition of fifty percent of their existing square footage is being accomplished.

E. All Group R occupancies shall install an automatic life safety fire sprinkler system in accordance with Code Section 15.24.110.

SECTION 7. Municipal Code Amendment. Chapter 15.25 (California Wildland Urban Interface Code) is added to Title 15 (Buildings and Construction) of the Sierra Madre Municipal Code to read as follows:

411714.3
SECTION 8. Repeal of Conflicting Ordinances. All existing ordinances or parts thereof conflicting or inconsistent with the provisions of this ordinance or the California Fire Code adopted are hereby repealed.

411714.3
reasonably necessary due to the local climatic, geological, and topographical reasons set forth in Exhibit A.

SECTION 16. Effective Date. Pursuant to Government Code Section 36937, this Ordinance shall take effect thirty days after its adoption, or January 1, 2026, whichever is later.

SECTION 17. Records. Pursuant to Government Code Section 40801, proof of certification and publication shall be entered in the book of Ordinances of the City Council.

SECTION 19. Certification. Pursuant to Government Code Section 36932, the City Clerk shall certify the passage, approval, and adoption of this Ordinance by the City Council.

SECTION 20. Filing with State. The City Clerk shall file a certified copy of this Ordinance with the California Building Standards Commission.

PASSED, APPROVED AND ADOPTED, this 28th day of October, 2025 ___________________________
Robert Parkhurst, Mayor

I HEREBY CERTIFY that the foregoing Ordinance was introduced by first reading on the 14th day of October, 2025, and duly adopted at a regular meeting held on the 28th day of October 2025, by the City Council of the City of Sierra Madre, California, by the following vote:

411714.3
AYES:

NOES
ABSTAIN:

ABSENT:
___________________________
Laura Aguilar, City

City of Sierra Madre

ALTERNATIVES

1. Introduce Ordinance No. 1486 for first reading by title only.

2. Direct staff to revise Ordinance No. 1486 and conduct first reading as amended by title only.

SUMMARY
On January 1, 2026, the state of California will be adopting a new fire code.

Page 2 of 4 ends

ANALYSIS
Ordinance No. 1486 amends Title15.24 as follows:

Section 1. Section 15.24.010 is amended to adopt the 2025 California Fire Code.

Section 2. Section 15.24.020 is amended to replace the words “International Fire Code” with “California Fire Code”
Section 3. Section 15.24.070 Amendments to the California Fire Code.

Section 101.1 of the California Fire Code is amended to identify “this code” as the Sierra Madre Fire Code.

Section 113.4 identifies fire code violations and penalties as misdemeanors, and may be punishable by administrative, civil, or criminal action.

Section 114.4 identifies failure to comply penalties as misdemeanors, and may be punishable by administrative, civil, or criminal action.

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square footage percentages.

Section 5. Section 15.24.120 is amended to continue to require automatic fire sprinklers in buildings being renovated based on square footage percentages.

Section 6. Section 15.25.010 is established to adopt the 2025 California Wildland Urban Interface Code as published with no amendments.

Sections 7-19. Repeal of Conflicting Ordinances and other legal Code Adoption language.

STRATEGIC PLAN CORRELATION
Ordinance No. 1486 and enforcement of the 2025 California Fire Code and 2025 California Wildland Urban Interface Code is aligned with Goal 2: Public Safety.

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CITY OF

SIERRA MADRE STAFF REPORT

PLANNING & COMMUNITY PRESERVATION
DATE: December 9, 2025
TO: Honorable Mayor and City Council
FROM: Clare Lin, Director of Planning & Community Preservation By: Katelyn Huang, Assistant Planner
SUBJECT: Second Reading of Ordinance No. 1488 Amending Chapter 17.72 (Signs) of Title 17 (Zoning) of the Sierra Madre Municipal Code

RECOMMENDATION
It is recommended the City Council conduct a second reading of Ordinance No. 1488 amending Chapter 17.72 (Signs) of Title 17 (Zoning) of the Sierra Madre Municipal Code.

DISCUSSION & ANALYSIS
The City Council held a Public Hearing and unanimously approved the first reading of Ordinance No. 1488 at its regular meeting on October 28, 2025. The second reading of Ordinance No. 1488 is hereby presented before the City Council for consideration and adoption.

For additional information regarding Ordinance No. 1488, see Attachment 2.

ENVIRONMENTAL ANALYSIS
The proposed action does not constitute as a project under the California Environmental Quality Act (“CEQA”), based on Section 15061(b)(3) of the CEQA Guidelines, as it can be determined with certainty that it will have no impact on the environment.

FISCAL IMPACT
There is no impact to the General Fund as a result of the recommended action.

Second Reading of Ordinance No. 1488
December 9, 2025

Page 2 of 2 ends

Approved by:
___________________________
Michael Bruckner
City Manager
Attachment(s):

1. Ordinance No. 1488

2. First Reading Agenda Report

ATTACHMENT A
ORDINANCE NO. 1488

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SIERRA

MADRE, CALIFORNIA APPROVING A MUNICIPAL CODE TEXT
AMENDMENT (MCTA 25-03) AND RECOMMENDING THE CITY
COUNCIL ADOPT AN ORDINANCE AMENDING CHAPTER 17.72
(“SIGNS”) OF TITLE 17 (“ZONING”) OF THE SIERRA MADRE

MUNICIPAL CODE

RECITALS
WHEREAS, Sierra Madre Municipal Code (“SMMC”) Chapter 17.72 (Signs) seeks to balance residents’ freedom of expression with aesthetic concerns by introducing content-neutral sign regulations;
WHEREAS, the City desires to amend Chapter 17.72 to clarify terms and remove content-based restrictions;
WHEREAS, the Planning Commission held a public hearing on September 18, 2025, and adopted Resolution No. 25-13 recommending approval of a municipal code text amendment (MCTA 25-03) by ordinance to the City Council.

WHEREAS, the City Council held a public hearing on October 28, 2025, on the first reading of Ordinance No. 1488 amending Chapter 17.72 (Signs) of Title 17 (Zoning) of the Sierra Madre Municipal Code;

THEREFORE, THE CITY COUNCIL OF THE CITY OF SIERRA MADRE DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. Recitals. The Recitals above are true and correct and incorporated herein by reference.

SECTION 2. Amendment. Section 17.72.010 (“Definitions”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.010 – Definitions.

Unless it is apparent from the context that another meaning is intended, the following words when used herein shall have the meaning attached to them by this section. "Abandoned sign" means any sign or sign structure is considered abandoned if for a period of ninety consecutive days or more, there is no sign copy appearing on the sign, or if the establishment to which the sign is attached has ceased operation and where the sign has been forsaken or deserted.
"Alteration" means a change of sign text, sign face, color, size, shape, illumination, position, location, construction, or supporting structure of any sign. "Animated sign" means any sign or part thereof that uses movement, lighting or special materials to depict action or create a special effect to imitate movement. "Area of sign" means the surface space within a single continuous perimeter containing the sign message together with any frame, material or color forming an integral part of the display, but excluding support structures and incidental parts not drawing attention to the subject matter. The area of a sphere or other irregular shaped sign shall be measured by its projection or sight area.
"Awning" means any permanent or temporary structure attached to and wholly supported by a building, and installed over or in front of openings or windows and consisting of a fixed or movable frame and a top of canvas or other similar material covering the entire space enclosed between the frame and the building. "Canister signs" means a sign that contains all the text and/or logo symbols within a single enclosed cabinet that may or may not be illuminated. "Canopy" means any structural, ornamental roof-like appendage, freestanding or attached to a building, including roof overhangs, but excepting awnings. "Clearance" means the vertical distance between the bottom of a sign and the finished grade below the sign.
"Directional sign" means an on-site sign designed and erected solely for the purpose of directing vehicular and/or pedestrian traffic safely within a project, pursuant to Section

17.72.130 herein.
"Double-faced sign" means any single sign structure having two sign face areas, with each face oriented up to one hundred eighty degrees from the other. "Election sign" means any sign concerning candidates for elective office or involving a ballot measure.
"Face of building" means the general outer surface of the main exterior wall of any building, not including cornices, bay windows and other ornamental trim. "Freestanding sign" means a sign supported by one or more posts erected on the ground.
"Illuminated sign" means any sign that has a source of light on the surface of the sign or in the interior of the sign itself.
"Indirectly lighted sign" means any sign that is illuminated from a remote location. "Marquee" means a permanent projecting roof structure attached to and supported by a building wall, which may project over a public right-of-way. "Neighborhood shopping centers" means three or more businesses, with separate entrances, that function as an integral unit and which utilize common off-street parking and access.
"Outdoor advertising structure" means any sign that has a flat surface sign space upon which advertising may be posted, painted or affixed, and that is primarily designed for the rental or lease of such sign space for advertising not relating to the use of the property upon which the sign exists.
"Outside display" means any permitted amount of goods, merchandise, material, landscape items or similar articles that are placed immediately outside a business. Such outside display shall not include prices, advertisements, or information regarding goods and services offered.
"Painted signs" means any sign that incorporates or utilizes no other materials than paint, located on any building surface excepting windows. “Parkway” means that portion of the right-of-way between the traveled roadway and sidewalk or, where there is no sidewalk, that portion of the right-of-way between the traveled roadway and the private property line.
"Pedestrian oriented signs" means a sign that is mounted from a building façade or awning such that it hangs directly over a public sidewalk or building walkway and that it is designed, installed and intended to be viewed primarily by individuals walking by or near the store front. Such signs include projecting blade signs. "Political sign" means any sign expressing a political, religious, or other ideological sentiment not involving an election.
"Portable sign" means a moveable temporary sign designed and placed immediately outside the location of a business. This includes A-frame and similar signs. "Projecting sign" means any sign, the surface of which is not parallel to the face of the supporting wall and that is supported wholly by such wall. Signs on marquees that extend over the right-of-way that are placed so as not to be parallel with the street shall be considered projecting signs. This definition shall include "V" or wing-type signs, blade and bracket signs.
“Right-of-way” means any of the following that are controlled, used or dedicated for use by the public and located within the city’s jurisdictional limits: streets, roadways, highways, avenues, lanes, alleys, sidewalks, parkways, medians, and similar public property.
"Roof sign" means any sign erected upon or over the roof or parapet of any building and supported in whole or in part by the building.
"Sign" means any device for visual communication, including any announcement, declaration, display, illustration or insignia that is used to advertise or promote the products or services of any person, business group or enterprise available on the lot where located. Architectural features consisting of an integral structural part of a building shall not be considered a sign.
"Sign height" means the vertical distance measured from the ground level to the top of the sign.
"Temporary sign" means any sign, banner, decorative flag, pennant, valance, and advertising display. Display or other item intended to draw attention to, or provide information for a business. Such signs are typically constructed of cloth, canvas, light fabric, cardboard, wood, Plexiglas, wall board or other light materials with or without frames.
"Wall sign" means any sign affixed to the wall of any building or structure, in essentially a flat position on the wall.
"Window sign" means any sign painted on or affixed to the inside of a window.

SECTION 3. Amendment. Section 17.72.020 (“Prohibited signs”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.020 – Prohibited Signs.

The following signs are inconsistent with the purposes and standards of this chapter and are therefore prohibited in all zones:

A. Rotating, moving, flashing, changing, reflecting or blinking signs except time and temperature signs and other public service signs which may produce a changing message with lights, which does not create any traffic hazards and subject to approval of the planning commission;
B. Animated signs;
C. Signs on public property or right-of-way unless otherwise authorized within this chapter, and as provided in under Section 17.20.020(J)(6); D. All off-site signs;
E. Outdoor advertising structures, defined herein and commonly called "billboards"; F. Signs employing exposed neon tubing, excluding reverse channel letters with silhouette illumination, neon signs approved under a creative sign permit and neon window signs not exceeding ten percent of the window area; G. Abandoned business signs;
H. Canister signs also know as "can" or "cabinet" signs; and, I. Roofmounted signs., and
J. Signs that are not public facing.

SECTION 4. Amendment. Section 17.72.030 (“General provisions”) of Chapter

17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.030 – General provisions.

The following general sign provisions and regulations shall apply.

A. Sign Placement. Signs shall be placed facing the public right-of-way, interior courtyards or parking areas. Signs shall not be placed in a manner to interfere with the privacy or enjoyment of residences.

B. Trade Construction Signs. One sign advertising the various construction trades shall be permitted on construction sites where there is an active building permit.

Such signs shall not exceed thirty-two square feet in area.

C. Proper Maintenance of Signs. The user, owner or lessee of a sign authorized hereunder shall maintain the sign in good repair with all illumination, if any, functioning, with all letters intact, and colors that are not faded. A sign that is not in good repair is a nuisance and shall be abated pursuant to the Sierra Madre Municipal Code.

D. "No Trespassing" Signs. A "no trespassing" or "no dumping sign" not exceeding three square feet shall be permitted for public health and safety purposes in addition to other authorized signs.

E. Freestanding Sign Height. Unless otherwise specified, the maximum height for freestanding signs shall be six feet.

F. Painted Window Signs—Size. The maximum area of a painted window sign is twenty percent of each windowpane and the sign copy shall be changed at least every forty-five days.

G. Awning signs. Signs on awnings are permitted provided the sign copy is limited to the valance if one exists, or covers not more than twenty percent of the awning surface, if no valance exists.

H. Projection of Signs. The following schedule shall be applied to all those signs that project over public rights-of-way excluding those signs mounted directly on a marquee.

Clearance Maximum Projection
Less than 8′ Not permitted
8′ to 16′ 1′ plus 6″ for each foot of clearance in
excess of 8′
Over 16′ 5′
I. Marquee Signs. Signs may be mounted on the side and face perimeter of a marquee provided that those signs do not project more than one foot above said marquees. Signs mounted on the sides of marquees shall not project toward the street further than the edge of the marquee. Signs may be mounted under marquees provided that the clearance is a minimum of eight feet.

J. Glare from Signs. All illuminated signs in all zones shall be designed in such manner as to avoid undue glare or reflection of light on private property in the surrounding area and so as not to create a traffic safety hazard.

K. Election Sign Regulations. Election signs are permitted without a permit in all zones, however, the following regulations apply to candidates, their campaign committee(s) and their respective signs.

1. A one hundred dollar cash bond shall be posted with the city to guarantee removal of election signs by candidates or their campaign committee(s) for all signs related to the campaign;

2. Signs shall not exceed six square feet in area with the aggregate signage for each lot not exceeding eighteen square feet and signs shall not exceed six feet in height above the adjacent grade;

3. Signs shall not be illuminated in residential zones;

4. Signs shall not be nailed to trees, fences, public utility poles and shall not be located on city facilities;

5. Signs shall be designed and placed in a manner that does not create a vehicular or pedestrian traffic safety hazard as determined by the city engineer.

6. Signs shall be removed within ten days after the election or bond posted shall be forfeited and the city shall use whatever part of the bond money as is necessary for removal. Any amount of the bond remaining shall be refunded upon request made within ninety days after the election; and

7. The one hundred dollar bond requirement shall also apply to signs located at campaign or party headquarters.

L. Political Sign Regulations. Political signs are permitted without a permit in all zones subject to the following regulations:

1. Signs shall not exceed six square feet in area with no side greater than three feet and the aggregate signage for each lot not exceeding twelve square feet and signs shall not exceed six feet in height above the adjacent grade;

2. Signs shall not be illuminated in residential zones;

3. Signs shall not be nailed to trees, fences, public utility poles and shall not be located in the public right-of-way; and

4. Signs shall be designed and placed in a manner that does not create a vehicular or pedestrian traffic safety hazard as determined by the city engineer.

SECTION 5. Amendment. Section 17.72.040 (“Sign regulations – Residential zones”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.040 – Sign regulations—R-1 and R-2 Residential zones.

A. The following sign types and sizes are permitted without a permit:

1. A nameplate not exceeding one square foot in area containing the name and address of occupant of the premises;

2. One unlighted freestanding sign not exceeding six square feet in area pertaining only to the sale, lease or hire of the particular building, property or premises upon which displayed;

3. Historic plaques and markers provided that are approved by the planning commission.

4. Temporary signs in accordance with section 17.72.190.

B. A sign permit shall, however, be required for all other signs.signs up to twenty square feet in area per side for multiple dwellings, hotels, clubs, lodges, churches, schools, parks and signs approved under a conditional use permit.

C. Signs exceeding twenty square feet per side are prohibited.

SECTION 6. Amendment. Section 17.72.050 (“Sign regulations – Special conditions and uses”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.050 – Residential zones—Special conditions and usesSign regulations—R-3 zones.

A. Notwithstanding section 17.72.040(A), in all R-3 zones The the following types and sizes of non-illuminated signs are permitted without a permit, provided that they are installed flat against an on-site building or structure and shall not extend above the top of the wall to which they are affixed:

1. One nameplate per unit not exceeding one square foot in area containing the name and address of occupant of the premises;

2. One sign with the name and address of the building not to exceed two and one-half square feet in area; and

3. One freestanding sign not to exceed nine square feet in area, pertaining only to the sale, lease or hire of only the particular building, property or premises upon which displayed.

4. Temporary signs in accordance with section 17.72.190.

B. Notwithstanding sections 17.72.040(A) and 17.72.050(A), within the R-E overlay, the following types and sizes of non-illuminated signs are permitted without a permit, provided that they are installed flat against an onsite building or structure and shall not extend above the top of the wall to which they are affixed:

1. One nameplate per unit not exceeding one square foot in area containing the name and address of occupant of the premises;

2. One sign with the name and address of the building and business not to exceed five square feet in area; and

3. One freestanding sign not to exceed nine square feet in area pertaining only to the sale, lease or hire of only the particular building, property or premises upon which displayed.

4. Temporary signs in accordance with section 17.72.190.

A sign permit shall, however, be required for illuminated signs and signs in excess of the size limits set forth in, or otherwise inconsistent with, subsection A above.

C. Signs exceeding twenty square feet per side are prohibited.

SECTION 7. Amendment. Section 17.72.060 (“Reserved”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.060 Sign regulations—R-E overlay zoneReserved.

A. The following types and sizes of non-illuminated signs are permitted without a permit, provided that they are installed flat against an on-site building or structure and shall not extend above the top of the wall to which they are affixed:

1. One nameplate per unit not exceeding one square foot in area containing the name and address of occupant of the premises;

2. One sign with the name and address of the building and business not to exceed five square feet in area; and

3. One sign not to exceed nine square feet in area, pertaining only to the sale, lease or hire of only the particular building, property or premises upon which displayed.

B. A sign permit shall, however, be required for illuminated signs and signs in excess of the size limits set forth in, or otherwise inconsistent with, subsection A above.

C. Signs exceeding twenty square feet per side are prohibited.

SECTION 8. Amendment. Section 17.72.110 (“Review by the planning commission”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.110 – Review by the planning commission.

The planning commission’s review shall be required for the design and location of signs in excess of forty square feet, all signs projecting above the top of a building line, and freestanding signs in excess of twenty square feet. All other signs shall be reviewed and approved by the director; provided, however, that either the applicant or the director can request review by the planning commission.

SECTION 9. Amendment. Section 17.72.190 (“Temporary signs in Residential Zones”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is amended with additions denoted by underlined text and deletions denoted by struck through text.

17.72.190 – Temporary signs and displaysin Residential Zones.

A temporary sign is permitted without a permit in all residential zones subject to the following requirements:

A. signs shall be limited to a freestanding sign or a sign affixed to a freestanding wall or fence in essentially a flat position thereon;
B. temporary signs shall not exceed six square feet in area with the aggregate signage of each lot not exceeding eighteen square feet; C. except as otherwise authorized by this chapter, freestanding temporary signs located within a front yard shall not exceed a sign height of 42 inches; D. temporary signs shall not be illuminated or reflective; E temporary signs shall not be nailed to trees or public utility poles; F. temporary signs shall be designed and placed in a manner that does not create a vehicular or pedestrian traffic safety hazard as determined by the city engineer;
G. temporary signs shall not be placed on awnings or canopies; H. signs shall not be placed within five feet from any shared property line; I. temporary signs relating to a timed event shall be removed 10 days following the event to which they relate.

SECTION 10. Addition. Section 17.72.195 (“Temporary signs and displays in C & M Zones”) of Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) is hereby added with additions denoted by underlined text.

17.72.195 – Temporary signs and displays in C & M Zones.

A temporary sign and/or temporary display permit shall be required in all C and M Zones, and may be issued by the director subject to the requirements of Sections

17.72.140 through 17.72.190180, inclusive. At the director's discretion a permit for outdoor display and portable signs can be issued for a twelve-month period. That a copy of the approved permit shall be forwarded to the code enforcement officer.

A. Outside Display. The display of goods and merchandise immediately outside a business is permitted subject to an approved permit as follows:

1. A dimensioned site plan shall be submitted to the director, that indicates the location of the outside display area;

2. The maximum display depth shall be no greater than five feet from the façade face but in no case closer than five feet to the edge of the sidewalk, with a maximum height of four above the sidewalk grade and the display shall cover not more than fifty percent of the width of the storefront (outdoor dining is exempt from these limitations);

3. Goods and merchandise displayed outside of a business shall be limited to those items regularly stocked and sold in the business. Further, the display shall be installed and maintained in a neat and orderly fashion at all times, and goods may only be displayed during normal business hours; and,

4. An encroachment permit shall be obtained from the department of public works.

B. Temporary Banners. Temporary banners and similar signs as defined in this chapter, may be permitted by the director as follows:

1. Application for a temporary sign shall be made on forms provided by the director of development services. The application shall also indicate the size of the banner;

2. A maximum of four temporary sign permits may be approved for any single business location within a calendar year, with the total cumulative temporary sign display days not to exceed sixty days. The maximum period lot any individual temporary sign permit shall not exceed thirty days;

3. If such temporary sign is to be placed on the public sidewalk, the applicant shall submit in addition to a temporary sign application, a site plan indicating the location of the temporary sign and an encroachment permit shall be obtained from Public Works; and

4. Temporary banners shall be placed on the building façade. The attachment of banners to trees, light and utility poles or similar configuration shall not be permitted.

C. Portable Signs. A moveable temporary sign that is designed and placed immediately outside the location of a business is allowed with an approved permit.

1. A dimensioned site plan shall be submitted to the director that indicates the location and size of the portable sign. The sign shall be located immediately adjacent to the storefront or building façade and there shall be not less than five feet between the sign area and edge of the sidewalk to allow for free and unobstructed pedestrian access;

2. Signs shall not exceed a total sign area of twenty-four square feet, or twelve square feet for each sign face;

3. Portable signs may only be displayed during normal business hours; and

4. An encroachment permit shall be obtained from the department of public works.

SECTION 10. California Environmental Quality Act. The City Council has considered all of the evidence in the record, including the staff reports, the testimony received during the public hearing on the matter held by the City Council, and hereby determines that the text amendments to Chapter 17.72 (“Signs”) of Title 17 (“Zoning”) of the Sierra Madre Municipal Code not a project as defined by the California Environmental Quality Act (CEQA) under Title 14, Section 15378 of the California Code of Regulations and has no potential to result in direct or indirect physical change to the the environment.

Therefore, this ordinance is exempt from CEQA review, pursuant to Title 14, Section 15061(b)(3) of the California Code of Regulations.

SECTION 11. Severability. If any section, subsection, subdivision, paragraph, sentence, clause or phrase of this Ordinance, or any part thereof is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance or any part thereof. The City Council hereby declares that it would have passed each section, subsection, subdivision, paragraph, sentence, clause or phrase thereof, irrespective of the fact that any one or more section, subsection, subdivision, paragraph, sentence, clause or phrase would be subsequently declared invalid or unconstitutional.

SECTION 12. Publication. The City Clerk shall cause this Ordinance to be published or posted in accordance with California Government Code Section 36933, shall certify to the adoption of this Ordinance and her certification, together with proof of the publication, to be entered in the book of Ordinances of the City Council.

SECTION 13. Effective Date. This Ordinance shall take effect thirty days after its adoption pursuant to California Government Code Section 36937.

PASSED, APPROVED AND ADOPTED this ___ day of ____________, 2025.

Robert Parkhurst, Mayor
ATTEST:

Laura Aguilar, City Clerk

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS:

CITY OF SIERRA MADRE )
I HEREBY CERTIFY that the foregoing Ordinance was introduced by second reading on the 9th day of December, 2025, and duly adopted by the City Council of the City of Sierra Madre, California, at a regular meeting held on the ___ day of ___________, 2025, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

Laura Aguilar, City Clerk
TO: Honorable Mayor and Members of the City Council
FROM: Katelyn Huang, Assistant Planner
Aleks Giragosian, City Attorney
REVIEWED BY: Michael Bruckner, City Manager
Clare Lin, Director of Planning & Community Preservation Joshua Wolf, Senior Planner
Julia Homaechevarria, Deputy City Attorney
DATE: October 28, 2025
SUBJECT: FIRST READING OF ORDINANCE NO. 1488 AMENDING
CHAPTER 17.72 (SIGNS) OF TITLE 17 (ZONING) OF THE SIERRA

MADRE MUNICIPAL CODE

RECOMMENDATION
It is recommended the City Council conduct its first reading of Ordinance No. 1488 amending Chapter 17.72 (Signs) of Title 17 (Zoning) of the Sierra Madre Municipal Code.

ALTERNATIVES
The City Council may:

1. Adopt Ordinance No. 1488 amending Chapter 17.72 (Signs) of Title 17 (Zoning) of the Sierra Madre Municipal Code; or

2. Adopt with modifications Ordinance No. 1488; or

3. Continue consideration of Ordinance No. 1488; or

4. Reject consideration of Ordinance No. 1488.

EXECUTIVE SUMMARY
Sierra Madre Municipal Code (“SMMC”) Chapter 17.72 regulates the placement and design of signs on public and private property within the City. Chapter 17.72 was adopted in 2003 (Ordinance No. 1205) and has not been updated since its adoption. It is recommended that the City Council conduct the first reading of Ordinance No. 1488, amending Chapter 17.72 (Signs) of Title 17 (Zoning) of the Sierra Madre Municipal Code.

City of Sierra Madre

AGENDA REPORT
Robert Parkhurst, Mayor
Kristine Lowe, Mayor Pro Tem
Edward Garcia, Council Member
Gene Goss, Council Member
Kelly Kriebs, Council Member
Sue Spears, City Treasurer

ATTACHMENT B

BACKGROUND
On December 10, 2024, Mayor Pro Tem Lowe requested to agendize a discussion of political and election related signs in the public parkway. On February 11, 2025, the City Council considered the regulation of signs under Chapter 17.72. During the discussion, there was some uncertainty regarding what constitutes the “public parkway”, as that term is not defined under Chapter 17.72. Additionally, the City Attorney raised a concern regarding the potential unconstitutionality of specifically limiting the installation of political and election related signs.

According to the February 11, 2025, meeting minutes, the City Council directed staff to clarify the following:
 Who maintains the parkways and why?
 The homeowner’s right to use the parkway.
 Signs in general.
 Are there state and county restrictions that apply to the City?  For election signs, are there time restrictions?”
At the September 9, 2025, City Council meeting, the City Council requested the Planning Commission recommend amendments to SMMC Chapter 17.72 (Signs) to address the issues relating to Regulation of Signs in Right-of-Ways and Regulation of Election and Political Signs.

Lastly, the City Council requested the Planning Commission consider whether to regulate the number of signs on private property and, if appropriate, how many.

On September 18, 2025, the Planning Commission held a public hearing on the draft ordinance with the proposed amendments:
 Definitions for “Parkway” and “Right-of-way”.
 Prohibition on signs located on public property or right-of-way unless specifically authorized and non-public-facing signs.
 Remove regulations for election and political signs that impose content-based restrictions.
 Temporary signs in Residential Zones.

The Planning Commission unanimously approved the Municipal Code Text Amendment (MCTA 25-03), pursuant to Planning Commission Resolution No. 25-13 (Attachment B) with changes regarding separation requirements for temporary signs and the definition for “Right-of-way”.

ANALYSIS
The proposed amendments to Sierra Madre Municipal Code Chapter 17.72 (Signs) are intended to update and refine the City’s sign regulations to ensure consistency with constitutional requirements and provide greater clarity regarding sign placement. The existing ordinance, adopted in 2003, has never been amended since its adoption. The proposed amendments address these deficiencies by providing clear definitions for “Parkway” and “Rightof-way”, eliminating content-based regulations on speech, and consolidating residential signage standards to improve clarity, consistency, and enforceability.

Issue 1: Regulation of Signs in Right-of-Ways
There are a number of sections in Chapter 17.72 limiting the placement of signs in the right-of- way; however, it is not clear what constitutes a parkway and who may install or remove signs within the parkway.

SMMC 17.72.020 imposes a blanket prohibition on signs in the right-of-way, stating, “The following signs are inconsistent with the purposes and standards of this chapter and are therefore prohibited: … Signs on public property or right-of-way unless otherwise authorized within this chapter, and as provided in Section 17.20.020(J)(6) [garage sale signs] … All off-site signs … .” SMMC 17.72.030(K)(4) & (L)(3) state “Signs shall not be nailed to trees, fences, public utility poles and shall not be located in the public right-of-way.” Neither “Parkway” nor “Right-of-way” are defined terms in Chapter 17.72. SMMC 10.04.130 (related to vehicles and traffic) defines “Parkway” to mean, “That portion of the street other than a traveled roadway.” SMMC 5.32.200 (related to cable television systems) defines “Public rightof-ways” to mean, “any of the following that are controlled, used or dedicated for use by the public and located within the city’s jurisdictional limits: streets, roadways, highways, avenues, lanes, alleys, sidewalks, rights-of-way and similar public property within which grantee may place its facilities for operating a cable system.” SMMC 12.16.010 defines “Streets” to mean, “Public streets and public parkways, including the public sidewalks.” The definitions are scattered throughout different parts of the Code and inconsistent.

Property owners are generally responsible for maintaining the public parkway owned by the City. SMMC 10.08.210 imposes an obligation on adjacent property owners to maintain their hedges, shrubbery, and trees in parkways. SMMC 16.32.150 mandates the subdivider of a parcel to plant trees in parkways. But it is not clear whether the maintenance obligations under the different code sections cited applies to signs not installed by the property owner.

Issue 2: Regulation of Election and Political Signs
SMMC 17.72.030(K) regulates election signs and SMMC 17.72.030(L) regulates political signs.

These regulations were adopted in 2003, but the case law has evolved, especially following the seminal U.S. Supreme Court case of Reed v. Town of Gilbert (2015) 576 U.S. 155.

Under the First Amendment, restrictions on speech that are content-based — meaning regulations of speech based on the subject matter or the message expressed — are presumptively unconstitutional and subject to strict scrutiny, justified only if they are narrowly tailored to serve a compelling state interest. (R.A.V. v. St. Paul (1992) 505 U.S. 377, 395; Simon & Schuster, Inc. v. Members of N.Y. State Crime Victims Bd. (1991) 502 U.S. 105, 115.) A municipal code that singles out “political signs” or “election signs” for regulation, are facially content-based because it imposes unique regulations based entirely on the communicative content of the sign. (Reed v. Town of Gilbert (2015) 576 U.S. 155.) Such laws must withstand strict scrutiny—a standard that is rarely satisfied. Municipalities may regulate signs based on content-neutral considerations, such as size, location, materials of signs or for safety, but carving out political or election signs for disparate treatment impermissibly privileges or disadvantages speech based on its communicative content.

Courts have routinely struck ordinances that single out election or political signs, finding they cannot be justified as a mere exercise of aesthetics or traffic safety. (Clark v. City of Williamsburg, Kansas (2019) 388 F.Supp.3d 1346 [holding that city ordinance was not narrowly tailored to interests of aesthetics or traffic safety].) Requirements that signs be summarily removed 10 days after an election have survived challenges (Baldwin v Redwood City (9th Cir 1976) 540 F2d 1360); however, courts have struck down limits on how far in advance an election sign may be posted, because such signage would be effectively banned other times of the year. (City of Antioch v. Candidates' Outdoor Graphic serv. (ND Cal 1982) 557 F. Supp 52, 60.) Further, removal deposits and permit systems have been deemed unnecessarily burdensome and arbitrary in light of the interests such regulations may properly serve. (Baldwin v Redwood City (9th Cir 1976) 540 F2d 1360, 1372.) Thus, the bond requirement imposed by SMMC 17.72.030 may also risk constitutional challenges.

Proposed Amendments:

Staff drafted Ordinance 1488 in response to the direction provided by the City Council and the Planning Commission:
 Adds definitions for “Parkway” and “Right-of way”;
 Deletes references to election signs and political signs;  Deletes SMMC 17.72.030(K)-(L) regarding regulations specific to election signs and political signs; and
 Amends SMMC 17.72.190 to incorporate regulations related to elections signs and political signs into the regulations for temporary signs.

In addition to the amendments directed by City Council, Planning staff took the opportunity to make the following amendments to the Code:
 Deleted SMMC 17.72.060 (Sign Regulations — R-E Overlay Zone) and incorporated those edits into SMMC 17.72.050 (Residential Zones — Special Conditions and Uses); and
 Amended various other sections to clarify the ordinance’s intent and to make nonsubstantive updates to zoning and section references.

SMMC Sections 17.72.040 through 17.72.060 provide regulation on signage within specific residential zones. The proposed amendments consolidate generalized regulations in residential zones (SMMC Section 17.72.040) and specific regulations in residential zones (SMMC Section

17.72.050) where existing regulation based on specific zones will be incorporated. Staff finds this change necessary to address the fact that the R-E Overlay Zone1is no longer a zone independent from other residential zones, but an overlay that applies alternative provisions to multiple types of residential zones based on its area designated in the zoning map.

STRATEGIC PLAN CORRELATION
Goal 3 – Infrastructure & Growth Management
Objective 3.2: Design Standards & Housing Readiness
 Initiative 3.2.2: Objective Design Standards and Soft-Story Retrofit Program (State Senate Bill SB 330 compliance)
 Project 3.2.2A: Establish Objective Design Standards (SB 330)

1 The R-E (Residential Entrepreneur) Overlay Zone applies to a specifically designated geographic area on the zoning map where underlying zoning include single- and multi-family zoning. Prior to July 21, 2021, this overlay zone was its own zoning designation independent from other residential zones called the R-P (Residential Professional) Zone. A Cleanup Ordinance in 2023 changed all references from “R-P Zone” to “R-E Overlay Zone”.

Goal 4 – Organizational Excellence
Objective 4.3: Public Transparency & Communication
 Initiative 4.3.1: Produce financial transparency reports, open-budget, and resident engagement
Correlation Summary: Ordinance No. 1488 directly supports the City’s Strategic Plan by enhancing organizational sustainability through long-range policy modernization and consistent code implementation. The update to Chapter 17.72 (Signs aligns zoning and design regulations with current legal standards and objective planning practices (Goal 3), and improves public transparency and understanding of municipal regulations (Goal 4). Collectively, these amendments advance the City’s commitment to fiscal responsibility, regulatory clarity, and open governance.

ENVIRONMENTAL IMPACT (CEQA)
The amendments made by Ordinance No. 1488 to Chapter 17.72 (Signs) of Title 17 (Zoning) is not a project as defined by the California Environmental Quality Act (CEQA) under Title 14, Section 15378 of the California Code of Regulations and has no potential to result in direct or indirect physical change to the environment. Therefore, this ordinance is exempt from CEQA review, pursuant to Title 14, Section 15061(b)(3) of the California Code of Regulations.

FISCAL IMPACT
The fiscal impacts associated with this ordinance are limited to staff time expended in preparing the report and draft amendment, as well as the required noticing costs. One public hearing notice was published in the Mountain Views News in compliance with Government Code Sections 65854 and 65090. An additional notice will also be required to inform the public of the ordinance’s effective date.

PUBLIC NOTICE
This item has been noticed through the regular agenda notification process. Copies of this report can be accessed on the City’s website at SierraMadreCA.gov.

Government Code section 65090 requires that notice of a first reading of an ordinance be circulated in at least one newspaper of general circulation at least ten (10) days prior to the hearing. Notice of the public hearing introducing the ordinance was circulated in the October 18, 2025, edition of the Mountain Views News. Upon the passage of Ordinance No. 1488, a summary notice shall be published consistent with Government Code Section 36933(c)(1).

ATTACHMENTS
Attachment A: Ordinance No. 1488
Attachment B: Planning Commission Resolution 25-13
Attachment C: Chapter 17.72 (Signs) – redline
Attachment D: Chapter 17.72 (Signs) – clean

CITY OF

SIERRA MADRE STAFF REPORT

POLICE DEPARTMENT
DATE: December 9, 2025
TO: Honorable Mayor and City Council
FROM: Gustavo Barrientos, Chief of Police
By: Veronica Saucedo, Acting Captain
SUBJECT: Resolution No. 25-63 Accepting the FY 2024 State Homeland Security Program (SHSP) Grant in the Amount of $50,000 and Approving a Fiscal Year 2025/26 Supplemental Budget Appropriation in the Amount of $140,577 for FY 2022, FY 2023, and FY 2024 SHSP Grant Proceeds

RECOMMENDATION
It is recommended that the City Council:

1. Accept the 2024 SHSP grant and authorize and direct the City Manager, or their designee, to execute the grant agreement between the County of Los Angeles and the City of Sierra Madre Police Department for a State Homeland Security Program (SHSP) Grant Year 2024 in an amount not to exceed $50,000, and

2. Approve a supplemental budget appropriation of $140,577, representing previously accepted SHSP grants for grant years 2022, 2023, and the current 2024 for expenditures that will occur in Fiscal Year 2025/26.

SUMMARY
Annually, the U.S. Department of Homeland Security (DHS) allocates funding to local jurisdictions through the Homeland Security Grant Program (HSGP), which includes the State Homeland Security Program (SHSP), Urban Area Security Initiative (UASI), and Operation Stonegarden (OPSG). These programs support state and local efforts to prevent, prepare for, and respond to terrorism and other emergencies.

The Sierra Madre Police Department is eligible to receive funding through the SHSP and UASI components. For FY 2024, the Department submitted a grant request for the acquisition of police equipment to enhance emergency response capabilities, operational safety, and readiness during critical incidents. DHS, through Los Angeles County as the grant administrator, has approved the City’s request and allocated up to $50,000 in SHSP funding for this purpose.

Resolution No. 25-63 Accepting SHSP Grant Funds and Supplemental Budget Appropriation December 9, 2025

Page 2 of 3 ends

This report provides an overview of the grant award, outlines the required grant agreement with Los Angeles County, and requests appropriation of State Homeland Security Grant Program funds from FY 2022, FY 2023, and FY 2024 totaling $140,577.

DISCUSSION & ANALYSIS
The Sierra Madre Police Department has been awarded up to $50,000 in FY 2024 State Homeland Security Program (SHSP) funding for police equipment that supports critical incident response and operational safety. Los Angeles County, which administers HSGP funds regionally, has provided the City with a grant agreement requiring execution by the City Manager or designee.

In addition to the FY 2024 allocation, the City has two prior SHSP awards—$45,577 from FY 2022 and $45,000 from FY 2023—that were delayed due to statewide administrative backlogs stemming from the COVID-19 pandemic. These delays have resulted in all three grant years (2022, 2023, and 2024) sharing a consolidated performance period that expires on May 31, 2026.

To ensure the City may proceed with procurement and reimbursement across all eligible years, staff recommends appropriating the full amount of available grant funding.

The total amount available for reimbursement is $140,577 across the three grant years. Upon City Council authorization and execution of the County agreement, the Police Department will coordinate procurement of approved equipment in accordance with grant guidelines and reimbursement procedures.

STRATEGIC PLAN RELATIONSHIP
This item aligns with the City’s Strategic Goal of Public Safety, supporting a safe and vibrant community by enhancing enforcement and prevention efforts related to response to calls for service by fulfilling equipment recommendations, Strategy PS 2.3.

FISCAL IMPACT
There is no net General Fund impact, as all eligible expenses will be fully reimbursed. The SHSP grant operates on a reimbursement basis, requiring the City to initially front the cost of approved equipment purchases. Eligible expenditures—up to the total allocation of $140,577 across FY 2022, FY 2023, and FY 2024—will be reimbursed by Los Angeles County upon submission of required documentation, including invoices, proof of payment, and other grant-compliant records. Adoption of the proposed Resolution appropriates SHSP funding for all three grant years, Resolution No. 25-63 Accepting SHSP Grant Funds and Supplemental Budget Appropriation December 9, 2025

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enabling expenditures within the performance period of September 1, 2023, through May 31, 2026.

Approved by:
___________________________
Michael Bruckner
City Manager
Attachment(s):

1. State Homeland Security Grant (SHSP) 2024 Sub recipient Agreement

2. FY 2024 Homeland Security Grant Fact Sheet

3. Resolution No. 25-63
State Homeland Security Program
Subrecipient Agreement
Grant Year 2024
Between the
County of Los Angeles
and the
City of Sierra Madre

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SUBRECIPIENT AGREEMENT

BETWEEN THE

COUNTY OF LOS ANGELES
AND

THE CITY OF SIERRA MADRE
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 Sierra Madre, 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 $50,000, 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 Sierra Madre, 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]

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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 Veronica Saucedo, Acting Captain
V7AAUMZC1W97
242 W. SIERRA MADRE BLVD
SIERRA MADRE, CA 91024
626-355-1414
[email protected]
Michael Bruckner, City Manager/ Acting
Finance Director
City of Sierra Madre
342 W. Sierra Madre Blvd.

Sierra Madre, CA 91024
626-355-7135
[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

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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 8 ends

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 $50,000 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

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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,

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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

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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

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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

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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,

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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 SIERRA MADRE
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

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

EXHIBIT A
C
CalOES

GOVERNOR'S OFFICE

OF EMERGENCY SERVICES
Certification Regarding Lobbying
The Subrecipient, as identified below, certifies or affirms the truthfulness and accuracy of each statement of its certification and disclosure, if any. In addition, the Subrecipient understands and agrees that the provisions of 31 U.S.C. Chap. 38, Administrative Remedies for False Claims and Statements, apply to this certification and disclosure, if any.

Subrecipient: SIERRA MADRE POLICE DEPARTMENT/ CITY OF SIERRA MADRE _______________________ _
Signature of Authorized Agent: __________________ _
Printed Name of Authorized Agent: _MICHAEL BRUCKNER
_______________ _
Title: _City Manager_________ Date: __________ _

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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
Sierra Madre
Michael Bruckner City Manager
2024-0088

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

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)]
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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EXHIBIT D
FY 2024 Standard Assurances For Cal OES Federal
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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EXHIBIT D

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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FY 2024 Standard Assurances For Cal OES Federal
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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(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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FY 2024 Standard Assurances For Cal OES Federal
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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FY 2024 Standard Assurances For Cal OES Federal
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
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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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FY 2024 Standard Assurances For Cal OES Federal
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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FY 2024 Standard Assurances For Cal OES Federal
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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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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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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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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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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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
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
City of Sierra Madre 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.06 Goal #4 Subaward 051 LE All Spectrum Radios 3 HSGP-SHSP LE Equipment Operational Communications Build Deployable FY22; IJ #6 $ 50,000
Total $ 50,000

PROJECT LEDGER

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EXHIBIT E
City of Sierra Madre 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
$ 50,000.00
51 Purchase (6) P25 Compliant all-spectrum
(UHF/VHF/800/700 MHz) portable radios, (6)
programming cables, and (1) multi-radio
battery bank chargers
06CP-01-PORT;
10PE-01-PCHG;
06CP-03-PRAC
Radio, Portable; Chargers, Phone
and Radio; Accessories, Portable
Radio

SHSP LE
06 - Interoperable
Communications
Equipment
Deployable No N/A $ 50,000

EQUIPMENT

EXHIBIT E
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

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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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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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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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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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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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• 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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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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12 FY 2024 HSGP NOFO
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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15 FY 2024 HSGP NOFO
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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18 FY 2024 HSGP NOFO
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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20 FY 2024 HSGP NOFO
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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22 FY 2024 HSGP NOFO
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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24 FY 2024 HSGP NOFO

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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27 FY 2024 HSGP NOFO

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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43 FY 2024 HSGP NOFO
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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44 FY 2024 HSGP NOFO
Allowable Program Activities SHSP UASI OPSG
LETPA Costs
Integration and interoperability of systems and data, such as CAD and RMS, to facilitate the collection, Y Y N
Maturation, enhancement, and sustainment of designated state and major Urban Area fusion centers, including information sharing and analysis, threat recognition, terrorist interdiction, and intelligence analyst training and salaries (subject to certain conditions) Y Y N
Regional counterterrorism training programs for small, medium, and large jurisdictions to exchange information and discuss the current threat environment, lessons learned, and best practices to help prevent, protect against, and mitigate acts of terrorism Y Y N
Coordination of regional full-scale training exercises (federal, state, and local law enforcement participation) focused on terrorism-related events Y Y N Law enforcement Chemical, Biological, Radiological, Nuclear, and high yield Explosives detection and response capabilities, such as bomb detection/disposal capability development, sustainment, or enhancement, including canine teams, robotics platforms, and x-ray technology
Y Y N
Coordination between fusion centers and other operational analytic, and investigative efforts Y Y N
Implementation, maintenance, and sustainment of the Nationwide Suspicious Activity Reporting Initiative Y Y N
Implementation of the "If You See Something, Say Something®" campaign Y Y N Increase physical security, through law enforcement personnel and other protective measures, by implementing preventive and protective measures at critical infrastructure locations
Y Y N
h. SHSP and UASI Other Direct Costs
Recipients must comply with all the requirements in 2 C.F.R. Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards). In general, recipients should consult with their FEMA HQ Preparedness Officer prior to making any investment that does not clearly meet the allowable expense criteria. Funding guidelines established within this section support four of the five mission areas—Prevention, Protection, Mitigation, and Response—and associated core capabilities within the Goal. While Recovery is part of the Goal, it is not explicitly part of the HSGP. Allowable investments made in support of the national priorities, as well as other capability-enhancing projects must have a nexus to terrorism preparedness and fall into the categories of planning, organization, exercises, training, or equipment, aligned to building capability, closing capability gaps, and/or sustaining capabilities, as defined by CPG 201: THIRA/SPR Guide—3rd Edition (Comprehensive Preparedness Guide (CPG) 201, 3rd Edition (fema.gov)).

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

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

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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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46 FY 2024 HSGP NOFO
o Complete training to ensure baseline proficiency in intelligence analysis and production within six months of being hired; and/or,
o Previously served as an intelligence analyst for a minimum of two years either in a federal intelligence agency, the military, or state and/or local law enforcement intelligence unit. x. All fusion center analytical personnel must demonstrate qualifications that meet or exceed competencies identified in the Common Competencies for state, local, and tribal intelligence analysts, which outlines the minimum categories of training needed for intelligence analysts. A certificate of completion of such training must be on file with the State Administrative Agency (SAA) and must be made available to the recipient’s respective FEMA HQ Preparedness Officer upon request; and
xi. Migrating online services to the “.gov” internet domain.

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

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

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

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

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

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

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

In addition to the information regarding DHS Standard Terms and Conditions and Ensuring the Protection of Civil Rights, see the Preparedness Grants Manual for additional information on administrative and national policy requirements, including the following:
• 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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72 FY 2024 HSGP NOFO
provisions is available at https://www.fema.gov/about/offices/equal-rights/civilrights.

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

In accordance with civil rights laws and regulations, recipients and subrecipients must ensure the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment.
c. Environmental Planning and Historic Preservation (EHP) Compliance See the Preparedness Grants Manual for information on EHP compliance. d. National Incident Management System (NIMS) Implementation In expending funds under this program, recipients that are state, local, tribal, or territorial governments must ensure and maintain adoption and implementation of NIMS, including implementation of important operational systems defined under NIMS, such as ICS. The state, local, tribal, or territorial government must show adoption of NIMS during any point of the period of performance. See the Preparedness Grants Manual for information about NIMS implementation. e. Emergency Communication Investments
If an entity uses HSGP funding to support emergency communications investments, the following requirements shall apply to all such grant-funded communications investments in support of the emergency communications priorities and recognized best practices:
• 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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73 FY 2024 HSGP NOFO
CISA and will be verified by FEMA GPD through programmatic monitoring activities.

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

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

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

See the Preparedness Grants Manual for information on reporting requirements.

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74 FY 2024 HSGP NOFO

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

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

G. DHS Awarding Agency Contact Information

1. Contact and Resource Information
a. Program Office Contact
FEMA has assigned state-specific Preparedness Officers for the HSGP. If you do not know your Preparedness Officer, please contact FEMA Grants News by phone at (800) 368-6498 or by email at [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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75 FY 2024 HSGP NOFO
FEMA Regional Office contact information is available at:
https://www.fema.gov/fema-regional-contacts.
e. Equal Rights
The FEMA Office of Equal Rights (OER) is responsible for compliance with and enforcement of federal civil rights obligations in connection with programs and services conducted by FEMA and recipients of FEMA financial assistance. All inquiries and communications about federal civil rights compliance for FEMA grants under this NOFO should be sent to [email protected]. f. Environmental Planning and Historic Preservation
GPD’s EHP Team provides guidance and information about the EHP review process to recipients and subrecipients. All inquiries and communications about GPD projects under this NOFO or the EHP review process, including the submittal of EHP review materials, should be sent to [email protected].

2. Systems Information
a. FEMA GO
For technical assistance with the FEMA GO system, please contact the FEMA GO Helpdesk at [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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76 FY 2024 HSGP NOFO
• 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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77 FY 2024 HSGP NOFO

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

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

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

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

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

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

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

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

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

A waiver of the domestic content procurement preference may be granted by the agency awarding official if FEMA determines that:
• 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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79 FY 2024 HSGP NOFO

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

5. National Threat Evaluation and Reporting (NTER) Program Office As the threat landscape continues to evolve, the DHS Office of Intelligence and Analysis (I&A) National Threat Evaluation and Reporting (NTER) Program Office empowers homeland security partners to adapt to new threats and prevent terrorism and targeted violence. NTER equips homeland security partners with tools and resources to identify, report, and mitigate threats of terrorism and targeted violence to keep the Homeland safe primarily through two lines of effort: the Nationwide Suspicious Activity Reporting (SAR) Initiative (NSI) and Behavioral Threat Assessment Integration. a. Behavioral Threat Assessment Integration
NTER assists federal, state, local, tribal, and territorial (F/SLTT) partners with integrating a behavioral approach to violence prevention into their processes for identifying and mitigating homeland security threats of targeted violence, regardless of motive. Through training, partner capacity building, and information sharing, NTER supports the identification and mitigation of threats. The Office fills a national gap by providing a framework for Behavioral Threat Assessment and Management (BTAM) as a best practice for targeted violence prevention. • 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.

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

EXHIBIT F
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

EXHIBIT F
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

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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).

EXHIBIT F
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.

EXHIBIT F
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

EXHIBIT F
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.

EXHIBIT F
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:

EXHIBIT F
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

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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).

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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.

EXHIBIT F
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

EXHIBIT F
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.

EXHIBIT F
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

EXHIBIT F
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

EXHIBIT F
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).

EXHIBIT F
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
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
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
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
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).

EXHIBIT F
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
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
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
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
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

LOS ANGELES COUNTY/DEPARTMENT OF AUDITOR-CONTROLLER EXHIBIT G

SHARED SERVICES DIVISION

GRANT PAYMENT REQUEST
SECTION A: SUBMITTING YOUR REQUEST
Please submit Grant Payment Request Form along with legible supporting documents to: 1. Grant Name & Year:

[email protected] I I In the event e-mail is not available, you can mail your Grant payment request to (please do not fax or send duplicates):

Department of Auditor-Controller
Shared Services Division/ Attn: Grants Unit I I 320 W. Temple Street, Room 380 Los Angeles, CA 90012
SECTION B: SUB-RECIPIENT'S INFORMATION

1. Sub-recipient's Name: (reimbursement check will be made payable to a payee entered 1

3. Taxpayer ID#: 4. Contact's Name:

2. Mailing Address (please let us know where you want your check delivered, induding attention line if necessary): 4. Contact's phone:

4. Contact's e-mail:

SECTION C: DETAIL PAYMENT REQUEST INFORMATION

4. EHP required? 6. PURCHASE METHOD

1. SOLUTION AREA 2. PROJECT# (Environmental & Historic 5. VENDOR'S INVOICE # (including Training) 7.CLAIM (e.g. equipment, training, (e.g. 011.22) Preservation) (Maximum of 5 invoices) AMOUNT planning, exercise, organization) (indicate the
If Competitive, amount per each
No Yes indicate the# of Non-Competitive Sole Source line) (attach State bids. Bid
Approval)

8. TOTAL $
SECTION D: SUB-RECIPIENT'S CERTIFICATION
I certify that (please use the checkbox):

D 1. I am the duly authorized officer of the daimant herein and this daim is in all respect true and correct. All expenditures were made in accordance with applicable laws, rules, regulations and grant conditions and assurances.

STAMP WITH RECEIVED DATE HERE:
□ 2. All instructions for this form were followed and all the supporting documentation (per instructions) is induded with this daim.

3. ------------------ AUTHORIZED SIGNATURE DATE

4. -------------- AUTHORIZED PRINTED NAME AUTHORIZED TITLE

5. AUTHORIZED CONTACT INFORMATION (If different from Section B):

PHONE# -----------
E-MAIL:

NOTE: This Form is intended or Internal SSD review purpose only.

Revised on April 2021
ASSIGNED INVOICE NO.:
0 F. ORGANIZATION (Continued)
Verification

SAMPLE COPY

6. For Projects with backfill expenditures for Organization:
b. Does the Subrecipient have documentation that the
backfill expenditures were approved by the State?
c. Did the Subrecipient appropriately document the
backfill expenditures using employee timecards and
other payroll documentation?

7. Were employee timecards utilized in Organization activities signed and dated by the employee and direct supervisor?

8. Were the Organization expenditures consistent with the State approved grant award and/or post award modification(s)?

9. Ensure that the Subrecipient corrected areas of noncompliance that remain outstanding and were reported as findings in prior Grant Year monitoring reports maintained by HSGA:
a. If the Project prior Grant Year monitoring report finding was resolved, explain resolution and indicate such in the current report as resolved.
b. If the Project prior Grant Year monitoring report finding is not resolved, indicate why it has not been resolved and what the Subrecipient is doing to resolve the prior year finding and indicate such in the current report.

Page 11 of 11 ends

Sierra Madre City CouncilDecember 9, 2025

Sierra Madre City Council
December 9, 2025