FY23 SHSGP VFD Notification of Sub Recipient Award, Award Binder and Assurances — Visalia City Council, March 18, 2024 (part 2 of 2)

The NIEM Emergency Management domain supports emergency-related services (including preparing first responders and responding to disasters), information sharing, and activities such as homeland security and resource and communications management. The NIEM Emergency Management domain has an inclusive governance structure that includes federal, state, local, industry, and, where necessary, international partnerships. The NIEM Emergency Management domain is committed to community support via technical assistance and NIEM training. For more information on the NIEM Emergency Management domain, to request training or technical assistance or to just get involved, go to https://niem.gov/EM.

Infrastructure Resilience Planning Framework (IRPF)
State, local, tribal, and territorial (SLTT) governments are faced with complex long-term decisions, limited sources of revenue, and changing populations. CISA developed the IRPF as a resource for SLTT planners. The IRPF provides a process and a series of tools and resources for incorporating critical infrastructure resilience considerations into planning activities. The IRPF can be used to support capital improvement plans, hazard mitigation plans, or other planning documents, as well as funding requests.

For more information, see Infrastructure Resilience Planning Framework (IRPF) (cisa.gov).

Integrated Public Alert and Warning System (IPAWS)
The current IPAWS Supplemental Guidance on Public Alert and Warning provides guidance on eligible public alert and warning activities and equipment standards for prospective SLTT recipients. The intent of this document is to promote consistency in policy across federal grant programs and to ensure compatibility among federally funded projects. For more information on the IPAWS, go to https://www.fema.gov/informational-materials.

Homeland Security Information Network (HSIN)
HSIN is a user-driven, web-based, information sharing platform that connects all homeland security professionals including the DHS and its federal, state, local, tribal, territorial, international, and private sector partners across all homeland security mission areas. HSIN is used to support daily operations, events, exercises, natural disasters, and incidents. To support user mission needs, HSIN provides three sets of services for secure information sharing. The first service provides a shared place for communities to securely collaborate on homeland security issues and includes core functions such as a web conferencing and instant messaging tools with white boarding, video, and chat services for real-time communication and situational awareness. The second set provides secure dissemination and sharing capabilities for homeland security alerts, reports, and products. The third set allows users to access and query a variety of shared data and services from all homeland security mission areas and trusted federal partners. Preparedness grant funds may be used to support planning, training and development costs associated with developing and managing, mission critical, HSIN communities of interest and sites. Learn more about HSIN at HSIN HSGP Guidance | Homeland Security (dhs.gov).

SLTT Cybersecurity Engagement Program
CISA is responsible for enhancing the security, resilience, and reliability of the Nation’s cyber and communications infrastructure. CISA works to prevent or minimize disruptions to critical information infrastructure to protect the public, the economy, and government services. CISA leads efforts to protect the Federal “.gov” domain of civilian government networks and to collaborate with the private sector— the “.com” domain—to increase the security of critical networks.

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The DHS SLTT Cybersecurity Engagement Program within CISA was established to help non-federal public stakeholders and associations manage cyber risk. The program provides appointed and elected SLTT government officials with cybersecurity risk briefings, information on available resources, and partnership opportunities to help protect their citizens online. Through these and related activities, the program coordinates DHS’s cybersecurity efforts with its SLTT partners to enhance and protect their cyber interests. More information on all of the CISA resources available to support SLTT governments is available at Resources | CISA.

Framework for Improving Critical Infrastructure Cybersecurity When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the “Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework gathers existing international standards and practices to help organizations understand, communicate, and manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity program, the Framework provides initial guidance. For organizations with more advanced practices, the Framework offers a way to improve their programs, such as better communication with their leadership and suppliers about management of cyber risks.

CISA’s Critical Infrastructure Cyber Community C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in adoption of the Framework and managing cyber risks.

Additional information on the Critical Infrastructure Cyber Community C³ Voluntary Program can be found at Critical Infrastructure Cyber Community C³ Voluntary Program | CISA.

DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in protecting U.S.-based public and private entities and combines key elements of capabilities under the “Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based companies and SLTT governments defend their computer systems against unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services. Please visit Enhanced Cybersecurity Services (ECS) | CISA for a current list of ECS CSP points of contact.

Regional Resiliency Assessment Program (RRAP)
The RRAP is a cooperative assessment of specific critical infrastructure within a designated geographic area and a regional analysis of the surrounding infrastructure that address a range of infrastructure resilience issues that could have regionally and nationally significant consequences. These voluntary, non-regulatory RRAP projects are led by the Infrastructure Security Division and are selected each year by DHS with input and guidance from federal, state, and local partners. For additional information on the RRAP, visit Regional Resiliency Assessment Program | CISA.

Law Enforcement Support Office (LESO), or 1033 Program
The LESO facilitates a law enforcement support program, which originated from the National Defense Authorization Act of Fiscal Year 1997. This law allows the transfer of excess Department of Defense property that might otherwise be destroyed by law enforcement agencies across the United States and its territories.

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No equipment is purchased for distribution. All items were excess that had been turned in by military units or had been held as part of reserve stocks until no longer needed. Requisitions cover the gamut of items used by America’s military ― clothing and office supplies, tools, and rescue equipment, vehicles, small arms, and more. There is no fee for the equipment itself, however, the law enforcement agencies are responsible for the shipping costs.

For additional information on the LESO, please visit:
http://www.dla.mil/DispositionServices/Offers/Reutilization/LawEnforcement.aspx.

Supplemental Emergency Communications Guidance
Lessons learned from recent major disasters, unplanned events, and full-scale exercises have identified a need for greater coordination of emergency communications among senior elected officials, emergency management agencies, and first responders at all levels of government. Federal responders arriving on the scene of a domestic incident are not always able to communicate with SLTT response agencies, as well as key government officials. State and local first responders sometimes experience similar problems, particularly when the incident requires a multi-agency, regional response effort or when primary communications capabilities fail. This lack of operability and interoperability between federal and SLTT agencies―further complicated by problems with communications survivability and resilience―has hindered the ability to share critical information, which can compromise the unity-of-effort required for an effective incident response.

Departments and agencies at all levels of government have identified a need for improvement in a number of high-priority areas, including Governance, Planning, Training and Exercises, Operational Coordination, and Technology. In addition, communications resilience and continuity should be viewed as a critical component within each of these areas. These priorities are explained in detail in Section 2 of the SAFECOM Guidance. By addressing these priorities, which are reflective of proven best practices, emergency communications can be significantly improved at all levels of government. The end goal is to ensure operable, interoperable, and resilient communications that maintain a continuous flow of critical information, under all conditions, among multi-jurisdictional and multi-disciplinary emergency responders, command posts, agencies, critical infrastructure sectors, and government officials for the duration of an emergency response operation, and in accordance with NIMS and the National Emergency Communications Plan, which describes goals and objectives for improving emergency communications nationwide.

To help meet this goal, the SAFECOM Guidance outlines requirements for grant applications, including alignment to national, regional, and state communications plans (e.g., NECP, Statewide Communication Interoperability Plan (SCIP), Tactical Interoperability Communications Plan (TICP), FEMA Regional Emergency Communications Plan (RECP)), project coordination, and technical standards for emergency communications technologies. SCIPs define the current and future direction for interoperable and emergency communications within a state or territory, while TICPs are designed to allow urban areas, counties, regions, states/territories, tribes, or federal departments/agencies to document interoperable communications governance structures, technology assets, and usage policies and procedures. In addition, FEMA’s formal planning process has produced 10 RECPs and their associated state and/or tribal/territorial annexes that identify emergency communications capability shortfalls and potential resource requirements. Grant recipients are encouraged to leverage these planning resources as a source of input and reference for all emergency communications grant applications and investment justifications.

In addition, FEMA formally recognizes several statewide emergency communications governance bodies (e.g., SWIC, SIGB, Statewide Interoperability Executive Committee (SIEC), FirstNet State Single Point of Contact (SPOC)), and strongly encourages grant recipients to closely coordinate with these entities HSGP Appendix | 2023 Page A-48
when developing an emergency communications investment to ensure projects support the state or territory’s strategy to improve their communications capabilities with the goal of achieving fully operable, interoperable, and resilient communications. In addition, grant applicants should work with public and private entities, and across jurisdictions and disciplines, to demonstrate engagement with the Whole Community in accordance with Presidential Policy Directive-8 (PPD-8).

For regional, cross-border initiatives, FEMA requires applicants to coordinate projects with national level emergency communications coordination bodies, such as the National Council of Statewide Interoperability Coordinators (NCSWIC) and the Regional Emergency Communications Coordination Working Groups (RECCWGs). The NCSWIC promotes and coordinates state-level activities designed to ensure the highest level of public safety communications across the nation. RECCWGs are congressionally mandated planning and coordination bodies located in each FEMA Region and provide a collaborative forum to assess and address the survivability, sustainability, operability, and interoperability of emergency communications systems at all levels of government. Grant-funded investments that are coordinated with these bodies will help ensure that federally funded emergency communications investments are interoperable and support national policies.

Resilient Communications Guidance
Nothing better demonstrates a modern nation than its ability to effectively communicate. The risk imposed by the reliance on communication systems by government and the private sector can be reduced by understanding dependencies, analyzing effects, and taking action. Entities planning to use HSGP funding for communications investments are encouraged to work with state emergency management agencies, SWICs, SIGBs, and appropriate stakeholders at the regional, state, local, territorial, and tribal levels to:
• Establish robust, resilient, reliable, and interoperable communications capabilities. Account for the mission impact of communication system disruptions in your planning; • Ensure mission-related communications (voice, video, data, and network security requirements) are adequately planned for and understood. It is important to maintain current documentation of your communication systems architecture and perform regular audits. Your ability to continue operations is dependent on the availability of and access to communications systems with sufficient resiliency, redundancy, and accessibility to perform essential functions and provide critical services during a disruption;
• Ensure critical communication systems connectivity among key government leadership, internal elements, other supporting organizations, and the public under all conditions. As such, organizations should ensure current copies of vital records, including electronic files and software, are backed-up and maintained off-site;
• Ensure all communications systems/networks are traced from end to end to identify all Single Points of Failure (SPF). In doing so, grantees should work with communication service providers to add redundancy at key critical infrastructure facilities as needed; • Ensure key communication systems resiliency through:
o Ensuring availability of backup systems;
o Ensuring diversity of network element components and routing; o Ensuring geographic separation of primary and alternate transmission media; o Ensuring availability of back-up power sources;
o Ensuring availability and access to systems that are not dependent on commercial infrastructure;
o Maintain spares for designated critical communication systems; and o Work with commercial suppliers to remediate communication Single Points of Failure. • All communications system owners are encouraged to address the following issues:

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o Integrate communications needs into continuity planning efforts by incorporating mitigation options to ensure uninterrupted communications support; o Establish a cybersecurity plan that includes continuity of a communications component such as Radio Frequency (RF)-based communications that do not rely on public infrastructure;
o Maintain communications capabilities to ensure their readiness when needed; o Frequently train and exercise personnel required to operate communications capabilities o Test and exercise communications capabilities; and
o Consider Electromagnetic Pulse (EMP) protective measures for communications systems where practical.

DHS/FEMA Communications Support Services
CISA and FEMA offer a variety of technical assistance and other support services to assist state and local entities in their efforts to comply with the above requirements, including the SAFECOM Guidance, with the goal of ensuring interoperable and resilient emergency communications. A summary of DHS/FEMA support services is provided below. Grant recipients are encouraged to refer to the respective websites for additional information.

CISA Support:

CISA assists agencies through a myriad of services, including direct TA and training provided at no cost to the jurisdiction. The TA offerings include (but are not limited to):
• Coordinated statewide governance (e.g., State Mapping Tool, Interoperable Communications Reference Guides);
• Comprehensive emergency communications planning (e.g., SCIPs, TICPs, and Field Operations Guides);
• Next Generation 911 planning and implementation;
• Data operability and interoperability;
• Alerts and warnings;
• Broadband deployment;
• Cybersecurity education and awareness; and
• Communications Unit (COMU) planning and procedures.

Information on these services is available at https://www.cisa.gov/safecom/ictapscip-resources and https://www.cisa.gov/interoperable-communications-technical-assistance-program.

FEMA Disaster Emergency Communications Division (DEC) Support:

The DEC, within FEMA Headquarters’ Response Directorate, has developed State Communications Annexes for all 56 states and territories. DEC provides technical assistance, coordinated through the FEMA Region’s Regional Emergency Communications Coordinator (RECC) in scheduling with the states and territories for major updates to the Annexes. Major updates are scheduled on a 3 to 5-year cycle. FEMA DEC supports the major update with a team of communications and emergency management specialists that facilitate a process of interaction with state representatives. This process is coordinated through the SWIC or state designated representative. All documentation is the responsibility of the FEMA support team and validated through state interaction.

Minor yearly updates to the State Annexes are accomplished through the RECCWG process. FEMA DEC support staff, working in coordination with the region-specific RECC, incorporate pertinent update information provided by state and local representatives. Additionally, operational information identified through exercises and incident response activities is a source of update data. The FEMA RECC, with the HSGP Appendix | 2023 Page A-50
support of the DEC team, is responsible for maintaining the State Annexes ― changes and modifications to the Annexes are validated with the state through RECC coordination with the SWIC or designated state representative.

FEMA National Preparedness Directorate (NPD) Support:

NPD provides training, exercises, and technical assistance to SLTT stakeholders that support operational and emergency communications. Descriptions and resources specific to operational communication are available on FEMA’s website (https://www.fema.gov/core-capability-development-sheets) within the Response Mission Area and include the following information to support jurisdictions:
• Description of the operational communications core capability; • Training for building and sustaining operational communication with specific course titles:
o Trainings can also be found at https://www.firstrespondertraining.gov/. • Example capability targets to complete a THIRA:
o Help in developing targets can be found at www.preptoolkit.fema.gov/urt or requested at [email protected].
• Resource types that support operational communications:
o Additional resource types and position qualifications can be found at https://www.fema.gov/preparedness-checklists-toolkits.
• Tools to validate capabilities through exercises:
o Technical assistance and support from subject matter experts can be requested through www.fema.gov/national-exercise-program.

FEMA Office of National Continuity Programs (ONCP) Support:

NCP’s support services focus on holistic continuity planning, of which communications continuity is an important component. Currently, continuity communications training and technical assistance is limited to the FEMA National Radio System (FNARS) and IPAWS and is delivered either on an ad hoc basis at the request of the state entity, through a FEMA Region, or via a requirement for terms of use. Entities interested in ONCP support services should contact [email protected] or consult ONCP’s Continuity Resources Toolkit webpage at https://www.fema.gov/emergency-managers/national- preparedness/continuity/toolkit.

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Program Appendix B:

Tribal Homeland Security Grant Program (THSGP)
As a reminder, while this appendix contains THSGP-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the THSGP. Please be sure to read the main content of this Manual in addition to the program-specific appendices.

Alignment of THSGP to the National Preparedness System
The THSGP plays an important role in the implementation of the National Preparedness Goal by supporting the building, sustainment, and delivery of the core capabilities. The core capabilities are essential for the execution of critical tasks for each of the five mission areas outlined in the Goal.

Delivering core capabilities requires the combined effort of the whole community, rather than the exclusive effort of any single organization or level of government. THSGP allowable costs support efforts to build and sustain core capabilities across the prevention, protection, mitigation, and response mission areas described in the Goal.

Particular emphasis in THSGP will be placed on capabilities that address the greatest risks to the security and resilience of tribal communities and the United States and that provide a clear nexus to preventing acts of terrorism. Funding will support deployable assets that can be utilized through automatic assistance and mutual aid agreements. THSGP supports investments that improve the ability of jurisdictions nationwide to:
• Prevent a threatened or an actual act of terrorism;
• Protect our citizens, residents, visitors, and assets against the greatest threats and hazards; • Mitigate the loss of life and property by lessening the impact of future disasters; • Respond quickly to save lives, protect property and the environment, and meet basic human needs in the aftermath of a catastrophic incident; and/or
To support building, sustaining, and delivering these core capabilities, recipients will use the components of the National Preparedness System, which include Identifying and Assessing Risk, Estimating Capability Requirements, Building and Sustaining Capabilities, Planning to Deliver Capabilities, Validating Capabilities, and Reviewing and Updating. Additional information on the National Preparedness System is available at: http://www.fema.gov/national-preparedness-system.

FEMA requires recipients to prioritize grant funding to demonstrate how investments support identified national priorities and building capability, closing capability gaps, or sustaining capabilities as defined by CPG 201: THIRA/SPR Guide—3rd Edition. In addition to capability gaps they have identified at their level, recipients should consider areas where community capability gaps have consistently been the largest, which are outlined in the most recent National Preparedness Report. They include cybersecurity, economic recovery, housing, infrastructure systems, natural and cultural resources, and supply chain integrity and security. Addressing these areas for improvement will enhance preparedness nationwide.

Minimum funding amounts are not prescribed by the Department for these priorities; however, recipients are expected to support state, local, regional, and national efforts in achieving the desired outcomes of these priorities.
recipients are required to submit an SPR annually. For additional guidance on the THIRA/SPR, please refer to the Comprehensive Preparedness Guide (CPG) 201, Third Edition. Recipients must align THSGP grant investments in building and sustaining capabilities with closing capability gaps and/or sustaining capabilities they identified in their THIRA and SPR.

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Reporting on the Implementation of the National Preparedness System By December 31, 2023, any new THSGP recipients during calendar year 2023 are required to complete a THIRA/SPR that addresses all 32 core capabilities and is compliant with the Comprehensive Preparedness Guide (CPG) 201, Third Edition.

THSGP recipients must complete every step of the THIRA/SPR for the following eight core capabilities:

Cybersecurity; Infrastructure Systems; Mass Care Services; Mass Search and Rescue Operations; On- scene Security, Protection, and Law Enforcement; Operational Communications; Operational Coordination; and Public Information and Warning. For the remaining 24 core capabilities, THSGP recipients are only required to indicate planning, organization, equipment, training, and exercise gaps in functional areas related to those capabilities. THSGP recipients may optionally complete additional portions of the THIRA/SPR for these 24 core capabilities.

THSGP recipients are required to respond to a series of planning-related questions as part of the THIRA/SPR. THSGP recipients are required to submit a THIRA every three years to establish a consistent baseline for assessment. While the THIRA is only required every three years, THSGP Reporting Requirements
• THSGP reci pients must submit their THIRA/SPR through the Unified Reporting Tool (URT) on Prep Toolk it no later than December 31 for the years they have open THSGP grant awards. If a recipi ent has completed closeout for their THSGP grant award period of performance, they do not have to sub mit any more THIRA/SPR updates as the requirement does not apply to closed awards. Whi le UASIs are not required to complete a THIRA/SPR, it is encouraged. • Calendar year 2022 is the start of the new 3-year THIRA/SPR cycle and baseline assessment year for exi sting recipients. Any new grant recipients during calendar year 2023, for which the THIRA /SPR requirement applies, will start their new 3-year THIRA/SPR cycle and baseline assessm ent year in 2023. Please contact [email protected] if you have questions. • In each THSGP recipient’s Biannual Strategy and Implementation Report (BSIR), as part of progr ammatic monitoring, recipients will be required to describe how investments support building capability, closing capability gaps, or sustaining capabilities identified in the THIRA /SPR. THSGP recipients will, on a project-by-project basis, check one of the following:
o Building a capability with THSGP funding; or
o Sustain ing a capability with THSGP funding.

National Incident Management System (NIMS) Implementation Recipients receiving THSGP funding are required to implement the National Incident Management System (NIMS). NIMS guides all levels of government, nongovernmental organizations (NGO), and the private sector to work together to prevent, protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the whole community with the shared vocabulary, systems, and processes to successfully deliver the capabilities described in the National Preparedness Goal.

THSGP recipients must utilize standardized resource management concepts such as typing, credentialing, and inventorying resources that facilitates the effective identification, dispatch, deployment, tracking and recovery of their resources.

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The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarifies the NIMS implementation requirements in FEMA preparedness grant Notices of Funding Opportunities (NOFOs). As recipients and subrecipients of federal preparedness (non-disaster) grant awards, jurisdictions and organizations must achieve, or be actively working to achieve, all of the NIMS Implementation Objectives. The objectives can be found on the NIMS webpage at NIMS Implementation and Training | FEMA.gov.

Reporting Requirements
Recipients report in the applicable secondary NIMS assessment portion of the URT as part of their THIRA/SPR submission, as outlined in the THSGP NOFO.

Planning to Deliver Capabilities
Recipients shall develop and maintain a jurisdiction-wide, all threats and hazards Emergency Operations Plans (EOPs) consistent with CPG 101 Version 2.0 (CPG 101 v2). Recipients must submit an EOP once during the period of performance.

Reporting Requirements
Recipients report EOP compliance with Developing and Maintaining Emergency Operations Plans by completing the secondary CPG 101 v2 assessment portion of the URT as part of their THIRA/SPR submission, as outlined in the THSGP NOFO.

Validating Capabilities
All recipients will develop and maintain a progressive exercise program consistent with Homeland Security Exercise and Evaluation Program (HSEEP) guidance in support of the National Exercise Program (NEP). The NEP serves as the principal exercise mechanism for examining national preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’ Strategic Priorities, established by the National Security Council, and informed by preparedness data from jurisdictions across the Nation.

To develop and maintain a progressive exercise program consistent with HSEEP and in support of the NEP, recipients should engage senior leaders and other whole community stakeholders to identify preparedness priorities. These priorities should be informed by various factors, including jurisdiction- specific threats and hazards (i.e., the THIRA); areas for improvement identified by real-world events and exercises; external requirements such as state or national preparedness reports, homeland security policy, and industry reports; and accreditation standards, regulations, or legislative requirements. Recipients should document these priorities and use them to deploy a schedule of preparedness events in a multi-year Integrated Preparedness Plan (IPP). Information related to IPPs and Integrated Preparedness Planning Workshops (IPPWs) can be found on the HSEEP website at Homeland Security Exercise and Evaluation Program | FEMA.gov and Welcome - Preparedness Toolkit (fema.gov).

The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance, tools and resources, enhanced coordination, and the ability to directly influence and inform policy and preparedness programs. If you have any questions or would like to request assistance through the NEP, please visit the NEP website at Exercises | FEMA.gov or reach out to the NEP directly at [email protected].

Reporting Requirements
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• Recipients must have a current multi-year IPP that identifies preparedness priorities and activities. The current multi-year IPP must be submitted to [email protected] before January 31 of each year:
o Recipients are encouraged to enter their exercise information into the Preparedness Toolkit at https://preptoolkit.fema.gov/.
• Recipients must submit After-Action Report (AAR)/Improvement Plans (IPs) to [email protected] and indicate which fiscal year’s funds were used (if applicable); • Submission of AAR/IPs must occur within 90 days after completion of the single exercise or progressive series:
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate critical plans or those reflecting large-scale functional or full-scale exercises that took place at the state, territorial, tribal, or UASI level. Recipients are discouraged from submitting AAR/IPs specific to local jurisdictions that reflect drills; o If a recipient endures a significant real-world incident during the calendar year that delays or prevents conduct of a grant-funded exercise, they can submit the AAR from that event in place of the exercise AAR. Jurisdictions submitting real world AARs should include an explanation with the AAR submission to [email protected]; and o Recipients can access a sample AAR/IP template at
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.

THSGP Funding Guidelines
Recipients and subrecipients must comply with all applicable requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards located at 2 C.F.R. Part 200.

In administering a THSGP grant award, recipients must comply with the following general requirements:

THSGP Priorities
See the annual THSGP NOFO.

Allowable Costs
Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of THSGP funds, such as financial management and monitoring. Recipients may use up to 5% of the amount of the award for M&A, and where applicable, subrecipients may use up to 5% for M&A of the amount they receive. Reasonable costs of grant management training are also allowable.

Indirect Costs
Indirect costs are allowable under this program. See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

Allowable Direct Costs
The following pages outline global allowable costs guidance specifically applicable to THSGP.

Allowable activities made in support of the national priorities, as well as other capability-enhancing projects must fall into the categories of planning, organization, equipment, training, or exercises (POETE). Additional detail about each of these allowable expense categories, as well as sections on additional activities including explicitly unallowable costs is provided. In general, recipients should THSGP Appendix | 2023 Page B-5
consult their FEMA Preparedness Officer prior to implementing any investment to ensure that it clearly meets the allowable expense criteria established by the guidance.

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

Planning
Planning efforts can include prioritizing needs; conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Infrastructure Resilience Planning Framework and related CISA resources; updating preparedness strategies; and allocating resources across stakeholder groups (e.g., law enforcement, fire, emergency medical services, health care systems, public health, behavioral health, public works, rural water associations, agriculture, information technology, emergency communications, and the general public, including people with disabilities) and levels of government. Planning provides a methodical way to engage the whole community in thinking through the life cycle of potential crises, determining required capabilities, and establishing a framework for roles and responsibilities. Planning must include participation from all stakeholders in the community who are able to contribute critical perspectives and may have a role in executing the plan. Planning should be flexible enough to address incidents of varying types and magnitudes.

Planning activities should focus on the prevention, protection, mitigation, and response mission areas outlined in the Goal. All jurisdictions are encouraged to work with Citizen Corps Whole Community Councils, nongovernmental entities, and the general public in planning activities. Whole community planning should integrate program design and delivery practices that ensure representation and services for 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.

Recipients must use the CPG 101 v2, Third Edition in order to develop robust and effective plans.

For additional planning and resource information, please see:
• FEMA CPG 101 v.2 - http://www.fema.gov/pdf/about/divisions/npd/CPG_101_V2.pdf • CISA Infrastructure Resilience Planning Toolkit - http://www.cisa.gov/idr-program • FEMA Citizen Corps - http://www.ready.gov/citizen-corps • FEMA CERT - http://www.fema.gov/community-emergency-response-teams • Ready.gov - www.ready.gov/kids
• Emergency Planning with Children - http://www.fema.gov/media-library/assets/documents/94775 • National Disaster Recovery Framework - https://www.fema.gov/sites/default/files/2020- 06/national_disaster_recovery_framework_2nd.pdf
Additionally, THSGP funds may be used for planning activities related to 911 call capabilities, alert and warning capabilities, and implementation of the REAL ID Act (Pub. L. No. 109-13).

Continuity Capability
FEMA is responsible for developing, managing, and promulgating national continuity planning, guidance, training, and exercise programs for the whole community. To support this role, FEMA provides direction and guidance to assist in developing capabilities for continuing federal and state, local, tribal, and territorial (SLTT) government jurisdictions and private sector organizations' essential functions across a broad spectrum of emergencies.

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Presidential Policy Directive 40: National Continuity Policy, Federal Continuity Directive (FCD) 1, FCD 2, and Continuity Guidance Circular (CGC) outline continuity requirements for agencies and organizations and provide guidance, methodology, and checklists. For additional information on continuity programs, guidance, and directives, visit the Continuity Resource Toolkit at https://www.fema.gov/emergency-managers/national-preparedness/continuity/toolkit.

Organization
Recipients may use grant funds for organization activities:
• Organizational activities may include, paying salaries and benefits for personnel, including individuals employed to serve as qualified intelligence analysts. 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.
• Other organization activities may include implementing 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.

Additionally, migrating online services to the “.gov” internet domain is an allowable expense.

Equipment
The 21 allowable prevention, protection, mitigation, response, and recovery equipment categories and equipment standards for THSGP are listed on the web-based version of the Authorized Equipment List (AEL). Unless otherwise stated, equipment must meet all mandatory regulatory and DHS-adopted standards to be eligible for purchase using these funds. In addition, recipients and subrecipients, as applicable, agencies will be responsible for obtaining and maintaining all necessary certifications and licenses for the requested equipment. Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior approval from 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 unallowable equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or vehicles of any kind with weapons installed. Recipients should analyze the costs and benefits of purchasing versus leasing equipment, especially high-cost items, and those subject to rapid technical advances. Large equipment purchases must be identified and explained. For more information regarding property management standards for equipment, please reference 2 C.F.R. Part 200, including 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services, issued May 10, 2022. In addition, recipients that are using THSGP funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at Funding Resources | CISA.

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

Requirements for Small Unmanned Aircraft System
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply with FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards, and also include a description of the policies and procedures in place to safeguard individuals’ privacy, civil rights, THSGP Appendix | 2023 Page B-7
and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the sUAS equipment.

SUAS policies are not required at the time of application but must be received and approved by FEMA prior to obligating THSGP funds. All grant-funded procurements must be executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients that use THSGP funds for sUAS, FEMA advises that there is a general privacy concern related to the use of this equipment if the data the devices collect is transmitted to servers not under the control of the operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers outside the United States. The U.S. Department of Homeland Security’s Privacy Office suggests the recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data breaches.

Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2023 DHS Appropriations Act further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign- made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign- made versus domestic sUAS.

Acquisition and Use of Technology to Mitigate UAS (Counter-UAS) In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.

The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do they conduct legal reviews of commercially available product compliance with those laws. The advisory does not address state and local laws nor potential civil liability, which UAS detection and mitigation capabilities may also implicate.

It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state criminal, surveillance, and communications laws. Entities should conduct their own legal and technical analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’ representations of the systems’ legality or functionality. Please also see the DHS press release on this topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use- technology-detect-and-mitigate-unmanned-aircraft.

Training and Exercises
Tribes are strongly encouraged to use THSGP funds to develop or maintain a homeland security training program. Allowable training-related costs under the THSGP include the establishment, support, conduct, and attendance of training specifically identified under the THSGP or in conjunction with emergency preparedness training by other federal agencies (e.g., the Department of Health and Human Services or the Department of Transportation). Training conducted using THSGP funds should address a performance gap identified through an assessment or contribute to building a capability that will be evaluated through a formal exercise. Exercises should be used to provide the opportunity to demonstrate and validate skills learned in training, as well as to identify training gaps. Any training or training gaps evaluated though a formal exercise, including those for vulnerable populations including children, the elderly, pregnant women, and individuals with disabilities or other access and functional needs should be identified in an AAR/IP.

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All training and exercises conducted with THSGP funds should support the development and testing of the jurisdiction’s Emergency Operations Plan (EOP), consistent with the priorities in the National Preparedness System. 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 instruction design, available with additional training information at First Responder Training System and First Responder Training Systemhttps://www.firstrespondertraining.gov/frts/trdc/state/development.

FEMA supports and encourages the coordination of all emergency preparedness training towards the achievement of the Goal. To this end, FEMA supports the establishment of a Tribal Training Point of Contact (TTPOC). The role of the TTPOC is to coordinate the tribes’ training needs and activities with FEMA and FEMA’s federal training partners and holds the same authority and roles that state training points of contact serve within SAAs nationwide. FEMA will coordinate with Tribal Training Officers (TTOs) as it relates to FEMA training when notified by recipients.

Per FEMA Grant Programs Directorate IB 432, Review and Approval Requirements for Training Courses Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal entities, and high-risk urban areas are no longer required to request approval from FEMA for personnel to attend non- DHS/FEMA training as long as the training is coordinated with and approved by the state, territory, tribal, or high-risk urban area TPOC and falls within the FEMA mission scope and the jurisdiction’s EOP. For additional information on review and approval requirements for training courses funded with preparedness grants, please refer to Review and Approval Requirements for Training Courses Funded Through Preparedness Grants Policy (fema.gov)https://www.fema.gov/sites/default/files/2020- 09/fema_gpd-review-approval-requirements-training-policy_09-10-13.pdf.

DHS/FEMA Provided Training and Education
FEMA offers tuition-free training and education programs and courses through several providers including the Center for Domestic Preparedness, the Emergency Management Institute, and the National Training and Education Division’s Training Partner Program (TPP). TPP includes the Center for Homeland Defense and Security, National Domestic Preparedness Consortium, Rural Domestic Preparedness Consortium, and training partners through the Continuing Training Grants program.

FEMA’s National Preparedness Course Catalog
This online searchable catalog features a wide range of course topics in multiple delivery modes to meet FEMA’s mission scope as well as the increasing training needs of federal, state, local, territorial, and tribal audiences. The catalog can be accessed at NTED | National Preparedness Course Catalog Home (firstrespondertraining.gov).

Training Not Provided by DHS/FEMA
These trainings include courses that are either state sponsored or federal sponsored (non-DHS/FEMA), coordinated and approved by the SAA or their designated TPOC, and fall within the FEMA mission scope to prepare SLTT personnel to prevent, protect against, mitigate, and respond to acts of terrorism or catastrophic events.
• State Sponsored Courses. These courses are developed for and/or delivered by institutions or organizations other than federal entities or FEMA and are sponsored by the SAA or their designated TPOC.
• Joint Training and Exercises with the Public and Private Sectors. These courses are sponsored and coordinated by private sector entities to enhance public-private partnerships for training personnel to prevent, protect against, mitigate, and respond to acts of terrorism or THSGP Appendix | 2023 Page B-9
catastrophic events. In addition, states, territories, tribes, and high-risk urban areas are encouraged to incorporate the private sector in government-sponsored training and exercises.

Additional information on both FEMA provided training and other federal and state training can be found at First Responder Training System.

Training Information Reporting System (“Web-Forms”)
Web-Forms is an electronic data management system built to assist SAAs, designated TPOCs, and federal agencies with submitting non-National Training and Education Division provided training courses for inclusion in the State/Federal-Sponsored Course Catalog through electronic forms. The information collected is used in a two-step review process to ensure the training programs adhere to the intent of the HSGP guidance and the course content is structurally sound and current. As these programs may be delivered nationwide, it is vital to ensure each training program’s viability and relevance to the Homeland Security mission. Reporting training activities through Web-Forms is not required under FY 2023 THSGP. However, the system remains available and can be accessed through the Web-Forms section of the FEMA National Preparedness Course Catalog to support recipients in their own tracking of training deliveries.

Exercises
For additional information on conducting exercises under THSGP, please refer to the earlier section in this appendix titled “Validating Capabilities” on page B-3.

Personnel Activities
Personnel hiring, overtime, and backfill expenses are permitted under this grant in order to perform allowable THSGP planning, training, exercise, and equipment activities.

Not more than 50% of total THSGP funds may be used for personnel activities as directed by the Homeland Security Act of 2002, as amended by the Personnel Reimbursement for Intelligence Cooperation and Enhancement (PRICE) of Homeland Security Act (Pub. L. No. 110-412) (6 U.S.C. §609(b)(2)(A)). This 50% cap may be waived, however, per 6 U.S.C. § 609(b)(2)(B). For further details, THSGP recipients should refer to IB 421b, or contact their FEMA HQ Preparedness Officer. THSGP funds may not be used to support the hiring of any personnel for the purposes of fulfilling traditional public safety duties or to supplant traditional public safety positions and responsibilities.

Construction and Renovation
Construction projects are only permitted where they will assist the recipient to achieve target capabilities related to preventing, preparing for, protecting against, or responding to acts of terrorism, including through the alteration or remodeling of existing buildings for the purpose of making them secure against acts of terrorism. THSGP funding may not be used for construction and renovation projects without prior written approval from FEMA. All recipients of THSGP funds must request and receive approval from FEMA before any THSGP funds are used for any construction or renovation. Additionally, recipients are required to submit an SF-424C Form containing budget detail citing the construction project costs and an SF-424D Form for standard assurances for the construction project. The total cost of any construction or renovation paid for using THSGP funds may not exceed the greater amount of $1 million or 15% of the THSGP award.

All construction and renovation projects require Environmental Planning and Historic Preservation (EHP) review. Recipients and subrecipients are encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential THSGP Appendix | 2023 Page B-10
for project effects, compliance with all state and local EHP laws and requirements). Projects for which the recipient believes an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer within six months of the award and completed EHP review materials must be submitted no later than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

THSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. § 5196(j)(9), which cross-references Davis-Bacon). Grant recipients 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 similar to the contract work in the civil subdivision of the state in which the work is to be performed. Additional information regarding compliance with the Davis- Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following website Davis-Bacon and Related Acts | U.S. Department of Labor (dol.gov).

Communications Towers
For the purposes of the limitations on funding levels only, communications towers are not considered construction. When applying for construction funds, including communications towers, at the time of application, recipients must submit evidence of approved zoning ordinances, architectural plans, and any other locally required planning permits.

When applying for funds to construct communication towers, recipients and subrecipients must submit evidence that the Federal Communication Commission’s Section 106 review process has been completed and submit all documentation resulting from that review, with a FEMA Grant Programs Directorate EHP Screening Form, to FEMA as part of the project’s EHP Review submittal. Recipients and subrecipients are encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their Tribal Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects; compliance with all state and local EHP laws and requirements). Projects for which an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer within six months of the recipient’s receipt of the award. Completed EHP review materials for communication tower projects must be submitted no later than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

Multiple Purpose or Dual-Use of Funds
Many activities that support the achievement of target capabilities related to terrorism preparedness may simultaneously support enhanced preparedness for other hazards unrelated to acts of terrorism. See 6 U.S.C. § 609I. However, all THSGP-funded projects must assist recipients and subrecipients in achieving target capabilities related to preventing, preparing for, protecting against, or responding to acts of terrorism.

Whole Community Preparedness
In addition to the Citizen Corps Whole Community Councils and Community Emergency Response Team (CERT) programs mentioned above, youth preparedness activities are another allowable cost. Bolstering youth preparedness across the nation is a priority for FEMA as the Agency works with state, local, tribal, and territorial partners to create a culture of preparedness in the United States. Information on youth- THSGP Appendix | 2023 Page B-11
centric educational curricula, games, planning materials, and other relevant resources can be found at https://www.ready.gov/kids. Furthermore, FEMA’s Individual and Community Preparedness Division (ICPD) and regional based Community Preparedness Officers (CPOs) are available to provide grant recipients with guidance and assistance. Please email [email protected] to contact one of the Agency’s subject matter experts.

The following are examples of youth preparedness activities that grantees are encouraged to undertake as allowable costs:
• Reach out to a local school board or elementary school to encourage the adoption of the Student Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based emergency preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach format. Students will learn about disasters, emergencies, and hazards, and how to create a disaster supply kit and family emergency communication plan. An overview of the STEP program along with the instructor guide and student activity book is available at https://www.ready.gov/student-tools-emergency- planning-step; and
• Sponsor the creation of a Teen CERT in your jurisdiction. The CERT Program is a national program of volunteers trained in disaster preparedness and emergency response. Volunteers come from all ages and all walks of life, including teenagers. Additional information, including a step- by-step guide on how to start a Teen CERT, is available at https://www.ready.gov/teen-cert.

The following tools are available to order from FEMA’s warehouse free of charge:
• “Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The “Prepare with Pedro: Disaster Preparedness Activity Book” is designed to teach young children and their families about how to stay safe during disasters and emergencies. The book follows Pedro around the United States and offers safety advice through crosswords, coloring pages, matching games, and more. Additional information, including an ordering form, is available at https://www.ready.gov/prepare-pedro; and
• The Ready 2 Help card game is a fun way for kids to learn how to respond to emergencies by working with friends and using skills that will help in a real emergency. Ready 2 Help teaches five simple steps to stay safe and make a difference until help arrives:
o Stay Safe;
o Stay Calm;
o Get Help;
o Give Info; and
o Give Care.

Ready 2 Help was designed for children ages 8 and up. Additional information, including an ordering form, is available at https://www.ready.gov/ready-2-help.

Other Allowable Costs
Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty coverage, licenses, and user fees. These contracts may exceed the period of performance if they are purchased incidental to the original purchase of the system or equipment as long as the original purchase of the system or equipment is consistent with that which is typically provided for, or available through, these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending THSGP Appendix | 2023 Page B-12
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased may not exceed the period of performance of the award used to purchase the maintenance agreement or warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.

Grant funds are intended to support the National Preparedness Goal and fund projects that build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, and respond to those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs which must be in (1) direct support of existing capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program, and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs must also be in support of equipment, training, and critical resources that have previously been purchased with either federal grant money or any other source of funding other than FEMA preparedness grant program dollars.

Critical Emergency Supplies
In furtherance of DHS’s mission, critical emergency supplies, such as shelf-stable food products, water, and basic medical supplies are an allowable expense under THSGP. Prior to allocating grant funds for stockpiling purposes, each Tribe must have FEMA’s approval of a five-year viable inventory management plan, an effective distribution strategy, and related sustainment costs if the planned grant expenditure is over $100,000.

The inventory management plan and distribution strategy, to include sustainment costs, will be developed and monitored by FEMA. FEMA will provide program oversight and technical assistance as it relates to the purchase of critical emergency supplies under THSGP. FEMA will establish guidelines and requirements for the purchase of these supplies under THSGP and monitor development and status of the Tribe’s inventory management plan and distribution strategy. Linkages between specific projects undertaken with THSGP funds and strategic goals and objectives will be highlighted through regular required reporting mechanisms. If grant expenditures exceed the minimum threshold, the five-year inventory management plan will be developed and monitored by FEMA.

Secure Identification
THSGP funds may be used to support the development and production of enhanced tribal documents (e.g., Enhanced Tribal Cards) designed to meet the requirements of the Western Hemisphere Travel Initiative (WHTI). More information on the WHTI may be found at http://www.dhs.gov/files/programs/gc_1200693579776.shtm and https://www.cbp.gov/travel/us- citizens/western-hemisphere-travel-initiative.

When completing the Investment Justification, refer to the National Preparedness Goal at for a list of the core capabilities that best fit the proposed activities and costs. For additional assistance in determining the core capabilities that fit the proposed WHTI project, please contact the CSID by phone at (800) 368-6498 or by e-mail at [email protected].

Fidelity Bonds
Reasonable costs of fidelity bonds (or like insurance as provided for by applicable state or tribal laws) covering the maximum amount of THSGP funds the officer, official, or employee handles at any given time for all personnel who disburse or approve disbursement of THSGP funds may be allowable if required by the terms and conditions of the award or if generally required by the tribe in its general operations. If a fidelity bond is required by a tribe in its general operations, those costs must be charged as indirect costs. See 2 C.F.R. § 200.427.

THSGP Appendix | 2023 Page B-13
Framework for Improving Critical Infrastructure Cybersecurity When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the “Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework gathers existing international standards and practices to help organizations understand, communicate, and manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity program, the Framework provides initial guidance. For organizations with more advanced practices, the Framework offers a way to improve their programs, such as better communication with their leadership and suppliers about management of cyber risks.

Additional information on the Critical Infrastructure Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp.

THSGP Investment Modifications – Changes in Scope or Objective Changes in scope or objective of the award—including those resulting from intended actions by the recipient or subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §§ 200.308(c)(1), 200.407. THSGP is competitive, with applications recommended for funding based on threat, vulnerability, and consequence, and their mitigation of potential terrorist attacks. However, consistent with 2 C.F.R § 200.308(c)(1), Change in Scope Prior Approval, FEMA requires prior approval of any change in scope or objective of the grant-funded activity after the award is issued. See 2 C.F.R. § 200.308(b), (c). Scope or objective changes will be considered on a case-by-case basis, provided the change does not negatively impact the competitive process used to recommend THSGP awards.

Requests to change the scope or objective of the grant-funded activity after the award is made must be submitted via ND Grants as a Scope Change Amendment. The amendment request must include the following:
• A written request on the recipient’s letterhead, outlining the scope or objective change, including the approved projects from the IJ, the funds and relative scope or objective significance allocated to those projects, the proposed changes, and any resulting reallocations as a result of the change of scope or objective;
• An explanation why the change of scope or objective is necessary; • How the proposed scope or objective changes to the project support the vulnerabilities and capability gaps identified in the approved IJ; and
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• The request must also address whether the proposed changes will impact the recipient’s ability to complete the project within the award’s period of performance.

Recipients may not proceed with implementing any scope or objective changes until they receive prior written approval from FEMA through ND Grants.

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Program Appendix C:

Nonprofit Security Grant Program (NSGP)
As a reminder, while this appendix contains NSGP-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the NSGP. Please be sure to read the main content of this Manual in addition to the program-specific appendices.

NSGP grant recipients (e.g., State Administrative Agencies [SAA]) and subrecipients (e.g., nonprofit organizations) may only use NSGP grant funds for the purpose set forth in the grant award and must use funding in a way that is consistent with the statutory authority for the award. Grant funds may not be used for matching funds for other federal grants or cooperative agreements, 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.

Pre-award costs are allowable only with the prior written approval of FEMA and if they are included in the award agreement. To request pre-award costs a written request must be included with the application, signed by the Authorized Organizational Representative (AOR) of the entity. The letter must outline what the pre-award costs are for, including a detailed budget break-out of pre-award costs from the post-award costs, and a justification for approval. The following information outlines general allowable and unallowable NSGP costs guidance.

NSGP Funding Guidelines
Recipients and subrecipients must comply with all applicable requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards located at 2 C.F.R. Part 200.

In administering a NSGP grant award, recipients must comply with the following general requirements:

NSGP Priorities
See the annual NSGP NOFO.

Allowable Costs
Management and Administration (M&A)
M&A costs are for activities directly related to the management and administration of the award. M&A activities are those defined as directly relating to the management and administration of NSGP funds, such as financial management and monitoring, for that fiscal year. For example, FY 2023 M&A funding can only be used to cover administrative costs incurred in the management of FY 2023 NSGP grant awards. M&A expenses must be based on actual expenses or known contractual costs. 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, they are the necessary costs incurred in direct support of the grant or as a result of the grant and should be allocated across the entire lifecycle of the grant. Examples include preparing and submitting required programmatic and financial reports, establishing and/or maintaining equipment inventory, documenting operational and equipment expenditures for financial accounting NSGP Appendix | 2023 Page C-2
purposes, and responding to official informational requests from state and federal oversight authorities.

M&A costs include the following categories of activities:
• Hiring of full-time or part-time staff or contractors/consultants responsible for activities relating to the management and administration of NSGP funds. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327; and • Meeting-related expenses directly related to M&A of NSGP funds.

M&A costs are allowed under this program as described below:
• SAA (Recipient) for NSGP-Urban Area (NSGP-UA) and NSGP-State (NSGP-S) M&A:

SAAs may use and expend up to the percent noted in the relevant fiscal year (FY) NOFO for M&A purposes (5% for FY 2023) associated with their NSGP-UA and NSGP-S awards. SAAs must be able to separately account for M&A costs associated with the NSGP-UA award from those associated with the NSGP-S, and neither can exceed the percent noted in the relevant FY NOFO (5% of each award for FY 2023).
• Nonprofit (Subrecipient) for NSGP-UA and NSGP-S, and Community Project Funding M&A: Nonprofit organizations that receive a subaward under this program may use and expend up to the percent noted in the relevant FY NOFO for M&A purposes associated with the subaward (5% of each subaward for FY 2023).

Indirect Costs
Indirect costs are allowable under this program. See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

National Incident Management System (NIMS) Implementation Recipients receiving NSGP funding are strongly encouraged to implement NIMS. NIMS guides all levels of government, nongovernmental organizations (NGO), and the private sector to work together to prevent, protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the whole community with the shared vocabulary, systems, and processes to successfully deliver the capabilities described in the National Preparedness System.

Incident management activities require carefully managed resources (personnel, teams, facilities, equipment, and supplies). NIMS defines a national, interoperable approach for sharing resources, coordinating, and managing incidents, and communicating information. Incident management refers to how incidents are managed across all homeland security activities, including prevention, protection, mitigation, response, and recovery.

Utilization of the standardized resource management concepts such as typing, credentialing, and inventorying promote a strong national mutual aid capability needed to support delivery of core capabilities. Recipients should manage resources purchased or supported with FEMA grant funding according to NIMS resource management guidance.

Additional information on resource management and NIMS resource typing definitions and job titles/position qualifications is on FEMA’s website at NIMS Component–s - Guidance and Tools | FEMA.gov. Additional information about NIMS in general is available at National Incident Management System | FEMA.gov.

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Allowable Direct Costs
Planning
Funding may be used for security or emergency planning expenses and the materials required to conduct planning activities. Planning must be related to the protection of the facility and the people within the facility and should include consideration of access and functional needs as well as those with limited English proficiency. 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 CISA resources. Examples of planning activities allowable under this program include:
• Development and enhancement of security plans and protocols; • Development or further strengthening of security assessments; • Emergency contingency plans;
• Evacuation/Shelter-in-place plans;
• Coordination and information sharing with fusion centers; and • Other project planning activities with prior approval from FEMA.

Equipment
Allowable costs are focused on facility hardening and physical security enhancements. Funding can be used for the acquisition and installation of security equipment on real property (including buildings and improvements) owned or leased by the nonprofit organization, specifically in prevention of and/or protection against the risk of a terrorist or other extremist attack. This equipment is limited to select items on the Authorized Equipment List (AEL):
• 03OE-03-MEGA System, Public Address, Handheld or Mobile • 04AP-05-CRED System, Credentialing
• 04AP-09-ALRT Systems, Public Notification and Warning • 04AP-11-SAAS Applications, Software as a Service
• 05AU-00-TOKN System, Remote Authentication
• 05EN-00-ECRP Software, Encryption
• 05HS-00-MALW Software, Malware/Anti-Virus Protection
• 05HS-00-PFWL System, Personal Firewall
• 05NP-00-FWAL Firewall, Network
• 05NP-00-IDPS System, Intrusion Detection/Prevention
• 06CP-01-PORT Radio, Portable
• 06CC-02-PAGE Services/Systems, Paging
• 06CP-03-ICOM Intercom
• 06CP-03-PRAC Accessories, Portable Radio
• 10GE-00-GENR Generators
• 13IT-00-ALRT System, Alert/Notification
• 14CI-00-COOP System, Information Technology Contingency Operations • 14EX-00-BCAN Receptacles, Trash, Blast-Resistant
• 14EX-00-BSIR Systems, Building, Blast/Shock/Impact Resistant • 14SW-01-ALRM Systems/Sensors, Alarm
• 14SW-01-DOOR Doors and Gates, Impact Resistant
• 14SW-01-LITE Lighting, Area, Fixed
• 14SW-01-PACS System, Physical Access Control
• 14SW-01-SIDP Systems, Personnel Identification
NSGP Appendix | 2023 Page C-4
• 14SW-01-SIDV Systems, Vehicle Identification
• 14SW-01-SNSR Sensors/Alarms, System and Infrastructure Monitoring, Standalone • 14SW-01-VIDA Systems, Video Assessment, Security
• 14SW-01-WALL Barriers: Fences; Jersey Walls
• 15SC-00-PPSS Systems, Personnel/Package Screening
• 21GN-00-INST Installation
• 21GN-00-TRNG Training and Awareness
Unless otherwise stated, equipment must meet all mandatory statutory, regulatory, and FEMA-adopted standards to be eligible for purchase using these funds, including the Americans with Disabilities Act. In addition, recipients will be responsible for obtaining and maintaining all necessary certifications and licenses for the requested equipment, whether with NSGP funding or other sources of funds (see the Maintenance and Sustainment section below for more information). In addition, subrecipients that are using NSGP funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at Funding Resources | CISA.

Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior approval from FEMA. NOTE: Nonprofits should indicate in their budget narratives if a cost includes shipping and/or tax. It is not required to break the costs out as separate from the relevant purchase(s).

Applicants and subapplicants should analyze the cost benefits of purchasing versus leasing equipment, especially high-cost items and those subject to rapid technical advances. Large equipment purchases must be identified and explained. For more information regarding property management standards for equipment, please reference 2 C.F.R. Part 200, including but not limited to 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services, regarding prohibitions on covered telecommunications equipment or services.

The installation of certain equipment may trigger Environmental Planning and Historic Preservation (EHP) requirements. Please reference the EHP sections in the NOFO and this Manual for more information. Additionally, some equipment installation may constitute construction or renovation. Please see the Construction and Renovation section of this appendix for additional information.

Exercises
Funding may be used to conduct security-related exercises. This includes costs related to planning, meeting space and other meeting costs, facilitation costs, materials and supplies, and documentation.

Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting. All shortcomings or gaps—including those identified for children and individuals with access and functional needs—should be identified in an improvement plan. Improvement plans should be dynamic documents with corrective actions continually monitored and implemented as part of improving preparedness through the exercise cycle.

The Homeland Security Exercise and Evaluation Program (HSEEP) provides a set of guiding principles for exercise programs, as well as a common approach to exercise program management, design and development, conduct, evaluation, and improvement planning. For additional information on HSEEP, refer to Homeland Security Exercise and Evaluation Program | FEMA.gov. In accordance with HSEEP NSGP Appendix | 2023 Page C-5
guidance, subrecipients are reminded of the importance of implementing corrective actions iteratively throughout the progressive exercise cycle. This link provides access to a sample After Action Report (AAR)/Improvement Plan (IP) template: Improvement Plannin–g - HSEEP Resource–s - Preparedness Toolkit (fema.gov). Recipients are encouraged to enter their exercise data and AAR/IP in the Preparedness Toolkit.

Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty coverage, licenses, and user fees. These contracts may exceed the period of performance if they are purchased incidental to the original purchase of the system or equipment as long as the original purchase of the system or equipment is consistent with that which is typically provided for, or available through, these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending an existing maintenance contract on an already-owned piece of equipment system, coverage purchased may not exceed the period of performance of the award used to purchase the maintenance agreement or warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.

Grant funds are intended to support the National Preparedness Goal (the Goal) and fund projects that build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program, and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs may also support equipment, training, and critical resources that have previously been purchased with either federal grant or any other source of funding other than FEMA preparedness grant program dollars.

Construction and Renovation
NSGP funding may not be used for construction and renovation projects without prior written approval from FEMA. In some cases, the installation of equipment may constitute construction and/or renovation.

If you have any questions regarding whether an equipment installation project could be considered construction or renovation, please contact your Preparedness Officer. All recipients of NSGP funds must request and receive prior approval from FEMA before any NSGP funds are used for any construction or renovation. Additionally, recipients are required to submit a SF-424C Budget and budget detail citing the project costs and an SF-424D Form for standard assurances for the construction project. The total cost of any construction or renovation paid for using NSGP funds may not exceed the greater amount of $1 million or 15% of the NSGP award.

All construction and renovation projects require EHP review. Recipients and subrecipients are encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects, compliance with all state and local EHP laws and requirements). Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer within six months of the award and completed EHP review materials must be submitted no later than 12 months before the end of the period of performance. Additional information on EHP policy and EHP review can be found online at Environmental & Historic Preservation Grant Preparation Resources | FEMA.gov. EHP review packets should be sent to [email protected].

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NSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. § 5196(j)(9), which cross-references Davis-Bacon). Grant recipients 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 similar to the contract work in the civil subdivision of the state in which the work is to be performed. Additional information regarding compliance with the Davis- Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following website: https://www.dol.gov/whd/govcontracts/dbra.htm.

Training
Nonprofit organizations may use NSGP funds for the following training-related costs:
• Employed or volunteer security staff to attend security-related training within the United States; • Employed or volunteer staff to attend security-related training within the United States with the intent of training other employees or members/congregants upon completing the training (i.e., “train-the-trainer” type courses); and
• Nonprofit organization’s employees, or members/congregants to receive on-site security training.

Allowable training-related costs under the NSGP are limited to attendance fees for training and related expenses, such as materials, supplies, and/or equipment. Overtime, backfill, and travel expenses are not allowable costs.

Allowable training topics are limited to the protection of critical infrastructure key resources, including physical and cybersecurity, facility hardening, and terrorism/other extremism awareness/employee preparedness such as Community Emergency Response Team (CERT) training, indicators and behaviors indicative of terrorist/other extremist threats, Active Shooter training, and emergency first aid training. Additional examples of allowable training courses include: “Stop The Bleed” training, kits/equipment, and training aids; First Aid and other novice level “you are the help until help arrives” training, kits/equipment, and training aids; and Automatic External Defibrillator (AED) and AED/Basic Life Support training, kits/equipment, and training aids.

Training conducted using NSGP funds must address a specific threat and/or vulnerability, as identified in the nonprofit organization’s Investment Justification (IJ). Training should provide the opportunity to demonstrate and validate skills learned as well as to identify any gaps in these skills. Proposed attendance at training courses and all associated costs using the NSGP must be included in the nonprofit organization’s IJ.

Contracted Security Personnel
Contracted security personnel are allowed under this program only as described in the NOFO and Manual and comply with guidance set forth in IB 421b and IB 441. NSGP funds may not be used to purchase equipment for contracted security. The subrecipient must be able to sustain this capability in future years without NSGP funding, and a sustainment plan will be required as part of the closeout package for any award funding this capability.

Additionally, NSGP recipients and subrecipients 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 and applicable procedures for seeking a waiver, please see 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).

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Unallowable Costs
The following projects and costs are considered ineligible for award consideration:
• Organization costs, and operational overtime costs;
• Hiring of public safety personnel;
• General-use expenditures;
• Overtime and backfill;
• Initiatives that do not address the implementation of programs/initiatives to build prevention and protection-focused capabilities directed at identified facilities and/or the surrounding communities;
• The development of risk/vulnerability assessment models; • Initiatives that fund risk or vulnerability security assessments or the development of the IJ; • Initiatives in which federal agencies are the beneficiary or that enhance federal property; • Initiatives which study technology development;
• Proof-of-concept initiatives;
• Initiatives that duplicate capabilities being provided by the Federal Government; • Organizational operating expenses;
• Reimbursement of pre-award security expenses;
• Cameras for license plate readers/license plate reader software; • Cameras for facial recognition software;
• Weapons or weapons-related training; and
• Knox boxes.

NSGP Investment Modifications – Changes in Scope or Objective Changes in scope or objective of the award—whether as a result of intended actions by the recipient or subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §§ 200.308(c)(1), 200.407. NSGP is competitive, with applications recommended for funding based on threat, vulnerability, consequence, and their mitigation to a specific facility/location. However, consistent with 2 C.F.R § 200.308(c)(1), Change in Scope Notification, FEMA requires prior written approval of any change in scope/objective of the grant-funded activity after the award is issued. See 2 C.F.R. § 200.308(b), (c).

Scope/objective changes will be considered on a case-by-case basis, provided the change does not negatively impact the competitive process used to recommend NSGP awards. Requests to change the scope or objective of the grant-funded activity after the award is made must be submitted by the SAA via ND Grants as a Scope Change Amendment. The amendment request must include the following:
• A written request from the NSGP subrecipient on its letterhead, outlining the scope or objective change, including the approved projects from the subrecipient’s IJ, the funds and relative scope or objective significance allocated to those projects, the proposed changes, and any resulting reallocations as a result of the change of scope or objective; • An explanation why the change of scope or objective is necessary; • Validation from the SAA that any deviations from the approved IJ are addressed in the vulnerability assessment submitted by the subrecipient at the time of application; and • The subrecipient request must also address whether the proposed changes will impact its ability to complete the project within the award’s period of performance.

FEMA will generally not approve NSGP change-of-scope requests resulting from the following situations:

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• Subrecipients that relocate their facilities after submitting their application who are requesting a change of scope to allow them to use NSGP funds towards projects at the new facility; or • Subrecipients that renovate their facilities after submitting their application in cases where the subsequent renovations would affect the vulnerability/risk assessment upon which the IJ is based.

NSGP project funding is based on the ability of the proposed project to mitigate the risk factors identified in the IJ. For this reason, FEMA may reject requests to significantly change the physical security enhancements that are purchased with NSGP funding where FEMA believes approval of the request would change or exceed the scope of the originally approved project. FEMA will consider all requests to deviate from the security project as originally proposed on a case-by-case basis, consistent with 2 C.F.R. § 200.308(c)(1).

Subrecipients may not proceed with implementing any scope/objective changes until the SAA receives written approval from FEMA through ND Grants and until the SAA has made any required subaward modifications.

If a subrecipient is simply making changes to its own budget without impacting the scope or objective of the subaward, and where the budget changes do not involve other prior approval requirements listed in 2 C.F.R. § 200.407, then the subrecipient does not need the prior approval of the SAA or FEMA. See 2 C.F.R. § 200.308. Instead, the subrecipient is only required to report to the SAA the budget changes.

Similarly, the SAA should report those budget changes to FEMA.

Pass-Through Requirements
Pass-through funding is required under this program. Awards made to the SAA for the NSGP carry additional pass-through requirements. Pass-through is defined as an obligation on the part of the state to make subawards to selected nonprofit organizations. The SAA must provide funds awarded under NSGP to successful nonprofit applicants within 45 days of receipt of the funds. A letter of intent (or equivalent) to distribute funds is not sufficient. Award subrecipients that are selected for funding under this program must be provided with funding within 45 days from the date the funds are first made available to the recipient so that they can initiate implementation of approved investments.

For the SAA to successfully meet the pass-through requirement and provide funding to the subrecipients, the SAA must meet the following four requirements:
• There must be some action by the SAA to establish a firm commitment to award the funds to the selected nonprofit organization;
• The action must be unconditional on the part of the SAA (i.e., no contingencies for availability of SAA funds);
• There must be documentary evidence of the commitment of the award of funding to the selected nonprofit organization; and
• The SAA must communicate the terms of the subaward to the selected nonprofit organization.

If a nonprofit organization is selected for an NSGP award and elects to decline the award, the SAA must notify their FEMA Preparedness Officer. The SAA may not re-obligate to another subrecipient without prior approval. “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 NSGP awards via the ND Grants system. If an SAA accepts its award within 15 calendar days of receiving notice of the award in the ND Grants system, the 45-calendar day pass-through period will start on the date the SAA accepted the award. Should an SAA not accept the NSGP award within 15 calendar days of NSGP Appendix | 2023 Page C-9
receiving notice of the award in the ND Grants system, the 45-calendar days pass-through period will begin 15 calendar days after the award notification is sent to the SAA via the ND Grants system.

It is important to note that the period of performance start date does not directly affect the start of the 45- calendar day pass-through period. For example, an SAA may receive notice of the NSGP award on August 20, 2023, while the period of performance dates for that award are September 1, 2023, through August 31, 2026. In this example, the 45-day pass-through period will begin on the date the SAA accepts the NSGP award or September 4, 2023 (15 calendar days after the SAA was notified of the award), whichever date occurs first. The period of performance start date of September 1, 2023 would not affect the timing of meeting the 45-calendar day pass-through requirement.

SAM/UEI Requirements for Recipients and Subrecipients
As the direct applicant and recipient of NSGP funding, the SAA is required to have a Unique Entity Identifier (UEI) number and be registered in the System for Award Management (SAM) and must maintain the currency of the ’AA's information in SAM until the SAA submits the final financial report required under the award or receives final payment, whichever is later. First tier subrecipients, including nonprofit organizations under the NSGP, will only be required to register in SAM.gov to obtain the UEI, but will not be required to maintain an active registration in SAM.gov. Further guidance on obtaining a UEI in SAM.gov can be found at GSA UEI Update and here SAM.gov Update.

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Program Appendix D:

Transit Security Grant Program (TSGP)
As a reminder, while this appendix contains TSGP-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the TSGP. Please be sure to read the main content of this Manual in addition to the program-specific appendices.

TSGP grant recipients may only use TSGP grant funds for the purpose set forth in the Notice of Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award.

Grant funds may not be used for matching funds for 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.

TSGP Funding Guidelines
Costs charged to a TSGP award must be consistent with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400, FEMA’s Implementation of 2 C.F.R. Part 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Super Circular” or “Omni Circular”), dated December 23, 2014, regarding FEMA’s implementation of these provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations, see 2 CFR Grants Management Policy Updates.

Pre-Award Costs
Pre-award costs are not allowable and will not be approved, with the exception of costs resulting from pre-award grant writing services provided by an independent contractor that shall not exceed $1,500.00.

See below for more information on these costs.

TSGP Priorities
See the annual TSGP NOFO.

Security Plan Requirements
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):

Security plans should include the following, as appropriate:
• A prioritized list of all items included in the public transportation agency’s security assessment that have not yet been addressed;
• A detailed list of any additional capital and operational improvements identified by DHS or the public transportation agency and a certification of the public transportation agency’s technical capacity for operating and maintaining any security equipment that may be identified in such list; TSGP Appendix | 2023 Page D-2
• Specific procedures to be implemented or used by the public transportation agency in response to a terrorist attack, including evacuation and passenger communication plans and appropriate evacuation and communication measures for the elderly and individuals with disabilities; • A coordinated response plan that establishes procedures for appropriate interaction with state and local law enforcement agencies, emergency responders, and federal officials in order to coordinate security measures and plans for response in the event of a terrorist attack or other major incident;
• A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part 1582;
• Plans for providing redundant and other appropriate backup systems necessary to ensure the continued operation of critical elements of the public transportation system in the event of a terrorist attack or other major incident;
• Plans for providing service capabilities throughout the system in the event of a terrorist attack or other major incident in the city or region which the public transportation system serves; • Methods to mitigate damage within a public transportation system in case of an attack on the system, including a plan for communication and coordination with emergency responders; and • Other actions or procedures as the Secretary of Homeland Security determines are appropriate to address the security of the public transportation system.

Allowable Direct Costs
Specific investments made in support of the funding priorities in the annual TSGP NOFO generally fall into one of the following six allowable expense categories:
• Planning;
• Operational Activities;
• Equipment and Capital Projects;
• Training and Awareness Campaigns;
• Exercises; and
• Management and Administration.

The following provides guidance on allowable costs within each of these areas:

Planning
Planning activities address the Soft Targets/Crowded Places; Cybersecurity; and Planning Priorities.

TSGP funds may be used for the following types of planning activities:
• Development and enhancement of system-wide security risk management plans that ensure the continuity of essential functions, to include cyber;
• Development or further strengthening of continuity plans, response plans, station action plans, risk assessments, and asset-specific remediation plans; • Development or further strengthening of security assessments, including multi-agency and multi- jurisdictional partnerships and conferences to facilitate planning activities; • Hiring of full or part-time staff and contractors or consultants to assist with planning activities only to the extent that such expenses are for the allowable activities within the scope of the grant (not for the purpose of hiring public safety personnel); hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327; • Materials required to conduct planning activities;
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• Conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Infrastructure Resilience Planning Framework and related CISA resources;
• Planning activities related to alert and warning capabilities; and • Other project planning activities with prior approval from FEMA.

Operational Activities
Operational Activities address the Soft Targets/Crowded Places Priority.

FEMA encourages applicants to develop innovative operational approaches to enhance the security of transit systems. Projects that use visible, unpredictable deterrence, to include operational packages dealing with explosive detection canine teams, mobile screening teams, and anti-terrorism teams, directly support enhancing the protection of soft targets and crowded places. Implementation of one of the three Operational Package (OPack) models discussed below complements existing security systems and provides an appropriate, practical, and cost-effective means of protecting assets.

Agencies may submit Investment Justifications (IJ) to fund transit security police forces/law enforcement providers for patrols and activities on overtime, such as directed patrols, additional canine teams, mobile screening teams, or anti-terrorism team patrols. These activities must be dedicated to the transit environment and must be anti-terrorism in nature. Agencies must identify the type of activity, length of operation (hours), number of personnel, and cost based on length of operation and personnel. Agencies should also provide a risk-based justification for the request, to include linkage to a known event, such as hosting a significant regional sporting or political event; or a period of heightened awareness, such as a national holiday. Three OPack types have been developed to support operational activities and are available for funding under the TSGP:
• Explosives Detection Canine Teams (EDCTs). When combined with the existing capability of a transit security/police force, the added value provided through the addition of an EDCT is significant. EDCTs are a proven, reliable resource to detect explosives and are a key component in a balanced counter-sabotage program. The TSGP will provide funds to establish dedicated security/police force canine teams. Each canine team will be composed of one dog and one handler.
• Anti-Terrorism Teams (ATTs). The ATT capability provided through TSGP funding is for uniformed, dedicated transit patrols on a normal operational basis, rather than using teams only for a surge capacity as provided by FEMA in the past. ATTs do not supersede other local transit security forces; rather, they augment current capabilities. Each ATT will consist of four individuals, including two overt elements (e.g., uniformed transit sector law enforcement officer, canine team, mobile explosive screeners), and two discreet observer elements. • Mobile Explosive Screening Teams (MESTs). The MESt OPack will allow recipients the flexibility to deploy combinations of certified explosive ordinance technicians with mobile explosive screening technologies, including during local National Special Security Events. This screening technology will be coupled with mobile explosive screening technologies. Each MEST should have a minimum of two members and one mobile explosive screening apparatus.

Note: Funds for canine teams may not be used to fund drug detection and apprehension technique training. Only explosives detection training for the canine teams will be funded.

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Funding Availability for OPacks
OPacks have the potential to be funded for up to a 36-month period from the award date. The monetary figures presented below are stated in terms of cost per period of performance (which indicates actual/complete funding for the 36-month period). Additionally, any OPack costs after the 36-month period of performance (including expenses related to the maintenance, personnel, equipment, etc.) are the responsibility of the applicable transit system. If these positions are not sustained, the public transportation agency may not be eligible for this personnel support in the future. The table below identifies the maximum funding available for the different OPack types.

Available Funding for OPacks
Operational Package
Maximum Funding per Year
(12 months)
Maximum Funding per Period of
Performance (36 months)
EDCT $150,000 per team $450,000 per team
ATT $500,000 per team $1,500,000 per team
MEST $600,000 per team $1,800,000 per team
OPack Requirements
TSGp OPack funds may be used for new positions or to sustain existing capabilities/programs (e.g., canine teams) already supported by the recipient. Applicants submitting IJs for both new OPacks and sustainment funding for existing OPacks must clearly indicate which is their highest priority if funding is available for only one of the IJs. Additionally, applicants must provide the number of existing teams (EDCT, ATT, and MEST) already in place with either in-house funding or TSGP funding. The table below identifies specific OPack requirements.

OPack Requirements
Operational Package Requirements
Explosives Detection Canine Teams Please refer to the pages below for detailed information regarding EDCTs under the TSGP.

Five-Year Security Capital Plan and Operational Sustainment Applicant requests for OPack funding must include the submission of a Five-Year Security Capital and Operational Sustainment Plan in ND Grants. This plan must include how the agency proposes to implement capital projects and demonstrate how the agency will sustain the operational investments (including officers hired with federal funding) and capabilities after grant funding has been expended.

Requests for OPacks will not be funded if the applicant does not have a Security Capital and Operational Sustainment Plan.

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Operational Package Requirements
Anti-Terrorism Teams
Specific for the Canine Team within the ATT:
• Each canine team, composed of one dog and one handler, must be certified by an appropriate, qualified organization; • Canines should receive an initial basic training course and also weekly maintenance training sessions thereafter to maintain the certification;
• The basic training averages 10 weeks for the team, with weekly training and daily exercising (comparable training and certification standards, such as those promulgated by the Transportation Security Administration (TSA) Explosive
Detection Canine Program), the National Police Canine
Association (NPCA), the United States Police Canine
Association (USPCA), or the International Explosive
Detection Dog Association (IEDDA) may be used to meet
this requirement;
• The individuals hired for the covert and overt elements must be properly trained law enforcement officers; and
• Certifications should be on file with the recipient and must be made available to FEMA upon request
Mobile Explosives Screening Team Certifications should be on file with the recipient and must be made available to FEMA upon request.

Allowable Expenses for OPacks
The below table identifies allowable expenses for the various OPacks. Please see the inserted notes for clarification of certain allowable costs.

Allowable Expenses for OPacks
Operational Package
Salary and Fringe
Benefits
Training and
Certification
Equipment Costs
Purchase and Train
a Canine
Canine Costsb
1) EDCTa ✓ ✓ ✓ ✓c ✓
2) ATT ✓ ✓ ✓ ✓ ✓
3) MEST ✓ ✓d
a Travel costs associated with training for personnel, handlers, and canines are allowable b Canine costs include but are not limited to veterinary, housing, and feeding costs c One type of allowable training is training specific to the detection of common explosives odors. d Equipment and other costs can include but are not limited to explosives detection; stainless steel search tables; consumables such as gloves, swabs, and alcohol; and land mobile radios Specific Guidance on EDCTs
EDCT Certification. Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified organization. TSA-certified EDCTs will meet or exceed certification standards set by the TSA National Explosives Detection Canine Team Program (NEDCTP). Recipient EDCTs that do not participate in the NEDCTP will be required to certify annually under their respective agency, local TSGP Appendix | 2023 Page D-6
and state regulations. The recipient (i.e., TSGP-grant supported) will maintain certification, utilization, and training data to show their compliance in meeting or exceeding those guidelines set forth by the Scientific Working Group on Dog and Orthogonal Detection Guidelines (SWGDOG), as of September 14, 2007, in addition to requirements set forth in the NOFO.

EDCT Submission Requirements
1) The recipient will ensure that a written security procedure plan exists for the safekeeping of all explosive training aids, including safe transportation. The recipient will document the removal, use, and return of explosive training aids used during training exercises or for any other reason.

The plan and all documentation must be made available to FEMA upon request; 2) The recipient will comply with requirements for the proper storage, handling, and transportation of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulation; 3) The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a day, seven days per week on an on-duty or off-duty on call basis. If TSGP-funded EDCTs are not available, other non-TSGP-funded EDCTs may be utilized for this response. The intent is to provide maximum coverage during peak operating hours and to maintain the ability to promptly respond to threats that affect public safety or mass transit operations; 4) EDCTs under this grant are single purpose and will be trained to detect “live” explosives only not “simulated” explosives. EDCTs must not have received previous training to detect any other substances;
5) Recipient EDCTs will ensure that each EDCT receives on-site proficiency training at a minimum of four hours per week per duty cycle. This training shall include, but not be limited to mass transit passenger cars, terminal/platform, luggage, freight/warehouse, and vehicles. Complete, detailed, and accurate training records must be maintained for all proficiency training conducted by each EDCT. These records must be made available to FEMA upon request; 6) The TSGP grant recipient will conduct appropriate training or other canine activities, within view of the public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts which affect public safety or mass transit operations. Recipient EDCTs will also ensure that such activities include, over a period of time, a presence in operational areas of the mass transit system during peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at least 80% of their duty time, annually;
7) Recipient EDCTs will provide safe and sanitary kennel facilities for program canines, and these costs may be allowable with prior approval by FEMA. This applies to kenneling canines at the mass transit system, handlers’ residences, or commercial boarding facilities. Canines must not be left in makeshift accommodations or without proper supervision, protection, and care. The recipient will ensure that canines are transported on-duty and off-duty in vehicles configured with adequate temperature control, padding and screening to ensure proper health, safety, and security; and
8) Recipient EDCTs will ensure that adequate routine and emergency veterinary care are provided for all canines.

Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour notice to ensure compliance with applicable federal regulations.

Equipment and Capital Projects
Equipment and Capital Projects address the Soft Targets/Crowded Places; Cybersecurity; and Equipment/Capital Projects Priorities.

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Priority projects include Top Transit Asset List (TTAL) risk remediation and protection of other high- risk, high-consequence areas or systems that have been identified through system-wide risk assessments.

These costs include:
• Projects related to physical security enhancements at rail and bus stations in Urban Area Security Initiative (UASI) jurisdictions including security cameras, security screening equipment for people and baggage, and access control (e.g., fences, gates, barriers, etc.); and • Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers, Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems, process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment support. Cybersecurity assessments are allowable.

Equipment Acquisition
TSGP funds must comply with FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards. TSGP funds may be used for the following categories of equipment. A comprehensive listing of allowable equipment categories and types is found in the Authorized Equipment List (AEL).

These costs include:
• Personal protection equipment;
• Explosive device mitigation and remediation equipment; • Chemical, biological, radiological, nuclear, and explosive (CBRNE) operational search and rescue equipment, logistical support equipment, reference materials, or incident response vehicles • Interoperable communications equipment, including alert and warning capabilities; • Components or systems needed to address flaws in the computerized systems that control generators, switching stations, and electrical substations as well as other threats to infrastructure critical to the U.S. economy;
• Detection Equipment;
• Power equipment;
• Terrorism incident prevention equipment; and
• Physical security enhancement equipment.

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 noted, equipment must be certified as meeting required regulatory and FEMA-adopted standards to be eligible for purchase using TSGP funds. Equipment must comply with the Occupational Safety and Health Act requirement for certification of electrical equipment by a nationally recognized testing laboratory and demonstrate compliance with relevant FEMA-adopted standards through a supplier’s declaration of conformity with appropriate supporting data and documentation per International Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One and Two. Agencies must have all necessary certifications and licenses for the requested equipment, as appropriate, prior its purchase. DHS adopted standards are found at DHS Implementation Statement Regarding Standard Terms and Conditions for Research Grants | Homeland Security. In addition, recipients that are using TSGP funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at https://www.cisa.gov/safecom/funding.

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Equipment: Requirements for 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, Prohibited or Controlled Equipment Under FEMA Awards, and also include a description 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.

SUAS policies are not required at the time of application but must be received and approved by FEMA prior to obligating TSGP funds. All grant-funded procurements must be executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients that use TSGP funds for sUAS, FEMA advises that there is a general privacy concern related to the use of this equipment if the data the devices collect is transmitted to servers not under the control of the operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers outside the United States. The U.S. Department of Homeland Security’s Privacy Office suggests the recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data breaches.

Acquisition and Use of Technology to Mitigate UAS (Counter-UAS) In August 2020, FEMA alerted of an advisory guidance document issued by DHS, the Department of Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.

Cybersecurity Projects
TSGP funds may be used for projects that enhance the cybersecurity of:
• Access controls, sensors, security cameras, badge/ID readers, ICS/SCADA systems, process monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.); and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).

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When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the “Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework gathers existing international standards and practices to help organizations understand, communicate, and manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity program, the Framework provides initial guidance. For organizations with more advanced practices, the Framework offers a way to improve their programs, such as better communication with their leadership and suppliers about management of cyber risks.

DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in protecting U.S.-based public and private entities and combines key elements of capabilities under the “Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based companies and SLTT governments defend their computer systems against unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services. Please visit http://www.cisa.gov/enhanced-cybersecurity-services-ecs for a current list of ECS CSP points of contact.

Capital (Construction) Projects Guidance
Capital expenditures are defined in 2 CFR 200.1 Definitions as expenditures to acquire capital assets or expenditures to make additions, improvements, modifications, replacements, rearrangements, reinstallations, renovations, or alterations to capital assets that materially increase their value or useful life. Use of capital expenditures must comply with 2 CFR 200.439.

Recipients must obtain written approval from FEMA prior to the use of any TSGP funds for construction or renovation projects. When applying for construction funds, including communications towers, at the time of application, recipients must submit evidence of approved zoning ordinances, architectural plans, and any other locally required planning permits. Additionally, recipients are required to submit a SF-424C and budget detail citing the project costs and an SF-424D Form for standard assurances for the construction project.

All construction and renovation projects require Environmental Planning and Historic Preservation (EHP) review. Recipients are also encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects; compliance with all state and local EHP laws and requirements).

Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction 108-1-1, instances must also be identified to the FEMA HQ Preparedness Officer within the first six months of the award, regardless of the period of performance. Completed EHP review materials for construction and communication tower projects must be submitted no later than 12 months before the end TSGP Appendix | 2023 Page D-10
of the period of performance. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; and Training and Awareness Campaign Priorities.

Training
TSGP funds may be used for the following training activities:
• Training Topics. Priority topics include active shooter training, security training for employees, and public awareness/preparedness campaigns.
• Training Workshops. Grant funds may be used to plan and conduct training workshops to include costs related to planning, meeting space and other meeting costs, facilitation costs, materials and supplies, travel, and training plan development. Recipients are strongly encouraged to use free public space/locations/facilities, whenever available, prior to the rental of space/locations/facilities. Training should provide the opportunity to demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any training or training gaps, including those for children and individuals with disabilities or other access and functional needs, should be identified in an After-Action Report/Improvement Plan (AAR/IP) and addressed in the training cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or contractors/consultants may be hired to support training-related activities. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Reimbursement of these costs should conform with the policies of the state or local unit§ of government or the awarding agency, whichever is applicable. Such costs must be included within the funding allowed for program management personnel expenses, which must not exceed 10% of the total allocation. Dual compensation is unallowable. That is, an employee of a unit of government may not receive compensation from their unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities. 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.
• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to backfilling personnel, that are the direct result of attendance at FEMA and approved training courses and programs are allowable. Reimbursement of these costs should follow the policies of the state or local u§(s) of government or the awarding agency, whichever is applicable. In no case is dual compensation allowable.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as expenses by employees who are on travel status for official business related, approved training, subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense. • Supplies. Supplies, items that are expended or consumed during the course of the planning and conduct of the training p§ect(s) (e.g., gloves and non-sterile masks), are allowable expenses. • Funds Used to Develop, Deliver, and Evaluate Training, including costs related to administering the training, planning, scheduling, facilities, materials and supplies, reproduction of materials, and equipment are allowable expenses. Training should provide the opportunity to demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any training or training gaps, including those for children and individuals with disabilities or other access and functional needs, should be identified in the AAR/IP and addressed in the training cycle.

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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 instruction design. Information on FEMA-approved training can found at http://www.firstrespondertraining.gov/.

Awareness Campaigns
TSGP funds may be used for the development and implementation of awareness campaigns to raise public awareness of indicators of terrorism and terrorism-related crime, and for associated efforts to increase the sharing of information with public and private sector partners, including nonprofit organizations. DHS currently sponsors or supports a number of awareness campaigns. Please review materials, strategies, and resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness campaign for local constituencies and stakeholders.

Note: DHS requires that all public and private sector partners wanting to implement and/or expand the DHS “If You See Something, Say Something®” campaign using grant funds work directly with the DHS Office of Partnership and Engagement (OPE). This will help ensure that the awareness materials (e.g., videos, posters, trifolds, etc.) remain consistent with DHS’s messaging and strategy for the campaign and compliant with the initiative’s trademark, which is licensed to DHS by the New York Metropolitan Transportation Authority. Coordination with OPE, through the Campaign’s Office ([email protected]), must be facilitated by the FEMA HQ Preparedness Officer.

Exercises
Exercise activities address the Soft Targets/Crowded Places; Cybersecurity; and Exercises Priorities.

TSGP funds may be used for the following exercise activities:
• Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs related to planning, meeting space, and other meeting costs, facilitation costs, materials and supplies, travel, and documentation. Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting. Any shortcoming or gap identified, including those for children and individuals with disabilities or other access and functional needs, should be identified in an effective corrective action program that includes development of improvement plans that are dynamic documents, with corrective actions continually monitored and implemented as part of improving preparedness through the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be hired to support exercise-related activities. In order to be eligible for reimbursement, the costs for hiring staff must conform to the policies of the non-federal entity and federal statutes, where applicable. See, e.g., 2 C.F.R. § 200.430(a). The costs for hiring contractors or consultants must comply with the applicable federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. The costs for hiring staff, consultants, or contractors to support exercise-related activities costs must be included within the funding allowed for program management personnel expenses, which must not exceed 10% of the total allocation. Dual compensation is never allowable, meaning, in other words, that an employee of a unit of government may not receive compensation from their unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work may benefit both entities. 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.

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• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to backfilling personnel, which are the direct result of time spent on the design, development and conduct of exercises are allowable expenses. These costs are allowed only to the extent the payment for such services is in accordance with the policies of the state or unit§ of local government and has the approval of the state or the awarding agency, whichever is applicable.

Dual compensation is never allowable.
• Travel. Domestic travel costs are allowable as expenses by employees who are on travel status for official business related to the planning and conduct of exercise proj§(s), subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense. • Supplies. Supplies are items that are expended or consumed during the course of the planning and conduct of the exercise p§ect(s) (e.g., gloves, non-sterile masks, and disposable protective equipment).
• Other Items. These costs include the rental of space/locations for exercise planning and executing, rental of equipment, etc. Recipients are encouraged to use free public space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.

These also include costs that may be associated with inclusive practices and the provision of reasonable accommodations and modifications to provide full access for children and adults with disabilities.

Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly related to managing and administering the award. Recipients may use up to 5% of the amount of the award for their M&A.

FY 2023 TSGP funds may be used for the following M&A costs:
• Hiring of full-time or part-time staff, including contractors and consultants, to execute the following:
o Management of the current fiscal year TSGP Award;
o Design and implementation of the current fiscal year TSGP submission meeting compliance with reporting/data collection requirements, including data calls; o Information collection and processing necessary to respond to FEMA data calls; o Domestic-only travel expenses related to TSGP grant administration, in compliance with 2 C.F.R. Part 200; and
o Acquisition of authorized office equipment, including personal computers or laptops for TSGP M&A purposes.

Allowable Indirect Costs
Indirect costs are allowable under this. See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty coverage, licenses, and user fees. These contracts may exceed the period of performance if they are purchased incidental to the original purchase of the system or equipment as long as the original purchase of the system or equipment is consistent with that which is typically provided for, or available through, these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending an existing maintenance contract on an already-owned piece of equipment system, coverage purchased may not exceed the period of performance of the award used to purchase the maintenance agreement or warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.

Grant funds are intended to support the National Preparedness Goal and fund projects that build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program, and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs may also be in support of equipment, training, and critical resources that have previously been purchased with either federal grant or any other source of funding other than FEMA preparedness grant program dollars.

Encouraged Use of Certain Products Produced in the United States Pursuant to Executive Order 13858, “Strengthening Buy-American Preferences for Infrastructure Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent practicable and consistent with the law, iron and aluminum as well as steel, cement, and other manufactured products produced in the United States, in projects funded by an award under this grant program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation; ports, including navigational channels; water resources projects; energy production, generation, and storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care that all procurements and contract actions are consistent with law, the Preparedness Grants Manual and applicable appendices, the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§ 200.317-200.326.

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Program Appendix E:

Intercity Bus Security Grant Program (IBSGP)
As a reminder, while this appendix contains IBSGP-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the IBSGP. Please be sure to read the main content of this Manual in addition to the program-specific appendices.

IBSGP grant recipients may only use IBSGP grant funds for the purpose set forth in the Notice of Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award. Grant funds may not be used for matching funds for 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.

IBSGP Funding Guidelines
Costs charged to an IBSGP award must be consistent with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more information on 2 C.F.R. Part 200, please see IB 400 regarding FEMA’s implementation of these provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations, see 2 CFR Grants Management Policy Updates.

IBSGP Priorities
See the annual IBSGP NOFO.

Allowable Direct Costs
Specific investments made in support of the funding priorities discussed in the annual IBSGP NOFO generally fall into one of the following six allowable expense categories:

1. Planning;

2. Operational Activities;

3. Equipment and Capital Projects;

4. Training and Awareness Campaigns;

5. Exercises; and

6. Management and Administration.

The following provides guidance on allowable costs within each of these areas.

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Planning
Planning activities should address the Soft Targets/Crowded Places; Cybersecurity; and Planning Priorities.

IBSGP funds may be used for the following types of planning activities:
• Development and enhancement of system-wide security risk management plans, to include cyber; • Development or further strengthening of continuity of operations plans, response plans, station action plans, risk assessments, and asset-specific remediation plans; • Development or further strengthening of security assessments, including multi-agency and multi- jurisdictional partnerships and conferences to facilitate planning activities; • Hiring of full- or part-time staff and contractors or consultants to assist with planning activities only to the extent that such expenses are for the allowable activities within the scope of the grant (not for the purpose of hiring public safety personnel); hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327; • Materials required to conduct planning activities;
• Conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Infrastructure Resilience Planning Framework and related CISA resources;
• Planning activities related to alert and warning capabilities; and • Other project planning activities with prior approval from FEMA.

Operational Activities
Operational Activities should address the Soft Targets/Crowded Places Priority.

FEMA encourages applicants to develop innovative operational approaches to enhance the security of transportation systems. Examples include:
• Establishing or improving emergency communication systems linking drivers and over-the-road buses to company operation centers, law enforcement agencies or emergency response personnel; • Acquiring and installing equipment or systems that collect, store or exchange passenger and/or driver information with established government databases for security purposes; and • Implementing and operating established methodologies for screening passengers, their carry-on baggage, and/or their checked baggage, for weapons and/or explosives.

Equipment and Capital Projects
Equipment and Capital Projects should address the Soft Targets/Crowded Places; Cybersecurity; and Equipment/Capital Projects Priorities.

Equipment – Vehicle/Driver Security Enhancements
Vehicle Security Enhancements focus on vehicle disabling and anti-theft devices, real-time bus inventory and inventory control, tracking, monitoring, alert and warning capabilities, and locating technologies.

Driver security enhancements focus on protection for the bus driver to prevent would-be terrorists from immobilizing the driver and/or hijacking the bus. Applicants are discouraged from submitting projects that propose the use of closed-circuit television (CCTV) alone as an on-board deterrent to terrorism.

Rather, any cameras should have the capability and protocols in place for incident-based real-time monitoring. CCTV Systems that are primarily archival, and do not clearly specify the ability for live monitoring in the Investment Justification (IJ) will not be funded.

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Capital Projects – Facility Security Enhancements
• Projects related to physical security enhancements at bus stations, or operator-owned facilities including but not limited to lighting, security cameras, security screening equipment for people and baggage, and access control (e.g., fences, gates, barriers); • Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers, Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems, process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment support. Cybersecurity assessments are allowable; and
• Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or contractors/consultants may be hired to support security enhancement-related activities. 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. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.

Note: All Capital and Vehicle/Driver security enhancement projects that include cameras, video surveillance, or alarm systems MUST either be live monitored 24/7 or have the capability for real-time incident-based monitoring. CCTV Systems that are primarily archival and do not clearly specify the ability for live monitoring in the IJ will not be funded.

Equipment Acquisition
IBSGP funds must comply with FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards, and may be used for the following categories of equipment. A comprehensive listing of allowable equipment categories and types is found in the Authorized Equipment List (AEL). These costs include:
• Personal protection equipment;
• Explosive device mitigation and remediation equipment; • Chemical, biological, radiological, nuclear, and explosive (CBRNE) operational search and rescue equipment, or logistical support equipment;
• Interoperable emergency communications equipment;
• Detection equipment;
• Terrorism incident prevention equipment; and
• Physical security enhancement equipment.

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

Unless otherwise noted, equipment must be certified as meeting required regulatory and DHS- adopted standards to be eligible for purchase using these funds. Equipment must comply with the Occupational Safety and Health Act requirement for certification of electrical equipment by a nationally recognized testing laboratory and demonstrate compliance with relevant DHS-adopted standards through a supplier’s declaration of conformity with appropriate supporting data and documentation per International Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One and Two. Agencies must have all necessary certifications and licenses for the requested equipment, as appropriate, prior to the request. In addition, recipients that are using IBSGP funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. SAFECOM Guidance can be found at:
https://www.cisa.gov/safecom/funding.

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Cybersecurity Projects
IBSGP funds may be used for projects that enhance the cybersecurity of:
• Access controls; sensors; security cameras; badge/ID readers; ICS/SCADA systems; process monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.).

CCTV Systems that are primarily archival, and do not clearly specify the ability for live monitoring in the IJ will not be funded; and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).

When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (“The Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework gathers existing international standards and practices to help organizations understand, communicate, and manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity program, the Framework provides initial guidance. For organizations with more advanced practices, the Framework offers a way to improve their programs, such as better communication with their leadership and suppliers about management of cyber risks.

DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain types of malicious traffic from entering a company’s networks.

Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services.

Please visit Enhanced Cybersecurity Services (ECS) | CISA for a current list of ECS CSP points of contact.

Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any IBSGP funds for construction or renovation projects. When applying for construction funds, including communications towers, at the time of application, recipients must submit evidence of approved zoning ordinances, architectural plans, any other locally required planning permits. Additionally, recipients are required to submit a SF-424C and budget detail citing the project costs and an SF-424D Form for standard assurances for the construction project.

All Capital (Construction) projects require Environmental Planning and Historic Preservation (EHP) review. Recipients are also encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects; compliance with all state and EHP laws and requirements).

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Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction 108-1-1, instances must also be identified to the FEMA HQ Preparedness Officer within the first six months of the award. Completed EHP review materials for construction and communication tower projects must be submitted no later than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; and Training and Awareness Campaign Priorities.

Training
IBSGP funds may be used for the following training activities:
• Training Topics. Priority topics include active shooter training, security training for employees, and public awareness/preparedness campaigns. The IJ narrative for Training should include:
o A course syllabus, curriculum, or topic plan identifying the proposed course material and contents; and
o Provide the total cost of the training course, the number of participants, and the cost per participant breakdown.
• Training Workshops. Grant funds may be used to plan and conduct training workshops or conferences including costs related to planning, meeting space and other meeting costs, facilitation costs, materials and supplies, travel, and training plan development. • Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be hired to support training-related activities. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. The services of contractors/consultants may also be procured in the design, development, conduct, and evaluation of CBRNE training. 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.
• Overtime and Backfill Costs. Overtime and backfill costs associated with the design, development, and conduct of training are allowable expenses. Payment of overtime expenses will be for work performed by recipient or subrecipient employees in excess of the established work week related to the planning and conduct of the trainin§roject(s). Furthermore, overtime payments and backfill costs associated with sending personnel to training are allowable. Grant funds cannot be used for personnel or direct salary costs for employees to attend training sessions.

Recipients seeking to claim overtime or backfill costs will be required to submit verification.

Straight time costs are not eligible expenses.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, hotel, etc.) are allowable as expenses by employees who are on travel status for official business related to the planning and conduct of the trai§g project(s) or for attending courses. These costs must be in accordance with applicable state law and regulations as well as the principles at 2 C.F.R. Part 200. International travel is not an allowable cost under IBSGP.
• Supplies. Supplies are items that are expended or consumed during the course of the planning and conduct of the t§ning project(s) (e.g., copying paper, gloves, tape, and non-sterile masks). • Funds Used to Develop, Deliver, and Evaluate Training, including costs related to administering the training, planning, scheduling, facilities, materials and supplies, reproduction of materials, and equipment are allowable expenses. Training should provide the opportunity to IBSGP Appendix | 2023 Page E-6
demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any training or training gaps, including those for individuals with disabilities or other access and functional needs, should be identified in the AAR/IP and addressed in the training cycle. • Developing New Courses. 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. Information on FEMA-approved training can found at First Responder Training System. • Other Items. These costs include the rental of space/locations for planning and conducting training, badges, etc. Recipients are encouraged to use free public space/locations, whenever available, prior to the rental of space/locations.

Awareness Campaigns
IBSGP funds may be used for the development and implementation of awareness campaigns to raise public awareness of indicators of terrorism and terrorism-related crime, and associated efforts to increase the sharing of information with public and private sector partners, including nonprofit organizations. DHS currently sponsors or supports a number of awareness campaigns. Please review materials, strategies, and resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness campaign for your local constituencies and stakeholders.

Note: DHS requires that all public and private sector partners wanting to implement and/or expand the DHS “If You See Something, Say Something®” campaign using grant funds work directly with the DHS Office of Partnership and Engagement (OPE). This will help ensure that the awareness materials (e.g., videos, posters, trifolds, etc.) remain consistent with the Department’s messaging and strategy for the campaign and compliant with the initiative’s trademark, which is licensed to DHS by the New York Metropolitan Transportation Authority. Coordination with OPE, through the Campaign’s Office ([email protected]), must be facilitated by the FEMA HQ Preparedness Officer.

Exercises
Exercise activities should address the Soft Targets/Crowded Places; Cybersecurity; and Exercises Priorities.

IBSGP funds may be used for the following exercise activities:
• Funds Used to Design, Develop, Conduct, and Evaluate an Exercise. This includes costs related to planning, meeting space, and other meeting costs, facilitation costs, materials and supplies, travel, and documentation. Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting. Any shortcoming or gap identified, including those for children and individuals with disabilities or other access and functional needs, should be identified in an effective corrective action program that includes development of improvement plans that are dynamic documents, with corrective actions continually monitored and implemented as part of improving preparedness through the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be hired to support exercise-related activities. The services of contractor/consultant staff may be procured to support exercise-related activities. The services of contractors/consultants may also be procured to support the design, development, conduct, and evaluation of terrorism exercises.

Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.
• Overtime and Backfill Costs. Overtime and backfill costs associated with the design, development, and conduct of terrorism exercises are allowable expenses. Payment of overtime IBSGP Appendix | 2023 Page E-7
expenses will be for work performed in excess of the established work week related to the planning and conduct of the exercise project(s). Further, overtime payments and backfill costs associated with sending personnel to exercises are allowable, provided that the event being attended is a DHS sponsored exercise. For positions not funded by the grant award, grant funds cannot be used for personnel or straight salary costs for employees to attend exercises, meaning straight time costs for non-grant funded employees to attend exercise are not allowable. Instead, for positions not funded by the grant award, only overtime and backfill costs will be allowable for those employees to attend exercises. Recipients seeking to claim overtime or backfill costs will be required to submit verification.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, hotel, etc.) are allowable as expenses by employees who are on travel status for official business related to the planning and conduct of the exercise project(s). International travel is not allowable under this program. • Supplies. Supplies are items that are expended or consumed during the course of the planning and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective equipment).
• Other Items. These costs include the rental of space/locations for exercise planning and executing, rental of equipment, etc. Recipients are encouraged to use free public space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.

FY 2023 IBSGP funds may be used for the following M&A costs:
• Hiring of full-time or part-time staff including contractors and consultants, to execute the following:
o Management of the current fiscal year IBSGP award; and o Design and implementation of the current fiscal year IBSGP submission meeting compliance with reporting/data collection requirements, including data calls. • Information collection and processing necessary to respond to FEMA data calls; and • Domestic travel expenses related to IBSGP grant administration.

Indirect Costs
Indirect costs are allowable under this program. See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

Unallowable Costs
Specific unallowable costs include:
• 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; IBSGP Appendix | 2023 Page E-8
• General-use facility expenditures, to include, but not limited to ordinary facility maintenance, contracts for maintenance, and specifically backup or emergency generators; • General vehicle maintenance, service contracts, or warranties. This is different from maintenance and sustainment costs that are allowable, but only for projects funded under a grant award. For projects or equipment not funded by the grant award, general maintenance, service contracts, and warranties are not allowable;
• Expenditures for items such as general-use software (word processing, spreadsheet, graphics, etc.), general-use computers and related equipment (other than for allowable M&A activities, or otherwise associated preparedness or response functions), general-use vehicles, licensing fees, recurring operating costs (e.g., cell phone services, maintenance contracts); • Organizational operating expenses;
• Personnel costs, to include, but not limited to, overtime and backfill (except as detailed above); • Activities unrelated to the completion and implementation of the IBSGP; • Other indirect costs (meaning property purchase, depreciation, or amortization expenses); • Initiatives in which federal agencies are the beneficiary or that enhance federal property; • Initiatives which study technology development;
• Proof-of-concept initiatives;
• Initiatives that duplicate capabilities being provided by the Federal Government; • Other items not in accordance with the AEL, in accordance with FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards, or not previously listed as allowable costs; and
• Pre-award costs are not allowable and will not be approved, with the exception of costs resulting from pre-award grant writing services provided by an independent contractor that shall not exceed $1,500, as detailed in “Pre-Award Costs” above and in the IBSGP NOFO.

Other Allowable Costs
Mainte
nance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty coverage, licenses, and user fees. These contracts may exceed the period of performance if they are purchased incidental to the original purchase of the system or equipment as long as the original purchase of the system or equipment is consistent with that which is typically provided for, or available through, these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending an existing maintenance contract on an already-owned piece of equipment system, coverage purchased may not exceed the period of performance of the award used to purchase the maintenance agreement or warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.

Grant funds are intended to support the National Preparedness Goal (the Goal) and fund projects that build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs which must be in (1) direct support of existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program, and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs may also be in support of equipment, training, and critical resources that have previously been purchased with either federal grant or any other source of funding other than FEMA preparedness grant program dollars.

IBSGP Appendix | 2023 Page E-9
Bonds
Financial markets are not always predictable, and commercial suppliers are not always reliable; but there are options to provide resource contingencies to support an IBSGP award. • Prepayment Bond: Prepayment Bonds provide a measure of economic security for an organization that is going to advance funds to a vendor(s). The prepayment bond generally may be obtained through the vendor or bank. The prepayment bond protects funds in the event a vendor fails to perform (e.g., not finishing/delivering contracted service/equipment, or going out of business). Prepayment bonds are chargeable to an award. o Encouraged Prepayment Bond: Recipients are strongly recommended, but not required, to obtain a prepayment bond for awarded acquisition activities that exceed the Simplified Acquisition Threshold (SAT) (currently $250,000, but the applicable dollar threshold will be the SAT amount in place at the time of procurement) when recipients are contractually required to advance a down payment and when such advances contain no federal funds (only local funds).
o Required Prepayment Bond: Per 2 C.F.R. § 200.304(b), recipients are required to obtain a prepayment bond for awarded acquisition activities that exceed the SAT; a prepayment bond is required when recipients are contractually required to advance a down payment and when such advances contain only federal funds or a combination of federal and local funds.
• Fidelity Bond: Reasonable costs of fidelity bonds (or like insurance as provided for by applicable state or tribal laws) covering the maximum amount of IBSGP funds the officer, official, or employee handles at any given time for all personnel who disburse or approve disbursement of IBSGP funds may be allowable if required by the terms and conditions of the award or if generally required by the tribe in its generally operations. If a fidelity bond is required by a recipient in its general operations, those costs must be charged as indirect costs. See 2 C.F.R. § 200.427.

Encouraged Use of Certain Products Produced in the United States Pursuant to Executive Order 13858 “Strengthening Buy-American Preferences for Infrastructure Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent practicable and consistent with the law, iron and aluminum as well as steel, cement, and other manufactured products produced in the United States, in projects funded by an award under this grant program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation; ports, including navigational channels; water resources projects; energy production, generation, and storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care that all procurements and contract actions are consistent with law, this Manual and applicable appendices, the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§ 200.317-200.326.

IPR Appendix | 2023 Page F-1
Program Appendix F:

Intercity Passenger Rail (IPR) Program
As a reminder, while this appendix contains IPR-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the IPR. Please be sure to read the main content of this Manual in addition to the program-specific appendices.

The IPR grant recipient may only use IPR grant funds for the purposes set forth in the Notice of Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award.

IPR Funding Guidelines
Costs charged to a an IPR award must be consistent with the uniform administrative requirements and audit requirements for federal awards, located at 2 C.F.R. Part 200, Subparts A-D and F. For more information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400 regarding FEMA’s implementation of these provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov. Costs charged to an IPR award must also be consistent with the cost principles in the Federal Acquisition Regulation (FAR) Part 31.2 in lieu of 2 C.F.R. Part 200, Subpart E. Any conflicts between FAR 31.2 and 2 C.F.R.

Part 200, Subpart E shall be resolved in favor of the applicable provision in FAR 31.2.

IPR Priorities
See the annual IPR NOFO.

Security Plan Requirements
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):

Security plans should include the following, as appropriate:
• A prioritized list of all items included in the public transportation agency’s security assessment that have not yet been addressed;
• A detailed list of any additional capital and operational improvements identified by DHS or the public transportation agency and a certification of the public transportation agency’s technical capacity for operating and maintaining any security equipment that may be identified in such list; • Specific procedures to be implemented or used by the public transportation agency in response to a terrorist attack, including evacuation and passenger communication plans and appropriate evacuation and communication measures for the elderly and individuals with disabilities; • A coordinated response plan that establishes procedures for appropriate interaction with state and local law enforcement agencies, emergency responders, and federal officials in order to coordinate security measures and plans for response in the event of a terrorist attack or other major incident;
IPR Appendix | 2023 Page F-2
• A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part 1580;
• Plans for providing redundant and other appropriate backup systems necessary to ensure the continued operation of critical elements of the public transportation system in the event of a terrorist attack or other major incident;
• Plans for providing service capabilities throughout the system in the event of a terrorist attack or other major incident in the city or region which the public transportation system serves; • Methods to mitigate damage within a public transportation system in case of an attack on the system, including a plan for communication and coordination with emergency responders; and • Other actions or procedures as the Secretary of Homeland Security determines are appropriate to address the security of the system.

Allowable Costs
Specific investments made in support of the funding priorities discussed in the annual IPR NOFO generally fall into one of the following six allowable expense categories:
1) Planning;
2) Operational Activities;
3) Equipment and Capital Projects;
4) Training and Awareness Campaigns;
5) Exercises; and
6) Management and Administration.

The following provides guidance on allowable costs within each of these areas.

Planning
Planning activities that address the Soft Targets/Crowded Places Priority.

IPR funds may be used for the following types of planning activities:
• Development and enhancement of system-wide security risk management plans that ensure the continuity of essential functions, to include cyber;
• Development or further strengthening of continuity plans, response plans, station action plans, risk assessments, and asset-specific remediation plans; • Development or further strengthening of security assessments, including multi-agency and multi- jurisdictional partnerships and conferences to facilitate planning activities; • Hiring of full or part-time staff and contractors or consultants to assist with planning activities only to the extent that such expenses are for the allowable activities within the scope of this grant (not for the purpose of hiring public safety personnel); hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327 • Materials required to conduct planning activities;
• Conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Infrastructure Resilience Planning Framework and related CISA resources;
• Planning activities related to alert and warning capabilities; and • Other project planning activities, with prior approval from FEMA.

IPR Appendix | 2023 Page F-3
Operational Activities
Operational Activities that address the Soft Targets/Crowded Places Priority.

FEMA encourages applicants to develop innovative operational approaches to enhance the security of transit systems. Projects that use visible, unpredictable deterrence, including operational packages dealing with explosive detection canine teams, mobile screening teams, and anti-terrorism teams, directly support enhancing the protection of soft targets and crowded places. Implementation of one of the three Operational Package (OPack) models discussed below complements existing security systems and provides an appropriate, practical, and cost-effective means of protecting assets.

Agencies may submit IJs to fund transit security police forces/law enforcement providers for patrols and activities on overtime, such as directed patrols, additional canine teams, mobile screening teams, or anti- terrorism team patrols. These activities must be dedicated to the transit environment and must be anti- terrorism in nature. Agencies must identify the type of activity, length of operation (hours), number of personnel, and cost based on length of operation and personnel. Agencies should also provide a risk-based justification for the request, including linkage to a known event, such as hosting a significant regional sporting or political event; or a period of heightened awareness, such as a national holiday. Three OPack types have been developed to support operational activities and are available for funding under the IPR:
• Explosives Detection Canine Teams (EDCTs). When combined with the existing capability of a transit security/police force, the added value provided through the addition of an EDCT is significant. EDCTs are a proven, reliable resource to detect explosives and are a key component in a balanced counter-sabotage program. The TSGP will provide funds to establish dedicated security/police force canine teams. Each canine team will be composed of one dog and one handler.
• Anti-Terrorism Teams (ATTs). The ATT capability provided through TSGP funding is for uniformed, dedicated transit patrols on a normal operational basis, rather than using teams only for a surge capacity as provided by FEMA in the past. ATTs do not supersede other local transit security forces; rather, they augment current capabilities. Each ATT will consist of four individuals, including two overt elements (e.g., uniformed transit sector law enforcement officer, canine team, mobile explosive screeners), and two discreet observer elements. • Mobile Explosive Screening Teams (MESTs). The MEST OPack will allow recipients the flexibility to deploy combinations of certified explosive ordinance technicians with mobile explosive screening technologies, including during local National Special Security Events. This screening technology will be coupled with mobile explosive screening technologies. Each MEST should have a minimum of two members and one mobile explosive screening apparatus.

Note: Funds for canine teams may not be used to fund drug detection and apprehension technique training. Only explosives detection training for the canine teams will be funded.

Requests for OPacks will not be funded if the applicant does not have and submit a Security Capital and Operational Sustainment Plan.

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Funding Availability for OPacks
OPacks have the potential to be funded for up to a 36-month period from the award date. The monetary figures presented below are stated in terms of cost per period of performance (which indicates actual/complete funding for a 36-month period). Additionally, any OPack costs after the period of performance (including expenses related to the maintenance, personnel, equipment, etc.) are the responsibility of the applicable transit system. Additional funding may be applied for in future grant cycles to maintain this operational capability, but future funding is not guaranteed and requires approval.

If these positions are not sustained, the public transportation agency may not be eligible for this personnel support in the future. The table below identifies the maximum funding available for the different OPack types.

Available Funding for OPacks
Operational Package
Maximum Funding per Year
(12 months)
Maximum Funding per Period of
Performance (36 months)
EDCT $150,000 per team $450,000 per team
ATT $500,000 per team $1,500,000 per team
MEST $600,000 per team $1,800,000 per team
OPack Requirements
IPR OPack funds may be used for new positions or to sustain existing capabilities/programs (e.g., canine teams) already supported by the recipient. Applicants pursuing both new OPacks and sustainment funding for existing OPacks must indicate in their IJs which funding the higher priority for their agency is.

Additionally, applicants must provide the number of existing teams (EDCT, ATT, and MEST) already in place, regardless of how they are funded. The below table identifies specific OPack requirements.

OPack Requirements
Operational
Package
Requirements
EDCT Please refer to the pages below for detailed information regarding EDCTs under the IPR
ATT
Specific for the Canine Team within the ATT:
• Each canine team, composed of one dog and one handler, must be certified by an appropriate, qualified organization
• Canines should receive an initial basic training course and also weekly maintenance training sessions thereafter to maintain the certification • The basic training averages 10 weeks for the team, with weekly training and daily exercising (comparable training and certification standards, such as those promulgated by the Transportation Security Administration (TSA) Explosive Detection Canine Program), the National Police Canine Association (NPCA), the United States Police Canine Association (USPCA), or the International Explosive Detection Dog Association (IEDDA) may be used to meet this requirement
• The individuals hired for the covert and overt elements must be properly trained law enforcement officers
• Certifications should be on file with the recipient and must be made available to FEMA upon request
MEST Certifications should be on file with the recipient and must be made available to FEMA upon request
IPR Appendix | 2023 Page F-5
Allowable Expenses for OPacks
The table below identifies allowable expenses for the various OPacks. Please see the accompanying notes for clarification of certain allowable costs.

Allowable Expenses for OPacks
Operational Package
Salary and Fringe
Benefits
Training and
Certification
Equipment Costs
Purchase and Train
a Canine
Canine Costsb
1) EDCTa ✓ ✓ ✓ ✓c ✓
2) ATT ✓ ✓ ✓ ✓ ✓
3) MEST ✓ ✓d
a Travel costs associated with training for personnel, handlers, and canines are allowable b Canine costs include but are not limited to a canine’s veterinary, housing, and feeding costs c One type of allowable training is training specific to the detection of common explosives odors d Equipment and other costs can include but are not limited to explosives detection; stainless steel search tables; consumables such as gloves, swabs, and alcohol; and land mobile radios Specific Guidance on EDCT
EDCT Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified organization. TSA-certified EDCTs will meet or exceed certification standards set by the TSA National Explosives Detection Canine Team Program (NEDCTP). Recipient EDCTs that do not participate in the NEDCTP will be required to certify annually under their respective agency, local, and state regulations.

The recipient will maintain certification, utilization, and training data to show compliance in meeting or exceeding those guidelines set forth by the Scientific Working Group on Dog and Orthogonal Detection Guidelines (SWGDOG), as of September 14, 2007, in addition to the requirements set forth in the NOFO.

The plan and all documentation must be made available to FEMA upon request; 2) The recipient will comply with requirements for the proper storage, handling, and transportation of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulation; 3) The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a day, 7 days per week on an on-duty or off-duty on-call basis. If IPR-funded EDCTs are not available, other, non-IPR funded EDCTs may be utilized for this response. The intent is to provide maximum coverage during peak operating hours and to maintain the ability to promptly respond to threats that affect public safety or mass transit operations; IPR Appendix | 2023 Page F-6
4) EDCTs under this grant are single purpose and will be trained to detect “live” explosives only, not “simulated” explosives. EDCTs must not have received previous training to detect any other substances;
5) The recipient will ensure that each EDCT receives on-site proficiency training at a minimum of 4 hours per week per duty cycle. This training shall include, but not be limited to, mass transit passenger cars, terminals/platforms, luggage, freight/warehouses, and vehicles. Complete, detailed, and accurate training records must be maintained for all proficiency training conducted by each EDCT. These records must be made available to FEMA upon request; 6) The recipient will conduct appropriate training or other canine activities, within view of the public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts which affect public safety or mass transit operations. The recipient will also ensure that such activities include, over a period of time, a presence in operational areas of the mass transit system during peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at least 80% of their duty time, annually;
7) The recipient will provide safe and sanitary kennel facilities for program canines, and these costs may be allowable with prior approval by FEMA. This applies to kenneling canines at a mass transit system, handlers’ residences, or commercial boarding facilities. Canines must not be left in makeshift accommodations or without proper supervision, protection, and care. The recipient will ensure that canines are transported on-duty and off-duty in vehicles configured with adequate temperature control, padding, and screening to ensure proper health, safety, and security; and 8) The recipient will ensure that adequate routine and emergency veterinary care are provided for all canines.

Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour notice to ensure compliance with applicable federal regulations.

Equipment and Capital Projects
Equipment and Capital Projects that address the Soft Targets/Crowded Places and Cybersecurity Priorities.

Priority projects include Top Transit Asset List (TTAL) risk remediation and protection of other high- risk, high-consequence areas or systems that have been identified through system-wide risk assessments:
• Projects related to physical security enhancements at rail and bus stations in Urban Area Security Initiative (UASI) jurisdictions, including security cameras, security screening equipment for people and baggage, and access control (e.g., fences, gates, barriers, etc.); and • Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers, Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems, process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment support. Cybersecurity assessments are allowable.

Equipment Acquisition
IPR funds may be used for the following categories of equipment. A comprehensive listing of allowable equipment categories and types is found in the Authorized Equipment List (AEL). These costs include:
• Personal protection equipment;
• Explosive device mitigation and remediation equipment; IPR Appendix | 2023 Page F-7
• Chemical, biological, radiological, nuclear, and high explosive (CBRNE) operational search and rescue equipment, logistical support equipment, reference materials, or incident response vehicles;
• Interoperable communications equipment, including for alert and warning capabilities; • Components or systems needed to address flaws in the computerized systems that control generators, switching stations, and electrical substations as well as other threats to infrastructure critical to the U.S. economy;
• Detection Equipment;
• Power equipment;
• Terrorism incident prevention equipment; and
• Physical security enhancement equipment.

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

Unless otherwise noted, equipment must be certified as meeting required regulatory and FEMA-adopted standards to be eligible for purchase using IPR funds. Equipment must comply with the Occupational Safety and Health Act requirement for certification of electrical equipment by a nationally recognized testing laboratory and demonstrate compliance with relevant FEMA-adopted standards through a supplier’s declaration of conformity with appropriate supporting data and documentation per International Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One and Two. The recipient must have all necessary certifications and licenses for the requested equipment, as appropriate, prior its purchase. In addition, recipients that are using IPR funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at:
https://www.cisa.gov/safecom/funding.

SUAS policies are not required at the time of application but must be received and approved by FEMA prior to obligating IPR funds. All grant-funded procurements must be executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients that use IPR funds for sUAS, FEMA advises that there is a general privacy concern related to the use of this equipment if the data the devices collect is transmitted to servers not under the control of the operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers outside the United States. The U.S. Department of Homeland Security’s Privacy Office suggests the recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data breaches.

Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2023 DHS Appropriations further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign- made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign- made versus domestic sUAS.

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Acquisition and Use of Technology to Mitigate UAS (Counter-UAS) In August 2020, FEMA was alerted you of an advisory guidance document issued by DHS, the Department of Justice, the Federal Aviation Administration, and the Federal Communications Commission: https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation- technologies. The purpose of the advisory guidance document is to help non-federal public and private entities better understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate threats posed by UAS operations (i.e., Counter-UAS or C-UAS).

Cybersecurity Projects
IPR funds may be used for projects that enhance the cybersecurity of:
• Access controls, sensors; security cameras, badge/ID readers, ICS/SCADA systems, process monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.); and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).

When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the “Framework”), developed by the National Institute of Standards and Technology (NIST). The Framework gathers existing international standards and practices to help organizations understand, communicate, and manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity program, the Framework provides initial guidance. For organizations with more advanced practices, the Framework offers ways to improve their programs, such as through better communication with their leadership and suppliers about management of cyber risks.

DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in protecting U.S.-based public and private entities and combines key elements of capabilities under the “Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the Framework. Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based companies and SLTT governments defend their computer systems against unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from IPR Appendix | 2023 Page F-9
sensitive and classified Government Furnished Information. DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services. Please visit http://www.cisa.gov/enhanced- cybersecurity-services-ecs for a current list of ECS CSP points of contact.

Capital (Construction) Projects Guidance
The recipient must obtain written approval from FEMA prior to the use of any IPR funds for construction or renovation projects. When applying for construction funds, including communications towers, the recipient must submit evidence of approved zoning ordinances, architectural plans, any other locally required planning permits. Additionally, the recipient is required to submit a SF-424C and budget detail citing the project costs and an SF-424D Form for standard assurances for the construction project.

Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, EHP Directive and Instruction, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer within the first six months of the award, regardless of the length of the period of performance. Completed EHP review materials for construction and communication tower projects must be submitted no later than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

If the recipient uses funds for construction projects, it must comply with the Davis-Bacon Act (codified as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 1163(h) (cross-referencing 49 U.S.C. § 24312, which cross-references Davis-Bacon). It must ensure that its contractors or subcontractors for construction projects pay workers no less than the prevailing wages for laborers and mechanics employed on projects of a character similar to the contract work in the civil subdivision of the state in which the work is to be performed. Additional information regarding compliance with the Davis-Bacon Act, including the Department of Labor (DOL) wage determinations, is available at https://www.dol.gov/whd/govcontracts/dbra.htm.

Training and Awareness Campaigns
Training and Awareness Campaigns that address the Soft Targets/Crowded Places and Cybersecurity Priorities.

Training
IPR funds may be used for the following training activities:
• Training Topics. Priority topics include active shooter training, security training for employees, and public awareness/preparedness campaigns.
• Training Workshops. Grant funds may be used to plan and conduct training workshops, including costs related to planning, meeting space and other meeting costs, facilitation costs, materials and supplies, travel, and training plan development. The recipient is strongly IPR Appendix | 2023 Page F-10
encouraged to use free public space, locations, or facilities, whenever available, prior to the rental of space, locations, or facilities. Training should provide the opportunity to demonstrate and validate skills learned as well as to identify any gaps in these skills. Any training or training gaps, including those for children and individuals with disabilities or other access and functional needs, should be identified in an After-Action Report/Improvement Plan (AAR/IP) and addressed in the training cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or contractors/consultants may be hired to support training-related activities. Reimbursement of these costs should conform with the policies of recipient, as well as any applicable federal and FEMA policies, rules, and regulations. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Dual compensation is unallowable, in other words, an employee of a unit of government may not receive compensation from their unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities. Personnel hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such expenses are for allowable activities within the scope of the grant. • Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to backfilling personnel, that are the direct result of attendance at FEMA and approved training courses and programs are allowable. Reimbursement of these costs should follow the policies of the recipient, as well as any applicable federal and FEMA policies, rules, and regulations. state.

Dual compensation is never allowable.
• Travel. Domestic travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as expenses by employees who are on travel status for official business related, approved training, subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense. • Supplies. Supplies, items that are expended or consumed during the course of the planning and conduct of the training project(s) (e.g., gloves and non-sterile masks), are allowable expenses. • Funds Used to Develop, Deliver, and Evaluate Training. Funds used to develop, deliver, and evaluate training, including costs related to administering the training, planning, scheduling, facilities, materials and supplies, reproduction of materials, and equipment are allowable expenses. Training should provide the opportunity to demonstrate and validate skills learned as well as to identify any gaps in these skills. Any training or training gaps, including those for children and individuals with disabilities or other access and functional needs, should be identified in the AAR/IP and addressed in the training cycle.

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. Information on FEMA-approved training can found at http://www.firstrespondertraining.gov/.

Awareness Campaigns
IPR funds may be used for the development and implementation of awareness campaigns to raise public awareness of indicators of terrorism and terrorism-related crime and for associated efforts to increase the sharing of information with public and private sector partners, including nonprofit organizations. DHS currently sponsors or supports a number of awareness campaigns. Please review materials, strategies, and resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness campaign for local constituencies and stakeholders.

Note: DHS requires that all public and private sector partners wanting to implement and/or expand the DHS “If You See Something, Say Something®” campaign (“campaign”) using grant funds work directly with the DHS Office of Partnership and Engagement (OPE). This will help ensure that the awareness IPR Appendix | 2023 Page F-11
materials (e.g., videos, posters, trifolds, etc.) remain consistent with DHS’s messaging and strategy for the campaign and compliant with the initiative’s trademark, which is licensed to DHS by the New York Metropolitan Transportation Authority. Coordination with OPE, through the campaign’s office ([email protected]), must be facilitated by the FEMA Preparedness Officer.

Exercises
Exercise activities that address the Soft Targets/Crowded Places and Cybersecurity Priorities.

IPR funds may be used for the following exercise activities:
• Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs related to planning, meeting space and other meeting costs, facilitation costs, materials and supplies, travel, and documentation. Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting. Any shortcomings or gaps identified, including those for children and individuals with disabilities or other access and functional needs, should be identified in an effective corrective action program that includes development of improvement plans that are dynamic documents, with corrective actions continually monitored and implemented as part of improving preparedness through the exercise cycle.
• Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be hired to support exercise-related activities. Reimbursement of these costs should conform with the policies of the recipient, as well as any applicable federal and FEMA policies, rules, and regulations. Dual compensation is not allowable, meaning, in other words, that an employee of a unit of government may not receive compensation from their unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work may benefit both entities. 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. The recipient must follow all applicable procurement regulations at 2 C.F.R. Part 200 when procuring contractor services.
• Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to backfilling personnel, which are the direct result of time spent on designing, developing, and conducting exercises are allowable expenses. These costs are allowed only to the extent the payment for such services is in accordance with the policies of the recipient and has the approval of the awarding agency, if applicable. Dual compensation is never allowable. • Travel. Domestic travel costs are allowable as expenses by employees who are on travel status for official business related to the planning and conduct of exercise project(s), subject to the restrictions at 2 C.F.R. Part 200. International travel costs are not allowable expenses. • Supplies. Supplies are items that are expended or consumed during the course of the planning and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective equipment).
• Other Items. These costs include the rental of space or locations for exercise planning and executing, rental of equipment, etc. The recipient is encouraged to use free public space, locations, or facilities, whenever available, prior to the rental of space, locations, or facilities.

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Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly related to managing and administering the award. The recipient may use up to 5% of the amount of the award for its M&A costs.

Fiscal Year 2023 IPR funds may be used for the following M&A costs:
• Hiring of full-time or part-time staff, including contractors and consultants, to execute the following:
o Management of the current fiscal year IPR Award; and
o Design and implementation of the current fiscal year IPR submission meeting compliance with reporting/data collection requirements, including data calls. • Information collection and processing necessary to respond to FEMA data calls; • Domestic travel expenses related to IPR grant administration, in compliance with the Super Circular, 2 C.F.R. Part 200; and
• Acquisition of authorized office equipment, including personal computers or laptops for IPR M&A purposes.

Indirect Costs
Indirect costs are allowable under this program as described in the Federal Acquisition Regulation (FAR).

See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty coverage, licenses, and user fees. These contracts may exceed the period of performance if they are purchased incidental to the original purchase of the system or equipment as long as the original purchase IPR Appendix | 2023 Page F-13
of the system or equipment is consistent with that which is typically provided for, or available through, these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending an existing maintenance contract on an already-owned piece of equipment system, coverage purchased may not exceed the period of performance of the award used to purchase the maintenance agreement or warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.

Grant funds are intended to support the National Preparedness Goal and to fund projects that build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order to provide recipients with the ability to meet this objective, the policy set forth originally in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs that must be (1) in direct support of existing capabilities, (2) an otherwise allowable expenditure under the applicable grant program, and (3) tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs may also be in support of equipment, training, and critical resources that have previously been purchased with either federal grant or any other source of funding other than FEMA preparedness grant program dollars.

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Program Appendix G:

Port Security Grant Program (PSGP)
As a reminder, while this appendix contains PSGP-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the PSGP. Please be sure to read the main content of this Manual in addition to the program-specific appendices.

PSGP grant recipients and subrecipients may only use PSGP grant funds for the purposes set forth in the Notice of Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award. These grant funds may not be used for matching funds for 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.

PSGP Funding Guidelines
Costs charged to a PSGP award must be consistent with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more information on 2 C.F.R. Part 200, please visit Information Bulletin (IB) 400 regarding FEMA’s implementation of these provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov.

PSGP Priorities
See the annual PSGP NOFO.

Limitations on Funding
As part of the PSGP application process, applicants must complete the approved Investment Justification (IJ) template and included detailed budget sheets (incorporated into the IJ) provided addressing each initiative being proposed for funding. A single IJ should be submitted with each application. Each IJ should include all proposed projects in separate tabs within the IJ. Altered IJs or IJs that have been separated into multiple attachments will not be considered for funding. A corresponding detailed budget tab is included within the IJ and must be completed for each project, including the budget summary at the bottom of the form. Each project should represent the complete scope of work and materials required to achieve a single overall capability. For example, a project could be to procure a boat specifically designed and equipped as chemical, biological, radiological, nuclear and explosives (CBRNE) detection, prevention, response, and/or recovery platform. The IJ for this example project should include the CBRNE equipment in the same IJ as the vessel. The corresponding detailed budget should include a description of the equipment (i.e., 24’ Response Vessel) and computation (i.e., 1 x $375,000, total $375,000; Vessel mounted Rad/Nuke detection device, 1 x $25,000, total $25,000). Additionally, the total computation for the Total Project Cost, Federal Share, and non-Federal Share must be included in the detailed budget (i.e., Total $400,000; Federal Share $300,000; non-Federal Share $100,000). This demonstrates that the applicant and FEMA understand the level of Federal funding requested, as well as a commitment to the Cost Share required by the applicant to complete the project. (see “Cost-Share or Match” in the PSGP NOFO).

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In accordance with 46 U.S.C. § 70107(b)(2), PSGP funding for projects for the cost of acquisition, operation, and maintenance of security equipment or facilities to be used for security monitoring and recording, security gates and fencing, marine barriers for designated security zones, security-related lighting systems, remote surveillance, concealed video systems, security vessels, and other security-related infrastructure or equipment that contributes to the overall security of passengers, cargo, or crewmembers cannot exceed $1 million federal share per project.

The $1 million per project limitation applies only to those projects funded under 46 U.S.C. § 70107(b)(2) and does not apply to projects funded under other provisions of Section 70107.

Allowable Direct Costs
Specific investments made in support of the funding priorities discussed in the annual PSGP NOFO generally fall into one of the following six allowable expense categories:
• Planning;
• Operational Activities;
• Equipment and Capital Projects;
• Training and Awareness Campaigns;
• Exercises; and
• Management and Administration.

The following provides guidance on allowable costs within each of these areas.

Planning
Planning activities address the Soft Targets/Crowded Places; Cybersecurity; and Planning Priorities.

PSGP funds may be used for the following types of planning activities:
• Development or updating of port wide risk mitigation plan (PRMP), including the conduct of port security vulnerability assessments as necessary to support plan update/development; • Development and enhancement of security plans and protocols within the Area Maritime Security Plan (AMSP), PRMP, and the Business Continuity and Resumption of Trade Plans (BCRTP) in support of maritime security and risk mitigation planning; • Materials required to conduct planning activities noted in this section; • Travel and per diem related to the professional planning activities noted in this section; • Coordination and information sharing with fusion centers; • Planning activities related to alert and warning capabilities; • Conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Infrastructure Resilience Planning Framework and related CISA resources;
• Other port wide maritime security project planning activities, which emphasize the ability to adapt to changing conditions and be prepared to withstand, and recover from, disruptions due to emergencies with prior approval from FEMA; and
• Backfill, overtime, hiring of part-time temporary personnel, and contractors or consultants to assist with planning activities. Copies of PSGP-funded plans must be made available to FEMA and the U.

S. Coast Guard (USCG) upon request.

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Operational Activities
Operational Activities address the Soft Targets/Crowded Places Priority.

Explosive Detection Canine Teams (EDCTs)
Use of canines (K-9) for explosive detection is one of the most effective solutions for the detection of vehicle-borne IEDs. When combined with the existing capability of a port or ferry security/police force, the added value provided through the addition of a canine team is significant. EDCTs are a proven, reliable resource to detect explosives and are a key component in a balanced counter-sabotage program.

Eligibility for funding of EDCTs is restricted to:
• U.S. Ferry Systems regulated under 33 C.F.R. Parts 101, 103, 104, and the passenger terminals these specific ferries service under 33 C.F.R. Part 105; • Maritime Transportation Security Act (MTSA) regulated facilities; and • Port authorities, port police, and local law enforcement agencies that provide direct layered security for these U. S. Ferry Systems and MTSA-regulated facilities, and are defined in an AMSP, Facility Security Plan (FSP), or Vessel Security Plan (VSP).

Applicants may apply for up to $450,000 ($150,000/year for three years) per award to support this endeavor. At the end of the grant period (36 months), recipients will still be responsible for continuing the heightened level of capability provided by the EDCT. A sustainment plan must be submitted with the applicant’s IJ to address the 12-month period beyond the period of performance of the award.

Eligible EDCT Costs
Funds for these EDCTs may not be used to fund drug detection and apprehension technique training. Only explosives detection training for EDCTs will be funded. The PSGP EDCT funds may only be used for new or expanded capabilities/programs and cannot be used to pay for existing K-9 teams, personnel, or K-9 training costs already supported by the port area. Repair and replacement of existing EDCT equipment is allowed. Eligible costs include:
• Contracted K-9 and handler providing services in accordance with PSGP guidance; • Salary and fringe benefits of new full- or part-time K-9 handler positions; • Training and certifications (travel costs associated with training for new or expanded full or part time agency handlers, and canines are allowable);
• K-9 and handler equipment costs;
• Purchase and train a new K-9 and handler for CBRNE detection; and • K-9 maintenance costs including but not limited to veterinary, housing, and feeding costs.

Ineligible EDCT costs include, but are not limited to:
• Hiring costs, including costs associated with initial police academy training of new officers; • Meals and incidentals associated with travel for initial certification; • Vehicles modified to be used solely to transport canines; and • Repair or replacement of unallowable equipment.

EDCT Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified organization. K-9 and handler should receive an initial basic training course and weekly maintenance training sessions thereafter to maintain the certification. The basic training averages ten weeks for the canine team (K-9 and handler together) with weekly training and daily exercising. Comparable training and PSGP Program Appendix | 2023 Page G-4
certification standards, such as those promulgated by the Transportation Security Administration (TSA) Explosive detection canine program, the National Police Canine Association (NPCA), the U.S. Police Canine Association (USPCA), or the International Explosive Detection Dog Association (IEDDA) may be used to meet this requirement. Certifications and training records will be kept on file with the recipient and made available to FEMA upon request.

EDCT Submission Requirements
Successful applicants will be required to submit an amendment to their approved VSP or FSP per 33 C.F.R.

Parts 104 and/or 105 detailing the inclusion of a K-9 explosive detection program into their security measures. The recipient will ensure that a written plan or standard operating procedures (SOPs) exist that describe EDCT deployment policy to include visible and unpredictable deterrent efforts and on-call EDCTs rapid response times as dictated by the agency’s FSP or VSP. The plan or SOPs must be made available to FEMA and USCG upon request.

The recipient will comply with requirements for the proper storage, handling, and transportation of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulations.

Additional EDCT Resources Available for K-9 Costs
The PSGP, while providing the ability to defray some start-up costs, does not cover any recurring costs associated with EDCT programs. FEMA strongly encourages applicants to investigate their eligibility under other programs, and potential exclusions, when developing their K-9 programs.

Organization Costs
Allowable organization-related costs are limited to those activities associated with new and ongoing maritime security operations essential to the national priorities. All such activities must be focused exclusively on maritime security and coordinated with the local Captain of the Port (COTP). PSGP funding used for organizational costs will only fund immediate needs for personnel that will be directly engaged in maritime security activities. Allowable organization personnel costs include:
• Backfill, Overtime, Hiring of Full or Part-Time Personnel or Contractors/Consultants. Full or part-time staff or contractors/consultants may be hired to support maritime-security-related activities and/or training conducted under this grant only to the extent that such expenses are for the allowable activities within the scope of the grant. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Salary and fringe benefit payments must be in accordance with the policies of the state or unit(s) of local government and have the approval of the state or awarding agency. Dual compensation is not allowable. That is, an employee of a unit of government may not receive compensation from their unit or agency of government AND from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities. Limitations may apply for grant related activities.

See specific guidance provided within this Manual for additional details on allowable organization costs (i.e., Training – Personnel costs are limited to backfill and overtime). • Hiring new, full-time personnel to:
o Operate maritime security patrol vessels (first response agencies only); o Staff a new or expanded interagency maritime security operation center; o Support maritime security/counterterrorism efforts in the local Joint Terrorism Task Force (JTTF) and/or fusion center; and
o Support credentialing access to a MTSA facility.
• Backfill and Overtime costs for existing personnel to:

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o Operate patrol vessels in support of pre-planned, mission critical activities, as identified by the local COTP (not including routine patrol); and
o Attend approved maritime security training courses.
• Personnel or contracted costs to:
o Install, repair, and replace port security equipment acquired with FEMA preparedness grant funds. Note this does not include routine maintenance, such as oil changes and daily/weekly systems tests; and
o Management and administration (M&A) of projects funded under this program. • Contracted costs to:
o Provide approved training courses; and
o Provide warranty, maintenance, and service agreements for equipment purchased under this grant.

Organization costs will only be funded to address port (or facility) security needs as outlined in the NOFO and this appendix. PSGP funding for new permanent or part-time personnel will not exceed the 36-month period of performance. Applicants must provide reasonable assurance that personnel costs can be sustained beyond the 36-month award period. A sustainment plan must be submitted with the applicant’s IJ to address the 12-month period beyond the period of performance of the award.

Equipment and Capital Projects
Equipment and Capital Projects address the Soft Targets/Crowded Places; Cybersecurity; and Equipment/Capital Projects Priorities.

Equipment Acquisition
PSGP funds must comply with FEMA Policy 207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards. PSGP funds may be used for the following categories of equipment. A comprehensive listing of allowable equipment categories and types is found in the Authorized Equipment List (AEL).

Requests for vehicles of any type are subject to secondary review and approval by the National Review Panel. These costs include:
• Personal Protective Equipment (PPE) for maritime security providers, such as ballistic protective body armor (not including uniforms);
• CBRNE response and remediation equipment for maritime security providers; • CBRNE decontamination equipment for direct maritime security providers and MTSA-regulated industry;
• CBRNE detection-equipped patrol vehicles (not including armored personnel carriers or tow trucks), provided they will be used exclusively for port/facility CBRNE detection security operations. A CBRNE detection equipped patrol vehicle must include specifically identified, permanently mounted detection equipment;
• Trailers (not vehicles) designed to carry maritime security equipment essential to maritime security, mitigation, and response (such as boat trailers, dive trailers, or mobile command trailers); • Mobile Command Centers only when validated by the COTP as essential to address a specifically required capability outlined in the approved AMSP. This does not include prime movers (tow-trucks), personnel carriers, or equipment transport vehicles; • CBRNE detection-equipped and patrol watercraft vessel/small boat used to directly support maritime security for a facility or within a Port Area on a routine basis (CBRNE detection equipment requested with the watercraft/small boat in the IJ must be listed and also detailed in the budget). However, a vessel is not required to be CBRNE equipped; PSGP Program Appendix | 2023 Page G-6
• Marine firefighting vessels, provided they are outfitted with CBRNE detection equipment and are designed and equipped to meet NFPA 1925: Standard on Marine Fire-Fighting Vessels; • Firefighting foam and Purple-K Powder (PKP) may be purchased by public fire departments that have jurisdictions in a port area and would respond to an incident at an MTSA regulated facility; MTSA facilities may also receive funding for this purpose. Funding will be limited to a one-time purchase based on a worst-case incident at the facility or facilities; • Information-sharing technology; components or equipment designed to share maritime security risk information and maritime all-hazards risk information with other agencies (equipment must be compatible with generally used equipment);
• Maritime security risk mitigation interoperable communications equipment, including alert and warning capabilities;
• Terrorism incident prevention and response equipment for maritime security risk mitigation; • Physical security enhancements, to include TWIC projects (e.g., card readers, fences, blast resistant glass, turnstiles, hardened doors, and vehicle gates) at maritime facilities; • Portable fencing, closed-circuit televisions (CCTVs), passenger vans, minibuses, etc. to support secure passage of vessel crewmembers through a MTSA regulated facility; • Equipment that enhances continuity capabilities, such as interoperable communications, intrusion prevention/detection, physical security enhancements, software and other equipment needed to support essential functions during a disruption to normal operations; • Generators with appropriate capability (size) to provide back-up power to security systems and equipment that support Maritime Domain Awareness (not including routine operational capabilities):
o Access control equipment and systems;
o Detection and security surveillance equipment; and
o Enhancement of Command-and-Control facilities.
• Equipment for new personnel, such as personal protective equipment, is an allowable expense.

Weapons and equipment associated with weapons maintenance/security (e.g., firearms, ammunition, and gun lockers) are not allowable.

Recipients may purchase maritime security equipment not listed on the AEL, but only if they first seek and obtain prior approval from FEMA. In addition, recipients that are using PSGP funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at https://www.cisa.gov/safecom/funding.

Requirements for 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, Prohibited or Controlled Equipment Under FEMA Awards, and also include a description 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. SUAS policies are not required at the time of application but must be received and approved by FEMA prior to obligating PSGP funds. All grant-funded procurements must be executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients that use PSGP funds for sUAS, FEMA advises that there is a general privacy concern related to the use of this equipment if the data the devices collect is transmitted to servers not under the control of the operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers outside the United States. The U.S.

Department of Homeland Security’s Privacy Office suggests the recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data breaches.

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Additionally, the Joint Explanatory Statement (JES) accompanying the FY 2023 DHS Appropriations further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-made versus domestic sUAS.

Sonar Devices
The four types of allowable sonar devices are: imaging sonar, scanning sonar, side scan sonar, and three- dimensional sonar. These types of sonar devices are intended to support the detection of underwater improvised explosive devices and enhance maritime domain awareness. The eligible types of sonar, and short descriptions of their capabilities, are provided below:
1) Imaging Sonar: A high-frequency sonar that produces “video-like” imagery using a narrow field of view. The sonar system can be pole-mounted over the side of a craft or hand-carried by a diver. 2) Scanning Sonar: Consists of smaller sonar systems that can be mounted on tripods and lowered to the bottom of the waterway. Scanning sonar produces a panoramic view of the surrounding area and can cover up to 360 degrees.
3) Side Scan Sonar: Placed inside a shell and towed behind a vessel. Side scan sonar produces strip- like images from both sides of the device.
4) Three-Dimensional Sonar: Produces 3-dimensional imagery of objects using an array receiver.

Maritime Domain Awareness
Maritime domain is defined as “all areas and things of, on, under, relating to, adjacent to, or bordering on a sea, ocean, or other navigable waterway, including all maritime-related activities, infrastructure, people, cargo, and vessels and other conveyances.” Homeland Security Presidential Directive-13 (NSPD-41/HSPD- 13) (Maritime Security Policy, December 21, 2004). According to the National Plan to Achieve Maritime Domain Awareness for the National Strategy for Maritime Security (Oct. 2005), “Maritime Domain PSGP Program Appendix | 2023 Page G-8
Awareness (MDA) is the effective understanding of anything associated with the global maritime domain that could impact the security, safety, economy, or environment of the United States. MDA is a key component of an active, layered maritime defense in depth. It will be achieved by improving our ability to collect, fuse, analyze, display, and disseminate actionable information and intelligence to operational commanders.” Id. at ii. Applicants are encouraged to familiarize themselves with this National Strategy.

Improvised Explosive Device (IED) and CBRNE Prevention, Protection, Response, Recovery Capabilities
Port areas should continue to enhance their capabilities to prevent, detect, respond to, and recover from terrorist attacks employing IEDs, CBRNE devices, and other non-conventional weapons. Please refer to DHS Small Vessel Security Strategy (Apr. 2008).

Physical Security
Physical security is security measures that are designed to deny unauthorized access to facilities, equipment, and resources and to protect personnel and property from damage or harm (such as espionage, theft, or terrorist attacks). Physical security involves the use of multiple layers of interdependent systems and techniques. Physical security has been a focus of PSGP since the program’s inception in 2002. Primarily, physical security is intended to harden MTSA-regulated facilities against attacks. Law enforcement may contribute to physical security through patrols; however, patrol vessels generally enhance multiple core capabilities with a focus on CBRNE detection, deterrence, and response. Funding through PSGP for physical security projects should be only directed toward those projects that address identified MTSA required activities and identified in the entity FSP and/or the port area AMSP. Some examples of funded projects include TWIC-related equipment, fencing, lighting, gates, and CCTV. Physical security projects typically require EHP review prior to obligating PSGP funds.

Cybersecurity Projects
PSGP funds may be used for projects that enhance the cybersecurity of:
• Access controls;
• Sensors;
• Security cameras;
• Badge/ID readers;
• Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems; • Process monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.); and
• Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).

When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the “Framework”) developed by the National Institute of Standards and Technology (NIST), or other similar sources. The Framework gathers existing international standards and practices to help organizations understand, communicate, and manage their cyber risks. For organizations that do not know where to start with developing a cybersecurity program, the Framework provides initial guidance. For organizations with more advanced practices, the Framework offers a way to improve their programs, such as better communication with their leadership and suppliers about management of cyber risks.

The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in adoption of the Framework and managing cyber risks. Additional information on the Critical Infrastructure Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp. DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in protecting U.S.-based PSGP Program Appendix | 2023 Page G-9
public and private entities and combines key elements of capabilities under the “Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the Cybersecurity Framework.

Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based companies and SLTT governments defend their computer systems against unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services. Please visit http://www.cisa.gov/enhanced-cybersecurity-services-ecs for a current list of ECS CSP points of contact.
“Hub and spoke” cybersecurity projects are allowable under PSGP for cybersecurity projects that span multiple port area facilities. Hub and spoke cybersecurity projects may affect a parent organization’s multiple eligible entities, and maritime security partners, in multiple port areas to provide a port-wide benefit. Such projects may be submitted within a primary Port Area for the project implementation. For example, an applicant in the Port of Houston may submit a hub and spoke project within the Houston/Galveston port area which includes system hardening throughout the organization’s facilities in Houston, Port Lavaca, and Corpus Christi. Proportionally, costs associated with entities or subcomponents that are not covered under an AMSP and are not instrumental to enhancing maritime security must not be included in the detailed budget worksheet or investment justification and thereby prorating the cost of the project only to those facilities that are covered by the AMSP. Following the example noted above, the applicant may not include costs associated with cybersecurity of their non-maritime facilities, such as a non-MTSA regulated facility located in San Antonio. Hub and spoke projects are limited only to the enhancement of maritime security as outlined in this section and may not include non-maritime systems or facilities. Please clearly identify hub and spoke projects as such within your IJ and consult your COTP to verify project applicability to enhancing maritime security.

Cybersecurity projects should address risks to the marine transportation system and/or Transportation Security Incidents (TSIs) outlined in the applicable AMSP, or priorities prescribed under applicable FSP or VSP, as mandated under the MTSA or the PRMPs. At the port level, examples of cybersecurity projects include but are not limited to projects that enhance the cybersecurity of access control, sensors, security cameras, badge/ID readers, ICS/SCADA systems, process monitors and controls (such as those that monitor flow rates, valve positions, tank levels, etc.), security/safety of the ship-to-port-to-facility-to- intermodal interface, and systems that control vital cargo machinery at the ship/shore interface (such as cranes, manifolds, loading arms, etc.), and passenger/vehicle/cargo security screening equipment.

Vulnerability assessments are generally not funded under PSGP. However, considering the evolving malicious cyber activity, the relative novelty of cybersecurity as a priority within the program, and the need to adopt best practices included in the voluntary Cybersecurity Framework, vulnerability assessments may be funded as contracted costs. Port-wide assessments are eligible and must demonstrate that the assessment includes port area partners and are necessary to be completed as a single project to ensure a comprehensive evaluation of port area cyber security vulnerabilities. Personnel costs (other than M&A) are not an allowable expense for conducting these assessments.

CISA offers free resources to assist with initial assessments, please see https://www.cisa.gov/cyber- resource-hub for additional information. Applicants are encouraged to utilize free resources prior to requesting funds under this program.

Copies of completed cybersecurity assessments funded under PSGP that impact the maritime transportation system, lead to a “transportation security incident” (as that term is defined under 46 U.S.C. § 70101(6)), or are otherwise related to systems, personnel, and procedures addressed by the PSGP Program Appendix | 2023 Page G-10
facility and vessel plan shall be made available to FEMA and/or the local COTP upon request. The results of these cybersecurity assessments may be designated as Sensitive Security Information (SSI) and may be used to inform national maritime cybersecurity assessments.

Where a vulnerability assessment has been completed either through contracts or qualified personnel to identify existing gaps and required mitigation efforts, mitigating projects may be funded that include purchase of equipment, software, and infrastructure designed to harden cybersecurity. Specific questions on conducting vulnerability assessments should be referred to the respective FEMA Preparedness Officer.

Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any PSGP funds for construction or renovation projects. Additionally, PSGP funding may not be used to construct buildings or other physical facilities that are not constructed under terms and conditions consistent with the requirements of section 611(j)(9) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. § 5196(j)(9)) (the Stafford Act),3 which requires compliance with the Davis-Bacon Act (codified as amended at 40 U.S.C. §§ 3141 et seq.) for PSGP funded projects. Grant recipients 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 similar to the contract work in the civil subdivision of the state in which the work is to be performed. Additional information regarding compliance with the Davis- Bacon Act, including Department of Labor wage determinations, is available at http://www.dol.gov/whd/govcontracts/dbra.htm.

The following types of construction and renovation projects are allowable under PSGP, provided they address a specific vulnerability or need identified in AMSP or otherwise support the maintenance/sustainment of capabilities and equipment acquired through PSGP funding:
• Maritime Command and Control Centers;
• Interagency Operations Centers (IOCs) for maritime security; • Port Security Emergency Communications Centers;
• Buildings to house generators that support maritime security risk mitigation; • Maritime security risk mitigation facilities (e.g., dock house, ramps, and docks for existing port security assets);
• Hardened security fences/barriers at access points;
• Any other building or physical facility that enhances access control to the port/MTSA facility area; and
• PSGP funding may be used to purchase and/or upgrade a barge to support a staging area for maritime/port security patrols or maritime security risk mitigation responses. (Certain areas throughout the Nation may require a barge that can be permanently anchored or moored in certain areas to support maritime security risk mitigation activities.).

To be considered eligible for funding, the construction of fusion centers, operations centers, or communications centers must offer a port wide benefit and support information sharing and operational coordination among regional interagency and other port security partners. Applicants are reminded that the period of performance is 36 months. Eligible costs for construction or renovation projects may not exceed $1 million (federal share) per project, which may not exceed 10% of the total amount of the award, as stated 3 While the Maritime Transportation Security Act of 2002, as amended at 46 U.S.C. § 70107(b)(2), requires that such activities are carried out consistent with Section 611(j)(8) of the Stafford Act, a subsequent amendment to the Stafford Act by section 3 of Pub. L. No. 109-308 in 2006 redesignated the text of Section 611(j)(8) to 611(j)(9). The cross- reference in the Maritime Transportation Security Act of 2002 has not been updated.

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in 46 U.S.C. § 70107(b)(2)(A) and (B) (Section 102 of the Maritime Transportation Security Act of 2002, Pub. L. 107-295, as amended). Grant recipients are not permitted to use PSGP funds for construction projects that are eligible for funding under other federal grant programs. PSGP funds may only be used for construction activities directly related to maritime security risk mitigation enhancements.

All construction or renovation projects require Environmental Planning and Historic Preservation (EHP) review. The recipient is also encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with the relevant Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects; compliance with all state and local EHP laws and requirements). Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, EHP Directive and Instruction, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer within the first six months of the award, regardless of the length of the period of performance. Completed EHP review materials for construction and renovation projects must be submitted no later than 12 months before the end of the period of performance.

EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; and Training and Awareness Campaign Priorities.

Training
Port areas should assess their training and qualification requirements and coordinate training needs and qualification requirements of incident response personnel. Funding for personnel training is limited to those courses that are essential to enhance maritime security. A listing of courses that are currently approved for PSGP funding is included in the table below.

Some training activities require EHP Review, including exercises, drills or trainings that require any type of land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities designed to conduct training and exercises. Additional information on training requirements and EHP review can be found online at Environmental & Historic Preservation Grant Preparation Resources | FEMA.gov.

Funding for training courses not listed in Table 3 may be permitted on a case-by-case basis depending on the specific maritime security risk mitigation training needs of the eligible PSGP applicant. In such cases, an applicant will be required to explain in the IJ why none of the approved courses referenced in Table 3 satisfy the identified training need and must submit detailed course information for review and consideration by the local COTP field review team and the Nation Review Panel.

Further, in accordance with 46 U.S.C. § 70107(c)(2)(C), no cost share is required to train public safety personnel in the enforcement of security zones under section 46 U.S.C. § 70132 or assisting the enforcement of such security zones. Per 46 U.S.C. § 70132(d), the term “public safety personnel” includes any federal, state (or political subdivision thereof), territorial, or tribal law enforcement officer, firefighter, or emergency response provider
Training denoted with an asterisk (*) in the table below is exempt from cost share only to train public safety personnel who enforce security zones. Additional training of public safety personnel may be exempt if specifically identified by the COTP as exempt and necessary for enforcement or the assistance of enforcement of security zones as specified by 46 U.S.C. § 70132. Requests that fail to include a cost share for training that is not exempt from cost share requirements as outlined in 46 U.S.C. § 70132 PSGP Program Appendix | 2023 Page G-12
will not be considered for funding. Training for public safety personnel who do not provide enforcement of security zones are not exempt from cost share. Training rosters and certificates must be provided to FEMA upon request. Please consult your COTP prior to requesting cost share exempt training for enforcement of security zones. Refer to Section C.4 of the NOFO for more specific cost share information for that specific year’s requirements.

Seminars and workshops are not considered “Training”, however applicants wishing to host seminars or workshops with PSGP funding may be eligible for funding following the criteria set forth in the “Exercise” section of this guidance.

Table 3: Approved PSGP Training Courses
National Training and Education Division
Course Number Course Name
AWR-144 Port and Vessel Security for Public Safety and Maritime Personnel AWR-213 Critical Infrastructure Security and Resilience Awareness AWR-366-W Developing a Cyber Security Annex for Incident Response MGT-335 Event Security Planning for Public Professionals MGT-335-W Event Security Planning for Public Professionals, Web Based MGT-400 Master of Arts Degree in Homeland Security
MGT-425 Homeland Security Executive Leaders Program (ELP) MGT-452 Physical and Cybersecurity for Critical Infrastructure MGT-456 Integration of Cybersecurity Personnel into the Emergency Management Operations Center for Cyber Incidents
PER-330 The Surface Transportation Emergency Preparedness and Security for Mass Transit and Passenger Rail (STEPS-PT)
PER-331 Surface Transportation Emergency Preparedness and Security for Senior Officials or Administrators (STEPS Sr)
Federal-Sponsored
Course Number Course Name
DHS-006-PREV Seaport Security Anti-Terrorism Training Program (SSATP) DHS-011-PREV Maritime PRND Operations Course
DHS-016-PREV Protective Measures Training for Security Officers, Mid-Level Safety/Security Supervisors, and Property Managers
*DHS-011-PROT NASBLA BOAT Tactical Operators Course
*DHS-009-PROT Boat Operator's Anti-Terrorism Training
DHS-126-RESP NASBLA BOAT Crew Member Course
*DHS-128-RESP NASBLA - Pursuit and Stop Course
State-Sponsored
Course Number Course Name
CA-006-PREV Maritime Company, Vessel, and Facility Security Officer CA-007-PREV Basic Maritime Security Awareness
CA-008-PREV Basic First Responder Operational Maritime Security (FROMS) CA-015-RESP Maritime Facility Security Officer
CA-020-RESP WMD & Terrorism Awareness for Security Professionals ME-001-PROT Maritime Security Awareness for Military, First Responder and Law Enforcement Personnel
ME-002-PROT Command Strategies and Tactics for Marine Emergencies *ME-003-PROT Tactical Boat Operations for Maritime Security and LE Personnel ME-002-RESP Emergency Medical Operations in the Maritime Domain NJ-003-PREV Government Agency Maritime Security Awareness Program (GAMSAP) PSGP Program Appendix | 2023 Page G-13
NJ-015-PREV Security Awareness & Vigilance for Everyone NY-001-PREV Maritime Infrastructure Protection
NY-001-PROT Safe Boat Operators
*NY-002-PREV Tactical Escorts and Security Zones
NY-002-PROT Pattern Line Search/Recovery Course
NY-004-RESP Vehicle Borne Improvised Explosive Device Security Checkpoint Federal Law Enforcement Training Center (FLETC)
Course Number Course Name
*MTOTP Marine Law Enforcement Training Program
IBOT Inland Boat Operator’s Training
ENTP Electronic Navigation Training Program
*BOAT Boat Operator’s Anti-Terrorism Training Program
*MLETP Marine Law Enforcement Training Program
*CVBTP Commercial Vessel Boarding Training Program
*SSATP Seaport Security Anti-Terrorism Training Program Exercises
Exercise activities address the Soft Targets/Crowded Places; Cybersecurity; and Exercises Priorities.

Exercises funded under the PSGP typically include Seminars, Workshops, Tabletop, Functional, Drills, and Full-Scale exercises. PSGP-funded exercises must have a maritime security focus and include applicable documentation, after action reports, and improvement plans. See below for additional information.

Maritime entity training needs and qualification requirements of incident response personnel should be regularly tested through emergency exercises and drills. Exercises must test operational protocols that would be implemented in the event of a terrorist attack in the maritime environment in accordance with the Area Maritime Security Training Exercise Program (AMSTEP) or the TSA Intermodal Security Training Exercise Program (I-STEP) guidelines. AMSTEP or I-STEP exercises will follow the latest change in requirements contained in the Navigation and Inspection Circular (NVIC) 09-02. Exercises must be designed, developed and conducted consistent with the Homeland Security Exercise and Evaluation Program (HSEEP). Funding used for exercises will only be permitted for those exercises that are in direct support of a MTSA-regulated facility or a port area’s MTSA-required exercises (see 33 C.F.R. § 105.220 for a facility and 33 C.F.R. § 103.515 for the AMSP). These exercises must be coordinated with the COTP and AMSC and be consistent with HSEEP. More information on HSEEP may be found at https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep.

Some exercise activities require EHP Review, including exercises, drills or trainings that require any type of land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities designed to conduct training and exercises. Additional information on training requirements and EHP review can be found online at Environmental & Historic Preservation Grant Preparation Resources | FEMA.gov.

Recipients are required to submit an After-Action Report/Improvement Plan (AAR/IP) for each PSGP- funded exercise to [email protected], and the appropriate local COTP no later than 90 days after completion of the exercise conducted within the PSGP period of performance (POP). Recipients are reminded of the importance of implementing corrective actions iteratively throughout the progressive exercise cycle. Recipients are required to use the HSEEP AAR/IP template located at https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.

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Recipients of PSGP funding for exercises should verify in progress reports the completion of the exercise(s), after-action report(s), improvement plan(s), and notifications made to [email protected] and the COTP.

PSGP funds may be used for the following exercise activities:

Funds Used to Design, Develop, Conduct, and Evaluate an Exercise. This includes costs related to planning, meeting space, and other meeting costs, facilitation costs, materials and supplies, travel, and documentation. Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting. Any shortcoming or gap identified, including those for children and individuals with disabilities or other access and functional needs, should be identified in an effective corrective action program that includes development of improvement plans that are dynamic documents, with corrective actions continually monitored and implemented as part of improving preparedness through the exercise cycle.

Hiring of Full- or Part-Time Staff or Contractors/Consultants. Full- or part-time staff may be hired to support exercise-related activities. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Such costs must be included within the funding allowed for program management personnel expenses, which must not exceed 10% of the total allocation.

Dual compensation is never allowable, meaning, in other words, that an employee of a unit of government may not receive compensation from his or her unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both entities. 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.

Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to backfilling personnel that are the direct result of time spent on the design, development and conduct of exercises are allowable expenses. These costs are allowed only to the extent the payment for such services is in accordance with the policies of the state or unit(s) of local government and has the approval of the state or the awarding agency, whichever is more restrictive. Dual compensation is never allowable.

Travel. Domestic travel costs are allowable as expenses by employees who are on travel status for official business related to the planning and conduct of exercise project(s). International travel costs are not permitted.

Supplies. Supplies are items that are expended or consumed during the course of the planning and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective equipment).

Other Items. These costs include the rental of space/locations for exercise planning and executing, rental of equipment, etc. Recipients are encouraged to use free public space, locations, or facilities, whenever available, prior to the rental of space, locations, or facilities. These also include costs that may be associated with inclusive practices and the provision of reasonable accommodations and modifications to provide full access for children and adults with disabilities.

The National Exercise Program (NEP) serves as the principal exercise mechanism for examining national preparedness and measuring readiness. Recipients are strongly encouraged to nominate exercises into the NEP. For additional information on the NEP, please refer to http://www.fema.gov/national-exercise- program.

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Management and Administration (M&A)
M&A costs are allowed under this program. M&A costs are activities directly related to managing and administering the award. Recipients may use up to 5% of the amount of the award for their M&A. PSGP funds may be used for the following M&A costs:
• Hiring full-time or part-time staff, including contractors and consultants, to execute the following:
o Management of the awarded fiscal years’ PSGP award;
o Design and implementation of the awarded fiscal years’ PSGP submission meeting compliance with reporting/data collection requirements, including data calls; o Information collection and processing necessary to respond to FEMA data calls; o Travel expenses related to PSGP grant administration; and o Acquisition of authorized office equipment, including personal computers or laptops for PSGP M&A purposes.

Allowable Indirect Costs
Indirect costs are allowable under this program. See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

Unallowable Costs
Projects that do not provide a compelling maritime security benefit or have a direct nexus toward maritime security risk mitigation are not permitted. For example, projects that are primarily for economic or safety benefit (as opposed to having a direct maritime security risk mitigation benefit) are ineligible for PSGP funding. In addition, projects that provide a broad homeland security benefit (e.g., a communication system or fusion center for an entire city, county, state, etc.) as opposed to providing primary benefit to the port are ineligible for PSGP funding since these projects should be eligible for funding through other preparedness grant programs. The following projects and costs are considered ineligible for award consideration:
• 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;
• Projects in which federal agencies are the primary beneficiary or that enhance federal property, including sub-components of a federal agency;
• Projects that study technology development for security of national or international cargo supply chains (e.g., e-seals, smart containers, container tracking or container intrusion detection devices); • Proof-of-concept projects;
• Development of training;
• Projects that duplicate capabilities being provided by the Federal Government (e.g., vessel traffic systems);
• Business operating expenses (certain security-related operational and maintenance costs are allowable—see “Maintenance and Sustainment” and “Operational Costs” for further guidance); • Transportation Worker Identification Credential (TWIC) card fees; • Reimbursement of pre-award security expenses;
• Outfitting facilities, vessels, or other structures with equipment or items providing convenience rather than a direct security benefit. Examples of such equipment or items include but are not limited to office furniture, CD players, DVD players, AM/FM radios, TVs, stereos, entertainment satellite systems, entertainment cable systems and other such entertainment media, unless sufficient justification is provided. This includes weapons and associated equipment (i.e., holsters, optical PSGP Program Appendix | 2023 Page G-16
sights, and scopes), including but not limited to, non-lethal or less-than-lethal weaponry including firearms, ammunition, and weapons affixed to facilities, vessels, or other structures; • Standard issue uniforms (other than maritime security personal protective equipment [PPE]); • Expenditures for items such as general-use software, general-use computers, and related equipment (other than for allowable M&A activities, or otherwise associated) preparedness or response functions), general-use vehicles and licensing fees;
• Land acquisitions and right of way purchases;
• Funding for standard operations vehicles utilized for routine duties, such as patrol cars and fire trucks;
• Fuel costs (except as permitted for training and exercises); • Exercise(s) that do not support maritime security preparedness efforts; • Patrol vehicles and firefighting apparatus, other than those CBRNE detection equipped vehicles for port area and/or facility patrol or response purposes;
• Specialty vehicles such as trucks for towing boat trailers/equipment and armored personnel carriers; • Providing protection training to public police agencies or private security services to support protecting VIPs or dignitaries;
• Aircraft pilot training, including aircraft operations such as aircraft ditch training; • Post incident investigation training;
• Basic or advanced dive training (except marine unit CBRNE detection/response dive training); • Training for personnel not primarily assigned to maritime security activities or MTSA required security personnel (e.g., vessel patrol officers, facility security officers); and • Reimbursement for the maintenance and wear and tear costs of general use vehicles (e.g., construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances, repair, or cleaning of PPE, etc.).

Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts or agreements, warranty coverage, repair or replacement costs, licenses, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted. These contracts may exceed the period of performance if they are purchased incidental to the original purchase of the system or equipment as long as the original purchase of the system or equipment is consistent with that which is typically provided for, or available through, these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending an existing maintenance contract on an already-owned piece of equipment system, coverage purchased may not exceed the period of performance of the award used to purchase the maintenance agreement or warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.

Under PSGP, maintenance and sustainment is focused specifically on the repair and replacement of existing equipment and does not include routine activities such as oil changes or washing/cleaning existing equipment. For example, an IJ for a camera system maintenance contract should detail the number of cameras the applicant anticipates repairing/replacing during the period of performance (i.e., the port operates 100 cameras and typically replaces 10% of the system each year, funding is for the replacement of 30 cameras over the 3-year period of performance.

Grant funds are intended to support the National Preparedness Goal and fund projects that build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program, and (3) be tied to one of the core PSGP Program Appendix | 2023 Page G-17
capabilities in the five mission areas outlined in the Goal. Additionally, eligible costs may also be in support of equipment, training, and critical resources that have previously been purchased with either federal grant or any other source of funding other than FEMA preparedness grant program dollars.

Port-Wide Risk Management Plans
Port areas with existing PRMPs are encouraged to maintain their PRMPs and use them to identify projects that will serve to address remaining maritime security vulnerabilities. These ports are also encouraged to develop or maintain a BCRTP. For purposes of regional strategic and tactical planning, these plans must take into consideration all port areas covered by their AMSP, align with the port area’s AMSP, consider the entire port system strategically as a whole, and identify actions designed to effectively mitigate security risks associated with the system’s maritime critical infrastructure and key resources.

Additional Port Security Resources
• U.S. Department of Transportation “BUILD” grants for National Infrastructure Investments may include funding to support roads, bridges, transit, rail, ports, or intermodal transportation, see https://www.transportation.gov/BUILDgrants
• Cybersecurity assessments may be available via CISA, see https://www.cisa.gov/cyber-resource- hub
Sample Memorandum of Understanding/Agreement (MOU/MOA)
The sample MOU/MOA below demonstrates all of the elements required in the PSGP NOFO for acceptance for review as part of a grant application from a state or local agency providing security services to MTSA-regulated entities.

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PSGP Investment Modifications
The purpose of the grant award is to implement projects pursuant to the authorities at 46 U.S.C. § 70107.

Under extreme circumstances, a recipient may reallocate award funds from one project to another with prior written approval from FEMA, and in a manner consistent with 2 C.F.R. § 200.308 as long as it does not change the overall scope or objective of the award. Circumstances include, but are not limited to, an inability to complete the original project, disaster events perpetuating an immediate need to reprioritize funds, and changes in regulatory requirements. A recipient must explain the deviation from the original project, including why it is deviating from or scaling down the original project, and what specific circumstances that occurred after the time of its award that necessitate the reallocation request, in its reallocation request. The recipient must also identify how the reallocation request aligns with PSGP priorities and the recipient’s original application and the award’s scope of work. Due to legal limitations, reallocation requests that would change the scope of the overall project(s) are not permitted. FEMA will also coordinate such reallocation requests with the USCG COTP, and these requests must be verified and supported by the COTP as essential in addressing Port Area priorities. Please also see Section C.4 of this NOFO regarding cost share requirements, including the implications if the project costs are less than what was applied for.

Memorandum of [Understanding / Agreement]
Between [provider of layered security] and [recipient of layered security] Regarding [provider of layered security’s] Use of Port Security Grant Program Funds

1. PARTIES. The parties to this Agreement are the [Provider of Layered Security] and the [Recipient of security service].

2. AUTHORITY. This Agreement is authorized under the provisions of [applicable Area Maritime Security Committee (AMSC) authorities and/or other authorities].

3. PURPOSE. The purpose of this Agreement is to set forth terms by which [Provider of security service] shall expend Port Security Grant Program project funding in providing security service to [Recipient of security service]. Under requested PSGP grant, the [Provider of security service] must provide layered security to [Recipient of security service] consistent with the approach described in an approved grant application.

4. RESPONSIBILITIES: The security roles and responsibilities of each party a re understood as follows:
(1) [Recipient of security service]
Roles and responsibilities in providing its own security at each MARSEC level (2) [Provider of security service]
[-An acknowledgement by the facility that the applicant is part of their facility security plan.] [-The nature of the security that the applicant agrees to supply to the regulated facility (waterside surveillance, increased screening, etc.).]
[-Roles and responsibilities in providing security to [Recipient of security service] at each MARSEC level.]

5. POINTS OF CONTACT. [Identify the POCs for all applicable organizations under the Agreement; including addresses and phone numbers (fax number, e-mail, or internet addresses can also be included).]

6. OTHER PROVISIONS. Nothing in this Agreement is intended to conflict with current laws or regulations of [applicable State] or [applicable local Government]. If a term of this agreement is inconsistent with such authority, then that term shall be invalid, but the remaining terms and conditions of this agreement shall remain in full force and effect.

7. EFFECTIVE DATE. The terms of this agreement will become effective on [EFFECTIVE DATE].

8. MODIFICATION. This agreement may be modified upon the mutual written consent of the parties.

9. TERMINATION. The terms of this agreement, as modified with the consent of both parties, will remain in effect until the grant end dates for an approved grant. Either party upon [NUMBER] day’s wr itten notice to the other party may terminate this agreement.

APPROVED BY: Organization and Title
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Program Appendix H:

Emergency Management Performance Grant Program
As a reminder, while this appendix contains Emergency Management Performance Grant (EMPG) Program-specific information and requirements, the main content of this Manual (non-appendix information) contains important information relevant to all preparedness grant programs, including the EMPG Program.

NOTE: An “EMPG Requirements Matrix” is provided at the end of this Appendix. It is intended to serve as a useful reference for grant recipients and subrecipients by capturing all of the various programmatic and financial requirements associated with the FY 2023 EMPG Program.

EMPG Program Priorities
The national priorities for the FY 2023 EMPG Program are:
• Equity
• Climate Resilience
• Readiness
These priorities correspond directly to goals outlined in the 2022-2026 FEMA Strategic Plan. All EMPG Program recipients are encouraged to review the strategic plan and consider how FY 2023 EMPG Program funding can be used to support the Plan’s goals and objectives as they apply to the state/territory’s specific needs and the needs of the whole community. The national priorities are explained in further detail in the FY 2023 EMPG Program Notice of Funding Opportunity (NOFO).

Alignment of the EMPG Program to the National Preparedness System The EMPG Program contributes to the implementation of the National Preparedness System by supporting the building, sustainment, and delivery of core capabilities. Core capabilities are essential for the execution of critical tasks for each of the five mission areas outlined in the National Preparedness Goal (the Goal).

The EMPG Program’s allowable costs support efforts to build and sustain core capabilities across the Prevention, Protection, Mitigation, Response, and Recovery mission areas described in the Goal.

FEMA requires recipients to prioritize grant funding to demonstrate how EMPG Program-funded investments support 1) building or sustaining those capabilities that are identified as high priority through the Threat and Hazard Identification and Risk Assessment (THIRA)/Stakeholder Preparedness Review (SPR) process and other relevant information sources, such as: i) after-action reports (AARs) following exercises or real-world events; ii) audit and monitoring findings; iii) Hazard Mitigation Plans; and/or iv) other deliberate planning products; and 2) closing capability gaps that are identified in the state or territory’s most recent SPR. To better understand the relationship between building capabilities and closing capability gaps, refer to Comprehensive Preparedness Guide (CPG) 201: Threat and Hazard Identification and Risk Assessment (THIRA) and Stakeholder Preparedness Review (SPR) Guide.. In advance of issuing the FY 2023 EMPG Program awards, FEMA Regional Administrators will identify individual regional priorities based on their unique knowledge of each region’s preparedness and emergency management needs and will share those priorities with the states and territories within their region. The final priorities will be identified and mutually agreed to by the state/territory and Regional Administrator through a collaborative negotiation process. Ideally, all EMPG Program-funded projects, as outlined in the approved FY 2023 EMPG Program Work Plan, will support the priorities identified through this collaborative approach. See the EMPG Program Work Plan section for additional guidance.

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FEMA continues to place emphasis on capabilities that address the greatest risks to the security and resilience of the United States. When applicable, funding should support deployable assets that can be used anywhere in the Nation through automatic assistance and mutual aid agreements, including, but not limited to, the Emergency Management Assistance Compact. The EMPG Program supports investments that improve the ability of jurisdictions nationwide to:
• Prevent a threatened or an actual act of terrorism;
• Protect our citizens, residents, visitors, and assets against the greatest threats and hazards; • Mitigate the loss of life and property by lessening the impact of future disasters; • Respond quickly to save lives, protect property and the environment, and meet basic human needs in the aftermath of a catastrophic incident; or
• Recover through a focus on the timely restoration, strengthening, and revitalization of infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic, and environmental fabric of communities affected by a catastrophic incident.

The core capabilities contained in the Goal are highly interdependent and require the use of existing preparedness networks and activities to improve training and exercise programs, innovation, and appropriate administrative, finance, and logistics systems.

Implementation of the National Preparedness System
Identifying and Assessing Risk and Estimating Capability Requirements By December 31, 2022, recipients were required to complete a THIRA/SPR that addresses all 32 core capabilities and is compliant with Comprehensive Preparedness Guide (CPG) 201, Third Edition.

Recipients are required to submit a THIRA every three (3) years to establish a consistent baseline for assessment. 2022 is the start of the new 3-year THIRA/SPR cycle and baseline assessment year for existing recipients. Any new grant recipients during calendar year 2023, for which the THIRA/SPR requirement applies, will start their new 3-year THIRA/SPR cycle and baseline assessment year in 2023. Specific guidance on the requirements for each core capability is provided through program implementation support and supplemental guidance, as some core capabilities have fewer reporting requirements than others.

Recipients must continue to respond to a series of planning-related questions as part of the THIRA/SPR process.

While the THIRA is only required every three years, jurisdictions are required to submit an SPR annually.

The submission deadline is December 31st each year (as applicable). For additional guidance on the THIRA/SPR, please refer to Comprehensive Preparedness Guide (CPG) 201, Third Edition. Recipients are also encouraged to refer to the Preparedness Toolkit, which is an online portal that provides the whole community with tools to aid in implementing all six areas of the National Preparedness System.

Reporting:
• All EMPG Program recipients are required to submit a Biannual Strategy Implementation Report (BSIR) no later than 30 days after the end of each semi-annual reporting period. The BSIR is submitted via the Grants Reporting Tool (GRT).
o For the reporting period January 1-June 30, the BSIR is due no later than July 30 o For the reporting period July 1-December 31, the BSIR is due no later than January 30 • In each EMPG Program recipient’s Performance Progress Report (PPR), submitted via ND Grants on a quarterly basis, the recipient must describe how expenditures support building capability, closing capability gaps, or sustaining capabilities identified in the THIRA/SPR process. EMPG Program recipients will, on a project-by-project basis, check one of the following:

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o Building a capability with EMPG Program funding; or
o Sustaining a capability with EMPG Program funding.

Building and Sustaining Core Capabilities
Recipients must describe how proposed EMPG Program-funded projects will close capability gaps or sustain capabilities identified through the THIRA/SPR process, particularly SPR Step 2 (see Comprehensive Preparedness Guide (CPG) 201, Third Edition), or other relevant information sources that identify capability needs. See EMPG Program Work Plan section for additional guidance and requirements.

National Incident Management System (NIMS) Implementation EMPG Program recipients and subrecipients are required to implement NIMS. NIMS guides all levels of government, nongovernmental organizations (NGO), and the private sector to work together to prevent, protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the whole community with the shared vocabulary, systems, and processes to successfully deliver the capabilities described in the National Preparedness System. EMPG Program recipients must use standardized resource management concepts for resource typing, credentialing, and an inventory to facilitate the effective identification, dispatch, deployment, tracking, and recovery of resources.

EMPG Program funds may be used for NIMS implementation; specifically, to meet the requirements described in the NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions.

This document should be used as a guide for both identifying NIMS implementation objectives and needs and as a tool for evaluating NIMS compliance. Additional information about NIMS implementation is available at NIMS Implementation and Training.

Reporting:
• Recipients will answer questions in the applicable secondary NIMS assessment portion of the Unified Reporting Tool (URT) as part of a jurisdiction’s THIRA/SPR submission. This involves reporting on the status of the qualification system used within the jurisdiction and sub-jurisdictions, as outlined in the EMPG Program NOFO.
• Reporting will also be through a review by the FEMA Regional NIMS Coordinators during annual technical assistance visits with the states, tribes, and territories within their regions.

National Qualifications System (NQS) Implementation
For FY 2023, as a post-award requirement, all recipients in the 50 states and District of Columbia must work towards achieving the Phase 1 NQS Implementation Objectives outlined in the table below and must, at a minimum, execute the Implementation Plan they developed last year as part of the Phase 0 NQS Implementation Objectives. Jurisdictions that began implementation in FY 2023 shall have designed and adopted organizational qualification system procedures, a certification program and credentialing standards for incident workforce personnel in alignment with the NIMS Guideline for the National Qualification System. All other jurisdictions (including territories and FY 2023 EMPG Program subrecipients) are required to work toward implementation of NQS by developing an Implementation Plan, using the FEMA- provided two-page template referenced in the table below.

For all states and territories, the following requirements shall apply:
• At a minimum, only EMPG Program-funded deployable personnel, as determined by each recipient organization, will be required to meet NQS certification requirements.

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• Recipients and subrecipients will be considered in compliance with the NQS requirements as long they are working towards implementing the NQS Implementation Objectives as outlined in the table below.
• The expected completion date for each phase of the NQS Implementation Objectives is December 31 of the applicable calendar year (CY).

Additional NQS Implementation Guidance can be found at: National Qualification System Supplemental Documents | FEMA.gov.

NQS Implementation Phase Objectives
Phase 0: NQS Implementation Objectives for
CY 2022
Example Indicators
▪ Only the 50 States, the District of Columbia and
Puerto Rico shall work toward implementation
of NQS by developing an Implementation Plan,
using the FEMA-provided two-page template.
▪ The Implementation Plan will identify a
jurisdiction’s timeline for implementing NQS
by CY 2025.
▪ All other jurisdictions are encouraged to begin
working toward identifying, at a minimum,
frequently deployed positions and
implementation but will not be required until
CY 2023.
▪ Completion of a jurisdiction implementation
plan.
▪ Identification of implementation challenges.

Phase 1: NQS Implementation Objectives for
CY 2023 Example Indicators
▪ All jurisdictions shall work toward
implementation of NQS by developing an
Implementation Plan, using the FEMA-
provided two-page template.
▪ Jurisdictions that began implementation in CY
2022 shall have designed and adopted
organizational qualification system procedures,
a certification program and credentialing
standards for incident workforce personnel in
alignment with the NIMS Guideline for the
National Qualification System.
▪ Completion of a jurisdiction implementation
plan.
▪ Identification of implementation challenges.
▪ Qualification policies and procedures approved
by the jurisdiction. Procedures may include:
− Establishment of a Qualification Review
Board, or equivalent review processes for
incident workforce personnel qualifications.
− Individual and team coach and evaluation
processes for incident workforce personnel
qualifications.

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Phase 2: NQS Implementation Objectives for
CY 2024 Example Indicators
▪ All jurisdictions shall have designed and
approved organizational qualification system
procedures, certification program and
credentialing standards for incident workforce
personnel in alignment with the NIMS
Guideline for the National Qualification
System.
▪ Jurisdictions that began implementation in CY
2022 shall have issued position task books
(PTBs) to incident workforce personnel, as
designated by the jurisdiction, and ensure
incident workforce personnel show progress in
working towards task endorsements and
minimum training requirements.
▪ In CY 2024, all jurisdictions partially satisfy the
requirement by ensuring incident workforce
personnel, which they designate, meet the
minimum training requirements from the Job
Title/Position Qualification.
▪ Jurisdictions shall use a resource management
or qualification tool system to track the
qualification, certification and credentialing of
incident workforce personnel.
▪ Qualification policies and procedures approved
by the jurisdiction.
▪ Minimum criteria that trainees must meet to be
qualified in a specific position is outlined in the
NQS Job Title/Position Qualification.
▪ PTB issuance and completion data.
▪ Adoption of a resource management system
such as OneResponder, which is a web-based
application hosted in a cloud environment. It
allows AHJs to manage qualifications of
personnel.

Phase 3: NQS Implementation Objectives for
CY 2025
Example Indicators
▪ All jurisdictions shall have issued PTBs to
incident workforce personnel, which they
designate, and ensure incident workforce
personnel show progress in working towards
task endorsements and minimum training
requirements.
▪ PTB issuance and completion data.

Reporting:

Data collection and reporting on NQS implementation will be addressed via the following:
• NIMS secondary assessment questions on the URT. This involves reporting on the status of the qualification system used within the jurisdiction and sub-jurisdictions. • NIMS Regional Coordinator Program Guide that allows Regional NIMS Coordinators to review state NIMS programs by the end of CY 2023.
• Review by the Regional NIMS Coordinators during annual technical assistance visits with the states, tribes, and territories within their regions.

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Logistics Planning
Distribution Management Plans
EMPG Program recipients are required to develop and maintain a Distribution Management (DM) plan as an annex to their existing Emergency Operations Plan (EOP). Comprehensive Preparedness Guide (CPG) 101 provides guidance on the fundamentals of planning and development of Emergency Operations Plans.

The Distribution Management Plan Guide 2.0 (fema.gov) released in January 2022 provides information on how to develop the DM plan annex, key DM plan components, how to review and update a DM plan, and how FEMA reviews and evaluates the plans.

A state/territory should submit its DM Plan as both a Word document and PDF to its FEMA Regional Grants Division. The maturity level of the plan may vary by state/territory, but the recipient is required to submit a DM Plan that accurately reflects the state or territory’s current capabilities and capacity to distribute resources to survivors after a disaster and addresses the following components: Requirements Defining; Resource Ordering; Distribution Methods; Inventory Management; Transportation; Staging; and Demobilization.

The DM plan must be reviewed by recipients on an annual basis and updated as necessary by September 30th of each calendar year. In the applicable secondary CPG 101 assessment portion of the online URT, jurisdictions capture whether they have developed and incorporated a DM plan in their EOP. • The DM plan should focus on the distribution of commodities and supplies such as food, water, generators and tarps to survivors following a disaster. • The DM plan should address strategies/plans for the following:
o Requirements Defining
o Resource Ordering
o Distribution Methods
o Inventory Management
o Staging Areas
o Transportation
o Demobilization
FEMA Regional Logistics Branch staff will work with EMPG Program recipients to provide technical assistance during the development and maintenance of their DM plans, and to ensure all recipients have effective DM plans capable of integrating with federal, NGOs, private sector, and state, local, tribal, and territorial stakeholders during major disasters. Recipients should refer to the following for additional guidance:
• Information Bulletin (IB) 442, Guidance on Distribution Management Plans for the Fiscal Year 2019 Emergency Management Performance Grants Program; and • Distribution Management Plan Guidance found at: Planning Guides | FEMA.gov Additional Logistics Planning Resources
FEMA recommends that EMPG Program recipients use the following resources in developing their DM plan. To learn more about these programs and documents, or for any questions, please contact the Logistics Section Chief from your FEMA Region.
• The Logistics Capability Assessment Tool 2 (LCAT2) Flyer: The LCAT2 Flyer provides an overview of the LCAT2, how it is beneficial, how the LCAT process works, and how to obtain an LCAT2.

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• Points of Distribution (PODs) Training: FEMA Logistics developed a comprehensive POD training to assist states in developing actionable emergency distribution plans and understanding associated challenges. Additional information, including an explanatory DVD, POD guide, and online exam, are available on the Emergency Management Institute’s (EMI) website at FEMA - Emergency Management Institute (EMI) Course | IS-26: Guide to Points of Distribution. • Interagency Logistics (IL) Training: This basic IL training course (Interagency Logistics Training, E8540) familiarizes participants with the IL concepts of planning and response. The course also provides an overview of IL Partner disaster response organizations, discusses parameters for logistics support coordination, and creates a whole community forum to exchange the best logistics practices. Recipients may find more information on this and other courses by visiting the EMI website Emergency Management Institute | EMI Courses & Schedules (fema.gov). • Other Logistics Planning Resources: Recipients will find additional planning guidance at:

Planning Guides | FEMA.gov. Specific to logistics planning, Comprehensive Preparedness Guide (CPG) 101, Version 2.0 provides guidance on how to incorporate logistics into EOPs. Additionally, the Supply Chain Resilience Guide provides emergency managers with recommendations and best practices on how to analyze local supply chains and work with the private sector to enhance supply chain resilience using a five-phased approach.

Funding for Critical Emergency Supplies
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an allowable expense under the EMPG Program. Each state must have FEMA’s approval of a five-year viable inventory management plan prior to allocating grant funds for stockpiling purposes. The inventory management five-year plan should include a distribution strategy and related sustainment costs if the grant expenditure is over $100,000.

Reporting
Annual DM plan reviews will be reported in the Performance Progress Report (PPR) for the quarter ending September 30 of the most recently awarded EMPG Program. Reviews that result in an update must be submitted to the Regional Grants Division Director or Regional EMPG Program Manager for review by regional logistics staff. The Regional Logistics Staff will review and rate the plans using the latest FEMA Distribution Management Plan Guide 2.0.

Evacuation Planning
EMPG Program recipients should review and update their EOP in accordance with Comprehensive Preparedness Guide (CPG) 101 v3, Developing and Maintaining Emergency Operations Plans. Recipients are highly encouraged to include an evacuation plan or annex as part of their EOP as well as plans to exercise and validate the evacuation plan and capabilities. At a minimum, recipients should incorporate the National Response Framework’s Mass Evacuation Incident Annex’s planning considerations, and other FEMA documents related to evacuation planning, when developing their own Evacuation Plan or Annex.

See National Response Framework (NRF), Third Edition (June 2016) and NRF Mass Evacuation Incident Annex (June 2008). Additional National Preparedness resources are available at: National Preparedness and Planning Guides. Specific to evacuation planning, the Evacuation and Shelter in Place Guidance identifies relevant concepts, considerations, and principles that can inform jurisdictions in planning for evacuation and/or shelter-in-place protective actions.

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Disaster Housing Planning
State-Led Disaster Housing Task Force
Based on lessons learned from recent disasters, FEMA strongly encourages EMPG Program recipients to establish a State-Led Disaster Housing Task Force (SLDHTF) plan as part of their EOP or as a standalone document and update their plan at least once every two years.

SLDHTFs lead and coordinate state, local, private sector, and community-based actions to assess housing impacts, identify appropriate post-disaster housing options, and establish processes for expediting post- disaster housing delivery. SLDHTF plans should clearly identify the roles, responsibilities, composition, and mobilization procedures for the SLDHTF, and how the SLDHTF integrates into the incident command structure. To have a successful SLDHTF plan, FEMA encourages recipients to:
• Complete the State Housing Strategy Template; and
• Establish a State Disaster Recovery Coordinator.

State Housing Strategy Template
EMPG Program recipients are strongly encouraged to update their State Housing Strategy using the State Housing Strategy Template as part of their EOP or as a standalone document. In addition to the State Housing Strategy Template, recipients are encouraged to define and emphasize sheltering, short term, and permanent housing planning.

The State Housing Strategy Template helps states identify priorities and document critical, jurisdiction- specific processes and procedures to promote an efficient disaster housing mission. The template walks recipients through the following planning considerations as seen in the table below. See the State- Administered Direct Housing Grant Guide, July 2020 for the template and other supporting information.

State Housing Template Sections and Planning Considerations Template Section Planning Considerations
SLDHTF Plan
Organization
Participant inclusion, approaches for various types of housing disasters, available materials, available assistance programs, and sources for surge staffing Housing
Background
Identifying a jurisdiction’s current housing situation, priorities, capabilities, challenges, and known risks
Sheltering Phase
Strategy
Identifying planning leads, current resources, timeline, key partners, cross- jurisdictional agreements, and other risks
Interim Housing
Strategy
Identifying planning leads, current resources and capabilities, known areas of difficulty, key partners, relocation strategies, and risks Permanent
Housing Strategy
Identifying planning leads, long-term housing needs and prioritizations, current resources and capabilities, known areas of implementation challenges, relocation strategies, and risks
Pre-Disaster
Activities
Creating communication plans, survivor transition plans, mitigation plans, and program closeout goals
Post-Disaster
Activities
Prioritizing disaster housing recovery activities, creating timelines for project completion, documenting planned actions for assessing the availability of affordable housing resources and expediting the delivery of housing by expediting permitting and waiver processes, establishing an information sharing method, creating an Environmental Planning and Historic Preservation (EHP) strategy,

EMPG Program Appendix | 2023 Page H-9
Template Section Planning Considerations
identifying potential locations for Manufactured Housing Units and Recreational Vehicles, and identifying available federal disaster housing assistance State-Administered Direct Housing Implementation
FEMA encourages states to develop the capacity to administer FEMA Direct Housing Assistance through a reimbursable Inter-Governmental Service Agreement (IGSA). Under this arrangement, FEMA determines disaster survivors’ eligibility for specific direct housing options and makes all determinations regarding continuing eligibility, appeals, and eligibility terminations. FEMA also monitors the state’s administration of approved Direct Housing Options to ensure compliance with federal environmental, historic preservation, and floodplain management requirements as well as program conditions specified within the IGSA. States that choose to administer Direct Housing Assistance through an IGSA are required to develop a Direct Housing Administrative Plan and are encouraged to establish pre-placed contract to support the delivery of direct housing. Any contracts for this work would need to comply with the federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. For more information, regarding Direct Housing Assistance, please visit Chapter 5 of the Individuals and Households Program Unified Guidance and Chapter 3 of the Individual Assistance Program and Policy Guide (IAPPG).

Disaster Housing Exercises
Recipients are encouraged to exercise and validate their long-term sheltering and housing stabilization plans as part of an existing exercise program. This includes:
• Validating the organizational structure of the Housing Task Force and internal readiness capabilities to address post-disaster housing recovery issues or administer FEMA Direct Housing Assistance under an IGSA
• Validating disaster housing communication plans and procedures that coordinate and integrate the activities and information generated by internal/external partners • Validating data systems, security, and exchange protocols • Validating planned actions and milestones transitioning from emergency sheltering to temporary housing to permanent housing and long-term recovery
Additional Disaster Housing Planning Resources
Recipients are encouraged to review the planning guidance available at Planning Guides. The Planning Guides page includes: Planning Considerations: Disaster Housing Guidance for State, Local, Tribal and Territorial Partners (May 2020), which supplements Comprehensive Preparedness Guide (CPG) 101:

Developing and Maintaining Emergency Operations Plans. It provides guidance on national housing priorities, types of housing, key considerations and housing-specific planning recommendations for state, local, tribal and territorial (SLTT) jurisdictions to use, in conjunction with the Six-Step Planning Process described in CPG 101, to develop or improve disaster housing plans.

State Disaster Recovery Coordinator
The Pre-Disaster Recovery Planning Guide helps states prepare for recovery by developing pre-disaster recovery plans that follow a process to engage members of the whole community, develop recovery capabilities, and create an organizational framework for recovery efforts.

FEMA strongly recommends that EMPG Program recipients include pre-disaster recovery planning as part of their State Readiness and Preparedness efforts by establishing a State Disaster Recovery Coordinator (SDRC). An effective pre-disaster recovery plan and process is crucial to help recipients prepare for major disaster incidents and recover effectively. Recipients are encouraged to use the Pre-Disaster Recovery

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Planning Guide to help inform their identification and establishment of a SDRC. The SDRC position should be included in the State Administrative Plan with the following responsibilities:
• Development of the pre-disaster recovery plan, including state-level leadership and structure, formation of communication channels, multi-agency coordination, and building whole-community partnerships to support recovery efforts.
• Set the stage for necessary strategic, operational, and tactical post-disaster planning, actions, and processes.
• Maximize impact of federal, private sector, and nongovernmental dollars to enable recovery and resilience.
• Accelerate the delivery of resources, including funding and technical assistance, to disaster- impacted communities.
• Enable state leadership to better organize and identify gaps in the state’s recovery capabilities.

Disaster Financial Management Policies and Procedures
Lessons learned from recent hurricane seasons and wildfires demonstrate the need for impacted jurisdictions to improve their ability to immediately track and account for disaster costs. Disaster financial management includes policies and procedures that work to recover expenses pertaining to damage, emergency protective measures, and debris management during and after a disaster. These policies and procedures include, but are not limited to, those supporting eligible contract costs and force account labor, materials, and equipment.

State Administrative Plan
FEMA strongly recommends that EMPG Program recipients include disaster financial management planning as part of their State Administrative Plan. An effective disaster financial management plan and process is crucial to help recipients prepare for declarations of emergencies or major disasters and plan for reimbursement. The table below details the processes that should be included in the State Administrative Plan and recommendations on where they should be placed.

State Administrative Plan Guidance
State Administrative Plan
Section Recommendations Processes
• Section V Part D: Project
Funding and Reimbursement
• Section V Part G: Records
and Reports
• A process to ensure subrecipients are tracking and
documenting disaster costs necessary for federal
reimbursement, such as receipts, invoices, procurement
documents, contracts, and insurance coverage/claims
• Section V Part D: Project
Funding and Reimbursement
• Section V Part G: Records
and Reports
• A process to document disaster cost operations such as labor, equipment, and materials that are allowable under federal requirements
• Section V Part D: Project
Funding and Reimbursement
• A process to ensure that subrecipients are not receiving a duplication in benefits
• Section IV Part B:

Organization and Staffing
• A process to ensure pre-disaster contracts and procurement strategies are in place, if necessary
Additionally, recipients are encouraged to use EMPG Program funds for training that develops, delivers, and exercises disaster financial management procedures.

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Disaster Financial Management Resources
Recipients are encouraged to use the following resources to inform their disaster financial management planning efforts:
• State Administrative Plan Template: Recipients are recommended to use the State Administrative Plan template found on FEMA’s Public Assistance webpage to inform their planning efforts. The template includes example structure and content as a model for states to create own Administrative Plan.
• Public Assistance Program and Policy Guide: The Public Assistance Program and Policy Guide (PAPPG) combines all Public Assistance policy into a single volume and provides an overview of the PA program implementation process.
• Public Assistance Frequently Asked Questions and Guidance: Recipients are encouraged to view the Public Assistance Frequently Asked Questions and guidance found on the Public Assistance webpage to assist with disaster financial management planning efforts. The webpage provides information pertaining to documentation, Public Assistance grant funding eligibility, and hazard mitigation and can be found at Public Assistance Fact Sheets, Job Aids, and FAQs. • Office of Inspector General (OIG) Audit Tips: Recipients are recommended to consult the DHS OIG report, Audit Tips for Managing Disaster-Related Project Costs (OIG-17-120-D) for further assistance in documenting and accounting for disaster-related costs. This report is informed by OIG audit findings and can assist recipients in addressing issues that are frequent findings in disaster- related audits.
• Disaster Financial Management Guide: The Disaster Financial Management Guide provides guidance for state, local, tribal, and territorial partners on establishing and implementing sound disaster financial management practices.
• Procurement Disaster Assistance Team (PDAT): The PDAT provides training and other resources to assist grant recipients in their efforts to comply with federal procurement standards. See Contracting with Federal Funds for Goods and Services Before, During and After Disasters | FEMA.gov for additional information.

Training and Exercises
Integrated Preparedness Plan (IPP)
Recipients are expected to engage senior leaders and other whole community stakeholders to identify preparedness priorities specific to training and exercise needs, which will guide development of a state/territory multi-year IPP. Similar to the EMPG Program Work Plan development process, these priorities should be informed by various factors, including jurisdiction-specific threats and hazards (i.e., the THIRA); areas for improvement identified by real-world events and exercises (i.e., AARs); external requirements such as stakeholder preparedness reviews (i.e., SPRs), homeland security policy, and industry reports; and accreditation standards, regulations, or legislative requirements. Recipients must document these priorities, in conjunction with the Work Plan development process, and use them to deploy a schedule of preparedness events and activities in the IPP. Information related to IPPs and Integrated Preparedness Planning Workshops (IPPWs) can be found on the HSEEP website at Homeland Security Exercise and Evaluation Program and FEMA Preparedness Toolkit.

Recipients should ensure that their EMPG Program Work Plans and IPPs align with and are complementary to one another and are used in tandem to support shared priorities for building and sustaining the state/territory’s preparedness capabilities. Recipients should include planning, training, and exercise projects in their EMPG Program Work Plan that support priorities included in their IPP. The current multi- year IPP must be submitted to [email protected] and the Regional EMPG Program Manager before January 31 of each year.

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This will help ensure that priorities for both the IPP and EMPG Program Work Plan are based on building capability and/or closing capability gaps documented in their THIRA/SPR and other relevant sources of information. For example, if a recipient included Logistics and Distribution Management, Resilient Communications, and Housing as priorities for its IPP, those should also be priorities in its EMPG Program Work Plan. Additionally, IPPs should include all planning, training, and exercise activities funded by the EMPG Program as well as activities funded by other sources. This inclusion will ensure that recipients’ preparedness projects, investments, and activities are concentrated, focused, and oriented towards closing gaps related to their top priorities, regardless of funding source.

Validating Capabilities through Exercises
All recipients are required to develop and maintain a progressive exercise program consistent with HSEEP guidance in support of the National Exercise Program (NEP). The NEP serves as the principal exercise mechanism for examining national preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’ Strategic Priorities, established by the National Security Council and informed by preparedness data from jurisdictions across the Nation.

The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance, tools and resources, enhanced coordination, and the ability to directly influence and inform policy and preparedness programs. If you have any questions or would like to request assistance through the NEP, please visit the NEP website or reach out to the NEP directly at [email protected].

The exercises and priorities outlined in the IPP and all EMPG Program-funded exercises must be included in the FY 2023 EMPG Program Work Plan. To avoid duplicate reporting, applicants/recipients are not required to report EMPG Program-funded personnel costs associated with exercises in the FY 2023 EMPG Work Plan. See the EMPG Program Work Plan section for additional guidance.

Reporting
• All EMPG Program-funded exercise activities must be captured in the approved EMPG Program Work Plan.
• EMPG Program-funded exercise costs in the Work Plan can include costs to plan, conduct and evaluate the exercise (e.g., planning, materials, props, contractual services for conducting the exercise, AAR and Improvement Plan [IP], etc.).
• All EMPG Program-funded exercise activities must be reported quarterly. To simplify reporting, it is recommended that recipients submit an updated Exercise Data Table from the FY 2023 EMPG Program Work Plan Template as an attachment to the quarterly PPR. For those recipients who choose not to use the FY 2023 EMPG Program Work Plan Template, the data and information found in the Exercise Data Table must still be submitted (in any chosen format) as an attachment to the PPR.
• EMPG Program-funded personnel costs associated with exercises are not required in the FY 2023 EMPG Program Work Plan Template for application or reporting purposes. • Recipients must have a current multi-year IPP that identifies preparedness priorities and activities.

The current multi-year IPP must be submitted to [email protected] and the Regional EMPG Program Manager before January 31st of each year.
• Recipients are encouraged to enter their exercise information into the Preparedness Toolkit at FEMA Preparedness Toolkit.
• Recipients must submit AAR/IPs to [email protected] and copy their Regional EMPG Program Manager and indicate which fiscal year’s funds were used (if applicable). • Submission of AAR/IPs must take place within 90 days following completion of the single exercise or progressive series.

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o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate critical plans or those reflecting large-scale functional or full-scale exercises that took place at the state, territorial, tribal, or regional level. Recipients are discouraged from submitting AAR/IPs specific to local jurisdictions that reflect drills. o If a state, territory, or local jurisdiction has experienced a major disaster and they would like to request exemptions for a scheduled exercise, the recipient should send this request to its assigned Regional EMPG Program Manager through the quarterly PPR. Exemptions will be reviewed by the Region on a case-by-case basis. o Recipients can access a sample AAR/IP template at Preparedness Toolkit Improvement Planning Templates.

Training
Similar to the exercise guidance above, training activities should align to a current, multi-year IPP developed through an annual IPPW and build from training gaps identified in the THIRA/SPR and work plan development process. Further guidance concerning the IPP and the IPPW can be found at HSEEP Resources - Preparedness Toolkit.

Through the National Preparedness Directorate’s training and education enterprise, consisting of the Center for Domestic Preparedness (CDP), the Emergency Management Institute (EMI), and the National Training and Education Division’s partnerships with the National Domestic Preparedness Consortium, Rural Domestic Preparedness Consortium, Continuing Training Grants partners, and the Center for Homeland Defense and Security, FEMA develops and delivers training and education programs to increase capabilities, reduce risk, and build resilient communities. Over 700 tuition-free courses are offered to members of state, local, tribal, and territorial communities. By accessing the National Preparedness Course catalog, users will find all courses to include EMI training and includes links to the basic, advanced, and executive emergency management academies.

FEMA’s National Preparedness Course Catalog
This online searchable catalog features a compilation of courses managed by the three primary FEMA training organizations: the Center for Domestic Preparedness, EMI, and NTED. The catalog features a wide range of course topics in multiple delivery modes for federal, state, local, territorial, and tribal audiences.

The catalog is located at First Responder Training and Education Division.

Training should foster the development of a community-oriented approach to emergency management that emphasizes engagement at the community level, strengthens best practices, and provides a path toward building sustainable resilience, all of which is included in the curriculum of the EMI Basic Academy. The EMI Basic Academy provides a foundational education in emergency management as a way for emergency managers to begin or advance their career. The goal of the Basic Academy is to support the early careers of emergency managers through a training experience combining knowledge of all fundamental systems, concepts, and practices of cutting-edge emergency management.

EMPG Program funds used for training should support the nationwide implementation of NIMS. The NIMS Training Program establishes a national curriculum for NIMS and provides information on NIMS courses.

Recipients are encouraged to place emphasis on the core competencies as defined in the NIMS Training Program. NIMS is also included in the curriculum of the EMI Basic Academy. The NIMS Training Program can be found at NIMS Implementation and Training.

All EMPG Program-funded personnel are expected to be trained emergency managers (see NQS Implementation section). All EMPG Program-funded personnel must complete either the Independent Study courses identified in the Professional Development Series or the National Emergency Management Basic Academy delivered either by EMI or at a sponsored state, local, tribal, territorial, regional, or other

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designated location. Further information on the National Emergency Management Basic Academy and the Emergency Management Professional Program can be found at: EMI EMPP. A complete list of Independent Study Program Courses may be found at EMI Independent Study.

In addition to training activities aligned to and addressed in the IPP, all EMPG Program-funded personnel (including full- and part-time SLTT recipients and subrecipients) must complete the following training requirements and record proof of completion:
1) NIMS Training, Independent Study (IS)-100 (any version), IS-200 (any version), IS-700 (any version), and IS-800 (any version)4, and;
2) Professional Development Series (PDS) or the Emergency Management Professionals Program (EMPP) Basic Academy courses listed in the chart below.

PDS
Professional Development Series OR Basic Academy
Basic Academy Pre-requisites and Courses
IS-120.a: An Introduction to Exercises IS-100 (any version): Introduction to the Incident Command System
IS-230.d: Fundamentals of Emergency
Management IS-700 (any version): National Incident
Management System (NIMS)-An Introduction
IS-235.b: Emergency Planning IS-800 (any version): National Response Framework, An Introduction
IS-240.b: Leadership and Influence IS-230.d: Fundamentals of Emergency Management
IS-241.b: Decision Making and
Problem Solving E/L101: Foundations of Emergency
Management
IS-242.b: Effective Communication E/L102: Science of Disasters IS-244.b: Developing and Managing
Volunteers E/L103: Planning Emergency Operations
IS-244.b: Developing and Managing
Volunteers E/L104: Exercise Design
IS-244.b: Developing and Managing
Volunteers E/L105: Public Information & Warning
The EMI Basic Academy provides this foundational Emergency Management education. To ensure the professional development of the emergency management workforce, the recipients must ensure a routine capabilities assessment is accomplished and an IPP is developed and implemented.

Additional Training Information
Per FEMA Grant Programs Directorate Information Bulletin 432, Review and Approval Requirements for Training Courses Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal entities, and high-risk urban areas are no longer required to request approval from FEMA for personnel to attend non-DHS FEMA training as long as the training is coordinated with and approved by the state, territory, tribal, or high-risk urban area Training Point of Contact (TPOC) and falls within the FEMA mission scope and the jurisdiction’s EOP.

4 NIMS training courses IS-100, IS-200, IS-700, and IS-800 only need to be taken once to fulfill requirements. Also, previous versions of the IS courses are still considered as meeting the NIMS training requirement.

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FEMA will conduct periodic reviews of all state, territory, and urban area training funded by FEMA. These reviews may include requests for all course materials and physical observation of, or participation in, the funded training. If these reviews determine that courses are outside the scope of this guidance, recipients will be asked to repay grant funds expended in support of those efforts.

For further information on developing courses using the instructional design methodology and tools that can facilitate the process, State Administrative Agencies (SAAs), and TPOCs are encouraged to review the National Training and Education Division Training Resource and Development Center website at FRTS- TRDC Home.

Reporting
• All EMPG Program-funded training activities must be captured in the approved EMPG Program Work Plan and should be included in the IPP. This includes training for which the only expenses are for overtime and/or backfill costs associated with emergency management personnel attending the training.
• All EMPG Program-funded training activities must be reported quarterly. To simplify reporting, it is recommended the recipient submit an updated Training Data Table from the FY 2023 EMPG Program Work Plan Template as an attachment to the quarterly PPR. For those recipients who choose not to use the FY 2023 EMPG Program Work Plan Template, the data and information found in the Training Data Table must still be submitted (in any chosen format) as an attachment to the PPR.
• Recipients must report their NIMS implementation status of their jurisdiction and sub-jurisdictions, including the training of personnel, in the applicable secondary NIMS assessment portion of the URT as part of their THIRA/SPR submission.
• Recipients must maintain proof of completion of training requirements. Recipients are encouraged to use the OneResponder system to enter, track, and report training. • Training Information Reporting System (“Web Forms”): Web Forms is an electronic data management system built to assist SAA TPOCs and federal agencies to submit non-NTED training courses for inclusion in the State/Federal-Sponsored Course Catalog. The information collected is used in a two-step review process to ensure that the training programs adhere to the EMPG Program’s intent, and the course content is sound and current. While reporting training activities through Web Forms is not required under the EMPG Program, the system remains available and can be accessed through the Web-Forms section of the FEMA National Preparedness Course Catalog to support recipients in their own tracking of training deliveries.

Reviewing and Updating Planning Products
Based on the applicant’s current THIRA/SPR, capability levels, and resources, plans should be reviewed on an annual basis to determine if they remain relevant or need to be updated. This review should be based on a current THIRA/SPR and utilize information gathered during the capability validation process. These reviews will provide a means to determine priorities, direct preparedness actions, and calibrate goals and objectives.

Additional Considerations
Strengthening Governance Integration
FEMA preparedness grant programs are intended to support the core capabilities across the five mission areas of Prevention, Protection, Mitigation, Response, and Recovery that are necessary to prepare for incidents that pose the greatest risk to the Nation’s security. Each program reflects the Department’s intent to build and sustain an integrated network of national capabilities across all levels of government and the

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whole community. Disparate governance structures must be integrated and refined to ensure resources are targeted to support the most critical needs of a community based on risk-driven, capabilities-based planning. Strong and inclusive governance systems better ensure that disparate funding streams are coordinated and applied for maximum impact.

FEMA requires that all governance processes that guide the allocation of preparedness grant funds adhere to the following guiding principles:
• Coordination of Investments: Resources must be allocated to address the most critical capability needs as identified in the SPR and coordinated among affected preparedness stakeholders, including appropriate representatives of at-risk, underserved communities. • Transparency: Stakeholders must be provided visibility on how preparedness grant funds are allocated and distributed, and for what purpose.
• Substantive Local Involvement: The tools and processes that are used to inform the critical priorities, which FEMA grants support, must include local government representatives. At the state and regional levels, local risk assessments must be included in the overarching analysis to ensure that all threats and hazards are accounted for. Primary focus should be on the needs of socially vulnerable, underserved populations and ensuring equity for those most at risk relative to disaster preparedness, response, and recovery.
• Accountability: FEMA recognizes that unique preparedness gaps exist at the local level. Grant recipients are responsible for ensuring the effective use of funds to address those gaps and for maintaining and sustaining existing capabilities, particularly when it comes to serving the needs of at-risk, underserved communities.
• Support of Regional Coordination: Inter/intra-state partnerships and dependencies at the state and regional levels, including those within metropolitan areas, must be recognized.

Program Performance Reporting Requirements
Performance Progress Reports (PPR)
Recipients are responsible for providing performance reports to FEMA on a quarterly basis. As explained in the Standardized Programmatic Reporting section below, the quarterly PPRs must be based on the approved EMPG Program Work Plan and are due no later than 30 days after the end of the quarter.

Although not mandatory, recipients are encouraged to use the updated FY 2023 EMPG Program Work Plan Template – specifically the Implementation Schedule, Training Data Table, and Exercise Data Table – to report on the status of planned project activities, any risks that may affect project progress or success, and updates to project schedules. The PPR (in the form of an updated Work Plan) shall be submitted in ND Grants. See EMPG Program Work Plan section for additional guidance.

Programmatic Reporting Periods and Due Dates
The following reporting periods and due dates apply for the PPR:

Reporting Period Report Due Date
October 1 – December 31 January 30
January 1 – March 31 April 30
April 1 – June 30 July 30
July 1 – September 30 October 30

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Standardized Programmatic Reporting for the EMPG Program The FY 2023 EMPG Program Work Plan Template has been modified to standardize data collection, which enables improved analysis and reporting. The EMPG Program Work Plan includes ten components:
1) Grant Investment Strategy
2) Grant Activities Outline
3) Detailed Budget – Excluding Management and Administrative (M&A) 4) Budget Narrative – Excluding M&A
5) Detailed Budget – M&A Only
6) Budget Narrative – M&A Only
7) EMPG Program Summary
8) Implementation Schedule
9) Training Data Table
10) Exercise Data Table
Although use of the FY 2023 EMPG Program Work Plan Template is not mandatory (see EMPG Program Work Plan section), baseline data on personnel, training, and exercises, as well as the information included on the Grant Activities Outline and Implementation Schedule, must be provided in the EMPG Program Work Plan at the time of application regardless of the chosen work plan format.

The status of all EMPG Program-funded plans, training, and exercise activities must be reported quarterly as part of the PPR. To facilitate reporting, recipients are encouraged to submit an updated Implementation Schedule, Training Data Table, and Exercise Data Table from the FY 2023 EMPG Program Work Plan Template as an attachment to the quarterly PPR. Recipients who choose not to use the FY 2023 EMPG Program Work Plan Template must still provide the updated data and information included in the Implementation Schedule, Training Data Table, and Exercise Data Table, but may use a different format for reporting that information in their PPR submission.

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EMPG Program Funding Guidelines
Allowable Costs
Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of EMPG Program funds, such as financial management, reporting, and program and financial monitoring. Some examples of M&A costs include grants management training for M&A staff, equipment and supplies for M&A staff to administer the EMPG Program grant, travel costs for M&A staff to attend conferences or training related to the EMPG Program, travel costs for the M&A staff to conduct subrecipient monitoring, contractual services to support the M&A staff with M&A activities, and auditing costs related to the grant award to the extent required or permitted by statute or 2 C.F.R. Part 200. Characteristics of M&A expenses can include the following: 1) direct costs that are incurred to administer a particular Federal award; 2) identifiable and unique to each Federal award; 3) charged based on the activity performed for that particular Federal award; and 4) not duplicative of the same costs that are included in the approved Indirect Cost Rate Agreement, if applicable. It should be noted that salaries of state and local emergency managers are not typically categorized as M&A, unless the state or local Emergency Management Agency (EMA) chooses to assign personnel to specific M&A activities. In this case, personnel and fringe benefits for M&A is allowable.

If the SAA is not the EMA, the SAA is not eligible to retain funds for M&A. M&A costs are allowable for both state and local-level EMAs. The state EMA may use up to 5% of the EMPG Program award for M&A purposes. In addition, local EMAs may retain and use up to 5% of the amount received from the state for local M&A purposes.

Indirect Costs
Indirect costs are allowable under this program. See the “Procedures for Establishing Indirect Cost Rates” Section in “Pre-Submission Information” for more information.

Unrecovered Indirect Costs
In accordance with 2 C.F.R. § 200.306(c) “[u]nrecovered indirect costs, including indirect costs on cost sharing or matching may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency. Unrecovered indirect cost means the difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the non- Federal entity’s approved negotiated indirect cost rate.” Therefore, unrecovered indirect costs may be applied to meet cost share requirements of the EMPG Program grant with the approval of the Regional Grants Division. To meet the cost sharing requirements, the recipient’s indirect costs contributions must be verifiable, reasonable, allocable, necessary, and otherwise allowable under the grant program, and in compliance with all applicable Federal requirements and regulations.

Whole Community Preparedness
EMPG Program recipients should engage with the whole community to advance community and individual preparedness and to work as a nation to build and sustain resilience. Recipients should consider the three goals of the 2022-2026 FEMA Strategic Plan in their program design and delivery. Recipients should integrate program design and delivery practices that ensure representation and services for under- represented diverse populations that may be more impacted by disasters including children, seniors,

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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.

Individual preparedness should be coordinated by an integrated body of government and nongovernmental representatives as well, including but not limited to, elected officials, the private sector (especially privately owned critical infrastructure), private nonprofits, nongovernmental organizations (including faith-based, community-based, and voluntary organizations), advocacy groups for 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. By engaging these stakeholders, EMPG Program recipients can help FEMA develop and promote a suite of well-targeted solutions for individuals and communities to adopt. Recipients should coordinate preparedness initiatives with FEMA and whole community partners to efficiently apply federal funding to reach the goal of individual and community resilience.

The following preparedness programs are allowable expenses and resources:
• Community Emergency Response Team (CERT) programs, which educate volunteers about disaster preparedness for the hazards that may impact their area and train them in basic disaster response skills, such as fire safety, light search and rescue, team organization, and disaster medical operations. CERT offers a consistent, nationwide approach to volunteer training and organization that professional responders can rely on during disaster situations, allowing them to focus on more complex tasks.
• Financial Preparedness Activities that encourage and assist Americans in preparing for the true cost of disasters. Allowable activities include encouraging emergency savings, promoting home and renter’s insurance, and promoting flood insurance for individuals and families. Partnerships with local financial wellness organizations such as credit unions, financial counselors, community banks, and others that reach a variety of audiences are encouraged. • Preparedness of Community-Based Organizations that serve as a critical safety net for Americans disproportionately impacted by disasters. Examples of community-based organizations include but are not limited to food banks, food pantries, homeless shelters, school readiness and after school centers, adult day care centers, job training centers, legal assistance centers, and cultural centers. Allowable activities include Whole Community exercises, trainings, and activities focused on staff preparedness, information sharing with clients and government, and continuity of essential functions in the event of an emergency.
• Youth Preparedness Resources are available on Ready Kids. Bolstering youth preparedness across the nation is a priority for FEMA as the Agency works with state, local, tribal, and territorial partners to create a culture of preparedness in the United States. Information on youth-centric educational curricula, games, planning materials, and other relevant resources can be found at Ready Kids. Furthermore, FEMA’s Individual and Community Preparedness Division and regional- based Community Preparedness Officers are available to provide grant recipients with guidance and assistance. Please email [email protected] to contact one of the Agency’s subject matter experts.

The following are examples of youth preparedness activities that recipients are encouraged to undertake as allowable costs:
o Reach out to a local school board or elementary school to encourage the adoption of the Student Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based emergency preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach format. Students will learn about disasters, emergencies, and hazards, and how to create a

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disaster supply kit and family emergency communication plan. An overview of the STEP program along with the instructor guide and student activity book is available at Ready STEP.
o Sponsor the creation of a Teen for Community Emergency Response Team (CERT) in your jurisdiction. The CERT Program is a national program of volunteers trained in disaster preparedness and emergency response. Volunteers come from all ages and all walks of life, including teenagers. Additional information, including a step-by-step guide on how to start a Teen CERT, is available at Ready Teen CERT.

The following tools are available to order from FEMA’s warehouse free of charge:
o “Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The “Prepare with Pedro: Disaster Preparedness Activity Book” is designed to teach young children and their families about how to stay safe during disasters and emergencies. The book follows Pedro around the United States and offers safety advice through crosswords, coloring pages, matching games, and more. Additional information, including an ordering form, is available at Ready - Prepare with Pedro.
o The Ready 2 Help card game is a fun way for kids to learn how to respond to emergencies by working with friends and using skills that will help in a real emergency. Ready 2 Help teaches five simple steps to stay safe and make a difference until help arrives:
• Stay Safe
• Stay Calm
• Get Help
• Give Info
• Give Care
Ready 2 Help is designed for children ages 8 and up. Additional information, including an ordering form, is available at Ready 2 Help.

Planning
Planning spans all five mission areas of the Goal and provides a methodical way to engage the whole community in the development of a strategic, operational, and/or community-based approach to preparedness. EMPG Program funds may be used to develop or enhance emergency management planning activities. Some examples include:

Emergency Operations Plan
• Maintaining a current EOP that is aligned with guidelines set out in Comprehensive Preparedness Guide (CPG) 101: Developing and Maintaining Emergency Operations Plans • Modifying existing incident management and emergency operations plans • Developing/enhancing large-scale and catastrophic event incident plans Communications Plans
• Developing and updating Statewide Communication Interoperability Plans • Developing and updating Tactical Interoperability Communications Plans Administrative Plans
• Developing/enhancing financial and administrative procedures for use before, during, and after disaster events in support of a comprehensive emergency management program Whole Community Engagement/Planning
• Developing or enhancing mutual aid agreements/compacts, including required membership in EMAC

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• Developing/enhancing emergency operations plans to integrate citizen/volunteer and other Non- Governmental Organization (NGO) resources and participation • Integrating program design and delivery practices that ensure representation and services for 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.

Resource Management Planning
• Developing/enhancing logistics and resource management plans • Developing/enhancing volunteer and/or donations management plans Shelter and Evacuation Planning
• Developing/enhancing sheltering and evacuation plans, including plans for alerts/warning, crisis communications, pre-positioning of equipment for areas potentially impacted by mass evacuations, and re-entry
Recovery Planning
• Disaster housing planning, such as creating/supporting a state disaster housing task force and developing/enhancing state disaster housing plans
• Pre-event response, recovery, and mitigation plans in coordination with state, local, and tribal governments
• Developing/enhancing other response and recovery plans Developing recovery plans and preparedness programs consistent with the principles and guidance in the National Disaster Recovery Framework (NDRF) that will provide the foundation for recovery programs and whole community partnerships. Preparedness and pre-disaster planning were given special attention within the NDRF with specific guidance: Planning for a Successful Disaster Recovery (pages 63-70). For more information on the NDRF see National Disaster Recovery Framework.

Continuity Planning
Continuity planning and operations are an inherent element of each core capability. Continuity operations increase resilience and the probability that organizations can perform essential functions. FEMA develops and promulgates Federal Continuity Directives (FCDs) to establish continuity program and planning requirements for executive departments and agencies and Continuity Guidance Circulars (CGCs) for SLTT governments, non-governmental organizations, and private sector critical infrastructure owners and operators. This direction and guidance assist in developing capabilities for continuing the essential functions of federal, state, local, tribal, territorial governmental entities as well as the public/private critical infrastructure owners, operators, and regulators enabling them.

Presidential Policy 40, FCD 1, FCD 2, CGC 1, and CGC 2 outline the overarching continuity requirements and guidance for organizations and provide guidance, methodology, and checklists. For additional information on continuity programs, guidance, directives, and available technical assistance, visit Continuity Resources and Technical Assistance and the Office of National Continuity Programs.

Allowable continuity planning activities include the development of the following:
• Continuity of operations and Continuity of Government planning products for the continuance of essential functions and associated leadership;
• Risk-based needs assessments based on the THIRA to inform risk mitigation efforts to ensure the continuity of essential functions and associated leadership; and EMPG Program Appendix | 2023 Page H-22
• Public and private sector outreach and messaging regarding continuity resilience benefits and strategies.

Organization
Per the Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 93-288, as amended, (42 U.S.C. §§ 5121-5207), EMPG Program funds may be used for all-hazards emergency management operations, staffing, and other day-to-day activities in support of emergency management, including hazard mitigation staffing of the State Hazard Mitigation Officer position; staffing CERT and Citizen Corps positions at the state and local levels to promote whole community engagement in all phases of emergency management; performing closeout activities on FEMA disaster assistance grants; staffing permanent technical advisors on children’s needs at the state, local, tribal, and territorial levels; and supporting fusion center analysts who are directly involved in all-hazards preparedness activities as defined by the Stafford Act. Proposed staffing activities should be linked to accomplishing the activities outlined in the EMPG Program Work Plan. Recipients are encouraged to fund at least one dedicated Planner, Training Officer, and Exercise Officer. Personnel costs, including salary, overtime, compensatory time off, and associated fringe benefits, are allowable EMPG Program costs and must comply with 2 C.F.R. Part 200, Subpart E – Cost Principles.

Federal (and Mutual Aid) Emergency Response Official (F/ERO) Credentialing and Validation The following costs related to F/ERO credentialing and validation are allowable under the EMPG Program:
• Working group meetings and conferences relating to emergency responder credentialing and validation;
• Compiling data to enter into an emergency responder repository; • Coordinating with other state, local, territorial, and tribal partners to ensure interoperability among existing and planned credentialing and validation systems and equipment; and • Planning to incorporate emergency responder identity and credential validation into training and exercises.

Organizational Clothing Costs for Emergency Management Personnel There may be a need for emergency management personnel to wear clothing that clearly identifies their agency, organizational function, and responsibilities when carrying out their official emergency-related duties. EMPG funding may be used to purchase organizational clothing for full-time emergency management personnel who may be deployed for emergency operations, including when:
• The Emergency Operations Center (EOC) is activated;
• Emergency management personnel are deployed in the field to conduct damage assessments and response and recovery operations;
• Assisting in and delivering official emergency management training and exercises, and; • Providing public information briefs and interviews on behalf of their emergency management agency.

The state or territory emergency management agency should maintain an inventory of such clothing and uniforms to allow for issuance to other personnel who may be deployed for emergency operations.

In addition:
• EMPG funding may not be used to purchase clothing that would be used for everyday wear by emergency management employees or other personnel.
• Clothing, uniforms, undergarments, jackets, vests, etc. are also allowable for CERT members as listed on the Authorized Equipment List (AEL): 21GN-00-CCEQ | FEMA.gov.

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For a complete list of other eligible clothing and protective gear allowable for purchase with EMPG funding, applicants, recipients and FEMA staff are encouraged to refer to the AEL website for the most up- to-date information: Authorized Equipment List | FEMA.gov.

Equipment
Allowable equipment categories for the EMPG Program are listed in the Authorized Equipment List (AEL).

Unless otherwise stated, equipment must meet all mandatory regulatory and/or FEMA-adopted standards to be eligible for purchase using these funds. In addition, agencies will be responsible for obtaining and maintaining all necessary certifications and licenses for the requested equipment. Allowable equipment includes equipment from the following AEL categories:
• Personal Protective Equipment (Category 1)
• Information Technology (Category 4)
• Cybersecurity Enhancement Equipment (Category 5)
• Interoperable Communications Equipment (Category 6)
• Detection Equipment (Category 7)
• Power Equipment (Category 10)
• Chemical, Biological, Radiological, Nuclear, and Explosive (CBRNE) Reference Materials (Category 11)
• CBRNE Incident Response Vehicles (Category 12)
• Physical Security Enhancement Equipment (Category 14) • CBRNE Logistical Support Equipment (Category 19)
• Other Authorized Equipment (Category 21)
In addition to the above, general-purpose vehicles may be procured in order to carry out the responsibilities of the EMPG Program.

If recipients have questions concerning the eligibility of equipment not specifically addressed in the AEL, they should contact their Regional EMPG Program Manager for clarification. Applicants should analyze the cost benefits of purchasing versus leasing equipment, especially high-cost items and those subject to rapid technical advances. Large equipment purchases must be identified and explained. For more information regarding property management standards for equipment, please reference 2 C.F.R. Part 200, including 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405- 143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services, or successor policy, regarding prohibitions on covered telecommunications equipment or services.

Recipients using EMPG Program funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at SAFECOM Funding Resources.

In general, with exception of critical emergency supplies and the associated inventory management plan, equipment included in the AEL may be purchased without separate approval from FEMA. However, as with all grant-funded activities, the equipment purchase must be well justified and reasonable. Furthermore, the purchase must be supported by the approved Work Plan. If the equipment is not clearly supported by the approved Work Plan, the recipient must seek advance approval from the applicable FEMA Regional Grant Program Office prior to purchasing the equipment, and an updated Work Plan may be required.

FEMA will consider requests to purchase equipment that is not listed in the AEL on a case-by-case basis.

Such requests should be submitted in writing to the applicable FEMA Regional Grant Program Office.

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program staff to ensure nationwide consistency in the decision-making process and to support any necessary updates to the AEL.

Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft System (sUAS) must comply with FEMA Policy 207- 22-0002, Prohibited or Controlled Equipment Under FEMA Awards, and must include the policies and procedures in place to safeguard individuals’ privacy, civil rights, and civil liberties in the jurisdiction that will purchase, take title to, or otherwise use the sUAS equipment. Additional information and requirements applicable to sUAS purchases can be found in the AEL at 03OE-07-SUAS.

Acquisition and Use of Technology to Mitigate UAS (Counter-UAS) In August 2020, FEMA alerted of an advisory guidance document issued by DHS, the Department of Justice, the Federal Aviation Administration, and the Federal Communications Commission: Advisory on the Application of Federal Laws to the Acquisition and Use of Technology to Detect and Mitigate UAS.

The purpose of the advisory guidance document is to help non-federal public and private entities better understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate threats posed by UAS operations (i.e., Counter-UAS or C-UAS). The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do they conduct legal reviews of commercially available product compliance with those laws. The advisory does not address state and local laws nor potential civil liability, which UAS detection and mitigation capabilities may also implicate. It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state criminal, surveillance, and communications laws. Entities should conduct their own legal and technical analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’ representations of the systems’ legality or functionality. Please also see the DHS press release on this topic for further information:

Interagency Issues Advisory on Use of Technology to Detect and Mitigate UAS. For training on the application of UAS technology in emergency management programs, please refer to the National Preparedness Course Catalog and search 'UAS' on the website.

Funding for Critical Emergency Supplies
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an allowable expense under the EMPG Program. FEMA must approve a state’s five-year viable inventory management plan prior to allocating grant funds for stockpiling purposes. The five-year plan should include a distribution strategy and related sustainment costs if the grant expenditure is over $100,000.

Training
EMPG Program funds may be used for a range of emergency management-related training activities to enhance the capabilities of state and local emergency management personnel through the establishment, support, conduct, and attendance of training. Training activities should align to a current, multi-year IPP developed through an annual IPPW and build from training gaps identified in the THIRA/SPR process.

Further guidance concerning the IPP and the IPPW can be found at Preparedness Toolkit Program Management Templates. Training should:
• Foster the development of a community-oriented approach to emergency management that emphasizes engagement at the community level;
• Strengthen best practices; and
• Provide a path toward building sustainable resilience.

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Allowable training-related costs include the following:
• Funds Used to Develop, Deliver, and Evaluate Training: Includes costs related to administering training, such as planning, scheduling, facilities, materials and supplies, reproduction of materials, and equipment. Training should provide the opportunity to demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any training or training gaps, including those for children and individuals with disabilities or other access and functional needs, should be identified in the multi-year IPP and addressed in the training cycle. States are encouraged to use existing training rather than developing new courses. When developing new courses, states are encouraged to apply the Analysis, Design, Development, Implementation, and Evaluation (ADDIE) model for instructional design. More information is available at NTED | Training Resource Development Center.
• Overtime and Backfill: Overtime costs, including payments related to backfilling personnel, that are the direct result of attendance at FEMA and/or approved training courses and programs are allowable. These costs are allowed only to the extent the payment for such services is in accordance with the policies of the state or unit(s) of local government and has the approval of the state or FEMA, whichever is applicable. In no case is dual compensation allowable. That is, an employee of a unit of government may not receive compensation from their unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities.
• Travel: Travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as expenses by employees who are on travel status for official business related to approved training. International travel is not an allowable cost under this program unless approved in advance by FEMA. • Hiring of Full- or Part-Time Staff or Contractors/Consultants: Full- or part-time staff or contractors/consultants may be hired to support direct training-related activities. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Payment of salaries and fringe benefits must be in accordance with the policies of the state or unit(s) of local government and have the approval of the state or FEMA, whichever is applicable.
• Certification/Recertification of Instructors: Costs associated with the certification and re- certification of instructors are allowed. States are encouraged to follow the FEMA Instructor Quality Assurance Program to ensure a minimum level of competency and corresponding levels of evaluation of student learning. This is particularly important for those courses that involve training of trainers.

Additional types of allowable training or training-related activities include, but are not limited to:
• Developing/enhancing systems to monitor training programs • Conducting all-hazards emergency management training
• Attending EMI training or delivering EMI train-the-trainer courses • Attending other FEMA-approved emergency management training • State-approved, locally sponsored CERT training
• Mass evacuation training at local, state, territorial and tribal levels Exercises
Allowable exercise-related costs include:
• Funds Used to Design, Develop, Conduct and Evaluate Preparedness Exercises: This includes costs related to planning, meeting space and other meeting costs, facilitation costs, materials and supplies, travel, and documentation. Recipients are encouraged to use free public

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space/locations/facilities whenever available prior to the rental of space/locations/facilities.

Exercises should provide the opportunity to demonstrate and validate skills learned, as well as to identify any gaps in these skills. Gaps identified during an exercise, including those for children and individuals with disabilities or other access and functional needs, should be included in the AAR/IP and addressed in the exercise cycle.
• Hiring of Full- or Part-Time Staff or Contractors/Consultants: Full- or part-time staff may be hired to support direct exercise activities. Payment of salaries and fringe benefits must be in accordance with the policies of the state or unit(s) of local government and have the approval of the state or FEMA, whichever is applicable. The services of contractors/consultants may also be procured to support the design, development, conduct, and evaluation of exercises. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.
• Overtime and Backfill: The entire amount of overtime costs, including payments related to backfilling personnel, that are the direct result of time spent on the design, development and conduct of exercises are allowable expenses. These costs are allowed only to the extent the payment for such services is in accordance with the policies of the state or unit(s) of local government and has the approval of the state or FEMA, whichever is applicable. Dual compensation is never allowable, meaning, in other words, that an employee of a unit of government may not receive compensation from their unit or agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work may benefit both entities. • Travel: Travel costs (e.g., airfare, mileage, per diem, hotel) are allowable as expenses by employees who are on travel status for official business related to the planning and conduct of the exercise activities.
• Supplies: Supplies are items that are expended or consumed while planning and conducting the exercise activities (e.g., gloves, non-sterile masks, and disposable protective equipment). • HSEEP Implementation: This refers to costs related to developing and maintaining an exercise program consistent with HSEEP.
• Other Items: These costs are limited to items consumed in direct support of exercise activities, such as space/locations rentals for planning and conducting an exercise, equipment rentals (e.g., portable toilets, tents), food/refreshments, and the procurement of other essential nondurable goods.

Costs associated with inclusive practices and the provision of reasonable accommodations and modifications that facilitate full access for children and adults with disabilities are allowable.

Unauthorized exercise-related costs include:
• Reimbursement for maintenance and/or wear and tear costs of general use vehicles (e.g., construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances). The only vehicle costs that are reimbursable are fuel/gasoline or mileage. • Equipment that is purchased for permanent installation and/or use beyond the scope of exercise conduct (e.g., electronic messaging signs)
• Durable and nondurable goods purchased for installation and/or use beyond the scope of exercise conduct
Construction and Renovation
Construction and renovation projects for a state, local, tribal, or territorial government’s principal Emergency Operations Center (EOC), as defined by the SAA are allowable under the EMPG Program.

FEMA must provide written approval prior to the use of any EMPG Program funds for construction or renovation. Requests for EMPG Program funds for construction of an EOC must be accompanied by an EOC Investment Justification (located in the Related Documents tab of the EMPG Program Grants.gov

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posting) to their Regional EMPG Program Manager for review. Additionally, recipients are required to submit a SF-424C Form, SF-424D Form, and Budget detail citing the project costs.

The above examples are not intended to exclude other construction projects as potentially allowable costs.

For example, construction of a facility for the storage and distribution of critical emergency supplies and/or to serve as a staging area for deployment of emergency response resources is potentially an allowable expense. Other construction or renovation projects, such as a secondary or local EOC, will be considered on a case-by-case basis, as described below in the guidance regarding advance written approval.

Advance Approval Requirement
Recipients must receive advance written approval from FEMA prior to the use of any annual EMPG Program funds for construction or renovation, including such activities at the subrecipient level. Such costs would need to fall within the scope of the recipient’s final approved Work Plan, otherwise an updated Work Plan may be required. Such requests should be submitted in writing to the applicable FEMA Regional Grant Program Office. FEMA’s review and approval will involve both the regional office and the FEMA Grant Programs Directorate.

Real Property Use and Disposition Requirements
Real property improved under a federal award falls under the 2 C.F.R. Part 200 guidance for real property.

In accordance with 2 C.F.R. § 200.311, a recipient or subrecipient may only use real property acquired or improved under a federal award for the originally authorized purpose, as long as it is needed for that purpose, during which time the recipient or subrecipient must not dispose of or encumber its title or other interests. However, upon the end of that period where it needs the property for the originally authorized purpose (i.e., the functional use of the property for which FEMA awarded the grant), the recipient or subrecipient will then dispose of the property in keeping with the requirements set forth in 2 C.F.R. § 200.311.

When a grant-funded property is no longer needed for the originally authorized purpose, the recipient or subrecipient (through the pass-through entity) must obtain disposition instructions from the cognizant FEMA Regional Administrator or the pass-through entity. For additional information on this, see Information Bulletin 458a, Clarifying Guidance for the Annual Emergency Management Performance Grant (EMPG) and the FY 2020 COVID-19 EMPG Supplemental (EMPG-S) Programs.

Construction of Communication Towers
When applying for funds to construct communication towers, recipients and subrecipients must submit evidence that the Federal Communication Commission’s Section 106 review process has been completed and submit all documentation resulting from that review to FEMA prior to submitting materials for EHP review. Recipients and subrecipients are also encouraged to have completed as many steps as possible for a successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential historic preservation issues and to discuss the potential for project effects, compliance with all state and EHP laws and requirements). Projects for which the recipient believes an Environmental Assessment may be needed, as defined in Implementation of the National Environmental Policy Act, , and EHP Directive and Instructions: FEMA Directive 108-1 and FEMA Instruction 108-1-1, must also be identified to the Regional EMPG Program Manager within six months of the award, and completed EHP review materials must be submitted no later than 12 months before the end of the period of performance. EHP review packets should be sent to [email protected].

Davis-Bacon Act Compliance
EMPG Program recipients using funds for construction projects must comply with the Davis-Bacon Act and subsequent legislation (40 U.S.C. §§ 3141 et seq.). Grant recipients 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 similar to the contract work in the civil subdivision of the EMPG Program Appendix | 2023 Page H-28
state in which the work is to be performed. Additional information regarding compliance with the Davis- Bacon Act, including Department of Labor wage determinations, is available at Davis-Bacon and Related Acts.

Accessibility Compliance
EMPG Program recipients using funds to build or alter buildings must comply with accessibility requirements under the Rehabilitation Act of 1973 and Architectural Barriers Act of 1968 (ABA), as well as the Americans with Disabilities Act (ADA), if applicable, to ensure individuals with disabilities have access to such buildings. Accessibility standards under the ABA and ADA are highly similar. Additional information regarding compliance with the Architectural Barriers Act is available at Guide to the ABA.

Acquisition of Real Property
Acquisition of real property is permissible if such property is needed to support other allowable program costs or activities. For additional information on this, see Information Bulletin 458a, Clarifying Guidance for the Annual Emergency Management Performance Grant (EMPG) and the FY 2020 COVID-19 EMPG Supplemental (EMPG-S) Programs.

Advance Approval Requirement
Consistent with the requirements outlined above regarding construction activities, recipients and subrecipients (through the pass-through entity) must obtain advance written approval from the cognizant FEMA Regional Administrator prior to obligating annual EMPG Program funds for acquisition of real property. Additionally, in cases of acquisition or improving real property, recipients are required to submit a SF-429-B, Real Property Status Report, Attachment B providing details of the relevant property to be acquired.

Property Use, Reporting, and Disposition Requirements
The acquisition, use, and disposition of real property shall be subject to the provisions of 2 C.F.R. Part 200.

In accordance with 2 C.F.R. Part 200, recipients and subrecipients are required to report on the status of the acquired property on an annual basis using SF-429-A Real Property Status Report, Attachment A (General Reporting). Such reporting shall continue as long as the property is being used for the originally authorized purpose.

The same use and disposition guidance as outlined in Sections III.D.3 above applies to real property acquired with annual EMPG Program funds. For additional information on this, see Information Bulletin 458a, Clarifying Guidance for the Annual Emergency Management Performance Grant (EMPG) and the FY 2020 COVID-19 EMPG Supplemental (EMPG-S) Programs.

Leasing of Real Property
Leasing of real property is permissible if the property is needed to support other allowable annual EMPG Program activities.

Advance Approval Requirement
Recipients and subrecipients (through the pass-through entity) must obtain advance written approval from the cognizant FEMA Regional Administrator prior to obligating annual EMPG Program funds for the leasing of real property.

Allowable Period of Lease Expenses
In cases where a property will be leased and the lease will be paid in full or in part using annual EMPG Program, any costs associated with the lease that are charged to an annual EMPG Program award must occur within the period of performance of the associated award(s). Real property lease costs must also comply with 2 C.F.R. Part 200.

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Maintenance and Sustainment
Use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable under all active grant awards, unless otherwise noted.

EMPG Program funds are intended to support the Goal and fund activities and projects that build and sustain the capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats and hazards that pose the greatest risk to the security of the Nation. To assist recipients in meeting this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible maintenance and sustainment costs, which must be:
1) In direct support of existing capabilities;
2) An otherwise allowable expenditure under the applicable grant program; 3) Tied to one of the core capabilities in the five mission areas contained within the Goal; and 4) Shareable through the EMAC.

Additionally, eligible costs may also be in support of equipment, training, and critical resources that have previously been purchased with either federal grant funding or any other source of funding other than FEMA preparedness grant program dollars.

Unallowable Costs
Grant funds may not be used for the following:
• Unallowable Equipment: 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 firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or vehicles of any kind with weapons installed;
• Expenditures for weapons systems and ammunition;
• Costs associated with hiring, equipping, training, etc. sworn public safety officers whose primary job responsibilities include fulfilling traditional public safety duties such as law enforcement, firefighting, emergency medical services, or other first responder duties; • Costs that supplant traditional public safety positions and responsibilities; or • Activities and projects unrelated to the completion and implementation of the EMPG Program • Clothing used for everyday wear by emergency management employees or other personnel.

Recipients should consult with their Regional EMPG Program Manager prior to making any investment that does not clearly meet the allowable expense criteria established in this Manual and the EMPG Program NOFO.

Amendments for EMPG Costs
In 2 CFR 200.308(f) it states that the Federal awarding agency may, at its option, restrict transfer of funds among direct cost categories where the Federal share exceeds the simplified acquisition threshold, and the cumulative amount of the transfer exceeds 10% of the total budget last approved by the awarding agency.

For purposes of 2 CFR 200.308(f), the term “budget” includes both the federal and non-federal cost share.

For EMPG awards (which include a 50% cost share), if the recipient wants to revise their budget and there are transfers between the direct cost categories exceeding the Simplified Acquisition Threshold and the cumulative amount of the transfers exceeds 10% of the total project costs (federal and non-federal), then EMPG recipients must request prior written approval from their Regional EMPG Program Manager for EMPG Program Appendix | 2023 Page H-30
those transfers and amendments. Recipients should consult with their Regional EMPG Program Manager prior to making any changes to their EMPG Work Plan.

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EMPG Program Work Plan
Submission of an EMPG Program Work Plan is mandatory. It is a required component of the EMPG Program application. The Work Plan outlines the state’s emergency management sustainment and enhancement efforts, including new and ongoing activities and projects, that are driven by identified preparedness priorities and proposed for the EMPG Program period of performance. An FY 2023 EMPG Program Work Plan Template (available on the Grants.gov EMPG Program application page and on the FEMA.gov website at EMPG) is provided to facilitate the work plan development process. The submitted Work Plan must address all the data and information requirements included in the FY 2023 EMPG Program Work Plan Template and in the supplemental guidance included in this section. Therefore, EMPG Program applicants are strongly encouraged to use the provided FY 2023 EMPG Program Work Plan Template.

Prior to submission of the EMPG Program Work Plan, the applicant must work with the Regional Administrator or designated Regional EMPG Program Manager to identify three to five priority areas which will serve as the focus for EMPG Program-funded investments. The priorities must be mutually agreed to by the applicant and Regional Administrator and should be driven by the THIRA/SPR process – specifically, the outputs from the THIRA/SPR process – and other relevant information sources such as AARs, audit and monitoring findings, Hazard Mitigation Plans and other deliberate planning products.

Priorities should also reflect those included in each recipient's IPP so that recipients are focusing all investments, projects, and other resources on a common set of priorities. As they select priorities, applicants should consider which capability gaps would be most operationally consequential, must be closed most urgently, and could be meaningfully addressed within the period of performance. Applicants should refer to the EMPG Program NOFO for further guidance on the priority identification process.

Applicants must set at least one performance goal for each RA agreed-upon priority area that achieves a specific outcome. Each goal must be specific, measurable, and achievable within the period of performance, relevant to the priority area, and have a target date for completion. Applicants must describe how achieving each goal or objective will impact the priority area it supports by the end of the period of performance. Each goal must include an estimate quantifying the extent to which the supporting investments will close capability gaps (e.g., “Increase the percentage of people who can find and secure long-term housing by 10% within 1 year of an incident”). The FY 2023 EMPG Program Work Plan Template includes instructions and examples to help guide this process so that recipients can develop goals that focus on achieving specific outcomes.

The Regional Administrator or designated Regional EMPG Program Manager will ensure that the mutually agreed priorities are fully addressed in the EMPG Program Work Plan. In addition, the Regional Administrator must approve final Work Plans before states may draw down EMPG Program funds. Grant funds will be released upon approval of the state’s final Work Plan.

Following Work Plan approval, regional EMPG Program Managers will work closely with recipients to monitor progress toward goals and activities in the Work Plans during the performance period and may request further documentation from the recipients to clarify the projected Work Plan. Further, in accordance with 2 C.F.R. §200.308 – Revision of budget and program plans, any changes to the approved Work Plan – including changes in project scope and budget changes within any direct cost category exceeding 10% of the total award amount – will require advance approval from the Regional Administrator or designated Regional EMPG Program Manager.

EMPG Program Work Plan Instructions
The FY 2023 EMPG Program Work Plan Template has been updated to support the collection of objective information and quantitative data that will allow FEMA to measure program effectiveness and investment

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impacts more effectively. This also enables compliance with 2 C.F.R. § 200.301, which requires federal awarding agencies to measure recipient performance to show achievement of program goals and objectives, share lessons learned, improve program outcomes, and foster adoption of promising practices. To this end, the FY 2023 EMPG Program guidance in the NOFO and Work Plan requires recipients to link EMPG Program-funded investments to THIRA/SPR results and other relevant materials that inform capability priorities and needs and to include specific performance measures that will allow FEMA to measure the impact of those investments based on the core capabilities that are addressed.

The FY 2023 EMPG Program Work Plan Template largely complements the THIRA/SPR process outlined in the Comprehensive Preparedness Guide (CPG) 201, Third Edition (CPG 201, v3). As noted in CPG 201, v3, a coordinated approach to track investments, and understand the return on investments, can help improve the effectiveness of those investments. Tracking how EMPG Program-funded investments result in specific, quantitative changes in capabilities can help guide communities’ strategic planning considerations and inform resource allocation decisions that will maximize effectiveness in building or sustaining capabilities. Therefore, applicants are encouraged to refer to CPG 201, v3, along with their most recent THIRA and SPR, when developing their EMPG Program Work Plan.

The FY 2023 EMPG Program Work Plan Template consists of the following tabs: Definitions and Guidance, Quick Links, Grant Investment Strategy, Grant Activities Outline, Detailed Budget – Excluding M&A, Budget Narrative – Excluding M&A, Detailed Budget – M&A Only, Budget Narrative – M&A Only, EMPG Program Summary, Implementation Schedule, Training Data Table, and Exercise Data Table.

As explained above, the focus of the FY 2023 EMPG Program Work Plan Template is on improving data collection to better enable measurement of grant outcomes. Therefore, the narrative content is minimized and many of the cells include dropdowns for selecting applicable data. This approach also helps to simplify the Work Plan development process.

Instructions for each Work Plan section are provided below. Additional guidance and instructions are provided in the FY 2023 EMPG Program Work Plan Template.

Definitions and Guidance
The Definitions and Guidance tab collects applicant information and provides instructions for completing each subsequent tab.

Quick Links
The Quick Links Tab uses the link functionality in Excel to allow users to navigate throughout the template quickly and minimize the need to scroll through projects and implementation schedules.

Grant Investment Strategy
The intent of the Grant Investment Strategy tab of the FY 2023 EMPG Program Work Plan Template is to provide an overview of the state/territory's preparedness investment strategy. It should serve as the foundation for completing the remainder of the Work Plan. It includes separate sections to explain the following:
• The performance goals associated with each priority area; • The most recent THIRA/SPR results;
• Significant risks and capability gaps that currently exist; • Resulting preparedness priorities; and
• The anticipated impact of the proposed EMPG Program-funded investments.

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For the Performance Goals section, the applicant should identify the three to five priorities that were mutually agreed to and approved between the Regional Administrator and the state/territory. These goals serve as the focus for the EMPG Program-funded investments. The reference materials used to identify the priorities should be cited and their relevance explained in this section.

At least one performance goal should be identified for each priority area. Each goal must be specific, measurable, achievable within the period of performance, relevant to the priority area, and have a target date for completion (i.e., SMART goal). It should describe how achieving each goal will impact the priority area it supports by the end of the period of performance.

Grant Activities Outline
The Grant Activities Outline is used to capture the proposed EMPG Program-funded projects and link them to the identified priorities, performance goals, and gaps or needs. Coupled with the Implementation Schedule, the Grant Activities Outline supports identification and tracking of EMPG Program-funded project outcomes, which will enable better understanding of the impacts of those investments relative to the performance goals and the associated core capabilities. Identifying and tracking project outcomes also supports compliance with the Foundations for Evidence-Based Policy Making Act of 2018 and changes to

2.C.F.R related to performance, evaluation, and risk for federal grants. Applicants can also designate whether a project addresses equity considerations and/or climate change impacts. Examples of allowable activities and associated core capabilities for projects that address the FY 2023 EMPG Program national priorities of equity, climate resilience, and readiness can be found in the FY 2023 EMPG Program NOFO.

The Grant Activities Outline includes sections that allow the applicant to identify the performance goals that are supported by each project and the milestones that are critical to accomplishing each goal.

Additional guidance on performance goals and milestones, including specific examples of each, are provided below.

The Grant Activities Outline also requires the applicant to explain the objective and anticipated impact of each project relative to the associated priorities, performance goals, and related core capabilities:
• The “Project Objective” should explain what the project will accomplish; specifically, how the project will address the identified gap or need and how it supports one or more of the identified performance goals.
• The “Anticipated Project Impact” should explain the expected project outcome relative to the associated priorities and performance goals.
o The impact statement should include a quantitative estimate of the degree to which the project will contribute to achieving the identified performance goal (see hierarchy example below).

Effective completion of the Grant Activities Outline requires an understanding of the established planning hierarchy. Priorities are at the top of the hierarchy, followed by performance goals that define a clear outcome or end-state and provide the basis for addressing each priority. Project proposals should be identified based on the performance goals. High priority capability gaps or needs identified through the THIRA/SPR process, particularly SPR Step 2, and other assessments are also used to inform project selection and to identify specific project objectives. Project objectives, and accompanying impact statements, should complement the performance goals by including similar outcome-focused metrics, as explained above. Lastly, identifying the specific project activities are the last step in the process of completing the GAO. Project activities are key components and/or milestones that are critical to successful completion of the project.

An example of this planning hierarchy for completing the GAO is provided below:

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❖ Priority: Logistics and Supply Chain Management
➢ Performance Goal: Within 24 hours of an incident, identify and mobilize life-sustaining commodities, resources, and services to 10,000 people requiring shelter and 100,000 people requiring food and water. Maintain distribution system for at least 30 days. • Project: Update State Logistics and Distribution Management Plan and qualify 40 additional personnel for logistics operations in NQS.
o Project Objective/Impact: Increase capacity to identify and mobilize life-sustaining commodities, resources, and services to people requiring shelter, food, and water by 50%, allowing the state to do so for 7,500 people requiring shelter and 75,000 requiring food and water within 24 hours of an incident and maintain that distribution system for at least 30 days.
• Activity: Convene cross-discipline working group meeting on May 30, 2023, to review current State Logistics and Distribution Management Plan All EMPG Program-funded investments must be accounted for in the Grant Activities Outline. However, recognizing that some sustainment activities, such as funding of emergency manager salaries, may not align to a specific priority or performance goal, applicants are not required to identify priorities and performance goals for such investments. However, all other portions of the Grant Activities Outline must be completed as a means to justify the applicable sustainment costs.

In cases where emergency management personnel are not assigned to support specific projects included in the Work Plan, the applicant may choose to create a single project (e.g., Emergency Management Personnel Project) to encompass the majority of the EMPG Program-funded salaries and fringe benefits costs. This single project would be populated on the Grant Activities Outline and include the associated activities, priorities, goals, anticipated outcomes, milestones, etc. for the applicable EMPG Program-funded emergency management staff, including staff supporting the M&A activities.

The various elements of the Grant Activities Outline tab are outlined below, along with basic instructions for completing the required entries. Supplemental guidance and instructions are included in the FY 2023 EMPG Program Work Plan Template.
• Project Name: Provide a descriptive name for each planned project. Examples include “Development of Emergency Function Annexes,” “Development of Earthquake Scenario Loss Estimations,” “Implementation of Statewide Interoperability Plan,” “NIMS Training for Emergency Management Personnel,” “Development of Emergency Preparedness Plan for Individuals with Disabilities,” etc.
• Brief Project Description: Provide further details on the project, particularly where the project name does not sufficiently describe the project.
• Gap or Need Addressed: Briefly describe the specific gap or need addressed by the project. • Reference for Identified Gap or Need: Select the documentation used to identify the cited gap or need from the drop-down menu.
• Project Objective: Explain how the project addresses the identified gap or need, and how it supports the identified priorities and performance goals. • Anticipated Project Impact: Explain the expected project outcome relative to the associated priorities and performance goals.
• Build or Sustain: Select whether the project will build or maintain/sustain the identified core capability(ies).
• Equity: Select whether the project will address equity considerations. For FY 2023, at least one project must specifically address equity considerations. • Climate Change: Select whether the project will address the impacts of climate change.

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• EMPG Program National Priority Area: Select the applicable National Priority Area from the drop-down menu.
• Regional Administrator (RA) Agreed Upon Priority Area: Select from a drop-down list of the 32 core capabilities and other priorities identified in the latest version of the National Preparedness Report. If the priority is not included in the drop-down list, enter “other” for Primary, Secondary and/or Tertiary, and then enter the priority in the adjacent cell. • POETE Category: Select whether the project relates to Planning, Organization, Equipment, Training, or Exercises. Multiple POETE categories can be selected to accommodate projects that span multiple categories. For example, building capability often involves a combination of planning, training, and exercise activities. Space is provided to populate the Primary, Secondary and Tertiary POETE category.
• Emergency Management Accreditation Program (EMAP) Standard Element: This field is optional. It is made available to those states/territories that are EMAP certified and want to continue tracking their investments by EMAP Standard Elements. Select the appropriate EMAP Standard Elements from the drop-down menu, if applicable. • Mission Area: Select the appropriate preparedness mission area supported by the project:

Prevention, Protection, Mitigation, Response, or Recovery. Multiple mission areas can be selected to accommodate projects such as plans and exercises that involve multiple mission areas, and space is provided to populate the Primary, Secondary and Tertiary Mission Areas. • Core Capabilities: Select up to five core capabilities supported by the project. Indicate whether the Core Capability has a target with a gap rated as high priority. • Performance Goals: Select the performance goal(s) from the drop-down menu. The drop-down menu will consist of the performance goals as entered in the Grant Investment Strategy. • Current Capability Metrics: Identify capability metrics prior to the project implementation. • Milestones: Identify key project activities and other deliverables or outputs that are critical to accomplishing the identified performance goal and can be tracked to demonstrate progress toward achieving the performance goal.

Detailed Budget – Excluding M&A
The Detailed Budget – Excluding M&A tab enables a full accounting of all project activity costs, excluding M&A costs. This tab contains an itemization of non-M&A costs related to personnel, fringe benefits, travel, equipment, supplies, contractual services, construction, other, and indirect costs. For personnel and fringe benefits, the position title and percentage of time or fringe allocated to the EMPG Program grant is required. Each line item is assigned to its relevant project, allowing the information in mission areas, core capabilities, priorities, EMAP, and POETE categories to populate accordingly. This enables a breakdown of the full EMPG Program budget into various categories: Mission Area, Core Capabilities, National Priority Area, RA Agreed Upon Priority, EMAP Standard Elements, and POETE Category. The cells for each of these categories are automatically populated based on the project number as identified in the Grant Activities Outline.

Budget Narrative – Excluding M&A
The purpose of the Budget Narrative – Excluding M&A tab is to 1) justify the need for each line item and the cost estimates; 2) explain how costs relate to the programmatic goals of the project(s); and 3) supplement other budget information provided on the Detailed Budget – Excluding M&A tab. This tab will include a narrative for each cost category of the budget. For the Cost Share, applicants must include a detailed description of the source of the match/cost share. If funds or services are to be provided by a third party for in-kind match, a dated letter of commitment is required to document the donation. If the M&A Detailed Budget tab includes Indirect Costs, an approved Indirect Cost Rate Agreement signed by the recipient agency and the cognizant agency for the recipient, or a copy of the proposal to the cognizant

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federal or state agency for an indirect cost rate, must be included in the submission of the Work Plan for application purposes. Applicants who do not have a current negotiated indirect cost rate agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further instructions.

Detailed Budget – M&A Only
This Detailed Budget – M&A Only tab enables a full accounting of all project activity costs as they relate specifically to M&A costs. This tab contains an itemization of only M&A costs related to personnel, fringe benefits, travel, equipment, supplies, contractual services, construction, and other direct costs. For personnel and fringe benefits, the position title and percentage of time or fringe allocated to the EMPG Program grant is required. Each line item is assigned to its relevant project, allowing the information in mission areas, core capabilities, priorities, EMAP, and POETE categories to populate accordingly. This enables a breakdown of the full EMPG Program budget into various categories, including the following: Mission Area, Core Capabilities, National Priority Area, RA Agreed Upon Priority, EMAP Standard Elements, and POETE Category. The cells for each of these categories are automatically populated based on the project number as identified in the Grant Activities Outline.

Budget Narrative – M&A Only
The purpose of the Budget Narrative – M&A Only tab is to: 1) justify the need for each line item and the cost estimates; 2) explain how costs relate to the programmatic goals of the project(s); and 3) supplement other budget information provided on the Detailed Budget– M&A Only tab. For the Cost Share, applicants must include a detailed description of the source of the cost share/matching funds. If funds or services are to be provided by a third party for in-kind match, a dated letter of commitment is required to document the donation. This tab will include a narrative for each cost category of the budget.

Information for the Detailed Budget and Budget Narrative This section of the Work Plan is a detailed description of the budget found in the SF -424A and must include a detailed discussion of how EMPG Program funds will be used. Applicants must itemize costs related to personnel, fringe benefits, travel, equipment, supplies, contractual costs, other direct costs, indirect costs, and total costs.

Applicants should use the following instructions and budget cost category descriptions to complete the Budget Detail section of the Work Plan.

Personnel: List each position with a brief description of the duties and responsibilities (no personnel names), as well as the salary computation for staff. If a Cost-of-Living Adjustment increase and/or merit pay increase in salary will be provided for the position, include those costs in calculations for personnel and the associated fringe benefits on the applicabl e Detailed Budget and the Budget Narrative.

Fringe Benefits: List the computation for fringe benefits for each of the personnel listed in the budget worksheet. Estimated rates for fringe are allowable but provide the basis for that estimation in the budget narrative (e.g., average percent fringe paid for most employees within the agency). If not using an estimate, list fringe benefit and the associated costs for each employee that will be paid by EMPG Program funding (e.g., Social Security/FICA, Unemploymen t Compensation, Medicare, Retirement, Health Insurance, Life Insurance, etc.). Also, in cases where fringe benefits costs are included in an indirect cost rate agreement, the fringe benefits cannot also be charged as a direct cost for reimbursement.

Travel: Specify the mileage, per diem, estimated number of trips in -state and out-of-state, number of travelers, and other costs for each type of travel for staff. Travel may be integral to the purpose of the EMPG Program Appendix | 2023 Page H-37
proposed project (e.g., management, monitoring and/o r oversight of grant award and/or subrecipients) or related to propose project activities (e.g., attendance at training or meetings related to management of the EMPG Program award). Travel costs identified in this section are for employees of the applicant/recipient only. For travel costs related to staff training, include as many details as possible about each proposed training cost, including the name of the training course(s), training provider, personnel who will attend the training, proposed dates (estimates are accepted), etc. Travel category costs do not include 1) costs for travel of consultants, contractors, consortia members, or other partner organizations, which are included in the “Contractual” category; or 2) travel costs for employees of subrecipient agencies (those should be included in the Contractual category, if applicable).

Equipment: List each equipment item for EMPG Program purposes only by Line-Item Name and in the same order as listed on the Detailed Budget. Include a brief description of each equipment item (no brand names); per unit cost, quantity and total cost; location of equipment (if other than the direct recipient agency); and how the equipment will be utilized. Equipment is defined in 2 C .F.R. § 200.1.

Supplies: Include all tangible personal property other than those described in the definition of “equipment” as defined by 2 C.F.R. § 200.1. Supplies are also defined in 2 C.F.R. § 200.1. The budget detail should identify categories of supplies to be procured for EMPG Program purposes only (e.g., printing supplies, office supplies, etc.) and the calculation of those costs (e.g., based on monthly rates or based on an average of previous years’ similar costs). Non-tangible goods and services associated with supplies, such as printing service, photocopy services, and rental costs should be included in the “Other” category. Provide the basis for calculation of supplies including the Line-Item Name and list supplies in the Budget Narrative in the same order as listed on the Detailed Budget. Subrecipient M&A and non - M&A costs should be included in the “Other” category.

Contractual: Identify each proposed contract related to EMPG Program purposes only and specify its purpose and estimated cost. Contractual/consultant services are those services to be carried out by an individual or organization (do not include company or individual names in budget narrative), other than the applicant, in the form of a procurement relationship. Leased or rented goods (equipment or supplies) for EMPG Program purposes should be included in the “Other” category. The applicant should list the proposed contract activities along with a brief description of the scope of EMPG Program work or services to be provided and proposed duration. Include the basis for the calculation of contractual services costs (e.g., contractor training instructor speaking fee, contractor travel costs and contractor instructional materials).

Other: This category should include only those types of direct costs that do not fit in any of the other budget categories and are related to EMPG Program purposes only. Include a description of each cost by Line-Item Name and in the same order as listed on the applicable Detailed Budget. Include the basis for calculation of the costs. Examples of costs for EMPG Program purposes that may be in this category include the following: insurance, rental/lease of equipment or supplies, equipment service or maintenance contracts, printing or photocopying rental, etc. Subrecipient M&A and non -M&A costs from their subawards (e.g., subgrants) are a distinct type of cost under this category. The term “subaward” means an award of financial assistance (money or property) by any legal agreement made by the recipient to an eligible subrecipient. This term does not include procurement purchases, technical assistance in the form of services instead of money, or other assistance in the for m of revenue sharing, loans, loan guarantees, interest subsidies, insurance, or direct appropriations. Subcontracts are not subawards and belong in the contractual category. Applicants must provide the aggregate amount they propose to issue as subaward work and a description of the types of M&A and non -M&A activities to be supported.

Construction: Include construction costs, including renovation projects for a state or territorial government’s principal EOC. Include a description of the types of constructio n or renovation services proposed and the calculation of these costs (no company or individual names). Subrecipient construction

EMPG Program Appendix | 2023 Page H-38
costs should be included in the Other category. M&A funding cannot be used for construction or renovation costs.

Indirect Costs: If indirect charges are budgeted, indicate the approved rate and base (the cost categories for which this indirect cost percentage rate will be applied.) Indirect costs are those incurred by the recipient for a common or joint purpose that benefit more t han one cost objective or project and are not readily assignable to specific cost objectives or projects as a direct cost. In order for indirect costs to be allowable, the applicant must have a federal or state negotiated indirect cost rate (e.g., fixed, predetermined, final or provisional), or must have submitted a proposal to the cognizant federal or state agency. An approved Indirect Cost Rate Agreement signed by the recipient agency and the cognizant agency for the recipient, or a copy of the proposal t o the cognizant federal or state agency for an indirect cost rate, must be included in the submission of the Work Plan Template for application purposes.

Examples of Indirect Cost Rate calculations are shown below:

1. Personnel (Indirect Rate x Personnel = Indirect Costs)

2. Personnel and Fringe (Indirect Rate x Personnel & Fringe = Indirect Costs)

3. Total Direct Costs (Indirect Rate x Total Direct Costs = Indirect Costs) Applicants who wish to use a cost allocation plan in lieu of an indirect cost rate must a lso reach out to the FEMA Grants Management Specialist for further instructions. Per 2 C .F.R. Part 200, Appendix VII, paragraph D.1.b, state and local governments are not permitted to use the de minimus rate without seeking and receiving FEMA’s approval of a case-by-case exception. Applicants who wish to request the case -by- case exception should reach out to their FEMA Grants Management Specialist for further instructions.

Post-award requests to charge indirect costs will be considered on a case -by-case basis and based upon the submission of an agreement or proposal as discussed above or based upon the de minimis rate or cost allocation plan, as applicable.

EMPG Program Summary
This tab includes summary information for the award as entered in the budget tabs and the Grant Activity Outline. The overall budget summary will include the total award amount, federal amount, non-federal amount (cost share), and M&A amount, along with the calculated percentage of each. The additional budget summary tables will calculate the amount allocated for federal funds, non-federal funds (cost share) and total project costs for each cost category. There is also a budget summary table with similar information for each primary mission area and core capability.

The EMPG Program Summary tab also provides users with an overview of their progress in the FY 2023 EMPG Program Performance Metrics. The metrics are automatically populated from the calculations of information provided in the Grant Activities Outline. These metrics aim to provide the count, percentage, and associated dollar amount affiliated with the following performance metrics: 1) Capability-building Projects for Alignment to Capability Gaps in SPR; 2) Funding Spent on Capability-building Projects Aligned to Capability Gaps in SPR; 3) Building Capabilities for High Priority Targets; 4) Regional and National Priority Area Alignment; and 5) Plans-Training-Exercise Alignment. The EMPG Program Summary Tab further provides a count of all projects that address equity considerations and climate change impacts.

Implementation Schedule
The Implementation Schedule includes the basic elements of a project management plan. It is used to capture key project activities to include both EMPG Program-funded activities that are critical to accomplishing the project objectives as identified in the Grant Activities Outline, as well as tasks that are essential to effective project management. Thus, this product can be used as a basic project management EMPG Program Appendix | 2023 Page H-39
tool to plan and track the progress of key project activities and associated tasks. Key project activities should generally correlate with the “Milestones” identified for each project included in the Grant Activities Outline.

The Implementation Schedule enables the applicant to identify key project activities by year/quarter, the associated tasks, timelines, status reports, and challenges or risks that may affect successful completion of the activity as planned. It also allows for the tracking of project progress by including estimated and actual completion dates for each activity and the ability to enter quarterly accomplishments relating to the activity. This functionality allows for quarterly reporting of project progress, in accordance with the programmatic requirements of the EMPG Program. Also, data from the Implementation Schedule should be completed and submitted to FEMA as a component of quarterly reporting on grant activities.

The Implementation Schedule further allows the applicant to explain how their project addresses equity considerations. Possible examples include: 1) conducting vulnerability assessments to identify and fully understand the vulnerabilities and needs of underserved communities relating to emergency preparedness; and 2) updating emergency operations plans to ensure the needs of underserved communities are adequately addressed.

The Implementation Schedule also provides the applicant with the ability to explain how their project addresses the impacts of climate change.

Training Data Table
To facilitate consistent data reporting and performance measures collection, the FY 2023 EMPG Program Work Plan Template includes a Training Data Table. This table should reflect training activities outlined in the multi-year IPP and completion of required EMPG Program training courses. The data requirements are defined in the section below. Applicants/recipients are not required to report EMPG Program-funded personnel costs associated with training. Training related to the NQS is not reported on the Training Data Table. Also, data from the Training Data Table should be completed and submitted to FEMA as a component of quarterly reporting on grant activities. Upon entering the project name or number in the template, the cells located to the right of the main Training Data Table will auto-populate the associated priority, mission area, capabilities, and functional areas based on the project data included in the Grant Activities Outline.

Training Data Table Template
Project
Number
Project
Name
Name of
Training
Scheduled
Date
Date
Training
was
Conducted/
Completed
EMPG
Program
Required
Training?
(Y/N)
Number
of
Personnel
Trained
NIMS Training
Course Number
(if applicable)
Training
Identified
in IPP
(Y/N)
Training Data Table Definitions
• Column 1 – Project Number from the Grant Activities Outline • Column 2 – Project Name from the Grant Activities Outline • Column 3 – Name of training course
• Column 4 – Scheduled date of training course
• Column 5 – Date training was conducted or completed
• Column 6 – Is the training course required by the EMPG Program? • Column 7 – Number of personnel trained
• Column 8 – NIMS Training Course Number (if applicable)

EMPG Program Appendix | 2023 Page H-40
• Column 9 – Is the training identified in the multi-year IPP? Exercise Data Table
To facilitate consistent data reporting and performance measure collection, an Exercise Data Table should be completed for any exercises that meet EMPG Program requirements and/or exercises conducted in whole or part with EMPG Program funds. The Exercise Data should include EMPG Program-funded exercises and costs to run the exercise (e.g., planning, materials, props, contractual services for conducting the exercise, AAR and IP, etc.). Any exercise planned or conducted during the grant period of performance should be reported on the Exercise Data Table. Applicants/recipients are not required to report EMPG Program- funded personnel costs associated with exercises. Data from the Exercise Data Table should also be completed and submitted to FEMA as a component of quarterly reporting on grant activities. The data requirements are defined in the section below. Upon entering the project name or number in the template, the cells located to the right of the main Exercise Data Table will auto-populate the associated priority, mission area, capabilities, and functional areas based on the project data included in the Grant Activities Outline.

Exercise Data Table Template
Project
Number
Project
Name
Name of
Exercise
Scheduled
Date
Date
Exercise
Conducted/
Completed
Type of
Exercise
Exercise
Fulfills
Progressive
Exercise
Requirement
(Y/N)
Exercise
Identified
in IPP
(Y/N)
Date AAR
submitted
to FEMA
Exercise Data Table Definitions:
• Column 1 – Project Number from the Grant Activities Outline • Column 2 – Project Name from the Grant Activities Outline • Column 3 – Exercise Name
• Column 4 – Scheduled date of exercise
• Column 5 – Date exercise conducted/completed
• Column 6 – Type of exercise (select from drop-down menu) • Column 7 – Is the exercise part of a progressive exercise series? • Column 8 – Is exercise identified in the multi-year IPP? • Column 9– When was the AAR submitted to FEMA?

EMPG Program Appendix | 2023 Page H-41
EMPG Requirements Matrix

ID Category Requirement Location Due Date Cycle Due Date Submission Plan 1 Administrative
Pass through 100% of
award from SAA or
Territory to EMA.

NOFO
Within 15 days
of award date
(if applicable)
Varies Work Plan/Electronic Notification
2 Allowability
Critical Emergency
Supplies Purchases – 5-
year viable inventory
management plan with a
distribution strategy
App H Prior to award
(if applicable) Varies Work Plan/Amendment
3 Application Work Plan App H Per the NOFO Varies ND Grants 4 Application Project addressing
Equity Considerations
NOFO,
App H Per the NOFO Varies Work Plan: Grant Activities Outline and Budget Narrative
5 Civil Rights Civil Rights Evaluation
Tool PGM
Within 30 days
of receipt of
award
Varies
Email to:

[email protected]
and
cc: Regional EMPG Program Manager
6 Closeout
Closeout Reporting
Requirements.
(Note: ND Grants does
not have a closeout
module. Regional
closeout processes vary.)
PGM Per the Closeout
notification letter Varies ND Grants/Electronic Notification 7 Cost Share Cost Share App H
Application,
Quarterly,
Closeout
Varies
Work Plan Budget, Federal Financial
Report (FFR)/SF-425 (Quarterly and at
Closeout)
8 Davis-Bacon Davis-Bacon
Compliance App H For all EMPG
projects Varies Monitoring
9 EHP EHP approval PGM
Prior to any
construction,
renovation, or
ground
disturbing
activity
Varies
Email to:

[email protected], and cc:

Regional EMPG Program Manager
10 EHP Construction Towers App H
FCC Section 106
review must be
completed prior
to EHP review
Varies Monitoring
11 EMAC EMAC association NOFO Prior to award Varies Regional EMPG Program Manager to verify on EMAC website
12 Exercise
Exercise program
negotiated (align with
IPP/priorities)
App H Prior to award Varies Work Plan
13 Exercise AAR (After Action
Report)/IPs App H
90 days after
completion of
exercises
conducted in
Calendar Year
(CY) Q4
Varies
Email to: [email protected]
and
cc: Regional EMPG Program Manager
EMPG Program Appendix | 2023 Page H-42
ID Category Requirement Location Due Date Cycle Due Date Submission Plan 14 Performance
Measures

87.5% of all PTE
projects align with
building capability
and/or closing capability
gaps identified
NOFO Prior to award Varies Work Plan
15 Pre-Award Pre-award cost NOFO Prior to award
(if applicable) Varies Work Plan Budget
16 Priorities
3-5 Applicant and RA
mutually agreed upon
Priorities (Note: These
need not be the national
priorities)
App H Prior to award Varies Work Plan
17 Reporting
Threat and Hazard
Identification and Risk
Assessment (THIRA)
submitted
App H Every 3 years
starting in 2022 31-Dec Prep toolkit
18 Reporting State Preparedness
Review (SPR) submitted App H Annually 31-Dec Prep toolkit 19 Reporting
National Incident
Management System
(NIMS)
App H Annually 31-Dec Unified Reporting Tool (URT)
20 Reporting
National Qualification
System (NQS)
implementation
App H
Phased-in
Objectives due
Annually
31-Dec URT
21 Reporting
Distribution
Management Plan
(DMP) Plan review
App H
After initial
submission,
DMP updates
submitted
annually, as
necessary
30-Sep Email to: Regional EMPG Program
Manager
22 Reporting
Multi-year Training and
Exercise Plan
(TEP)/Integrated
Preparedness Plan (IPP)
developed
App H Annually 31-Jan
Email to: [email protected]
and
cc: Regional EMPG Program Manager
23 Reporting
Periodic Performance
Reporting (PPR) Status
of all EMPG Program-
funded plans, training
and exercise activities
must be reported
quarterly.

App H
Within 30 days
after the end of
the CY Quarter
30-Jan
30-Apr
30-July
30-Sep
ND Grants
24 Reporting Financial Quarterly
Reporting PGM
Within 30 days
after the end of
the CY Quarter
30-Jan
30-Apr
30-July
30-Sep
PARS
25 Reporting
Biannual Strategy
Implementation Report
(BSIR)
PGM - Biannual
No later
than:
30-Jan
30-July
Grant Reporting Tool (GRT)
26 Reporting –
Exercise
All EMPG Program-
funded exercise activities
must be reported
quarterly.

App H Quarterly
30-Jan
30-Apr
30-July
30-Sep
Exercise Data Table

EMPG Program Appendix | 2023 Page H-43
ID Category Requirement Location Due Date Cycle Due Date Submission Plan 27 Reporting –
Training
All EMPG Program-
funded training activities
must be reported
quarterly.

App H Quarterly
30-Jan
30-Apr
30-July
30-Sep
Training Data Table
28 Telecomms FirstNet PGM Prior to award
(if applicable) Varies Verified by Regional EMPG Program Manager
29 Telecomms SAFECOM PGM/
App H
Prior to award
(if applicable) Varies Verified by Regional EMPG Program Manager
30 Training
Training activities
captured (align with
IPP/priorities)
PGM/
App H Prior to award Varies Work Plan Training Data Table or PPR template
31 Training
EMPG funded personnel
who have completed:
• Basic Academy
OR
Professional
Development Series
AND
• NIMS
App H On-going Varies
Per Regional Guidance:
• ND Grants: with PPR
• Roster to Regional EMPG Program
Manager
• Reviewed During Monitoring
32 Training
Training attendance
information submitted
within 30 days of
attendance of training
supported with EMPG
funding (IB 432)
PGM/
App H On-going Varies Web-Forms

Visalia Fire Department
Visalia Fire Department
Purchase Hazmat Portable Radios

Chief Dan Griswold
420 N Burke St Visalia, CA 93292
(559) 713-4513
(559) 713-4808

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SAFECOM Guidance on Emergency Communications Grants
Frequently Asked Questions: Understanding Project 25 Standards and Compliance T
his document summarizes compliance requirements within the Project 25 (P25) Suite of Standards outlined in the SAFECOM Guidance on Emergency Communications Grants (SAFECOM Guidance).

State, local, tribal, and territorial recipients of federal grants for emergency communications projects should refer to these Frequently Asked Questions to understand P25 compliance and find necessary resources. For the purpose of this document, the terms “I” and “my” refer to the agency grant applicant seeking federal funds for emergency communications projects.

Project 25
Q1. What are P25 standards?
P25 is a Suite of American National Standard Institute (ANSI) Accredited Technical Standards and specifications that promote interoperability among digital two-way land mobile radio (LMR) communications products provided by different manufacturers. The standards focus on meeting the public safety community’s unique mission and critical voice requirements. The objective is to provide technical specifications that ensure communications equipment is interoperable, regardless of manufacturer. The P25 Suite of Standards is published by the Telecommunications Industry Association (TIA), a recognized ANSI standards development organization, and also known as TIA-102 standards. The P25 Steering Committee publishes a list of Approved Project 25 Suite of Standards that includes the most recent documents and revisions.

Q2. What is the P25 Compliance Assessment Program (CAP)? The P25 CAP is a formal, independent testing process administered by the Department of Homeland Security (DHS) Science and Technology Directorate, to ensure communications equipment offered by suppliers complies with the applicable published standards. Through this third-party testing by independent laboratories, the P25 CAP assures public safety agencies that the communications equipment they purchase complies with P25 standards for performance, conformance, and interoperability. Compliance test results, official summary test reports, and suppliers’ declarations of compliance are available at dhs.gov/science-and-technology/p25-cap .

Q3. What does P25 compliance mean?
In general, compliance means that equipment conforms to the technical specifications in the standard. However, federal grantors may have additional requirements beyond the P25 standards and grant recipients must address other compliance considerations, depending on operational requirements. To maximize interoperability, grant recipients should verify that digital voice systems and equipment to be purchased with federal grant funds comply with the P25 Suite of Standards as specified in their program’s grant guidance. This compliance preserves the value of federal investments in interoperable solutions for state, local, tribal, and territorial emergency responders.

Q4. Why is purchasing P25 compliant equipment so important to the public safety community? Purchasing P25 equipment ensures that digital LMR systems are compatible with other P25 systems from different manufacturers and thus will enable interoperable communications among emergency responders from various agencies, jurisdictions, and levels of government. P25 standards also enable manufacturers to compete on a more level playing field, providing agencies with a broader range of options when purchasing equipment.

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P25 Purchases Using Federally-Funded Grants
Following the tragic events of 9/11, Congress passed legislation to improve the interoperability of public safety communications systems and equipment. The legislation mandates that new or upgraded equipment must be interoperable in accordance with P25 standards. To assist agencies in meeting this mandate, federal grant programs and policies support the purchase of P25 compliant LMR equipment.

Q5. When applying for a federally-funded emergency communications project, how do I demonstrate that purchases are P25 compliant?
To ensure equipment and systems comply with the P25 Suite of Standards, grant applicants/ recipients should:
• Review the technical specifications detailed in the P25 Technology Interest Group’s (PTIG) Capabilities Guide to determine which standards are applicable to the proposed equipment purchase.
• Provide specific technical requirements and expectations for all functions, features, and capabilities of to be procured equipment and services to comply with all applicable P25 standards and expectations for interoperability in any Statements of Work or acquisition documents for communications procurements funded through federal grants. • Ensure all new and upgraded P25 eligible equipment, features, functions, and capabilities selected for procurement are P25 compliant and interoperable. If P25 LMR equipment and systems include non-standard features or capabilities when a comparable P25 feature or capability is available, recipients must also purchase the P25 standards-based feature or capability to ensure interoperability.
• Obtain documented evidence of P25 compliance from the manufacturer showing the equipment has passed all applicable compliance assessment test procedures and interoperability test procedures, if applicable, as defined in the latest P25 Compliance Assessment Bulletins for testing requirements. If such documentation is not available through the P25 CAP, agencies should obtain documented evidence from the manufacturer stating that all applicable tests were conducted in accordance with published P25 test procedures and successfully passed.1 Contact the P25 CAP at [email protected] for additional guidance.
1 Regardless of the status and availability of P25 CAP testing documentation, grant recipients should include comprehensive acceptance test plan(s) criteria in their procurement and contract documents. The manufacturer/vendor should verify the equipment or services are P25 standards compliant and interoperable with other equipment, features, functions, and capabilities.

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Q6. What will the federal agency issuing grant funding use to confirm equipment in my grant application is P25 compliant?
When reviewing grant applications, the federal agency will verify that proposed equipment purchases are P25 compliant by:
• Confirming the equipment to be purchased is on the P25 CAP Approved Equipment List. If the item is on the list, it is P25 compliant.
• Referring to the DHS Authorized Equipment List (applicable to DHS/Federal Emergency M
anagement Agency [FEMA] grants only). Note P25 standards may not be applicable to some items on this list.
• Reviewing the application package to confirm the applicant provided documentation from the m
anufacturer verifying the purchase is P25 compliant.

If the purchase cannot be verified as P25 compliant using these methods, the federal agency has the authority to request additional information, grant a waiver, or deny the purchase.

Q7. What if I want to purchase non-compliant P25 equipment? When a grant recipient wants to use federal funds to purchase equipment that does not align with P25 standards, the recipient should consult with the federal agency to determine if non-compliant P25 equipment is allowable. In such cases, written justification is often required.

Many agencies do not approve non-standards-based equipment unless there are compelling reasons for using other solutions. Funding requests to replace or add radio equipment to an existing non- compliant P25 system (e.g., new portable radios for an existing analog system) will be considered if there is a clear rationale for such equipment and written justification of how the equipment will advance interoperability and support eventual migration to an interoperable system. The written justification should also explain how that purchase will serve the needs of the applicant better than equipment or systems that meet P25 standards.

P25 Compliance for DHS Grant Recipients
Q8. DHS/FEMA requires its grant recipients to comply with the SAFECOM Guidance. As a DHS grant recipient, am I also required to comply with P25 standards? Yes, DHS/FEMA grant recipients are required to comply with P25 standards when purchasing LMR equipment. This requirement and other conditions specific to DHS/FEMA grant recipients are outlined in Appendix D of the SAFECOM Guidance. For additional information, reference the DHS Authorized Equipment List to determine allowable equipment types for individual grant programs. If the proposal includes any non-compliant P25 LMR equipment, DHS/FEMA grant recipients must apply for prior approval.

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P25 Compliance Resources
Q9. What resources should I use when applying for emergency communications grant funding? Grant applicants are strongly encouraged to work with their Statewide Interoperability Coordinator (SWIC). The SWIC should review the application prior to submission to ensure projects support the state or territory’s strategy to improve interoperable emergency communications. The SWIC should also confirm the funding request aligns with the latest versions of their Statewide Communication Interoperability Plan and the National Emergency Communications Plan, as these are vital plans to improving interoperability.

Q10. Where can I find more information about P25 standards and/or compliance? Grant recipients are invited to explore the wide range of information available from government and industry sources, including:
• P25 Suite of Standards for Land Mobile Radio: tiaonline.org/all-standards/committees/tr-8 • P25 Technology Interest Group: project25.org (Free registration required) • P25 Compliance Assessment Program: dhs.gov/science-and-technology/p25-cap • P25 Compliance Assessment Program list of approved radio equipment: dhs.gov/science-and- technology/approved-grant-eligible-equipment
• P25 Steering Committee’s Statement of P25 User Needs: cisa.gov/publication/p25 • Best Practices, Guidelines, and Considerations for Encryption:
cisa.gov/publication/encryption
• Best Practices for Planning and Implementation of P25 Inter-RF Subsystem and Console Subsystem Interfaces (ISSI and CSSI), Volumes I and II, and Primer: cisa.gov/publication/p25 • SAFECOM and the National Council of Statewide Interoperability Coordinators’ Land Mobile Radio Trio: LMR 101, LMR for Decision-Makers, and LMR for Project Managers:
cisa.gov/safecom/funding
About SAFECOM
SAFECOM was formed in 2001 after the terrorist attacks of September 11, 2001, as part of the Presidential E-Government Initiative to improve public safety interoperability, allowing emergency responders to communicate effectively before, during, and after emergencies and disasters.

SAFECOM is managed by the Cybersecurity and Infrastructure Security Agency (CISA). Through collaboration with CISA, emergency responders, and elected officials across all levels of government, SAFECOM works to improve emergency response providers’ inter-jurisdictional and interdisciplinary emergency communications interoperability across local, regional, tribal, state, territorial, international borders, and with Federal Government entities. For additional information regarding SAFECOM, visit cisa.gov/safecom.

Since 2007, the Cybersecurity and Infrastructure Security Agency (CISA) has worked with SAFECOM members and federal partners to develop the annual SAFECOM Guidance on Emergency Communications Grants (SAFECOM Guidance) for entities applying for federal financial assistance of emergency communications projects. It provides guidance to state, local, tribal, and territorial government grant recipients on:
• Recommendations for planning, coordinating, and implementing projects • Emergency communications activities that can be funded through federal grants • Best practices, policies, and technical standards that help to improve interoperability • Resources to help recipients comply with technical standards and common grant requirements SAFECOM’s public safety practitioners and the National Council of Statewide Interoperability Coordinators develop SAFECOM Guidance and other resources to benefit the community, including a list detailing federal financial assistance opportunities, a funding mechanisms guide for public safety communications systems, system lifecycle planning guidance, and informational brochures such as sustaining land mobile radio and implementing Project 25 standards. The latest release of the SAFECOM Guidance and other funding resources are located on the SAFECOM website at cisa.gov/safecom/funding.

Applicable to All Federal Programs Funding Emergency Communications SAFECOM Guidance provides information on eligible activities, technical standards, and other terms and conditions that are common to most federal emergency communications grants. Grants are administered by numerous federal agencies and are subject to various statutory and programmatic requirements. Thus, grant recipients should review individual grant guidance carefully to ensure their proposed activities are eligible, and that all standards, terms, and conditions required by the program are met.

With the caveat to follow program requirements when applying for federal funding, SAFECOM Guidance is recognized as the primary guidance on emergency communications grants by the Administration, the Office of Management and Budget, and federal grant program offices. Best practices and technical standards located within the SAFECOM Guidance help ensure that federally- funded emergency communications investments are interoperable and support national policies.

SAFECOM Guidance address all types of emergency communications, including land mobile radio, data exchange, alerts and warnings, and Internet Protocol-enabled technologies such as public safety broadband and Next Generation 911 systems.

Compliance Requirements for DHS Grants
In 2015, the Department of Homeland Security (DHS) began requiring its grant recipients to adopt SAFECOM Guidance recommendations and comply with specific terms and conditions outlined in Appendix D, “Compliance Requirement for DHS Grants” of the document. While only DHS/Federal Emergency Management Agency grant recipients are required to comply with SAFECOM Guidance, all entities are strongly encouraged to follow its recommendations when developing applications for emergency communications grants.

CISA | DEFEND TODAY, SECURE TOMORROW
@cisagov Facebook.com/CISA @CISAgov | @cyber | @uscert_gov cisa.gov/SAFECOM [email protected] Linkedin.com/company/cisagov

Emergency Communications Priorities
SAFECOM Guidance is designed to promote and align with the national goals established in the National Emergency Communications Plan, as well as other applicable Presidential Policy Directives, federal statutes, and regulations. SAFECOM members identified investment priorities to promote a consistent approach to improving emergency communications nationwide. State, local, tribal, and territorial government grant recipients are encouraged to target funding toward the following priorities:
❖ Priority 1: Governance and Leadership encourages:

Formalizing statewide governance structures and expanding membership composition to include the whole emergency communications community (e.g., public health, transportation, utilities, nongovernmental organizations).
❖ Priority 2: Planning and Procedures encourages:

Regularly updating strategic plans, considering the system lifecycle, and incorporating risk management strategies to protect against and mitigate disruptions to mission-critical communications.
❖ Priority 3: Training, Exercises, and Evaluation encourages:

Ensuring training and exercise programs to improve personnel’s ability to use all available resources and promote information sharing for multi-agency responses. ❖ Priority 4: Activities that Enhance Communications Coordination encourages:

Implementing the National Incident Management System to enhance coordination, developing procedures to support new technologies, and strengthening resilience and continuity of communications.
❖ Priority 5: Standards-Based Technology and Infrastructure encourages:

Supporting public safety requirements that drive research, development, testing, and evaluation of communications technologies and ensuring systems meet mission-critical needs and data interoperability.
❖ Priority 6: Cybersecurity encourages:

Developing and maintaining cybersecurity risk management and identifying and mitigating equipment and protocol vulnerabilities to enhance agencies’ cybersecurity posture.

Before applying for federal funding, SAFECOM Guidance recommends grant recipients review national and state plans, and coordinate with their statewide emergency communications leaders to ensure that proposals support current strategies. SAFECOM Guidance also provides information on changes in the emergency communications landscape and on federal grant requirements and restrictions to assist grant recipients in developing projects that are more likely to be awarded.

About SAFECOM
SAFECOM was formed in 2001 after the terrorist attacks of September 11, 2001, as part of the Presidential E-Government Initiative to improve public safety interoperability, allowing emergency responders to communicate effectively before, during, and after emergencies and disasters.

SAFECOM is managed by the Cybersecurity and Infrastructure Security Agency (CISA). Through collaboration with CISA, emergency responders, and elected officials across all levels of government, SAFECOM works to improve emergency response providers’ inter-jurisdictional and interdisciplinary emergency communications interoperability across local, regional, tribal, state, territorial, international borders, and with federal government entities. For additional information regarding SAFECOM, visit cisa.gov/safecom.

CALIFORNIA GOVERNOR’S OFFICE OF EMERGENCY SERVICES
FY
2023 State Homeland Security Grant Program
Grant
Number #2023-0042 CalOES ID# 107-00000
Subgrantee name: ____________________________________ Project: _________________

REQUEST FOR SOLE SOURCE PROCUREMENT AUTHORIZATION

1. Project name: _________________________ Project Budget: $__________________

2. Describe the project and/or activity that will be provided by the proposed sole source vendor/contractor.

3. Describe your organization’s standard procedures when sole source contracting is considered, including the conditions under which a sole source contract is allowed, and any other applicable criteria (i.e. approval requirements, monetary thresholds, etc.).

4. Indicate which of the following circumstances resulted in your organization’s need to enter into a sole source contract.
a. Item/service is only available from one source (Describe the process used to make that determination. Please provide details.)
b. A public urgency or emergency will not permit a delay resulting from competitive solicitation. According to the US Department of Homeland Security/FEMA, “Time constraints will not be considered a factor if the subgrantee has not sought competitive bids in a timely manner.” (Describe the urgency or emergency. Please provide details) c. After solicitation of a number of sources, competition was determined inadequate. (Describe the solicitation process that determined competition was inadequate. Please provide details, and attach any relevant supporting material, Request for Proposal, etc.)

5. Did your organization confirm that the contractor/vendor is not debarred or suspended?

6. Will your organization be able to complete all activities associated with the sole source contract by the end of the grant performance period?

7. Has your organization determined the costs are reasonable?

8. Please attach a copy of the cost benefit analysis prepared for this procurement.

Submitted by_________________________ __________________________ Date:_____________ (Name) (Signature)

Visalia City CouncilMarch 18, 2024

Visalia City Council
March 18, 2024