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Home My WebLink AboutA-2003-2661 2 3 4 5 6 7 .8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 / t), b. j * -0_7 A-2003-266 AGREEMENT TO TRANSFER FUNDS FOR FY 2002 STATE DOMESTIC PREPAREDNESS GRANT PURPOSES TltIS AGREEMENT is entered into this ~ay of; ~.[~~2003, which date is enumerated for purposes of reference only, by and between the COUNTY OF ORANGE, a ~olitical subdivision of the State of California, hereinafter referred to as "COUNTY", and hereinafter referred to as "SUBGRANTEE." WHEREAS, COUNTY, acting through its Sheriff-Coroner Depm'tmcnt in its capacity as the lead agency for the Orange County Operational Area, has applied for, received and accepted a grant from the State of California, acting thought its Office of Homeland Security, to enhance county-wide emergency preparedness, hereinafter referred to as "the grant", as set forth in the grant documents that are attached hereto as Attachments A and B and incorporated herein by reference. WHEREAS, the terms of the grant require that certain grant funds be transferred to SUBGRANTEE to be used by SUBGRANTEE to purchase equipment for grant purposes. NOW, THEREFORE, IT IS MUTUALLY AGREED AS FOLLOWS: 1. COUNTY shall transfer to SUBGRANTEE grant funds totaling GRANTEE shall use said grant funds only to acquire equipment as specified in the page(s) from the "Grant Detail Report" and "Budget Detail Worksheet" attached hereto as Attachments C and D and incorporated herein by reference. 2. Throughout its useful life, SUBGRANTEE shall use any equipment acquired with grant funds only for grant purposes. 3. SUBGRANTEE shall exercise due care to preserve and safeguard equipment acquired with grant funds from damage or destruction and shall provide regular maintenance and such repairs for said equipment as are necessarY, in order to keep said equipment continually in good working order. // CLEI<K OF COUNCIL Shmff2003/369 Page 1 of 4 5 6 7 ~8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 2 3 4 funds or their duly authorized representative(s), for examination, copying, or mechanical reproduction on or off the premises of SLrBGRANTEE, upon request during usual working hours. 11. SUBGRANTEE shall provide to COUNTY all records and information requested by COUNTY for inclusion in quarterly reports and such other reports or records as COUNTY may be required to provide to the agency from which COUNTY received grant funds or other persons or agencies. 12. COUNTY may terminate this Agreement and be relieved of the payment of any consideration to SUBORANTEE if a) SUBGRANTEE falls to perform any of the covenants contained in this Agreement, including the Attachments hereto, at the time and in the matter herein provided, or b) COUNTY loses funding under the grant. In the event of termination, COUNTY may proceed with the work in any manner deemed proper by COUNTY. 13. SUBGRANTEE and its agents and employees shall act in an independent capacity in the s Agreement, including the Attachments hereto, and shall not be considered officers, agency from which COUNTY received grant funds. 14. SUBGRANTEE and its officers, agents, employees shall abide by all applicable federal, State and local laws, including all applicable statutes, regulations, executive orders and ordinances. 15. SPECIAL PROVISION applicable: r~ SUBGRANTEE shall apply with all applicable provisions of the Single Audit Act of 1984 and the Single Audit Act Amendments of 1996. Any funds received in excess of current needs, approved amounts, or those found owed as a result ot'a final inspection or audit, must be refunded to the State upon thirty (30) days notice. Department of Justice, Office for Domestic Preparedness, State Domestic Preparedness Program. Application for Assistance Catalog of Fefleral Domestic Assistance # 16.007 Project Budget Period: Date of OdS Notification of Approval to March .3 I, 3004 Maximum Amount Authorized (from Appendt< A) Equipment Amount Requested $ Exercise Amount Requested $ Administrative Costs Requested $ 29,892 Total Amount Requested $1,195,664 $1~195.664 Award # 2002-TE-CX-0133 Applicant: County of Oranqe d nthori~ed Agent Mailing Addr~s 2644 Santiaao Canyon Road City, State, Zip Code Silverado, CA 92676 Contact Information: Terra Ouensin.q, Assistant Emerqency Manaqer Nameffitle Area Cocl~/O,~ce Telephone iVumber {714) 628-7158 E-MaiI Addr~s tduensino(~ocsd.ora Application Checklist.- The following items must be included with this grant application packitge: ' ' , · ' · .---- Program Narrative ar, d Bt:dgct Detail Wo~heet- Equipment . ' ' . -- Pro,ram Narrativ~ a~td B~dgcc Dct~i[ W~rksh=et - Exercises Governing Body Itcs,,ilici:m tlr' ' · , , ", , n~ded) Certification and Signature or Authorized Agent [ hereby certi./j, that the attached application represents the Operational Area consensus on terrorism equipment needs to improve the ?t~eratio. nal Area ~s capability to respond to terrorism incidents ~ /..: ~ -.~ ~.. ..~ ' ~'~.~... ,~ Michael S. Carona Signore of Author~ed Agent Printed Name She~ff-Comner ~--~..~.~Z · ~: F Title Date Region Administrator Application reviewed/approved by: HQ Disbursement Authorization Payment autb. orized by: Amount approved for payment: S PC,~lndex: Accotmt#tg .OFFICE OF THE cOUN'f~ C~OUNSEL 91~,N~E COUNTY, CN,tIK3RNt~ LU fl. n 0 W~S Document Retrieval Page I of 1 [Code of Federal Regulations] [Title 28, Volume 2] [Revised as of July 1, 2002] From the U.S. Government Printing Office via GPO Access [CZ'i~: 28C~t~.66.33] [Page 181-182] TITLE 28--JUDICIAL ADMINISTRATION CHAPTER I--DEPARTMENT OF JUSTICE (Continued) PART 66--UN!FORM ADMINISTHATIVE REQUIREMENTS FOR GRANTS AND COOPEHATIVE AGREEMENTS T Subpart C--Post-Award Requirements 'Sec. 66.33 Supplies. (a) The Omnibus Crime Control and Safe Streets Act of 1968, as amended, Public Law 90-351, section 808, requires that the title to all equipment and supplies purchased with section 403 or 1302 (block or formula funds) shall vest in the criminal justice agency or nonprofit organization that purchased the property if it certifies to the State office described in section 408 or 1308 that it will use the property for criminal justice purposes. If such certification is not made, title to the property shall vest in the State office, which shall seek to have the property used for criminal justice purposes elsewhere in [[Page 182]] the State prior to using it or disposing of it in any other manner. (b) Disposition. If there is a residual inventory of unused supplies exceeding $5,000 in total aggregate fair market value upon termination or completion of the award, and if the supplies are not needed for any other federally sponsored programs or projects, the grantee or subgrantee shall compensate the awarding agency for its share. [53 FR 8068 and 8087, Mar. 11, 1988, as amended by Order No. 1252-88, 53 FR 8069, Mar. 11, 1988] W',4IS Document Retrieval Page 2 of 3 (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the cost of the property, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the grantee or subgrantee is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. (e) Disposition. When original or replacement equipment acquired under a grant or subgrant is no longer needed for the original project or program or for other activities currently or previously supported by a Federal agency, disposition of the equipment will be made as follows: (1) Items of equipment with a current per-unit fair market value of less than $5,000 may be retained, sold or otherwise disposed of with no further obligation to the awarding agency. (2) Items of equipment with a current per unit fair market value in excess of $5,000 may be retained or sold and the awarding agency shall have a right to an amount calculated by multiplying the current market value or proceeds from sale by the awarding agency's share of the equipment. (3) In cases where a grantee or subgrantee fails to take appropriate disposition actions, the awarding agency may direct the grantee or subgrantee to take excess and disposition actions. (f) Federal equipment. In the event a grantee or subgrantee is provided federally-owned equipment: (1) Title will remain vested in the Federal Government. (2) Grantees or subgrantees will manage the equipment in accordance with Federal agency rules and procedures, and submit an annual inventory listing. (3) When the equipment is no longer needed, the grantee or subgrantee will request disposition instructions from the Federal agency. (g) Right to transfer title. The Federal awarding agency may reserve the right to-transfer title to the Federal Government or a third part named by the awarding agency when such a third party is otherwise eligible under existing statutes. Such transfers shall be subject to the following standards: (1) The property shall be identified in the grant or otherwise made known to the grantee in writing. (2) The Federal awarding agency shall issue disposition instruction within 120 calendar days after the end of the Federal support of the project for which it was acquired. If the Federal awarding agency fails to issue disposition instructions within the 120 calendar-day period the grantee shall follow (3) When title to equipment is transferred, the grantee shall be paid an amount calculated by applying the percentage of participation in the purchase to the current fair market value of the property. [53 FR 8068 and 8087, Mar. ll, 1988, as amended by Order No. 1252-88, 53 FY02 State Domestic Preparedness Program Orange County Operational Area The OCSD Bomb Squad is responsible for the explosive device suppression and investigation for the entire OC OA. However, not alt other first responding law enforcement officers have Personal Protective Equipment (PPE). Those unprotected law enforcement officers would be unable to assist, even in providing perimeter security, at a scene involving WMD without danger to themselves. priorities Provide narrative describing the equipment purchase priorities and how were they determined. The narrative should include: · an explanation of how the equipment prioritization was developed (i.e., describe how the TWG decided the priorities) · the selection criteria for the disciplines, cities, and special districts Included in the plan The OC TWG Training and Equipment Subcommittee is made up primarily of Law, Fire, and Health representatives. There has been a substantial learning curve as to how each discipline sees their respective role in a WMD event and how each discipline trains for such events. The recommendations in selecting equipment and providing a standard level of training seek to satisfy each discipline's needs based on their respective response missions. OC has identified the need to supply PPE to all initial first responders as the number one priority. When this goal has been met, secondary first responders, and supporting agencies/disciplines (public works, special districts, coroner, etc.) will receive a base line of PPE. The equipment procurement and selection objectives identified by the OC TWG Training/Equipment Subcommittee have been based upon the on going strategy for OC. The objectives are: To provide PPE for all law enforcement and fire/EMS first responders who may encounter terrorist and/or WMD incidents. The specialized equipment also has a training component to insure first responders have a standard level of training to use the specialty equipment. These are baseline recommendations only and do not reflect the needs of second echelon specialty responders such as HMRT's, the OCSD Bomb Squad, or SWAT. To provide fire services/HMRT's, EMS, and law enforcement personnel the essential capability of performing decontamination in the aftermath of a terrorist and/or WMD incident. The very intent of a terrorist act is to cause harm to a large number of civilian and first response personnel. Early decontamination has been recognized as a key component to victim survival. To provide radio equipment necessar7 for effective communications. The 800 MHz communications equipment currently used by OC law enforcement, fire services, HMRTs, Public Works, Special Districts, and EMS personnel is compatible but in short supply. Portable radios will provide the ability to put more specialized law and fire FY02 State Domestic Preparedness Program Orange County Operational Area The equipment funding allocation approved by the CC CA Executive Board for this grant, will allow the CC CA, cities, and special districts the opportunity to enhance their specialized equipment needs. The Orange County Transportation Authority (OCTA) has opted to purchase PPE for the contract OCSD deputies that provide security for the OCTA buses. The Department of Education (DOE) will purchase crisis management software for every School District in CC. Funding has been authorized for the OCSD Bomb Squad to purchase a much needed additional robot. The remainder of the funds allocated to the CC Special District Representatives that was not spoken for, was pooled together to purchase technical detection equipment for the HMRT's, and PPE for CC HCA/Environmental Health (CC sole provider). Additionally, the CC CA has a contingency plan to purchase supplementary equipment to benefit the CC CA in the event a jurisdiction decides not to · apply for the grant at the last minute. All equipment purchased must be made on a mutual aid basis. All sub-grantees in the OC OA have been made aware of this provision and have agreed to it. Again it is understood that some specialty equipment requires technical expertise to operate and although the individual piece of equipment may not be available to use, the equipment will be made available via the response agency. Equipment Procurement and Distribution Provide narrative describing the OA's procurement and distribution plan, and what selection criteria were used. The selection criteria should support the following details identified on the OA's budget detail worksheet: · funding amounts sub granted to specific jurisdictions · equipment being purchased and retained by the CA · equipment being purchased by the CA and distributed to specific Jurisdictions The CA Executive Board approved the following funding distribution: CC CA ALLOCATION $1,128,822 2.5 % GRANT ADMINISTRATION QCSD/EM $28,220 $1,100,602 QA SOLE PROVIDER AGENCY-BOMB SQUAD ROBOT 150,000 DISTRIBUTED TO PARTICIPATING JURISDICTIONS-SPECIAL DISTRICTS $50,000 Unallocated Funds $60,000 $840,602 CITIES PLUS UNINCORPORATED AREA BASE RATE OF $10,000.00 $350,000 DISTRIBUTED TO PARTICIPATING JURISDICTIONS- CITIES AND UNINCORPORATED AREA $490,602 % OF ALLOCATION CITIES POPULATION COUNTY OF FUNDS Aliso Viejo* 40,166 1.4% $16,703.70 Anaheim 334,700 11.4% $$5,861.37 Brea 36,850 1.3% $16,150.26 Buena Park 79,800 2.7% $23,318.61 Costa Mesa 110,700 3.8% $28,475.81 · FY02 State Domestic Preparedness Program Orange County Operational Area The contract city partners of the OCSD and the OCFA (noted in the funding distribution chart with an *) have designated the OCSD and OCFA to purchase equipment for law and fire first responders to support their jurisdictions (see budget worksheet). The funding allocated to the unincorporated area will be shared by the OCSD to purchase PPE for OCSD field deputies, the OCFA for detection equipment, and OC HCA/Environmental Health for PPE and Detection equipment (see budget worksheet). The OCSD Bomb Squad was allocated $150,000 to purchase a robot. The law enforcement equipment will be purchased by the OA and the equipment will be distributed to the jurisdictions. The equipment purchased for the OCFA will be purchased by the OA and the equipment will be sub granted to the OCFA. The Equipment purchases for HCA reflect the role of the Environmental Health Emergency Response Team (EH/ER). EH/ER is the HCA's on-scene representative at Nuclear, Biological, Chemical, and Radiological (NBCR) incidents. EH/ER is the local entity in charge of Environmental Surety issues, such as site quarantine, characterization, and remediation, at NBCR incidents. EH/ER takes a lead role in Biological Terrorism Response, with responsibilities that include sampling, screening, and transporting suspect Biological samples and acting as the interface between the Level 'B' Public Health Laboratory and the on-scene Unified Command. The 11 OC Special District Representatives were offered the opportunity to participate in the grant and allocated $10,000 each. The allocated funding to the Special Jurisdiction Representatives that was unallocated, or $60,000, was pooled together to purchase equipment to benefit the OA as a whole. Two specialty pieces of detection equipment will be purchased to support two of the four OC HMRT's and the remainder of the funding was allocated to the OC HCNEnvironmental Health for PPE (see budget worksheet). The funding for the equipment for the OCFA and HCA will be sub granted to them. The remainder of the funding has been distributed (base amount plus per capita) to the cities in OC that do not contract jointly with the OCSD/OCFA. The cities will be sub granted their perspective amounts to purchase equipment (see budget worksheet). If a jurisdiction(s) does not participate, their allocated funding will be used to purchase first responder equipment, from an established priority list, to benefit the OA as a whole. Measurable Proclram Obiectives Provide a narrative that contains measurable program outcomes/goals, objectives and evaluation methods for the equipment allocation. An example of a measurable program objective is: Goal: Address first responder equipment shortfalls identified in the Needs Assessment Ob/ective: Purchase all required equipment by the end of the grant award period. Evaluation Measure: Was the required equipment ordered by the end of the grant award period? Was the required equipment distributed by the end of the grant period? FY 02 State Domestic Preparedness Program Orange County Operational Area PROGRAM NARRATIVE - EXERCISE Problem Statement Provide narrative of how the exercise allocation fits with your overall Operational Area needs, as reflected in the previous CDP Needs Assessment. (If your needs have changed since the previous assessment, please explain the changes.) The narrative should also include: · which threat is the most likely (based upon needs assessment) · what type of exercises are needed to address the threat · how many of each type of exercise are needed · how many jurisdictions are expected to participate in each exercise, and from which disciplines · a description of how the cities, special districts, and county agencies were involved in the OA's decision-making process with respect to the exercise program. The CC CA Executive Board approved the grant funding to be allocated to develop an exercise focusing on the CC Private Sector Terrorism Response Group (PSTRG) and the CC Terrorism Early Warning Group (TEWG). The CC CA Executive Board represents the 114 members of the CC CA. The funding provided for in this grant will allow for one tabletop exercise. The Exercise will be an CA Exercise (it will not be held in conjunction with or in lieu of the Annual CA Exercise that is required in the Emergency Management Performance Grant), and the CC CA will be invited to attend/participate. The participatns will include the representation of the multi- agency/discipline CC TWG which includes all needed first and secondary responders of jurisdictions/agencies in such an event. During the FY '99 Needs Assessment, the CC 'RNG developed a Vulnerability Assessment for Potential Targets in CC. Representatives from the Vulnerability Assessment from CC are the membership of CC PSTRG. The mission statement of the CC PSTRG is: "Support the National Strategy for Homeland Security and other state and local counter-terrorism efforts by effectively addressing private sector safety, incident management, and public health consequences of potential terrorist attacks on the Critical Infrastructure within Orange County, through information and physical resource sharing in the Operational Area." The varied attractions in Orange County draw large diverse populations of attendees that are vulnerable to terrorist attacks. In terms of population, Anaheim is the tenth largest city in California, and the 59th largest city in the nation. The city has a permanent population of 310,000 and a visitor population of 22 million annually. Orange County has a large tourist population annuatly due to venues such as Disneyland/Disney's California Adventure, the Anaheim Convention Center, the Arrowhead Pond, Edison International Field (American League host of the 2002 World Series), Knott's Berry Farm, and the Huntington Beach Surf Competition, Orange FY 02 State Domestic Preparedness Program Orange County Operational Area It is anticipated there will be participation from the OC OA Executive Board which represents the "Policy Group" in the County/OA EOC. There will be participation from the OCSD (including the Bomb Squad, Coroner, Communications, and Emergency Management), OC PSTRG, and OC TEWG, OC Health Care Agency, State OES, JTTF, CATIC, and representatives of the OC OA. Overview of Jurisdictions' Capability Provide narrative describing: · current capabilities and a brief description of recent exercises · how the proposed exercises will increase the OA's capabilities to respond to WMD events · how the proposed exercises support the Mutual Aid System The OCSD conducted a Radiological Dispersal Device (RDD) tabletop exercise which included over 250 local, state and federal participants/observers in January 2002. The OC OA conducted its annual OA Exercise in April 2002. The topic of the functional exercise was Homeland Security. The annual OA Exercise in 2003 will focus on an Anthrax attack with the release at a large OC venue. Additionally, OC conducts an annual San Onofre Nuclear Generating Station (SONGS) exercise in accordance with the Nuclear Regulatory Commission. The proposed exercise will increase the OC OA's ability to respond to WMD events for the following reasons: · Maintain a 'baseline' of training for all OA/County EOC responders · Introduce the mechanism in place to manage such events (SEMS) to the Private Sector · Display the vital role the OC TEWG has in such an event (Threat Analysis, Play Books, Reciprocal Information/Intelligence Flow from the TEWG to the PSTRG) · Identify cdtical needs in Training, Equipment, Planning in OC for WMD events · Identify future WMD Exercise needs in the AAR, that will lead into the 2004 OC OA Field Exercise Measurable Program Objectives Provide a narrative that contains measurable program outcomes/goals, objectives' and evaluation methods for the exercise allocation. An example of a measurable program objective is: .Goal: Design, develop, conduct and evaluate a cycle and range of exercise activity of increasing complexity as identified in the Needs Assessment. Objective: Design, develop, conduct and evaluate the scheduled cycle and range of exercise activity by the end of the grant award period. Evaluation Measure: Were the range of events documented in the exercise cycle designed, developed, conducted and evaluated by the end of the grant award period? Goal: Wdte a Request for Proposal (RFP) to hire a contractor to develop an evaluated tabletop exercise that wilt include collaboration with the OCSD Emergency Management AGREEMENT TO TRANSFER FUNDS FOR FY 2002 STATE DOMESTIC PREPAREDNESS GRANT PURPOSES ATTACHMENT A AGREEM]~NT TO TRANSFER FUNDS FOR FY 2002 STATE DOMESTIC PREPAREDNESS GRANT PURPOSES ATTACHMENT B AGREEMENT TO TRANSFER FUNDS FOR FY 2002 STATE DOMESTIC PREPAREDNESS GRANT PURPOSES ATTACHMENT C GOVERNOR GRAY DAVIS STATE OF CAL~ORNIA ~.EORGE V. VlNSON IRECTOR O~'~'tCE OF HOMELAND SECURITY O~l~ OF rt~ GoveRNOR STATE CAPITOL SACRAMENTO, CA 95814 (916) 324-8908 MAIN (916) 323-9633 FAX June 26, 2003 Michael S. Carena Sheriff-Coroner Orange County 2644 Santiago Canyon Rd. Silverado, CA 92676 RECEIVED JUL 0 7 21]03 Dear Sheriff Carona: SUBJECT: NOTIFICATION OF APPLICATION APPROVAL FY02 State Domestic Preparedness C-rant Program 2002-133, OES//059-00000 The Office of Homeland Security has approved your grant application in the amount of $1,195,664.00. A copy of your approved application is enclosed for your records. In order to receive payment, a Governing Body Resolution and Grant Assurances form must be on file with the Governors Office of Emergency Services (OES). Payment must be requested using a Reimbursement Request Form; a copy has been enclosed. ~,~S grant is subject to all policies and provisions of the Single Audit Act of 1984 and the Single Audit Act Amendments of 1996. Any funds received in excess of current needs, approved amounts, or those found owed as a result of a final inspection or audit, must be refunded to the State within 30 days upon receipt of un invoice from OES. Quarterly reports must be prepared and submitted to OES for the duration of the grant period or until all activities are completed and the grant is formally closed. A quarterly report template, with instructions, will be distributed under separate cover prior to the deadline for the fu~t report. Failure to submit quarterly reports could result in grant reduction, termination or suspension. For farther assistance, please contact the OES Grant Management Section at (916) 845-8110. Sincerely, Enclosure c: Applicant's File County Board of Supervisors FROM O~ 0A EMERGENCY MGMT (TUE) 6, 3' 03 12:54/ST. 12:53/N0. 4862530541 P 4 0 ? ~ FROM OC OA EMERGENCY MGMT (TUE) 6. 3'0~ 12:55/ST. 12:53/N0,4862530541 P 8 FR~.OC OA EMERGENCY MGMT (TUE) 6. 3' 03 I2:56/ST. 12:53/NO. 4862530541 P 10 FRO~ OCOA E~ERGENCY MGMT 6. 3'03 ~2:56/ST. 12:53/N0. 4862530541 P 13 · FROM Od ~A EMERGENCY MGMT (TUE) 6. 3'03 12:57/ST. t2:53/N0. 486253054[ P 16 C) (TUE) 6. 3'03 12:58/ST. 12:53/NO. 4862530541 P 18 F~0M OC OA EMERGENC7 MGMT ~. S' 0~ 12:58/ST. 12:53/N0. 48625~0541 P 20 Lg FROM O~ OA EMERGENCY MGMT (TUE) 6. 3'03 12:59/ST. 12:53/NO. 4862520541 ? 22 FROM OC OA EMERGENCY ~GMT (TUE} 6. 3'03 13:00/ST. 12:53/NO. 4862530541 P 26 'F~OM 0C OA EMERGENCY MGMT (TUE) 6, 3' 03 I~:00/ST. 12:53/N0. 4862530541 P 28 FROM OC OA EMERGENCY MGMT (TUE) 6. 3'03 I3:01/ST. 12:53/NO. 4862530541 P 30 FROM 0C OA EMERGENCY MGMT (TUE) 6. 3'03 13:0I/ST. 12:53/NO. 4862530541 ? 32 FROM OC OA EMERGENCY MGMT 486253054[ ? 34 AGREEMENT TO TRANSFER FUNDS FOR FY 2002 STATE DOMESTIC PREPAREDNESS GRANT PURPOSES ATTACHMENT D ¢ .,~ o 0 4.1 °