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AGREEMENT TERMINA nON
Please complete this form when the attached agree~J1WJlPQ.$bnlMr~ ~ct.
Return form to the Sr. Deputy Clerk of the Councl!rM"3:0). Ca1l647'!~~ if you have any
questions. CLEf,!, UNCiL
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Date:
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City of Santa Ana
Clerk ofthe Council
Revised 8-7-03
"-
A-2006-092-03"l
INSURANCE NOT REQU'R~P
WORK MAY PROCEED
CLERK OF COUNCIL
DATE: 1- ( q -oG
OCt>f4. L.A.)
C.1-1:7~
CDBG PUBLIC SERVICES
MEMORANDUM OF UNDERSTANDING
WITH THE SANTA ANA POLICE DEPARTMENT
THIS CDBG PUBLIC SERVICES MEMORANDUM OF UNDERSTANDING
("MOU") is made as of the 1st day of July, 2006, by and between the City of Santa Ana, a
charter city and municipal corporation ("City") and the Santa Ana Police Department
("Subrecipient").
RECITALS
A. City has received an award of Community Development Block Grant ("CDBG")
funds from the Department of Housing and Urban Development.
B. Subrecipient is an entity of City and is engaged in administration of City's overall
CDBG program and seeks to provide the services described in "Exhibit A," in accordance with
the schedule of performance included therein, hereinafter referred to as "said Program".
Subrecipient represents that it is qualified and willing to operate said Program and certifies that
the activities carried out with funds provided under this Agreement will meet one or more of the
CDBG program's National Objectives (24 CFR Part 570.208).
C. City has approved the issuance of CDBG funds, in an amount not to exceed
$205,000, to Subrecipient for these services.
NOW, THEREFORE, in consideration of performance by the parties of the promises,
covenants and conditions herein contained, the parties hereto agree as follows:
1. Subrecipient's Services.
A. Statement of the Work. Subrecipient shall utilize City's CDBG funds to
provide for its administration of City's overall CDBG program and support of its Program as
described in Exhibit A.
B. Standard of Care. As a material inducement to City to enter into this
MOU, Subrecipient hereby represents and warrants that it has the experience necessary to
undertake the services to be provided as set forth in Exhibit A.
C. Compliance with Laws. All services rendered hereunder by Subrecipient
shall be provided in accordance with all ordinances, resolutions, statutes, rules and regulations of
City and any federal, state or local goverrunental agency having jurisdiction at the time service is
rendered. This MOU is subject to and incorporates the terms of the Housing and Community
Development Act of 1974, as amended; 24 Code of Federal Regulations ("CFR") Chapter V,
Part 570; City's CDBG Program Guidelines; and all amendments or successor regulations or
guidelines thereto ("CDBG Regulations").
2. Term of MOU, Subrecipient shall provide its services under this MOU for a 12
month period commencing on July 1,2006 through June 30, 2007.
3. Budget, Subrecipient agrees to complete said Program on or before June 30,
2006-07 and to use said funds to pay for necessary and reasonable costs allowable under the
federal law and regulations to operate said program. Other allowable program costs are detailed
in the Budget, as set forth in "Exhibit B," attached hereto and by this reference incorporated
herein. Subrecipient shall use all income received from said funds only for the same purposes
for which said funds may be expended pursuant to the terms and conditions of this Agreement.
No budgetary changes shall occur without City's prior approval. Subrecipient hereby certifies
and agrees that it will not use funds provided through this Agreement to pay for entertainment,
meals or gifts.
4. Compensation, Upon compliance with specified performance requirements, City
shall reimburse Subrecipient an amount not to exceed $205,000, which shall constitute full and
complete reimbursement for the implementation of this MOU. The parties understand and agree
that such reimbursement, if any, shall be conditioned upon receipt of such funds by City from
HUD and shall not be a charge on any other funds of City. The CDBG Funds shall be disbursed
by City to Subrecipient on a quarterly basis (October, January, April and July) subject to and upon
receipt and approval of a complete quarterly activity report from Subrecipient, with the final
payment subject to the satisfaction of the condition precedent of submittal of complete reporting
information due on or before July 15 of the applicable funding year, as hereinafter more fully set
forth. Subrecipient shall be obligated to perform such duties as would normally extend beyond
the term, including but not limited to obligations with respect to indenmification, audits,
reporting, data retention/reporting, and accounting.
5. Program Evaluation and Review/ Common Rule. Subrecipient shall make
performance, financial and all other records pertaining to this MOU available to all City and
HUD personnel. City and HUD personnel may inspect and monitor Subrecipient's facilities and
program operations, including the interview of Subrecipient's staff and program participants.
Subrecipient agrees to submit to City or HUD all data necessary to complete the Annual Grantee
Performance Report in accordance with HUD requirements and in the format and at the time
designated by City or HUD Project Directors or their designees. Pursuant to CFR 85 .40( a), the
City manages the day-to-day operations of each grant and subgrant supported activities. City
staff has detailed knowledge of the grant program requirements and monitors grant and subgrant
supported activities to assure compliance with Federal requirements. Such monitoring covers
each program, function and activity and performance goals are reviewed periodically.
6. Non-Discrimination and Equal Employment Opportunity. In the performance
of this MOU, Subrecipient shall not discriminate against any employee, subcontractor or
employment applicant because of race, color, creed, religion, sex, marital status, national origin,
ancestry, age, physical or mental handicap, medical condition or sexual orientation. Subrecipient
will take affirmative action to ensure that employees are treated without regard to their race,
color, creed, religion, sex, marital status, national origin, ancestry, age, physical or mental
handicap, medical condition or sexual orientation.
2
7. Record Keeping/Reporting, Subrecipient shall keep and maintain complete and
adequate records and reports to assist City in meeting and maintaining its record keeping
responsibilities under the CDBG Regulations, including the following:
(1) Records
a. Documentation evidencing program income requirements in
conformity with 24 CFR 570.504(b((2)(i), (ii) and 24 CFR 570.503(b)(3) and 24
CFR 570.208(a)(2)(B) ofthe income level of persons and/or families participating
in or benefiting by the Program.
b. Documentation of the number of persons and/or families participating
in or benefiting by the Program.
c. Household information shall include number of persons, identification
of head of household, race/ethnicity, and income verification.
d. Documentation of all CDBG Funds received from City.
e. Documentation of expenses as identified in the Budget Proposal,
including evidence of incurring the expense, invoices for goods or services, copies
of any and all contracts or documentation pertaining to costs for subcontractors,
plus all other invoices for which CDBG Funds were expended, and any payments
therefor.
f. Any such other related records as City shall reasonably require or as
required to be maintained pursuant to the CDBG Regulations.
(2) Reports
a. Payment Request. Concurrently with the submittal of each
quarterly report, on or before the 15th day of October, January, April and
July, Subrecipient shall submit both: an original invoice and true copies of
invoices, receipts, agreements, copies of any and all contracts or documents
pertaining to costs for subcontractors or other documentation supporting
and evidencing how the CDBG Funds have been expended during the
applicable quarter.
b. Quarterly Activity Report: Subrecipient agrees to keep monthly records of all
ethnic and racial statistics of persons and families benefited by Subrecipient in the
performance of its obligations under this Agreement, including, but not limited to, the
number oflow and moderate income persons and households assisted in accordance with
federal income limits, the number of female heads of households assisted, new program
information and year-to-date program statistics on expenditures, caseload and activities.
3
8. Revenue Disclosure Requirement, Subrecipient shall make available all books
and records pertaining to each project or business activity that is funded by CDBG Funds under
this MOU for inspection and audit by HUD's representatives, upon request, at any time during
the term of this MOU and during a period of 5 years thereafter. All such books and records shall
be maintained by Subrecipient at a location in Orange County. Failure of Sub recipient to comply
with the requirements of this section shall constitute a material breach for which City may
terminate or suspend this MOU.
9. Audit Report Requirements. Subrecipient agrees that if Subrecipient receives
Three Hundred Thousand Dollars ($300,000.00) or more in federal funds, Subrecipient shall
have an aunual audit conducted by a certified public accountant in accordance with the standards
as set forth and published by the United States Office of Management and Budget. Subrecipient
shall provide City with a copy of said audit by October I of the year following the program year
in which this Agreement is executed.
10. Termination, This Agreement may be terminated in the following manner for the
following reasons: (a) on thirty (30) days' written notice by either party; (b) upon five (5) days'
written notice for violation of Federal Laws governing the use of CDBG Funds by Subrecipient;
(c) terminated for convenience in accordance with 24 CFR 85.44; and (d) terminated due to the
non-performance of Subrecipient and/or failure of Subrecipent to perform the work described in
Exhibits A and B or failure to meet the performance standards and program goals set forth therein.
In the event of any such termination, Subrecipient shall only be entitled to reimbursement for
approved expenses incurred to the effective date of termination and any and all funds not used
must be returned to City per the paragraph below.
11. Reversion of Assets. Upon the expiration of this Agreement, Subrecipient shall
transfer to City any CDBG funds on hand at the time of the expiration of this Agreement as well as
any accounts receivable attributable to the use of CDBG funds. [24 CFR 570.503(b)(8).]
Disposition of real property or equipment shall be resolved pursuant to City guidelines.
Subrecipient's obligations and responsibilities set forth in this paragraph and in the
"Termination" clause and other requirements pertaining to program income shall not be affected
by the termination of this Agreement and shall survive the date of termination of this Agreement
for such period of time as City and/or HUD deems necessary for the responsibilities, duties and
obligations to be performed and completed to the satisfaction of City and HUD.
12, Exhibits. All documents referenced as exhibits in this MOU are hereby
incorporated in this MOD, including Exhibits A, A-I, B, B-1 and C.
13. Entire Agreement. This MOU, and all other documents incorporated herein by
specific reference, represent the entire and integrated agreement between City and Subrecipient.
This MOU supersedes all prior oral or written negotiations, representations or agreements. This
MOD may not be amended, nor any provision or breach hereof waived, except in a writing
signed by the parties that expressly refers to this MOD.
4
IN WITNESS WHEREOF, the parties have executed this Memorandum of
Understanding as of the date first written above.
ATTEST, ~
/~
~/ . /^-
// Patricia E. Healy
Clerk of the Council
APPROVED AS TO FORM:
JOSEPH W. FLETCHER
City Attorney
By:g~ f.~
Lisa E. Storck
Assistant City Attorney
CITY OF s/y AN~ ~_ _-
By: ~-e.-
DavidN. Ream
City Manager
"SUBRECIPIENT"
CITY OF SANTA ANA
Santa Ana Police Department
BY:\" 'y{~l(~,-
Name: Paul Walters
Title: Chief of Police
5
City of Santa Ana
Community Development Block Grant
Scope of Work
Name of Organization- Santa Ana Police
Name of Funded Program- Helicopter Program
Annual Accomplishment Goal
I. Total number of un duplicated clients (Santa Ana and Non-Santa Ana Residents) anticipated to be served by
the funded program, named above, during the l2-month contract period.
349 J OOPERSONS
II. Number of only unduplicated Santa Ana residents to be served by the funded program, named above,
during the l2-month contract period.
349 J OOPERSONS
Program and Funding Description
III. Description of Work - In the space below, describe the program to be funded during the l2-month
contract period.
The Santa Ana Police Helicopter Program provides response to service calls over the entire city, but the goal is to concentrate air
support on high priority calls and violent crimes in progress. The helicopter is an effective, technologically advanced tool that aids in
control and suppression of crime, and enhances officer and citizen safety during crimes in progress and pursuits. The helicopter
provides a safer environment for ground units responding to calls, as helicopter personnel inform them of potentially dangerous
situations. Well-informed officers are more secure in their work and more effective in combating crime, and citizens are assured of
rapid, effective services.
The helicopter provides service seven days per week from 9:00am to 3:00am. The Santa Ana Police Department has participated in
the Airborne Law Enforcement program for 17 years and provides one full time pilot and one part-time observer. During the
upcoming fiscal year, the Department plans to add an second observer to the program.
IV. Activities funded by this grant - How will CDBG funds be used for the funded program? Narratively
describe the budget for the funded program illustrated in Exhibit B and B-1.
Santa Ana Police Department contracts with ABLE (Airborne Law Enforcement), which is a JPA between Newport Beach and Costa
Mesa Police Departments, providing air support to Santa Ana officers and residents. CDBG Funds will be used to pay for the air
support services. The total contract amount is $383,625, of which $205,000 is provided through CDBG grant funding. The pilot's
salary of$138,625, plus training and overtime, and an additional $32,000 ofthe contract are provided by the police department.
Exhibit A
Page 1 of2
Schedule of Performance
Estimate the number of only unduplicated Santa Ana residents to be served by the funded program during the
l2-month contract period per quarter. (How many new Santa Ana clients will be served each quarter.)
Quarter 1: Julyl - September 30
Quarter 2: October! - December 31
Quarter 3: January I - March 31
Quarter 4: April I - June 30
349.100Persons
349 J OOPersons
349JOOPersons
349JOOPersons
349.100Total number ofunduplicated Santa Ana residents to be
served. (Must equal the number for II above.)
Schedule of Invoicing
Estimate the amount of grant funds to be requested during the l2-month contract period on a quarterly basis.
Quarter I: July I - September 30
Quarter 2: October! - December 31
Quarter 3: January I - March 31
Quarter 4: April I - June 30
$51.250
$51.250
$51.250
$51.250
$205.000Total Grant (Must equal the Total Program Budget
indicated on Exhibit B.)
Exhibit A
Page 2 of2
CITY OF SANA ANA
Community Development Block Grant
Outcome Tracking
IMPO R T ANT: The City of Santa Ana is in the process of incorporating the new HUD Performance
Outcome Tracking guidelines, therefore this section is subject to change in order to be compliant with
HUD regulations. If the situation should occur that the current tracking system is not sufficient to meet
HUD regulations an amendment to this contract will be needed.
Instructions: From the list of activities below select the activity that best describes the purpose ofthe program that will be funded
in fiscal year 06-07 by these grant funds. Two activities have multiple outcomes, therefore if "Senior Services" or "Youth Services" is
selected, please select the one outcome that best describes the purpose of the funded program. ONLY if none of the activities listed
adequately describe the funded program, please select that last activity "Low- and Moderate Income Services".
Fulfillment
Tracking HUD Objective to be fulfilled HUD Outcome to be fulfilled illustrated by
HUD Indicator
Suitable Creating Specific Outcome
Activity/Program Outcome Tracking Goal Living Decent Economic A vailabilityl Affordability Sustainability Indicator #
Environment Housing Opportunitie Accessibility (Please see page 4
of 4 for desc.)
nti-CrimeServices Track thereduclion in educe response time to
sponse time and the eriouscrimcs in the City's
umber of criminal oW-lllldModerate.Jncome
~ apprehended as a result. reabyatlcast3minutcs
suIting in thcapprchcnsion 2
f 1,500 criminals that may X X
thcrwisecscllpe
.U5_year goal to be
achieved by FY 09/10
llir Housing Services Provide fllir housing service 1. Provide fair housing
ndongoing analysis of ounseling, education and
impedimenlstofairhollsing. ~orcementservicesto
D ,000 Santa Ana households X X 2
"US_year goal to be
chievedbyFY09!1O
.0 Annually assess actions to 2
hmmateimpedimenlsto fal X X
ousing.
omelessnessPrevention Track assisted individuals 0% of assisted individuals
ho retained their housing or nd households will retain
tilities for at lcast6 months eirhousing or utilitics for 14
D after assistance was t lcast6 months after X X
provided. ssistanceisprovided.
mergencyShelter Track individuals who 50% of
eceived support services .ndividllalslhouscholdsthat 12 or
that were linked to one or reprovidedvrithemcrgency
D ~additionalsupport helterwill transition to X X
serviceandlorappropriate .nterim housing (i.e., 13
ousmg. ransitionalhousing)
ransitionalHousing Track homeless individuals % of homeless individuals
who participated in articipatingintransitional 2
transitional housing program ousingprogram will be X X
D that were placed in laced in permanent housing.
lCrmanenthousing.
upportiveServices Track individuals who O%ofindividualslfamilies
:eceived SllppOrt services el:eiving SUPPOrl services
that were linked to one or ill be linked to one or more 2
D orc additional support dditionalsupportservice X X
serviceandlorappropriate ndlorapproprialehousing.
housing.
Exhibit A-I
Page I of 4
Fulf'dlment
illustrated by
Trackinl! HUD Ob' ective to be fulfilled HUD Outcomes to be fulrdled HUD Indicator
Suitable Creating Specific Outcome
Decent Availability/ Indicator #
Activity/Program Outcome Tracking Goal Living Housing Economic Accessibility Affordability Sustainabilit) (Please see page 4
Environment Jopportunitie of 4 for dcsc.)
ScniorScrvices LTrackassistedsenior I. 80% of assisted senior
citizens that remained itizcns will remain
D independenlforatlcastI 'ndcpendent for at least I X X 2
ear after services were ear aftcr services are
provided provided.
2, Trackseniol'5receiving .90%ofseniorsrccciving
rcfcrralsthatwerelinkedto referrals will be linkcd to thc 2
D the services sought. ServlCCSSOUght X X
!Owner-Occupied Number of owner,s assisted Physical safety and comfort
~ousingRehabilitation to rehabihtatc thelrprimary ill be improved for Low
rsidence forthc following ndModemteincome
mcomecalegones: ouseholds by improving
D -Extremely Low lncome omes to a lcvel that meets 9
-Very Low lncome FcxcccdsHUDhousing X X
-Moderate Income ualitystandards.
Special Needs Calegories
-Large Families
rnilElderlyServices Traek frail elderly O%offrailelderly
individuals that were linked individuals will be linked 10 2
D to Ihe services sought. the serviees sought X X
isabledScrvices Track disables persons upport independent living
!whose independcnt living for90%ofdisablcdpersons 2
D iwas supported by CIty funds. ssisted by City funds. X X
crviccsforMentallylll Track individuals assisted 100% of individuals assisted
with City resources that were ith City resources willbc
D providcdanenlrypoinlinlo rovidcd an entry point into
theregionalmentalheallh theregiona!mentalhealth X X 2
aresyslemandlinkedtoat are system and linkcd to llt
least one lldditional mental lellst one lldditional mental
ealthsupportiveservice. ealth supportive service,
ervices for Substance rack how many individullls 'rovidc entry into the
ddicted ith substance addiclion in egionalrecovcry systcm for
ere provided lln cntry into S individullls with
the regional recovery system ubstancc addietion and link
D and linked to additional hcm to additionlll services. 2
services. X X
".S-yeargolll to be
ehievedby FY 09/10
outhServices I, Trackimprovcmentin I. Forcducation-based
prc-tcst,post-testseores. rograms, improve pre-test 2
D ost-testscoresby50% X X
2. Tracknumbcrof 2,Provideopportunitiesfor
D individuals exposed to the xposure to the fine arts. X X 2
finellrts.
D 3. Trackchildrenlyouth 3,90%ofchildrenlyouth
seeking referrals that were seeking referrals will be X X 2
linkedtotheservicessoughl. linked to the services sought.
.ow-and Modcratc- Track program participanls 190010 of program participants
comeScrvices that were linked to services twill be linked to services 2
sought. sought. X X
D
Exhibit A-I
Page 2 of 4
Description of Outcome Tracking System:
Please describe your organization's outcome tracking system that will enable you to fulfill the outcome selected above.
Exhibit A-I
Page 3 of 4
Specific Outcome Indicators
2) Public service activities
Number of persons assisted:
. with new access to a service
. with improved access to a service
. where activity was used to meet a quality standard or measurably improved quality, report the number
that no longer only have access to substandard service
9) Owner occupied units rehabilitated or improved
Total number of units:
Number occupied by elderly
Number of units brought from substandard to standard condition (HQS or local code)
Number qualified as Energy Star
Number of units brought into compliance with lead safe housing rule (24 CFR part 35)
Number of units made accessible for persons with disabilities
12) Number of homeless persons given overnight shelter
13) Number of beds created in overnight shelter or other emergency housing
14) Homelessness Prevention
. Number of households that received emergency financial assistance to prevent
homelessness
. Number of households that received emergency legal assistance to prevent
homelessness
Exhibit A-I
Page 4 of 4
LIST ALL OTHER PROGRAM FUNDS THAT HAVE BEEN SECURED FOR 06-07
(Total Funds for Program must equal Total Program Budget above)
Source Amount
Santa Ana CDBG $ 205,000
Police De artment Funds $ 367,826
Total Funds for Program
Exhibit B
Page 1 of 1
$
572,826
2006-2007 Funded Personnel
.
Name of Organization:
Name of Program
Santa Ana Police Department
Helicopter Program
ADMINISTRATIVE STAFF
Position Title Annual Annual Total CDBG Funds % of time Of this time % of Total
Salary Benefits Compensation Requested for spent on percent of Compensation
this position funded time serving Eligible
nrOQram Santa Ana
Sergeant $ 157,000 $ 157,000 $ - 0%
$ - $ - 0%
$ - $ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
Total Amount Reauested $ -
Must equal amount indicated on Exhbit B
PROGRAM STAFF
Position Title Annual Annual Total CDBG Funds % of time Of this time % of Iota 1
Salary Benefits Compensation Requested for spent on percent of Compensation
this position funded time serving Eligible
orogram Santa Ana
$ - $ - 0%
$ - $ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
Total Amount Reauested $ -
Must equal amount indicated on Exhbit B
CONTRACTUAL/PROFESSIONAL SERVICES
Position Title Annual Annual Total CDBG Funds % of time Of this time % of Total
Contract Benefits Compensation Requested for spent on percent of Compensation
Amount this position funded time serving Eligible
nrovram Santa Ana
Patrol (ABLE) Contract $ 383,625 $ 383 625 $ 205,000 100% 100% 100%
$ - $ - 0%
$ - $ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
$ - 0%
Total Amount Reouested $ 205 000
Must equal amount indicated on Exhbit B
***Please note for personnel whose time is not directly traced to serving Santa Ana and instead a percentage is used please
confirm the percentage is accurate prior to requesting reimbursement.
Exhibit B-1
Page 1 of I
Certification Regarding Lobbying
Certification for Contracts. Grants, Loans, and Cooperative Agreements
The undersigned certifies, to the best of his or her knowledge and belief, that:
(I) No Federal appropriated funds have been paid or will be paid, by or on behalf of the
undersigned, to any person for influencing or attempting to influence an officer or
employee of any agency, a Member of Congress, an officer or employee of Congress, or
an employee of a Member of Congress in connection with the awarding of any Federal
contract, the making of any cooperative agreement, and the extension, continuation,
renewal, amendment, or modification of any Federal contact, grant, loan or cooperative
agreement.
(2) If any funds other than Federal appropriated funds have been paid or will be paid to
any person for influencing or attempting to influence an officer or employee of any
agency, a Member of Congress, an officer or employee of Congress, or an employee of a
Member of Congress in connection with this Federal contract, grant, loan, or cooperative
agreement, the undersigned shall complete and submit Standard Form-LLL, "Disclosure
Form to Report Lobbying," in accordance with its instructions.
(3) The undersigned shall require that the language of this certification be included in the
award documents for all subawards at all tiers (including subcontract, subgrants, and
contracts under grants, loans, and cooperative agreements) and that all subrecipients shall
certifY and disclose accordingly.
This certification is a material representation of fact upon which reliance was placed
when this transaction was made or entered into. Submission of this certification is a
prerequisite for making or entering into this transaction imposed by Section 1352, Title
31, U. S. Code. Any person who fails to file the required certification shall be subject to
a civil penalty of not less than $10,000 and not more than $100,000 for each such failure.
Grantee/Contactor Organization
Program Title
I .
~l I ~ l (,VA l.hAl \
'Name of CertifYing Officer
('" ~lA-L:~-
Signature
/-r~ uL
Date
EXHIBIT C
Page I of2
SUBRECIPIENT warrants the following:
I. SUBRECIPIENT will comply with Public Law 88-352, Title VI of the Civil Rights
Act of 1964 (42 U. S. C. section 2000 et seq.) and implementing regulation in 24 CFR
Part I.
2. No person in the United States shall on the ground of race, color, religion, national
origin, or sex, be excluded from participation in, or be denied the benefits of, or be
subjected to discrimination under any program or activity funded in whole or in part with
community development funds made available pursuant to the ACT.
3. All laborers and mechanics, employed by contractors or subcontractors in the
performance of construction work financed in whole or in part with community
development funds shall be paid wages at rates not less than those prevailing on similar
construction in the locality as determined in accordance with the Davis-Bacon Act, as
amended, 40 U. S. C. Sections 276 a 1-5, except for individuals who perform services for
which they volunteered; do not receive compensation for such services; or are paid
expenses, reasonable benefits, or a nominal fee for such services; and are not otherwise
employed at any time in construction work.
4. SUBRECIPIENT will comply with all Federal statutes applicable to projects funded
with community development funds, except that (a) SUBRECIPIENT does not assume
CITY'S environmental responsibilities described at 24 CFR 570.604; and (b)
SUB RECIPIENT does not assume CITY'S responsibility for initiating the review process
under Executive Order 12372.
EXHIBIT C
Page 2 of2