HomeMy WebLinkAbout21A - LOCAL BOARD CERTIFICATIONREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
APRIL 7, 2015
TITLE:
SUBMISSION OF LOCAL AREA
APPLICATION FOR INITIAL
DESIGNATION AND LOCAL BOARD
CERTIFICATION
{STRATEGIC PLAN NO. 2,4)
/ ItITY MANAG
RECOMMENDED ACTION
CLERK OF COUNCIL USE ONLY:
APPROVED
❑ As Recommended
❑ As Amended
❑ Ordinance on 1" Reading
❑ Ordinance on 2nd Reading
❑ Implementing Resolution
❑ Set Public Hearing For_
CONTINUED TO
FILE NUMBER
Approve submittal of an application for Initial Local Area Designation and Initial Local Board
Certification for Program Year 2015 -2017 under the Workforce Innovation Opportunity Act and
authorize the Mayor to sign as the Chief Local Elected Official.
WORKFORCE INVESTMENT BOARD RECOMMENDATION
At its regular meeting on March 19, 2015, by a vote of 15:0 (Didion, Elliot, Everett, Fischer,
Gonzalez, Jimenez -Hamy, Knitter, Korthuis, Martinez, Rutledge, and Wadhera absent absent),
the Workforce Investment Board recommended to:
Approve the application for Initial Local Area Designation and Initial Local Board
Certification for Program Year 2015 -2017 and authorize the Chair to sign.
Forward the Initial Local Area Designation and Initial Local Board Certification for Program
Year 2015 -2017 to City Council for approval and authorize signature of the Mayor.
DISCUSSION
On July 22, 2014, the Workforce Innovation Opportunity Act (WIOA), the first legislative reform of
the public workforce system in 15 years, was enacted. This landmark legislation was designed to
strengthen and improve the nations' public workforce system by helping workers acquire the
skills employers need and to provide businesses a skilled workforce necessary to compete in a
global economy.
For the next two complete program years following enactment, WIOA legislation directs the State
of California Governor to approve requests for initial designation of any area that was designated
under the Workforce Investment Act (WIA) as long as the local area has performed successfully
and has maintained fiscal integrity. After the initial two year designation period, continued
21A-1
Submission of Local Area Application For Initial
Designation and Local Board Certification
April 7, 2015
Page 2
designation will be contingent on the development and submission of a regional workforce
development plan addressing regional economic priorities and industry clusters as well as
continued meeting local performance measures.
The City of Santa Ana ( "City ") has met the conditions outlined in the Initial Designation of Local
Workforce Areas and Initial Certification of Local Boards application (Exhibit 1). Provided the
application is approved by Council at the April 7, 2015 City Council meeting, signatures from the
Workforce Investment Chair and the Mayor will be obtained and the fully signed application will
be submitted to the State by the June 30, 2015 deadline. Submitting the fully signed application
by the State's deadline will prevent the disruption of workforce programs and services while
transitioning to full implementation of WIOA,
Notification of approval or denial of the application will be
approved, the initial designation will be effective from Jul y
denied, the City may contest the decision through an appeal
STRATEGIC PLAN ALIGNMENT
sent to the City by May 10, 2015. If
1, 2015 through June 30, 2017. If
process.
Approval of this item supports the City's efforts to meet Goal #2 (Youth, Education, Recreation),
Objective #4 (Partner with groups and organizations to promote education, senior services, job
training and development for all Santa Ana residents).
FISCAL IMPACT
There is no fiscal impact associated with this action.
WL G(�/1�..� /(
Kelly Re d
Executh !rector
Community Development Agency
KR/DS /If /sb
Exhibits: 1. Application for Initial Local Workforce Area and
Initial Certification of Local Boards PY 2015 -16
2. Workforce Services Directive WSD 14 -10
21A-2
Existing Local Area
Application for Initial Local Area Designation
Program Years 2015 -17
and
Initial Local Board Certification
Program Year 2015 -16
Local Workforce Investment Area
SANTA ANA
Page 1 of 8
F.�i iB
Existing
Application for Initial
and Initial Local
Local Area
Local Area Designation
Board Certification
This application will serve as your request for Local Workforce Development Area (local
area) initial designation for Program Years (PYs) 2015 -17 and Local Workforce
Development Board (local board) initial certification for PY 2015 -16 under the Workforce
Innovation and Opportunity Act (WIOA).
If the California Workforce Investment Board determines the application is incomplete, it
will either be returned or held until the necessary documentation is submitted. Please
contact your Regional Advisor for technical assistance or questions related to
completing and submitting this application.
City of Santa Ana
Name of Local Area
1000 E. Santa Ana Blvd., Suite 200
Mailing Address
Santa Ana, CA 92701
City, State Zip
Date of Submission
Contact Person
Contact Person's Phone Number
Page 2 of 8
21A-4
Local Area Levels of Performance
Instructions: Enter your local area's negotiated levels of performance and actual levels
of performance for PYs 2012 -13 and 2013 -14.
Performance Table
Name of Local Area: City of Santa Ana
Common Measure
Negotiated
PY 2012 -13
Actual
PY 2012 -13
Negotiated
PY 2013 -14
Actual
PY 2013 -14
Adult
Entered Employment Rate
61.1%
72.0%
64.0%
77.6%
Employment Retention Rate
75.5%
79.9%
82.0%
78.9%
Average Earnings
$11,800
$10,811
$12,000
$12,164
Dislocated Worker
Entered Employment Rate
58.9%
60.2%
65.0%
70.8%
Employment Retention Rate
83.0%
91.1%
85.0%
85.5%
Average Earnings
$14,000
$15,166
$14,750
$14,376
Youth {ages 14-2ir
Placement in Employment or
Education
72%
82.4%
74.0%
72.0%
Attainment of a Degree or Certificate
60%
86.1%
65.0%
86.0%
Literacy and Numeracy Gains
54%
73.3%
67.0%
83.1%
*Note: For PY 2012 -13, each local area's youth performance goals were the same as the
State level goals.
Page 3 of 8
21A-5
Local Board Membership
Current Local Board Membership
Provide a list of individuals currently appointed to the local board and their respective
membership category (e.g., business, local education entity, labor organization, community
based organization, etc.) in the following chart (Workforce Investment Act [WIA] Section 117).
Or, attach a roster of the current local board which identifies each member's respective
membership category.
Name
Title
Membership Category
Caleb Everett
CEO
Private Sector
Bob Fischer
President, Owner
Private Sector
Marjorie Knitter
President
Private Sector
Patrick Korthuis
Owner
Private Sector
Greg Lewis
Partner
Private Sector
Lee McMurtray
VP Global Community Banking
Private Sector
Steve Pwinica
General Manager
Private Sector
Stacey Sanchez
Exec. Director
Private Sector
Andy Whadera
President
Private Sector
Dave Elliott
CEO
Private Sector
Bea Gonzalez
Store Manager
Private Sector
Darren Rutledge
General Manager
Private Sector
Ignacio Alegre
Rehab Supervisor
Department of Rehabilitation
Gilbert Davila
Organizing Rep
Labor
John Didion
Exec. Vice Chancellor
Carl Perkins, Applied Tec. ED Act
Ana Jimenez -Hami
Executive Director
CBO - Disabilities
Brent Beasley
Business Manager
Labor
Carlos de la Riva
One Stop Director
WIA Title I; HUD
Willia Edmonds
Job Developer
CBO — Disabilities, Training and Employ.
Erlinda Martinez
President
Education, Adult Ed., WIA Title II
Clarence Ray
Executive Director
CDBG — Employ. And Training
Bob Tucker
Labor Relations Rep
Labor
Rob Claudio
Deputy Division Manager
Wagner Peyser, TAA, Veterans, YEOP
Lee de Leon
CEO
CBO
Nathan Nishimoto
Director Family Self Suffic.Div
TANF; Programs under Sec 403(a)(5)
Robert Ruiz
Secretary Treasurer
Labor
Plan for WIOA Local Board Compliance
Identify the actions the local chief elected official (CEO) will take in order to ensure
WIOA local board membership compliance by June 30, 2016.
Santa Ana WIB is currently discussing changes to its board structure, membership composition
and committee structure. Recommendations are anticipated to be forwarded to the chief
elected official and city council for consideration and adoption in June 2015.
Page 4 of 8
21A-6
Sustained Fiscal Integrity
The local area hereby certifies that it has not been found in violation of one or more of
the following during PYs 2012 -13 or 2013 -14:
• Final determination of significant finding(s) from audits, evaluations, or other
reviews conducted by State or local governmental agencies or the Department of
Labor identifying issues of fiscal integrity or misexpended funds due to the willful
disregard or failure to comply with any WIA requirement, such as failure to grant
priority of service or verify participant eligibility; or
• Gross negligence - defined as a conscious and voluntary disregard of the need to
use reasonable care, which is likely to cause foreseeable grave injury or harm to
persons, property, or both; or
• Failure to observe accepted standards of administration. Local areas must have
adhered to the applicable uniform administrative requirements set forth in Title 29
Code of Federal Regulations (CFR) Parts 95 and 97, appropriate Office of
Management and Budget circulars or rules, WIA regulations, and State guidance.
Highlights of these responsibilities include:
o Timely reporting of WIA participant and expenditure data
o Timely completion and submission of the required annual single audit
o Have not been placed on cash hold for longer than 30 days
(In alignment with WIOA Section 106[e][2])
Page 5 of 8
21A-7
Local Area Assurances
Through PY 2016 -17, the local area assures that:
A. It will comply with the applicable uniform administrative requirements, cost
principles, and audit requirements included in the appropriate circulars or rules of the
Office of Management and Budget (WIOA Section 184[a][2] and [3]).
Highlights of this assurance include:
• The local area's procurement procedures will avoid acquisition of
unnecessary or duplicative items, software, and subscriptions (in
alignment with Title 2 CFR Section 200.318).
• The local area will maintain and provide accounting and program records,
including supporting source documentation, to auditors at all levels, as
permitted by law (Title 2 CFR Section 200.508).
Note that failure to comply with the audit requirements specified in Title 2 CFR Part
200 Subpart F will subject the local area to potential cash hold (Title 2 CFR Section
200.338).
B. All financial reporting will be done in compliance with federal and State regulations
and guidance.
Highlights of this assurance include:
• Reporting will be done in compliance with Workforce Services Directive
WSD12 -3, Quarterly and Monthly Financial Reporting Requirements.
• All close out reports will comply with the policies and procedures listed in
Workforce Services Directive WSD09 -12, WIA Closeout Handbook.
Note that failure to comply with financial reporting requirements will subject the local
area to potential cash hold. (Title 2 CFR Section 200.338)
C. Funds will be spent in accordance with federal and State laws, regulations, and
guidance.
Highlights of this assurance include
• The local area will meet the requirements of State Senate Bill 734, to spend a
minimum of 25 percent of combined total of adult and dislocated worker formula
fund allocations on training services (California Unemployment Insurance Code
Section, 14211).
• The local area will not use funds to assist, promote, or deter union organizing
(WIOASection 181[b][7]).
Page 6 of 8
21A-8
D. The local board will select the America's Job Center of Californiasm (AJCC)
Operator(s), with the agreement of the local CEO, through a competitive process
such as a Request for Proposal (RFP), unless granted a waiver by the state (WIOA
Section 121 [d][2][A] and 107[g][2]).
E. The local board will collect, enter, and maintain data related to yarticipant
enrollment, activities, and performance necessary to meet all CaIJOBSs reporting
requirements and deadlines.
F. The local board will comply with the nondiscrimination provisions of WIOA Section
188, including the collection of necessary data.
G. It will comply with State Board policies and guidelines, legislative mandates and /or
other special provisions as may be required under federal law or policy, including the
WIOA or state legislation.
H. Priority shall be given to veterans, recipients of public assistance, other low- income
individuals, and individuals who are basic skills deficient for receipt of career and
training services funded by WIOA Adult funding (WIOA Section 134[c][3][E] and
Training and Employment Guidance Letter 10 -09).
Page 7 of 8
21A-9
Application Signature Page
Instructions: The local CEO and local board chair must sign and date this form.
Include the original signatures in the application package.
By signing the application below, the local CEO and local board chair request initial
designation of the existing local area and initial certification of the existing local board.
They certify that the local area has performed successfully and sustained fiscal integrity
during PYs 2012 -13 and 2013 -14. Additionally, they agree to abide by the local area
assurances included in this application.
Local Workforce Investment Board Chair
Signature
Lee Mc Murtray
Name
Chair, Santa Ana WIB
Title
Date
Page 8 of 8
21A -10
Local Chief Elected Official
Signature
Miguel Pulido
Name
Mayor, City of Santa Ana
Title
Date
E ®Dl� Employment C/'+T C
Department DIRGIj 1 I�G
State o f California WORKFORCE SERVICES Number: WSD14 -10
Date: February 20, 2015
69:01:df:17276
TO: WORKFORCE DEVELOPMENT COMMUNITY
SUBJECT: INITIAL LOCAL AREA DESIGNATION AND LOCAL BOARD
CERTIFICATION UNDER WIOA
EXECUTIVE SUMMARY
Purpose
This directive communicates policy and procedures regarding the initial designation of
Local Workforce Development Areas (local areas) and the initial certification of Local
Workforce Development Boards (local boards) under the Workforce Innovation and
Opportunity Act (WIOA).
Scope
This directive applies to all current local areas interested in receiving designation and
local board certification under the new WIOA.
Effective Date
This directive is effective on the date of its issuance.
REFERENCES
• WIOA (Public Law 113 -128) Sections 106 and 107
• Workforce Investment Act (WIA) Section 116
• Title 2 Code of Federal Regulations (CFR) Chapter I, Chapter ll, Part 200, et al.,
"Uniform Administrative Requirements, Cost Principles, and Audit Requirements
for Federal Awards ;" Final Rule (Uniform Guidance)
• Title 2 CFR Part 2900 et al., "Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards" (Uniform Guidance)
• Title 29 CFR Part 95: "Grants and Agreements with Institutions of Higher
Education, Hospitals, and Other Non - Profit Organizations"
The EDD is an equal opportunity employer /program. Auxiliary aids and services are available upon request to individuals with disabilities.
.ca.gov
Page 1 of 72
L "I IBI� "I
• Title 29 CFR Part 97: "Uniform Administrative Requirements for Grants and
Cooperative Agreements to State and Local Governments"
• Title 20 CFR Part 652 et. al: WIA; Final Rules
• California Unemployment Insurance Code Section 14202(c)
• Workforce Services Directive WSD12 -14, Subject: Program Year (PY) 2013 -17
Local Plans and Board Certification (Biennial and High Performing) (May 22,
2013)
• WIA Directive WIAD06 -10, Subject: Local Area Nonperformance Policy
(November 14, 2006)
• WIA Directive WIAD02 -6, Subject: Subsequent Designation of Temporary and
State Board Recommended Local Areas (September 18, 2002)
• Workforce Services Information Notice WSIN12 -62, Subject: Late Monthly,
Quarterly, Closeout, Audit and Participant Reports (May 23, 2013)
STATE - IMPOSED REQUIREMENTS
This directive contains some State - imposed requirements. These requirements are
indicated by bold, italic type.
FILING INSTRUCTIONS
This directive finalizes Workforce Services Draft Directive WSDD -111, issued for
comment on January 16, 2015. The Workforce Services Division received 61 comments
during the draft comment period. These comments resulted in substantive changes to
the directive which can be viewed as highlighted text. The highlighted text will remain
on the Internet for 30 days from the issuance date. A summary of the comments is
provided as Attachment 3. Retain this directive until further notice.
BACKGROUND
The WIOA Sections 106 and 107 provide the criteria for the initial designation of local
areas and initial certification of local boards. Specifically, the WIOA Section 106
requires the Governor to designate local areas within the state, while Section 107
requires the Governor to certify one local board for each local area in the state. The
California Workforce Investment Board (State Board) and the Employment
Development Department (EDD), acting under the authority of the Governor, have
established policies and procedures within this directive for the initial designation of
local areas and the initial certification of local boards. These policies are intended to
provide maximum flexibility to local areas so they may have sufficient time to prepare
for and fully comply with the new WIOA requirements for subsequent local area
designation and local board recertification.
Page 2 of 7
21A -12
POLICY AND PROCEDURES
Initial Local Area Designation
As stated in WIOA Section 106, the Governor shall approve a request made for initial
designation by any local area if the area did the following during PYs 2012 -13 and
2013 -14:
• Was designated as a local area under WIA
• Performed successfully
• Sustained fiscal integrity
Initial designation is effective July 1, 2015, through June 30, 2017. Local areas
must apply for initial designation using the process included in this directive.
Local areas that would like to modify their current geographical boundaries are
eligible to apply under their new structure.
Subsequent designation will be effective July 1, 2017. Local areas should be
planning and preparing to meet the WIOA requirements for subsequent designation
(i.e., perform successfully, sustain fiscal integrity, and in the case of a local area in a
planning region, meet the regional planning requirements in WIOA Section 106[c][1])
during the initial designation period. Additionally, local areas should be preparing to
meet the new Office of Management and Budget (OMB) and Department of Labor
Uniform Guidance in 2 CFR 200 and 2 CFR 2900, which applies to new awards and
additional funding (funding increments) to existing awards made after December 26,
2014 (i.e., the youth allocations beginning April 1, 2015, and all subsequent
allocations).
Local areas will be expected to develop new services, enter new collaborative
partnerships, and /or create innovative workforce development strategies in alignment
with WIOA during the initial designation period. The EDD and the State Board will
provide technical assistance and guidance to local boards implementing WIOA activities
and assess the extent to which local boards are designing a better system for
customers. The assessment of local performance goals during the initial designation
period will consider the extent to which local boards implement WIOA, and the potential
impact on customer outcomes. During local area performance negotiations, the State
Board will work with local boards who undertake activities that result in new services,
partnerships, and /or service redesign or other WIOA transitional activities to ensure that
local areas have the opportunity to set goals that enable them to perform successfully.
Definitions
Performed Successfully - a local area has achieved at least 80 percent of their local
performance goal on each performance measure for PYs 2012 -13 and 2013 -14. (WIOA
Section 106[e][1]).
The state has provided the following flexibility to the definition of performed
successfully, for purposes of initial local area designation only. This flexibility is in
Page 3 of 7
21A -13
alignment with WIA Directive WIA06 -10 and the local board recertification criteria in
Workforce Services Directive WSD12 -14.
A local area is still eligible for initial designation if it achieved at least 80 percent
of its local performance goal on seven or more of the performance measures
during either PY 2012 -13 or PY 2013 -14. To remain eligible, the local area must
attach a Corrective Action and Technical Assistance Plan (as required in WIA
Directive WIAD06 -10) to its initial local area designation and initial local board
certification application.
A local area is ineligible for initial designation if it did not achieve at least 80
percent of its local performance goal on two or more performance measures
during both PY 2012 -13 and 2013 -14.
Sustained fiscal integrity — the local area has not been found in violation of one or more
of the following during PYs 2012 -13 or 2013 -14:
Final determination of significant finding(s) from audits, evaluations, or other
reviews conducted by state or local governmental agencies or the Department of
Labor identifying issues of fiscal integrity or misexpended funds due to the willful
disregard or failure to comply with any WIA requirement, such as failure to grant
priority of service or verify participant eligibility.
Gross Negligence - defined as a conscious and voluntary disregard for the need
to use reasonable care, which is likely to cause foreseeable grave injury or harm
to persons, property, or both.
Failure to observe accepted standards of administration. Local areas must have
adhered to the applicable uniform administrative requirements set forth in Title
29 CFR Parts 95 and 97, appropriate Office of Management and Budget
circulars or rules, WIA regulations, and state guidance. Highlights of these
responsibilities include the following:
• Timely reporting of WIA participant and expenditure data
• Timely completion and submission of the required annual single audit
• Have not been placed on cash hold for longer than 30 days
(In alignment with WIOA Section 106[e][2])
Existing Local Area — A local area that was designated as a local area under WIA.
Modified Local Area — A local area that is considering local area modification as part of
its initial designation application. Examples include the following: two areas proposing
to merge into a new combined single local area, various local areas that will be
combined in a new single local area, or a local area that will be expanded to include
part or parts of another current local area.
Page 4 of 7
21A -14
Initial Local Area Designation Application Process
The local Chief Elected Official (CEO) must follow the applicable process included
below in order to request initial designation:
• Existing Local Areas
Complete the Existing Local Area - Application for Initial Local Area Designation
and Initial Local Board Certification Program Year 2015 -16 (Attachment 1).
For local areas that are requesting local area modification as part of their initial
designation, complete the Modified Local Area - Application for Initial Local Area
Designation and Initial Local Board Certification Program Year 2015 -16
(Attachment 2).
The local CEO must submit the completed application to the State Board no later than
5:00 p.m., March 31, 2015, by one of the following methods:
Mail California Workforce Investment Board
P.O. Box 826880
Sacramento, CA 94280 -0001
Courier California Workforce Investment Board
800 Capitol Mall, Suite 1022
Sacramento CA 95814
Hand Deliver California Workforce Investment Board
800 Capitol Mall, Suite 1022
Sacramento CA 95814
Note the following: Some local areas may be unable to obtain local approval by the
submission deadline (e.g., due to the scheduling of their respective board meetings). If
so, the local area may submit an unsigned copy of the application with an explanation
for the absent signature(s) and the date by which the signed original will be sent. The
signed application must be submitted to the State Board by June 30, 2015. Failure to
meet this deadline will result in the local area not receiving full initial designation status
until a signed application is received.
Assessment of the Application
The State Board, in coordination with EDD, will verify the information provided in the
application once a completed application is received. The State Board will consider all
information provided, and determine whether to recommend approval or denial of the
application at its spring 2015 meeting.
The local CEO will be notified in writing by May 10, 2015, regarding the approval or
denial of its initial designation application. If approved, the initial designation will be
Page 5 of 7
21A -15
effective July 1, 2015, through June 30, 2017. If denied, the local CEO may contest the
decision using the appeal process below.
Appeal Process for Initial Designation
A unit of local government (or combination of units) which has requested and been
denied initial designation as a local area under WIOA may appeal the denial to the
State Board, in accordance with WIOA Section 106.
An entity which has been denied initial designation may appeal the decision and
request a hearing. An appeal and request for hearing must be mailed to the State Board
within 20 calendar days from the mailing date of the notice of denial of initial
designation. The appeal must (1) be in writing and state the grounds for the appeal, and
(2) state the reasons why the appellant should be initially designated.
The State Board will contact the appellant to schedule a hearing date within five
calendar days of the receipt of the appeal. The State Board will conduct the appeal
hearing process and provide a written decision to the appellant no later than five
calendar days after the hearing.
Appeal of State Board Decision
A unit or combination of units of general government whose appeal has not resulted in
designation as a local area may also appeal the denial to the Department of Labor.
(WIOA Section[b][5])
Initial Local Board Certification
The WIOA Section 107 requires the Governor to certify one local board for each local
area in the state. Local boards will be initially certified as follows, in order to provide
local areas an opportunity to restructure their local boards in accordance with WIOA
requirements:
• Local Boards within Existing Local Areas
Complete the Existing Local Area - Application for Initial Local Area Designation
and Initial Local Board Certification Program Year 2015 -16 (Attachment 1). Note
that this application is used for both initial local area designation and initial local
board certification.
The existing local board will be automatically initially certified through PY
2015 -16 upon approval of initial designation of a local area.
• Local Boards for Local Areas requesting designation as new. modified, Local Areas
Complete the Modified Local Area - Application for Initial Local Area Designation
and Initial Local Board Certification Program Year 2015 -16 (Attachment 2). Note
that this application is used for both initial local area designation and initial local
board certification.
Page 6 of 7
21A -16
The local CEO will be notified in writing by May 10, 2015, regarding the approval
or denial of its initial local board certification.
Initial local board certification will be effective July 1, 2015, through June 30,
2016.
Local board recertification will be effective July 1, 2016. Therefore, local boards will
be expected to complete all necessary tasks to meet the local board recertification
requirements during the initial certification period. These recertification requirements
will include the recertification criteria under WIOA (i.e., meet WIOA local board
membership requirements, meet or exceed performance requirements, and sustain
fiscal integrity), and an assessment of the local board's progress on key WIOA
implementation tasks (e.g., new youth service requirements, procurement of one -stop
operators unless granted an exemption under WIOA Section 107[g][2]). The
assessment of local performance goals during the certification period will consider the
extent to which local boards implement WIOA, and the potential impact on local
performance levels.
ACTION
Please bring this directive to the attention of the local CEO, local board, and other
relevant parties.
INQUIRIES
Contact your assigned Regional Advisor if you have questions concerning this directive.
/S/ JOSE LUIS MARQUEZ, Chief
Central Office Workforce Services Division
Attachments are available on the Internet:
1. Existing Local Area - Application for Initial Local Area Designation and Initial
Local Board Certification Program Year 2015 -16
2. Modified Local Area - Application for Initial Local Area Designation and Initial
Local Board Certification Program Year 2015 -16
3. Summary of Comments
Page 7 of 7
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21A -18