HomeMy WebLinkAbout2227 2019 MOA for Orlando/Orange Urban Area Security Initiative (UASI)CITY OF
S.kNFORD
;,'
FLORIDA
(SANF'ORD POLICE DEPARTMENT)
T'RANSMITT'AL MEMORANDUM
r,0: City Clerk
t;: Request for Services
The item(s) noted below is/are attached and forwarded to your office for the following action(s):
❑
Development Order
❑
Mayor's signature
❑
Final Plat (original mylars)
❑
Recording
❑
Letter of Credit
❑
Rendering
❑
Maintenance Bond
®
Safe keeping (Vault)
❑
Ordinance
❑
❑
Performance Bond
❑
Resolution
®
2019 Memorandum of Agreement for Participating
Orlando/Orange Urban Area Security
Initiative (UASI) Agencies
Once completed, please:
❑ Return original
❑ Return copy
® Maintain the fully executed copy on file.
Special Instructions:
Please advise if you have any questions regarding the above.
Thank you!
g ani 2Uoe& 06.15.20
From Date
2019 MEMORANDUM OF AGREEMENT (MOA)
FOR PARTICIPATING ORLANDO/ORANGE
URBAN AREA SECURITY INITIATIVE (UASI) AGENCIES
This Agreement is entered into this 30 day of December, 2019, by and between the Orange County
Sheriffs Office (OCSO), a political subdivision of the State of Florida, (the "Recipient") and Orange,
Seminole, Lake, and Osceola Counties, political subdivisions of the State of Florida; all other
participating counties and cities (listed in the attached appendices) of the State of Florida, collectively
known as the "Orlando/Orange Urban Area (O/OUA) Participants."
RECITALS
WHEREAS, the State of Florida, Division of Emergency Management (FDEM) (hereinafter referred to
as the "Division") is providing financial assistance to the O/OUA in the amount $3,087,500.00 dollars
($3,250,000.00 less the 5% State Management and Administration) through the FY 2019 Urban Area
Security Initiative (UASI); and
WHEREAS, the OCSO is the Recipient for the O/OUA UASI Grant Program; and
WHEREAS, as the Division requires that the urban areas selected for funding take a regional
metropolitan area approach to the development and implementation of the UASI Grant Program and
involve core cities, core counties, contiguous jurisdictions, mutual aid partners, and State agencies; and
WHEREAS, the Urban Area has been defined as the City of Orlando, Orange, Seminole, Lake, and
Osceola Counties; and
WHEREAS, the OCSO wishes to work with the O/OUA Participants through the Urban Area Working
Group process to enhance the O/OUA and its surrounding jurisdiction's ability to prevent, protect
against, respond to, and recover from acts of terrorism, or any other manmade or natural disaster;
WHEREAS, on or about the 30 of December, 2019, the OCSO entered into an agreement with the State
of Florida, Division of Emergency Management (hereinafter to as the "Division") for a Federally Funded
Sub grant Agreement, #R0024; CFDA Number 97.067.
NOW THEREFORE, in consideration of the foregoing, the parties here to agree as follow:
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2019 UASI GRANT
I. PURPOSE
A. This Agreement delineates responsibilities of the OCSO and the O/OUA Participants for
activities under the FY 2019 UASI Grant Program, by the Division.
B. This Agreement serves as the Scope of Work among all Participants and the OCSO.
II. SCOPE
A. The provisions of this Agreement apply to FY 2019 UASI activities to be performed at the
request of the Division, provided at the option of the OCSO, and in conjunction with,
preparation for, or in anticipation of, a major disaster or emergency related to terrorism and or
weapons of mass destruction.
B. No provision in this Agreement limits the activities of the Urban Area Working Group or its
Recipient Agency in performing local and state functions.
Ill. DEFINITIONS
A. Critical Infrastructure: Any system or asset that if attacked would result in catastrophic loss of
life and/or catastrophic economic loss management of resources (including systems for
classifying types of resources); qualifications and certification; and the collection, tracking, and
reporting of incident information and incident resources.
B. Core City: A city at the center of a metropolitan area.
C. Core County: The county within which the core city is geographically located.
D. Urban Area Security Initiative (UASI) Grant Program: The UASI Grant Program is intended to
provide financial assistance to address the unique multi -discipline planning, organization,
equipment, training, and exercise needs of high -threat, high-density Urban Areas, and to
assist these Areas in building and sustaining capabilities to prevent, protect against, respond
to, and recover from threats or acts of terrorism, all hazards or man-made disasters.
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2019 UAS! GRANT
E. National Incident Management System (NIMS): The NIMS provides a consistent nationwide
template to enable all levels of government, tribal nations, non-governmental organizations,
and private sector partners to work together to prevent, protect against, respond to, recover
from, and mitigate the effects of incidents, regardless of cause, size, location, or complexity.
F. Urban Area Working Group (UAWG): The UAWG is responsible for coordinating the
development and implementation of all program initiatives. The UAWG may also support the
State's efforts to develop the Stakeholder Preparedness Review, particularly as it relates to
UASI activities.
G. Orlando/Orange Urban Area (O/OUA) Administrator: The (O/OUA) Administrator shall be the
Orange County Sheriffs Office.
H. Urban Area: An Urban Area is limited to inclusion of jurisdictions contiguous to the core city
and county/counties, or with which the core city or county/counties have established formal
mutual aid agreements.
I. Stakeholder Preparedness Review (SPR): The SPR is a self-assessment of a jurisdiction's
current capability levels against the targets identified in the Threat and Hazard Identification
and Risk Assessment (THIRA).
J. Threat and Hazard Identification and Risk Assessment (THIRA): The THIRA is a three-step
risk assessment process to help communities understand their risks and determine the level of
capability they need in order to address those risks. The outputs form this process lay the
foundation for determining a community's capability gaps as part of the SPR.
K. Florida Division of Emergency Management (FDEM): The non -Federal pass-through entity
that provides a subaward to a sub -recipient to carry out part of a Federal program.
IV. OCSO SHALL BE RESPONSIBLE FOR:
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2019 UASI GRANT
A. Providing an administrative department within the OCSO, authorization to carry out the herein
agreed upon responsibilities of this Memorandum of Agreement (MOA).
B. Ensuring the participation of the following critical stakeholders in the UASI THIRA, UASI SPR,
and strategy development process: law enforcement, emergency medical services, emergency
management, the fire service, hazardous materials, public works, governmental administrative,
public safety communications, healthcare and public health.
C. Complying with the requirements of the 2 CFR Chapter 1, Chapter 11, Part 200, et al. Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Link: https.-//w_wW.egfr.qov/cqi-
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D. Ensuring satisfactory progress toward the goals or objectives set forth in the grant application.
E. Complying with all grant agreement requirements and/or special conditions.
F. Submitting required programmatic and financial reports.
V. THE O1OUA PARTICIPANTS SHALL BE RESPONSIBLE FOR:
A. Providing personnel who will act as the main liaison (the project manager) and partner with the
OCSO, authorized to carry out the herein agreed upon responsibilities of the MOA.
B. Tracking of their grant purchased federally funded assets via their respective internal inventory
control system and attach the provided 2019 UASI inventory tag to 2019 UASI grant
purchased equipment. Note: For reconciliation purposes, OCSO as Recipient will maintain
and manage a grant -wide database for all federally funded assets purchased under this
contract.
C. Submitting budget detail worksheets to include approved modifications for direct purchases of
equipment or services.
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2019 UASI GRANT
D. Ensure deliverables and performance are followed on Attachment B when developing and
providing quotes for allowable expenditures to OCSO.
E. Fallow Environmental Planning & Historic Preservation (EHP) compliance guidelines on
Attachment C, if the project requires an EHP.
F. Participating as a member of the UAWG to include coordinating with and assisting the O/OUA
in conducting a UASI SPR and UASI THIRA, which in turn, will guide development of an Urban
Area Homeland Security Strategy.
G. Ensuring and assisting the participation of the following critical stakeholders in the UASI SPR
and UASI THIRA and updating of the O/OUA strategies: law enforcement, emergency medical
services, emergency management, the fire service, hazardous materials, public works,
governmental administrative, public safety communications, healthcare and public health.
H. The OCSO and O/OUA participants shall be governed by applicable State and Federal laws,
rules and regulations, including those program statutes and regulations identified and outlined
in Attachment D.
I. Ensuring satisfactory progress toward the goals or objectives set forth in the grant application.
J. Following UASI Grant Project agreement requirements and/or special conditions as provided
in the FDEM agreement.
K. Ensure that equipment obtained from the UASI Grant Program is readily available for use by
personnel trained to use such equipment for actual emergencies or exercises. Also, ensure
that such equipment is readily available for onsite monitoring by DHS/FEMA, FDENE, and the
O/OUA. If the agency is incapable of staffing the equipment, such equipment shall be made
available to another partnering agency for use during any actual emergencies or exercises.
Failure to ensure equipment availability may result in loss of funding and/or equipment to the
partner agency.
L. All equipment obtained from the UASI Grant Program is the sole responsibility of the receiving
agency. This includes, where applicable, maintenance, replacement, training on equipment,
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2019 UASI GRANT
and insuring of equipment and personnel, and compliance with intra -agency auditing
requirements.
M. Take affirmative steps to assure that small and minority businesses, women's business
enterprises, and labor surplus area firms are used whenever possible. Relevant Vendor
Listing Link: hft ://dsbs.sba.ciov/dsbs/searctL/dsp dsbs.cfm
N. Ensuring required NIMS Awareness Course(s) is/are completed by relevant personnel.
O. Providing a signed document recognizing NIMS in principle and policy.
Vi. THE OCSO AND THE OIOUA PARTICIPANTS AGREE:
A. That funding acquired and identified for the UASI will be administered solely by the OCSO.
B. The OCSO is not responsible for personnel salaries, benefits, workers compensation or time
related issues of any participating agency personnel.
C. OCSO and all other Participants are subdivisions as defined in Chapter 768.28, Florida
Statutes, and each agree to be fully responsible for their respective acts and/or omissions of
its agents or employees to the extent permitted by law. Nothing herein is intended to serve as
a waiver of sovereign immunity by any participant to whom sovereign immunity may be
applicable. Nothing herein shall be construed as consent by a state agency or subdivision of
the State of Florida to be sued by third parties in any manner arising out of this Agreement or
any other contract.
D. For the purposes of executing the conditions established in this MOA, each Participating
Agency's point of contact (POC) will be designated by each County or City in accordance with
their internal policies and procedures. The OCSO or designees will remain the UASI POC.
(See Appendix A)
E. In the event the Division determines that any funds disbursed were not spent in accordance
with the conditions of the UASI Grant Agreement, the Agency that procured the item(s) in
question shall be held liable for reimbursement to the OCSO of all such funds not spent in
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2019 UASI GRANT
accordance with these applicable regulations and agreement provisions within thirty (30) days
after notifications of said non-compliance. Notwithstanding the above, no funds shall be
directly provided to O/OUA participants under this Agreement. I
VII. AUDITS
A. The OCSO and O/OUA participants shall comply with the audit requirement contained in 2
CFR Part 200, Subpart F.
B. OCSO shall follow Generally Accepted Accounting Principles (GAAP), as defined by 2 CFR
§200.49.
C. When conducting an audit of the OCSO performance under the OCSO and FDEM agreement,
FDEM shall use Generally Accepted Government Auditing Standards (GAGAS), as defined by
2 CFR §200.50.
VIII. RECORDS
A. As required by 2 C.F.R. §200.336, the Federal awarding agency, Inspectors General,
the Comptroller General of the United States, and the Division, or any of their authorized
representatives, shall enjoy the right of access to any documents, papers, or other records of
the OCSO and O/OUA participants which are pertinent to the Federal award, in order to make
audits, examinations, excerpts, and transcripts. The right of access is not limited to the
required retention period but lasts as long as the records are retained. The O/OUA
participants will also give the OCSO or the Comptroller General, through any authorized
representative, access to and the right to examine all records, books, papers or documents
related to the grant.
IX REPORTS
A. Programmatic status reports are due within fifteen (15) days after the end of each calendar
quarter. The O/OUA PARTICIPANTS (program manager) must submit a programmatic status
report before the fifteen (15) days after the end of each calendar quarter.
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2019 UASI GRANT
B. All financial commitments herein are made subject to the availability of funds and the
continued mutual agreements of the participants.
X. CONDITIONS, AMENDMENTS, AND TERMINATION
A. The O/OUA PARTICIPANTS will not illegally discriminate against any employee or applicant
for employment on the grounds of race, color, religion, sex, age, or national origin in fulfilling any
and all obligations under this Agreement.
B. Any provision of this Agreement later found to be in conflict with Federal law or regulation, or
invalidated by a court of competent jurisdiction, shall be considered inoperable and/or superseded
by that law or regulation. Any provision found inoperable is severable from this Agreement, and
the remainder of the Agreement shall remain in full force and effect.
C. This Agreement may be modified or amended only in writing and approval by all the O/OUA
PARTICIPANTS.
D. This Agreement may be terminated by any O/OUA PARTICIPANTS on thirty (30) days written
notice to the OCSO and the return of any and all equipment that has been received through the
UASI Funding program.
E. This Agreement shall be considered the full and complete agreement between the
undersigned parties, and shall supersede any prior MOA among the OIOUA PARTICIPANTS,
written or oral, except for any executor obligations that have not been fulfilled.
F. This Agreement may be executed in several parts, each of which shall be considered a valid
MOA, provided that each of the O/OUA PARTICIPANTS to the Agreement has executed at least
one (1) original copy of the Agreement and has transmitted copy of the signature page hereof to
the other O/OUA PARTICIPANTS.
G. This Agreement will end at the conclusion of the stated grant performance period of March 31,
2021.
H. Subcontracts: If the O/OUA PARTICIPANTS subcontracts any of the work required under this
Agreement, a copy of the unsigned subcontract must be forwarded to the Division for review and
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2019 UASI GRANT
approval before it is executed by the Recipient. The OIOUA PARTICIPANTS agrees to include in
the subcontract that (i) the subcontractor is bound by the terms of this Agreement, (ii) the
subcontractor is bound by all applicable state and federal laws and regulations, and (iii) the
subcontractor shall hold the Division, OCSO, and O/OUA PARTICIPANTS harmless against all
claims of whatever nature arising out of the subcontractor's performance of work under this
Agreement, to the extent allowed and required by law. The O/OUA PARTICIPANTS shall
document in the quarterly report the subcontractor's progress in performing its work under this
Agreement.
For each subcontract, the O/OUA PARTICIPANTS shall provide a written statement to the
Division as to whether that subcontractor is a minority business enterprise, as defined in 2 CFR
§200.321.
e RFCIPIENT
zco
BY: �O —
JOHN W. MINA
SHERIFF OF ORANGE COUNTY, FLORIDA
DATE:
APPROVED AS TO FORM AND LEGALITY
FOR THE RELIANCE OF THE SHERIFF OF
NGE COUNTY, FLORIDA
BY: A'sVz 9- .)R —,-?el
CIPIENT ATTORNEY
Page 9 of 34
2019 UASI GRANT
ORANGE COUNTY, FLORIDA
By: Orange County Board of County Commissioners
0111
By:
Jerry L. Demings
Orange County Mayor
Date: MAY 0 5 2020
ATTEST: Phil Diamond, CPA, County Comptroller
As Clerk of the Board of County Commissioners
By: 1(a<Ad—
Deputy Clerk
Signature page for Orange County, Florida
Pop 10 of 34
2019 UASI GRANT
ATTEST:
�25MMIRM15 WWAS-611AIL04
Typed Name: Denise Aldridge
Title: City Clerk
M7
Typed Name: Orlando Rol6n
Title: Chief of Police
Signature page for The City of Orlando
PARTICIPATING AGENCY
The City of Orlando, A Municipal
Corporation of the State of Florida
0
Typed Name: Buddy Dyer V
Title: Mayor
APPROVED AS TO FORM AND LEGALITY
Aw'&tN"Wvt
Participating Agency Attorhh "
Page 11 of 34
2019 UASI GRANT
PARTICIPATING AGENCY
The City of Daytona Beach, a Municipal
Corporation of the State of Florida
.w
ATTEST.
i
YL. gy
Typed Name:'Typed Name: JCfe @`. ht a l
Title: (IA -U 4 Title: ,
APPROVED AS TO FORM AND LEGALITY
-FaMicipating g n y Attorney
Signature page for The City of Daytona Beach
Page 12 of 34
2019 UASI GRANT
PARTICIPATING AGENCY
Lake County Sheriff's Office,
A Political Subdivision of the State of
Florida
ATTEST:
A
1 By:
Typed Name:
-�QAtr*% J Typed Name:
Title: Title:
AS TO FORM AND LEGALITY
Do-eq-tc A. S ctt,dfti
Participating Agency Attorney
Signature page for Lake County Sheriffs Office
Page 13 of 34
2019 UASI GRANT
2019 MEMORANDUM OF AGREEMENT (MOA)
FOR PARTICIPATING ORLANDO/ORANGE
URBAN AREA SECURITY INITIATIVE (UASI) AGENCIES
PARTICIPATING AGENCY
Lake County BCC, a Political
Subdivision of the State of Florida
BOARD OF COUNTY COMMISSIONERS
LAKE COUNTY, FLORIDA
Leslie Campion, Chairman
. t
'r—rtll —1(4, -e-
This �V- '
, ) day of 2020
ATTEST:
Gary T
ney, Cler�Boar,JCounty C
n
of Lake County, Florida
Approved as to form and legality:
Melanie Marsh
County Attorney
Signature page for Lake County BCC
Pan 14 of 34
2019 UASI GRANT
PARTICIPATING AGENCY
Osceola County Sheriffs Office,
A Political Subdivision of the State
of Florida
ATTEST:
gy:
Typed Name: &Wllbll WIMMWS Typed Name. 6 ZA6-dC-A
J ! �
Title: OG. AS-5)'CrA 1, Title:
APPROVED AS TO FORM AND LEGALITY
Parkicip ting Agency Attorney
Signature page for Osceola County Sheriffs Office
Page 15 of 34
201g UAS{ GRANT
ATTEST:
PARTICIPATING AGENCY
Osceola County BCC,
A Political Subdivision of the State
of Florida
Typed Name:'1)e,6YW-0 IaLX6 Typf
Title: *,b-ec�jzt--, rteck— Ti
1 0
Signature page for Osceola County BCC
Page 16 of 34
2019 UASI GRANT
APPROVED AS TO FORM AND LEGALITY
Pafticipating Agency Attorney
ATTEST:
win
Typed Name. 71U4( Hcuohtu-
Title: 0±1 nerk-
PARTICIPATING AGENCY
The City of Sanford, a Municipal
of the State of Florida
By:
Typed Name:
Title: Mawr
Signature page for The City of Sanford
Page 17 of 34
2019 UASI GRANT
PARTICIPATING AGENCY
Seminole County Sheriffs Office,
A Political Subdivision of the State
of Florida
Typed Name: Typed Name:
Title: FJ( T< Title:
APPROVED AS TO FORM AND LEGALITY
Partici ting Agency Attorney
Signature page for Seminole County Sheriffs Office
Page 18 of 34
2019 UASI GRANT
Title: Clerk of Court & Comptroller
Signature page for Seminole County BCC
PARTICIPATING AGENCY
Seminole County BCC,
A Political Subdivision of the State
of Florida
Name: Jay 7 -embower
Page 19 of 34
2019 UASI GRANT
APPROVED AS TO FORM AND kgGALITY
�i
kA —
Participating Agency Attkney
Appendix A
Point of Contact
Daytona Beach Police Department
POC: Chief Craig Capri
Address: 129 Valor Blvd., Daytona Beach, FL 32114
Email: caDrIcr
pL1,rqia(5)dbDdAJS
Lake County Sheriffs Office
POC: Lieutenant Ralph McDuffie
Address: 360 West Ruby Street Tavares, FL 32778
Email: Rai, h.McDuffie(d)1cso.orQ
Lake County Department of Public Safety/Emergency Management Division
POC: Thomas Carpenter, Interim Emergency Management Division Manager
Address: 315 West Main Street, Suite 411 Tavares, FL 32778-7800
Email: tqaSryenter@lakeqoyntf1j oy
�
Orlando Police Department
POC: Chief Orlando Rol6n
Address: 100 South Hughey Avenue, Orlando, FL 32801
Email: orlando.rolon@citvoforlando.net
Orange County Emergency Management
POC: Chief Lauraleigh Avery, Acting Emergency Manager
Address: 6590 Amory Court, Winter Park, FL 32793
Email:
Osceola County Sheriff's Office
POC: Sheriff Russ Gibson
Address: 2601 E. Ido Bronson Memorial Hwy., Kissimmee, FL 34744
Email: rqLibPosceo1a.orq
Osceola County Office of Emergency Management
POC: Director Bill Litton
Address: 2586 Partin Settlement Rd., Kissimmee, FL 34744
Email: Lill.litton@ c la.orq
p�LAq__
Sanford Police Department
POC: Chief Cecil Smith
Address: 815 Historic Goldsboro Blvd., Sanford, FL 32771
Email: Cecil. Srnith@)§p0fordf1.g_qv
Seminole County Sheriffs Office
POC: Captain Mark Pergola
Address: 100 Bush Blvd., Sanford, FL 32773
Email: miler -cola seminolesheriff.or
Seminole County Emergency Management
POC: Chief Administrator Alan Harris
Address: 150 Bush Blvd. Sanford, FL 32773-6179
Email: gh@Lris serjnoLecountyfLgp
y
Page 20 of 34
2019 UASI GRANT
Attachment A
Scooe of Work
Sub -Recipients must comply with all the requirements in 2 C.F.R. Part 200 (Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards).
Funding is provided to perform eligible activities as identified in the Domestic Homeland Security —
Federal Emergency Management Agency National Preparedness Directorate Fiscal Year 2019
Homeland Security Grant Program (HSGP), consistent with the Department of Homeland Security State
Strategy. Eligible activities are outlined in the Scope of Work for each category glow:
1. Issue and Project Description — Issue #45 The Urban Area Security initiative (UASI) has
allowable Management and Administration (M&A) costs associated with it. The Division of
Emergency Management, as the designated State Administrative Agency, will retain five (5)
percent of the total UASI amount allocated to Florida for M&A purposes. These funds will provide
the SAA with the means to manage and administer the UASI grant. The proper management and
administration of these funds ensures that each project listed will be fulfilled, or partially fulfilled,
more efficiently while remaining in compliance with the DHS Federal Fiscal Year 2019 Homeland
Security Grant Program Guidance.
11. Categories and Eligible Activities
FY 2019 allowable costs are divided into the following categories for this agreement: Planning,
Organizational, Exercise, Training, Equipment and Management and Administration. Each
category's allowable costs have been listed in the °Budget Detail Worksheet" above.
A. Allowable Planning Related Costs
HSGP funds may be used for a range of emergency preparedness and management planning activities
such as those associated with the development, review, and revision of the THIRA, SPR, continuity of
operations plans, and other planning activities that support the Goal and placing an emphasis on
updating and maintaining a current EOP that conforms to the guidelines outlined in CPG 101 v 2.0.
o Developing hazard/threat-specific annexes that incorporate the range of prevention, protection,
response, and recovery activities;
e Developing and implementing homeland security support programs and adopting DNS/FEMA
national initiatives;
• Developing related terrorism and other catastrophic event prevention activities;
• Developing and enhancing plans and protocols;
• Developing or conducting assessments;
• Hiring of full -or part-time staff or contracticonsuttants to assist with planning activities (not for
the purpose of hiring public safety personnel fulfilling traditional public safety duties);
• Materials required to conduct planning activities;
• Travel/per diem related to planning activities;
• Overtime and backfill casts (in accordance with operational Cost Guidance);
• Issuance of WHTI-compliant Tribal identification card;
• Activities to achieve planning inclusive of people with disabilities;
• Coordination with Citizen Corps Councils for public information/education and development of
volunteer programs;
• Update governance structures and processes and plans for emergency communications; and
• Activities to achieve planning inclusive of people with limited English proficiency.
C. Allowable Organization Related Costs (HSGP and UASI Only)
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2019 UASI GRANT
Sub -Recipients proposed expenditures of SHSP or UASI funds to support organization activities
include:
• Program Management;
• Development of whole community partnerships, through groups such as Citizen Corp Councils;
Structures and mechanisms for information sharing between the public and private sector;
• Implementing models, programs, and workforce enhancement initiatives to address
ideologically inspired radicalization to violence in the homeland;
• Tools, resources, and activities that facilitate shared situational awareness between the public
and private sectors;
• Operational Support;
• Utilization of standardized resource management concepts such as typing, inventorying,
organizing, and tracking to facilitate the dispatch, deployment, and recovery of resources before,
during, and after an incident;
• Responding to an increase in the threat level under the National Terrorism Advisory System
(NTAS) or needs resulting from a National Special Security Event; and
Paying salaries and benefits for personnel to serve as qualified Intelligence Analysts. Per the
Personnel Reimbursement for Intelligence Cooperation and Enhancement (PRICE) of Homeland
Security Act, Pub. L. No. 110-412, § 2, codified in relevant part, as amended, at 6 U.S.C. § 609(a),
HSGP and UASI funds may be used to hire new staff and/or contractor positions to serve as
intelligence analysts to enable information/intelligence sharing capabilities, as well as support
existing intelligence analysts previously covered by HSGP or UASI funding. See 6 U.S.C. §
609(a). To be hired as an intelligence analyst, staff and/or contractor personnel must meet at
least one of the following criteria:
• Complete training to ensure baseline proficiency in intelligence analysis and production within
six months of being hired; and/or,
• Previously served as an intelligence analyst for a minimum of two years either in a federal
intelligence agency, the military, or state and/or local law enforcement intelligence unit.
Intelligence Analyst Activities Allowable Costs (HSGP and UASI)
All fusion center analytical personnel must demonstrate qualifications that meet or exceed
competencies identified in the Common Competencies for state, local, and tribal Intelligence
analysts, which outlines the minimum categories of training needed for intelligence analysts. A
certificate of completion of such training must be on file with the SAA and must be made available
to the recipient's respective FEMA HQ Program Analyst upon request. States and Urban Areas
must justify proposed expenditures of HSGP or UASI funds to support organization activities
within their IJ submission. All SAAB are allowed to utilize up to 50 percent (50%) of their HSGP
funding and all Urban Areas are allowed up to 50 percent (50%) of their UASI funding for
personnel costs. At the request of a Sub -Recipient of a grant, the FEMA Administrator may grant
a waiver of the 50 percent (50%) limitation noted above. Request for waivers to the personnel
cap must be submitted by the SAA to GPD in writing on official letterhead, with the following information:
• Documentation explaining why the cap should be waived;
• Conditions under which the request is being submitted; and
• A budget and method of calculation of personnel costs both in percentages of the grant award
and in total dollar amount. To avoid supplanting issues, the request must also include a three-
year staffing history for the requesting entity.
Law Enforcement Terrorism Prevention (LETP) Activities Allowable Costs (HSGP and UASI)
LETP Activities eligible for use of LETPA focused funds include but are not limited to:
Page 22 of 34
2019 UASI GRANT
• Maturation and enhancement of designated state and major Urban Area fusion centers,
including Information sharing and analysis, threat recognition, terrorist interdiction, and training/
hiring of intelligence analysts;
• Coordination between fusion centers and other analytical and investigative efforts including,
but not limited to Joint Terrorism Task Forces (JTTFs), Field Intelligence Groups (FIGS), High
Intensity Drug Trafficking Areas (HIDTAs), Regional Information Sharing Systems (RISS)
Centers, criminal intelligence units, and real-time crime analysis centers;
• Implementation and maintenance of the Nationwide SAR Initiative, including training for front
line personnel on identifying and reporting suspicious activities; and
• Implementation of the "if You See Something, Say Something" campaign 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.
• 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) to ensure
all public awareness materials (e.g., videos, posters, tri -folds, etc.) are consistent with
the 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 (seesay@hq.dhs.gov),
must be facilitated by FEMA.
• Increase physical security, through law enforcement personnel and other protective measures,
by implementing preventive and protective measures at critical infrastructure site or at -risk
nonprofit organizations; and
r Building and sustaining preventive radiological and nuclear detection capabilities, including
those developed through the Securing the Cities initiative.
Organizational activities under HSGP and UASI include:
Operational Overtime Costs. In support of efforts to enhance capabilities for detecting, deterring,
disrupting, and preventing acts of terrorism and other catastrophic events, operational overtime costs
are allowable for increased protective security measures at critical infrastructure sites or other high-risk
locations and to enhance public safety during mass gatherings and high-profile events. In that regard,
HSGP Sub -Recipients are urged to consider using grant funding to support soft target preparedness
activities. HSGP or UAS1 funds may be used to support select operational expenses associated with
increased security measures in the authorized categories cited below:
• Backfill and overtime expenses for staffing State or Major Urban Area fusion centers;
• Hiring of contracted security for critical infrastructure sites;
• Participation in Regional Resiliency Assessment Program (RRAP) activities;
• Public safety overtime;
• Title 32 or State Active Duty National Guard deployments to protect critical infrastructure sites,
including all resources that are part of the standard National Guard deployment package (Note:
Consumable costs, such as fuel expenses, are not allowed except as part of the standard
National Guard deployment package);
• Increased border security activities in coordination with CBP;
• National Terrorism Advisory System;
• National Security Events;
• Special Event Assessment Rating (SEAR) Level 1 through 4 Events 38
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• States of Emergency;
• National Critical Infrastructure Prioritization Program (NCIPP);
• Directed Transit Patrols; and
• Operational Support to a Federal Agency.
Operational Overtime Requests:
• Except for an elevated WAS alert, HSGP or UASI funds may only be spent for operational
overtime costs upon prior written approval by FEMA. The SAA must submit operational overtime
requests in writing to its assigned FEMA Program Analyst (PA). FEMA will consider requests for
special event activities up to one year in advance. However, such requests must be within the
award's current period of performance and must not result in the need for a request to extend the
period of performance.
• All operational overtime requests must clearly explain how the request meets the criteria of one
or more of the categories listed in the table above. Requests must address the threat environment
as it relates to the event or activity requiring operational overtime support and explain how the
overtime activity is responsive to the threat.
• Post -event operational overtime requests will only be considered on a case-by-case basis,
where it is demonstrated that exigent circumstances prevented submission of a request in
advance of the event or activity.
• Under no circumstances may DHS/FEMA grant funding be used to pay for costs already
supported by funding from another federal source.
• States with UASI jurisdictions can use funds retained at the state level to reimburse eligible
operational overtime expenses incurred by the state (per the above guidance limitations). Any
UASI funds retained by the state must be used in direct support of the high-risk urban area.
States must provide documentation to the UAWG and DHS/FEMA upon request demonstrating
how any UASI funds retained by a state would directly support the high-risk urban area.
• FEMA will consult and coordinate with appropriate DHS components as necessary to verify
information used to support operational overtime requests.
Personnel Costs (HSGP and UASI)
Personnel hiring, overtime, and backfill expenses are permitted under this grant to perform allowable
HSGP planning, training, exercise, and equipment activities. Personnel may include but are not limited
to training and exercise coordinators, program managers for activities directly associated with HSGP
and UASI funded activities, intelligence analysts, and Statewide interoperability coordinators (SWIG).
Sub -Recipients should refer to Information Bulletin No. 421, Clarification on the Personnel
Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of 2008
(Public Law 110-412 - the PRICE Act), Aug. 22, 2017. HSGP funds may not be used to support the
hiring of any personnel to fulfil traditional public health and safety duties nor to supplant traditional public
health and safety positions and responsibilities.
The following definitions apply to personnel costs:
• Hiring. State and local entities may use grant funding to cover the salary of newly hired
personnel who are exclusively undertaking allowable DHS/FEMA grant activities as specified in
this guidance. This may not include new personnel who are hired to fulfill any non-DHS/FEMA
program activities under any circumstances. Hiring will always result in a net increase of Full
Time Equivalent (FTE) employees.
• Overtime. These expenses are limited to the additional costs that result from personnel
working over and above 40 hours of weekly work time as the direct result of their performance
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of DHS/FEMA-approved activities specified in this guidance. Overtime associated with any other
activity is not eligible.
• Backfill=Related Overtime. Also called "Overtime as Backfill," these expenses are limited to
overtime costs that resin from personnel who are working overtime (as identified above) to
perform the duties of other personnel who are temporarily assigned to DHS/FEMA-approved
activities outside their core responsibilities. Neither overtime nor backfill expenses are the result
of an increase of FTE employees.
Supplan#ing. Grant funds will be used to supplement existing funds and will not replace
(supplant) funds that have been appropriated for the same purpose. Applicants or recipients may
be required to supply documentation certifying that a reduction in non-federal resources occurred
for reasons other than the receipt or expected receipt of federal funds.
D. Allowable Training Related Costs (SHGP and UASI)
Allowable training -related costs under HSGP include the establishment, support, conduct, and
attendance of training specifically identified under the HSGP and UASI programs and/or in conjunction
with emergency preparedness training by other Federal agencies (e.g., MHS and DOT). Training
conducted using HSGP funds should address a performance gap identified through an AAR/IP or other
assessments (e.g., National Emergency Communications Pian NECP Goal Assessments) and
contribute to building a capability that will be evaluated through a formal exercise. Any training or training
gaps, including those for children, older adults, pregnant women, and individuals with disabilities and
others who also have access or functional needs, should be identified in the AAR/IP and addressed in
the state or Urban Area training cycle. Sub -Recipients are encouraged to use existing training rather
than developing new courses. When developing new courses, Sub -Recipients are encouraged to apply
the Analysis, Design, Development, Implementation and Evaluation (ADDIE) model of instructional
design.
• Overtime and backfill for emergency preparedness and response personnel attending
DHS/FEMA-sponsored and approved training classes
• Overtime and backfill expenses for part-time and volunteer emergency response personnel
participating in DHS/FEMA training
• Training workshops and conferences
• Activities to achieve training inclusive of people with disabilities
• Full- or part-time staff or contractorstconsultants
• Travel
• Supplies associated with allowable approved training that are expended or consumed during the
course of the planning and conduct of the exercise project(s)
• Instructor certification/re-certification
• Coordination with Citizen Corps Councils in conducting training exercises
• Interoperable communications training
Additional Training Information
Per DHS/FEMA Grant Programs Directorate Policy FP 207-008-064-1, Review and Approval
Requirements for Training Courses Funded Through Preparedness Grants, issued on September 9,
2013, states, territories, Tribal entities and 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 Urban Area Training Point of Contact (TPOC) and faits within
the FEMA mission scope and the jurisdiction's Emergency Operations Plan (EOP). The only exception
to this policy is for Countering Violent Extremism courses. DHS/FEMA will conduct periodic reviews of
all state, territory, and Urban Area training funded by DHS/FEMA. These reviews may include requests
for all course materials and physical observation of, or participation in, the funded training. If these
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reviews determine that courses are outside the scope of this guidance, Sub -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, SAAs and TPOCs are encouraged to review the NTED Responder Training
Development Center (RTDC) website.
DHSIFEMA Provided Training. These trainings include programs or courses developed for and
delivered by institutions and organizations funded by DHS/FEMA. This includes the Center for Domestic
Preparedness (CDP), the Emergency Management Institute (EMI), and the National Training and
Education Division's (NTED) training partner programs including, the Continuing Training Grants, the
National Domestic Preparedness Consortium (NDPC) and the Rural Domestic Preparedness
Consortium (RDPC).
Approved State and Federal Sponsored Course Catalogue. This catalogue lists state and Federal
sponsored courses that fall within the DHS/FEMA mission scope, and have been approved through the
FEMA course review and approval process. An updated version of this catalog can be accessed at:
wWw.firstrespondertrainbg_qov.
Training Not Provided by DHSIFEMA. 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 DHS/FEMA mission scope to prepare state, local, Tribal, and territorial
personnel to prevent, protect against, mitigate, respond to, and recover from 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, respond to, and recover from acts of
terrorism or catastrophic events. Overtime pay for first responders and emergency managers
who participate in public-private training and exercises is allowable. In addition, States, territories,
Tribes, and Urban Areas are encouraged to incorporate the private sector in government-
sponsored training and exercises.
Additional information on both DHS/FEMA provided training and other federal and state training can be
found at: www.firstrespondertraining.gov.
Training Information Reporting System ("Web -Forms"). Web -Forms is an electronic form/data
management system built to assist the SAA and its designated State, territory and Tribal Training Point
of Contact (TPOC). Reporting training activities through Web -Forms is not required under FY 2019
HSGP, however, the system remains available and can be accessed through the FEMA Toolkit located
at hftp://www.firstrespondertraining.gov/admin in order to support grantees in their own tracking of
training.
FDEM State Training Office Conditions: For the purposes of this Agreement, any training course
listed on the DHS approved course catalog qualifies as an authorized course. The Sub -Recipient can
successfully complete an authorized course either by attending or conducting that course.
• In order to receive payment for successfully attending an authorized training course, the Sub -
Recipient must provide the Division with a certificate of course completion; additionally, the
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Sub -Recipient must provide the Division with all receipts that document the costs incurred by
the Sub -Recipient in order to attend the course.
• In order the receive payment for successfully conducting an authorized course, the Sub -
Recipient must provide the Division with the course materials and a roster sign -in sheet;
additionally, the Sub -Recipient must provide the Division with all receipts that document the
costs incurred by the Sub -Recipient in order to conduct the course."
• For courses that are non -DHS approved training, Sub -Recipient must request approval to
conduct training through the use of the Non -TED Form and provide a copy, along with email,
showing approval granted for conduct.
• For the conduct of training workshops, Sub -Recipient must provide a copy of the course
materials and sign -in sheets.
• The number of participants must be a minimum of 15 in order to justify the cost of holding a
course. For questions regarding adequate number of participants please contact the FDEM
State Training Officer for course specific guidance. Unless the Sub -Recipient receives
advance written approval from the State Training Officer for the number of participants, then
the Division will reduce the amount authorized for reimbursement on a pro -rata basis for any
training with less than 15 participants.
• The Sub -Recipient must include with the reimbursement package a separate copy of the
page(s) from the State (and County or Regional) MYTEP reflecting the training.
E. Allowable Equipment Related Costs (SHGP and UASQ
The 21 allowable prevention, protection, mitigation, response, and recovery equipment categories for
HSGP are listed on the Authorized Equipment List (AEL). The AEL is available at
hftp://`www.fema.gov/authorized-equipment-list. Some equipment items require prior approval from
DHS/FEMA before obligation or purchase of the items. Please reference the grant notes for each
equipment item to ensure prior approval is not required or to ensure prior approval is obtained if
necessary. Unless otherwise stated, all equipment must meet all mandatory regulatory and/or
DHS/FEMA-adopted standards to be eligible for purchase using these funds. In addition, recipients will
be responsible for obtaining and maintaining all necessary certifications and licenses for the requested
equipment.
Grant funds may be used for the procurement of medical countermeasures. Procurement of medical
countermeasures must be conducted in collaboration with State/city/local health departments who
administer Federal funds from HHS for this purpose. Procurement must have a sound threat -based
justification with an aim to reduce the consequences of mass casualty incidents during the first crucial
hours of a response. Prior to procuring pharmaceuticals, grantees must have in place an inventory
management plan to avoid large periodic variations in supplies due to coinciding purchase and
expiration dates. Grantees are encouraged to enter into rotational procurement agreements with
vendors and distributors. Purchases of pharmaceuticals must include a budget for the disposal of
expired drugs within each fiscal year's period of performance for HSGP. The cost of disposal cannot be
carried over to another FEMA grant or grant period.
The equipment, goods, and supplies (the eligible equipment*) purchased with funds provided under
this agreement are for the purposes specified in "Florida's Domestic Security Strategy". Equipment
purchased with these funds will be utilized in the event of emergencies, including, but not limited to,
terrorism -related hazards. The Sub -Recipient shall place the equipment throughout the State of Florida
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in such a manner that, in the event of an emergency, the equipment can be deployed on the scene of
the emergency or be available for use at a fixed location within two (2) hours of a request for said
deployment. The Florida Division of Emergency Management (FDEM) must approve any purchases of
equipment not itemized in a project's approved budget in advance of the purchase.
The Sub -Recipient will, in accordance with the statewide mutual aid agreement or other emergency
response purpose as specified in the 'Florida Domestic Security Strategy," ensure that all equipment
purchased with these funds is used to respond to any and all incidents within its regional response area
as applicable for so long as this Agreement remains in effect. Prior to requesting a response, the FDEM
will take prudent and appropriate action to determine that the level or intensity of the incident is such
that the specialized equipment and resources are necessary to mitigate the outcome of the incident.
F. Disposition
When original or replacement equipment acquired- under a Federal award is no longer needed for the
original project or program or for other activities currently or previously supported by a Federal awarding
agency, except as otherwise provided in Federal statutes, regulations, or Federal awarding agency
disposition instructions, the Sub -Recipient must request disposition instructions from FDEM Office of
Domestic Preparedness and the State Administrative Agency will request deposition instructions from
Federal awarding agency as required by the terms and conditions of the Federal award. The Sub -
Recipient shall notify the FDEM Office of Domestic Preparedness at: 2555 Shumard Oak Blvd.,
Tallahassee, Florida 32399 one year in advance of the expiration of the equipment's posted shelf -life
or normal life expectancy or when it has been expended. The Sub -Recipient shall notify the FDEM
immediately if the equipment is destroyed, lost, or stolen.
G. Requirements for Small Unmanned Aircraft System (SHSP, UASI, and OPSG)
All requests to purchase Small Unmanned Aircraft Systems (SUAS) with FEMA grant funding must
comply with IS 426 and IS 438 and 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.
Sub -Recipients must use HSGP funds for cybersecurity projects that support the security and
functioning of critical infrastructure and core capabilities as they relate to terrorism preparedness and
may simultaneously support enhanced preparedness for other hazards unrelated to acts of terrorism.
Law Enforcement Readiness (SHSP, UASI, and OPSG)
OPSG grant funds may be used to increase operational, material, and technological readiness
of SL.TT law enforcement agencies. The Delegation of Immigration Authority, Section 287(g) of the
Immigration and Nationality Act (iNA) program allows a state or local law enforcement entity to enter
into a partnership with ICE, under a joint Memorandum of Agreement (MOA), to receive delegated
authority for immigration enforcement within their jurisdictions SHSP, UASI, or OPSG grant funds may
be requested and may be approved on a case-by-case basis for immigration enforcement training in
support of the border security mission. Requests for training will be evaluated on a case-by-case basis
and can only be used for certification in the section 287{8} program provided by DHS/ICE. SHSP, UASI,
or OPSG Sub -Recipients with agreements under section 287(8) of the Immigration and Nationality Act
(8 U.S.C. § 1357(g)) to receive delegated authority for immigration enforcement within their jurisdictions
may also be reimbursed for section 287(8) related operational activities with approval from FEMA on a
case-by-case basis. For OPSG, Sub -Recipients must be authorized by USBP Headquarters and
Sectors, and operational activities must be coordinated through a USBP Sector. 47
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J. Maintenance and Sustainment (SHSP, UASI, and OPSG)
The use of DHS/FEMA preparedness grant funds for maintenance contracts, warranties, repair or
replacement costs, upgrades, and user fees are allowable, as described in FEMA Policy FP 205-402-
125-1 under all active and future grant awards, unless otherwise noted. Except for maintenance plans
or extended warranties purchased incidental to the original purchase of the equipment, the period
covered by maintenance or warranty plan must not exceed the POP of the specific grant funds used to
purchase the plan or warranty.
Grant funds are intended to support the Goal by funding 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 FEMA's IB 379, Guidance to State Administrative
Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding, initially for FY 2007-2011,
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; (3) be tied to one of the core capabilities in the five mission areas contained within the
Goal, and (4) shareable through the Emergency Management Assistance Compact. 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 DHSIFEMA
preparedness grant program dollars.
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Attachment B
Deliverables and Performance
State Homeland Security Program (HSGP): HSGP supports the implementation of risk driven,
capabilities -based State Homeland Security Strategies to address capability targets set in Urban
Area, State, and regional Threat and Hazard Identification and Risk Assessments (THIRAs). The
capability levels are assessed in the State Preparedness Report (SPR) and inform planning,
organization, equipment, training, and exercise needs to prevent, protect against, mitigate, respond
to, and recover from acts of terrorism and other catastrophic events.
Planning Deliverable: Subject to the funding limitations of this Agreement, the Division shall
reimburse the Sub -Recipient for the actual cost of successfully completing Planning activities
consistent with the guidelines contained in the Comprehensive Planning Guide CPG 101 v.2. For
additional information, please see http://www.fema.gov/pdf/about/divisions/npd/CPG_l01 V2.pdf or
grant guidance (Notice of Funding Opportunity). For the purposes of this Agreement, any planning
activity such as those associated with the Threat and Hazard identification and Risk Analysis (THIRA),
State Preparedness Report (SPR), and other planning activities that support the National
Preparedness Goal (NPG) and place an emphasis on updating and maintaining a current Emergency
Operations Plan (EOP) are eligible. The Sub -Recipient can successfully complete a planning activity
either by creating or updating such plan(s).
Organization Deliverable: Subject to the funding limitations of this Agreement, the Division shall
reimburse the Sub -Recipient for the actual eligible costs for Personnel, Intelligence Analysts,
Overtime and Operational Overtime.
Exercise Deliverable: Subject to the funding limitations of this Agreement, the Division shall
reimburse the Sub -Recipient for the actual cost of successfully completing an exercise which meets
the Department of Homeland Security Homeland Security Exercise and Evaluation Program (HSEEP)
standards and is listed in A) the State of Florida Multi -Year Training & Exercise Plan (MYTEP), and B)
County or Regional TEP for the region in which the Sub -Recipient is geographically located.
Information related to TEPs and HSEEP compliance can be found online at:
https://www.Ilis.dhs.gov/hseep. For the purposes of this Agreement, any exercise which is compliant
with HSEEP standards and contained in the State of Florida MYTEP qualifies as an authorized
exercise. The Sub -Recipient can successfully complete an authorized exercise either by attending or
conducting that exercise.
Training Deliverable: Subject to the funding limitations of this Agreement, the Division shall
reimburse the Sub -Recipient for the actual cost of successfully completing a training course listed on
the Department of Homeland Security (DHS) approved course catalog. For non -DHS approved
courses the Sub -Recipient shall obtain advance FDEM approval using the Non -TED form by
contacting their grant manager. The DHS course catalog is available online at:
http://training.fema.gov/. For the purposes of this Agreement, any training course listed on the DHS
approved course catalog qualifies as an authorized course. The Sub -Recipient can successfully
complete an authorized course either by attending or conducting that course.
Equipment Deliverable: Subject to the funding limitations of this Agreement, the Division shall
reimburse the Sub -Recipient for the actual cost of purchasing an item identified in the approved project
funding template and budget of this agreement and listed on the DHS Authorized Equipment List (AEL).
For the purposes of this Agreement, any item listed on the AEL qualifies as an authorized item. The 21
allowable prevention, protection, mitigation, response, and recovery equipment categories and
equipment standards for HSGP are listed on the web -based version of the Authorized Equipment List
(AEL) on the Lessons Learned Information System at http://beta.fema.gov/authorized-equipment-list.
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In addition, agencies will be responsible for obtaining and maintaining all necessary certifications and
licenses for the requested equipment.
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Attachment C
Environmental Planning & Historic Preservation (EHP) Comodiance Guidelines
ENVIRONMENTAL PLANNING & HISTORIC PRESERVATION (EHP) COMPLIANCE GUIDELINES
The following types of projects are to be submitted to FEMA for compliance review under Federal
environmental planning and historic preservation (EHP) laws and requirements prior to initiation of the
project:
• New Construction, Installation and Renovation, including but not limited to:
o Emergency Operation Centers
o Security Guard facilities
o Equipment buildings (such as those accompanying communication towers)
o Waterside Structures (such as dock houses, piers, etc.)
• Placing a repeater and/or other equipment on an existing tower
• Renovation of and modification to buildings and structures that are 50 years old or older
• Any other construction or renovation efforts that change or expand the footprint of a facility or
structure including security enhancements to improve perimeter security
• Physical Security Enhancements, including but not limited to:
o Lighting
o Fencing
o Closed-circuit television (CCTV) systems
o Motion detection systems
o Barriers, doors, gates and related security enhancements
In addition, the erection of communications towers that are included in a jurisdiction's interoperable
communications plan is allowed, subject to all applicable laws, regulations, and licensing provisions.
Communication tower projects must be submitted to FEMA for EHP review.
EHP DETERMINATION PROCESS
I. Submit the Final Screening Memo to the SAA for review prior to funds being expended.
11. The SAA will review and notify the Sub -Recipient of its decision. The grantee should incorporate
sufficient time and resources into the project planning process to accommodate EHP requirements.
APPROVAL PROCESS TO FEMA
1. Prepare a formal written Scope of Work with details outlined in the attached EHP Compliance
Requirements, page 2.
11. The Final Screening Memo should be attached to all project information sent to the Grant
Programs Directorate (GPD) for an EHP regulatory compliance review.
Ill. Complete the attached National Environmental Policy Act (NEPA) Compliance checklist
IV. Prepare maps indicating the location(s) of proposed project (Guidance provided)
V. Take photographs of the location(s) of proposed project (Guidance provided)
VI. Forward all documents to the SAX All documents are then forwarded to GPD electronically via the
Centralized Scheduling and Information Desk (CSID) at askcsid@dhs.gov.
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VII. CSID will send an email confirming receipt of the project description.
Vill. FEMA Program Analyst sends notification to SAA when review is complete. SAA notifies Sub -
Recipient of FEMA's final decision.
IX. THE PROJECT MAY BEGIN ONCE FINAL FEMA APPROVAL IS RECEIVED. Grantee should
incorporate sufficient time and resources into the project planning process to accommodate EHP
requirements. Grantees must receive written approval from FEMA prior to the use of grant funds for
project implementation.
VI. Forward all documents to the SAA. All documents are then forwarded to GPD electronically via
the Centralized Scheduling and Information Desk (CSID) at askcsid@dhs.gov.
VII. CSID will send an email confirming receipt of the project description.
VIII. FEMA Program Analyst sends notification to SAA when review is complete. SAA notifies Sub -
Recipient of FEMA's final decision.
IX. THE PROJECT MAY BEGIN ONCE FINAL FEMA APPROVAL IS RECEIVED. Grantee should
incorporate sufficient time and resources into the project planning process to accommodate
EHP requirements.
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Attachment D
Program Statutes and Reaulations,
1) Age Discrimination Act of 1975 42 U.S.C. § 6101 et seq.
2) Americans with Disabilities Act of 1990 42 U.S.C. § 12101-12213
3) Chapter 473, Florida Statutes
4) Chapter 215, Florida Statutes
5) Chapter 252, Florida Statutes
6) Title \11 of the Civil Rights Act of 1964 42 U.S.C. § 2000 et seq.
7) Title VI Il of the Civil Rights Acts of 1968 42 U.S.C. § 3601 et seq.
8) Copyright notice 17 U.S.C. §§ 401 or 402
9) Assurances, Administrative Requirements and Cost Principles 2 C.F.R. Part 200
10) Debarment and Suspension Executive Orders 12549 and 12689
11) Drug Free Workplace Act of 1988 41 U.S.C. § 701 et seq.
12) Duplication of Benefits 2 C.F.R. Part 200, Subpart E
13) Energy Policy and Conservation Act 42 U.S.C. § 6201
14) False Claims Act and Program Fraud Civil Remedies 31 U.S.C. § 3729-3733 also 31 U.S.C.
3801-3812
15) Fly America Act of 1974 49 U.S.C. § 41102 also 49 U.S.C. § 40118
16) Hotel and Motel Fire Safety Act of 199015 U.S.C. § 2225a
17) Lobbying Prohibitions 31 U.S.C. § 1352
18) Patents and Intellectual Property Rights 35 U.S.C. § 200 et seq.
19) Procurement of Recovered Materials section 6002 of Solid Waste Disposal Act
20) Terrorist Financing Executive Order 13224
21) Title IX of the Education Amendments of 1972 (Equal Opportunity in Education Act) 20 U.S.C.
1681 et seq.
22) Trafficking Victims Protection Act of 2000 22 U.S.C. § 7104
23) Rehabilitation Act of 1973 Section 504, 29 U.S.C. § 794
24) USA Patriot Act of 2001 18 U.S.C. § 175-172c
25) Whistleblower Protection Act 10 U.S.C. § 2409, 41 US.C. § 4712, and 10 U.S.C. § 2324, 41
U.S.C. § 4304 and § 4310
26) 53 Federal Register 8034
27) Rule Chapters 27P-6, 27P-11, and 27P-19, Florida Administrative Code
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