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1996-1028_ORANGE, COUNTY OF_Memorandum of Contract No. EC41972 1ontract No. EC41972 1 COUNTY OF ORANGE 2 ENVIRONMENTAL MANAGEMENT AGENCY 3 HOUSING AND REDEVELOPMENT 4 COMMUNITY DEVELOPMENT BLOCK GRANT 5 ( Program Year XXI O 6 7 TITLE OF PROJECT: City of San Juan Capistrano - Rehabilitation Single Residential 8 Units 9 10 11 day of C 12 MEMORANDUM OF CONTRACT entered into this 13 1996, 14 15 BY AND BETWEEN City of San Juan Capistrano, a municipal 16 corporation, in the State of California, and 17 hereinafter referred to as "CITY". 18 19 AND COUNTY OF ORANGE, a political subdivision 20 of the State of California and recognized Urban 21 County under the Federal Housing and 22 Community Development Act of 1974 (Public 23 Law 93-383), as amended, hereinafter referred 24 to as "COUNTY". 25 26 RECITALS 27 28 This Contract is made with reference to the following facts, among others: 29 30 WHEREAS, the COUNTY anticipates entering into a separate contract for the 31 period July 1, 1996 - June 30, 1997 with the United States Department of Housing and 32 Urban Development (HUD) to receive funds under Title I of the Housing and 33 Community Development Act of 1974 (Public Law 93-383, as amended) for the 34 purpose of funding projects meeting one of the HUD national objectives, and 35 WHEREAS, COUNTY and CITY previously entered into a Cooperation 36 Agreement dated July 21, 1993 in which both parties agreed to cooperate in the 37 undertaking, or assist in the undertaking, of community development and housing 38 assistance activities, and 39 WHEREAS, CITY has submitted to COUNTY an application for funding of a 40 project described herein and -1- 0 fontract No. EC41972 1 WHEREAS, COUNTY adopted its Final Annual Action Plan on April 9, 1996 by 2 Resolution No.96-230 which sets forth the project described herein, and 3 WHEREAS, HUD has accepted and certified the aforementioned Final Annual 4 Action Plan. 5 NOW, THEREFORE, IT IS AGREED by and between the parties that the 6 following provisions as well as all related Federal Regulations, including 24 CFR 570, 7 and appropriate State and County laws and regulations including the attached 8 GENERAL CONDITIONS, identified as Exhibit "A", and Exhibit 'B" are part of this 9 Contract. 10 I. SCOPE OF SERVICES 11 A. ACTIVITIES 12 CITY will act as PROJECT MANAGER and will be responsible for 13 administering a Year XXII Community Development Block Grant project described as 14 follows in a manner satisfactory to the COUNTY and consistent with any standards 15 required as a condition of providing these funds: 16 Project Descri tp ion: 17 18 The City of San Juan Capistrano will use CDBG funds for eligible owner- 19 occupied or rental properties at various mobile home sites, providing low interest 20 loans, deferred payment loans, and grants which will benefit low- and moderate- 21 income individuals. Project support costs are included as part of this project. 22 Upon written approval from the DIRECTOR, the CITY may incur costs towards other 23 uses eligible under the applicable State and Federal regulations, particularly the 24 Federal regulations at 24 CFR Part 570.202. 25 Program Deliver 26 Activity No. 1: Housing Rehabilitation 27 Activity No. 2: 28 Activity No. 3: 29 General Administration: CITY shall provide the oversight, administration and 30 project management necessary to accomplish all contracted activities. -2- • fontract No. EC41972 1 National Objective: The subject activities are consistent in complying with the 2 following national objectives as set forth in Title 24 CFR Part 570.208 (a)(3): 3 Low/Moderate Housing Benefit. 4 B. LEVELS OF ACCOMPLISHMENT 5 In addition to the normal administrative services required as part of this Contract, the 6 CITY agrees to meet the following level(s) of accomplishment: 7 Activity Level of Accomplishment 8 Activity No. 1: Rehabilitation 15 Mobile Homes 9 Activity No. 2: 10 Activity No. 3: 11 C. BUDGET 12 1. This contract is in an amount not to exceed $75,000.00 (Seventy-five 13 Thousand Dollars and 00 cents). 14 2. Project Funding 15 a. The subject proposal will be financed under this contract as 16 follows: 17 Project Overhead $ 15,000.00 (Fifteen Thousand Dollars and 18 no/100) 19 Construction $60,000.00 (Sixty Thousand Dollars and no/100) 20 Total CDBG Funds $75,000.00 (Seventy-five Thousand Dollars and 21 no/100) 22 23 3. Funds shall be used for the following items: Costs related to 24 construction of project and salaries including benefits. 25 4. Line items identified in Section I.C.2. above are to be considered as 26 estimates. Compensation for costs incurred during the life of this contract may be 27 reallocated between said line items. Furthermore, compensation may be reallocated 28 Ito address any costs incurred for previously unbudgeted uses eligible under the 29 applicable State and Federal regulations upon written request by CITY and written 30 approval by the DIRECTOR, particularly the Federal regulations at 24 CFR Parts -3- 4pontract No. EC41972 1 570.201 -207. 2 D. PERFORMANCE MONITORING 3 The COUNTY will, in accordance with Section III.A. of this Contract, monitor the 4 performance of the CITY against the goals and performance standards required 5 herein. Substandard performance as determined by COUNTY will constitute non- 6 compliance with this Contract and COUNTY may thereafter terminate the Contract 7 pursuant to Section H of Exhibit A "General Conditions", attached hereto. 8 CITY agrees: 9 1. To comply with all applicable Federal and COUNTY regulations, as may 10 be periodically revised by HUD, Office of Management and Budget, or other Federal 11 agencies and COUNTY. 12 2. To fully cooperate with the COUNTY on matters concerning the 13 scheduled completion and submittal of materials, information and documentation 14 requested by the COUNTY to comply with Federal Grantee Performance Reporting 15 requirements. Failure to do so may result in the COUNTY withholding future 16 payment. 17 3. To comply with COUNTY procedures concerning the Grantee 18 Performance Report (GPR) Form. The CITY also acknowledges that the GPR Form is 19 a monitoring tool that will be reviewed and evaluated to determine CITY's level of 20 accomplishments relative to this Contract. 21 4. To fully comply with the terms and conditions of the subject agreement. 22 Failure to do so may result in the suspension or termination of said agreement. Any 23 terms or conditions proposed subsequent to the effective date of this contract are 24 invalid until such time that the DIRECTOR has considered and approved said terms 25 and conditions in writing. Any revisions to the terms and conditions setforth herein 26 shall be incorporated into this agreement in accordance with Section I.G. 27 (Amendments) of Exhibit "A" attached. 28 29 -4- • lontract No. EC41972 1 H. TIME OF PERFORMANCE 2 Services of the CITY shall begin on July 1, 1996 and shall be completed by June 30, 3 1997. The term of this contract and the provisions herein may be extended to cover 4 an additional time period as specified in Section V.B. of this Contract. 5 111. PAYMENTS 6 A. CONTRACT AMOUNT 7 It is expressly agreed and understood that the total amount to be paid by the COUNTY 8 under this Contract shall not exceed the amount stated in Section I.C. of this Contract. 9 Drawdowns for the payment of eligible expenses shall be made against the eligible cost 10 items specified in Section I.C. herein, and in accordance with Exhibit A attached and 11 shall be accompanied by the required performance reports. 12 1B. REIMBURSEMENT 13 On a monthly basis CITY may invoice COUNTY for reimbursement of eligible costs 14 (See Exhibit A). Concurrently with its request for the aforementioned funds, CITY 15 shall submit to the COUNTY the following support documentation: (Copies of) paid 16 invoices, receipts, payroll records, bank statements, cancelled checks and other items 17 adequate to document project expenditures. CITY shall also provide a performance 18 report for the time period identified in the aforementioned reimbursement invoice, 19 including Grantee Performance Direct Benefit Activity Information addressing its 20 level of performance with each activity undertaken relative to the scope of services 21 set forth in Section I., herein. Compensation of CITY reimbursement invoices will 22 depend upon appropriate and timely performance of objectives as setforth above. 23 COUNTY may withhold payment if CITY fails to meet measurable objectives as set 24 forth in Sections I.A. and I.B. above. No payment will be authorized if any preceding 25 month's reports or invoices are not submitted to COUNTY. 26 IV. NOTICES 27 Communication concerning this Contract shall be directed as follows: 28 29 -5- • 41ontract No. EC41972 1 For the COUNTY: 2 3 County of Orange 4 EMA-Housing and Redevelopment 5 1770 North Broadway 6 Santa Ana, California 92706 7 Attn: Chief, Grant Management Section 8 9 For the CITY: 10 11 City of San Juan Capistrano 12 32400 Paseo Adelanto 13 San Juan Capistrano, CA 92677 14 Attn: Tom Tomlinson 15 V. SPECIAL CONDITIONS 16 A. SPECIAL CONDITIONS DEFINITIONS 17 For the purposes of this Contract the following definitions shall apply: 18 1. PROJECT MANAGER: The party responsible for, but whose 19 responsibility is not limited to the following: Contracting, monitoring and 20 implementing the project through completion. 21 2. DIRECTOR: Director of the Orange County Environmental 22 Management Agency (EMA) or his designee. 23 3. REIMBURSABLE BASIS: The CITY will provide the funds for the 24 project and will submit proof of payment to COUNTY, whereupon after approval by 25 COUNTY, COUNTY will repay the CITY. 26 4. CONSTRUCTION BID PACKAGE: A package of bidding documents 27 which includes proposal, bidding instructions, contract documents, detailed estimated 28 costs and plans and specifications for a construction project, all prepared in accordance 29 with applicable Federal regulations. 30 B. PROJECT FUNDING 31 1. The project shall be completed and all funds provided through this 32 Contract shall be expended on eligible project activities prior to June 30, 1997. CITY 33 shall submit any invoices for expenditures under this Contract within 90 days of the 34 Contract expiration date. -6- • 41ontract No. EC41972 1 2. The date for PROJECT completion and expenditure of all funds may be 2 extended by the DIRECTOR for a period not to exceed twelve (12) months from June 3 30, 1997. Any such extension must be in writing and signed by the DIRECTOR. In the 4 event of such extension, the deadline for submittal of invoice shall be 90 days after the 5 new completion date. After Contract expiration, all unexpended funds remaining 6 from this Contract may be allocated by COUNTY to other eligible program. 7 3. Prior to the DIRECTOR authorizing any contract extension, the 8 COUNTY must receive a written request from an officially recognized CITY 9 representative (i.e. Director, Mayor, City Manager) to extend this contract. Said 10 written request must include a revised budget for funds being extended, if that budget 11 is different in scope of services from the originally agreed upon scope of services. 12 4. Any request for the extension of this contract must be received by the 13 DIRECTOR at least forty-five (45) days prior to June 30, 1997. 14 5. Failure to extend this contract prior to the agreed upon termination date 15 may result in the COUNTY withholding payment of future payments, terminating 16 this contract and/or reallocating all unobligated funds to be used on other eligible 17 projects managed through the Urban County Program. 18 6. Invoices for all approved expenditures under this contract must be 19 submitted within 90 days of the completion or termination of this contract. Any 20 unobligated funds remaining after the expiration of this contract may be allocated by 21 the COUNTY on other eligible projects managed through the Urban County Program. 22 C. PROGRAM INCOME 23 1. The CITY shall comply with regulations set forth in Title 24 CFR 570.504 , 24 as well as all applicable state or County regulations concerning the reporting and 25 payment procedures for program income, as set forth in Section H.C. of the attached 26 Exhibit "A" (General Conditions). 27 2. All Program Income accrued shall be drawn down prior to the CITY 28 receiving any reimbursement from grant funds administered by COUNTY. 29 -7- Contract No. EC41972 1 D. CITY agrees: 2 1. That the project shall be implemented and appropriately maintained for 3 Community Development purposes as defined by applicable HUD provisions to 4 ensure maximum feasible benefit and utilization of the project by low- and moderate- 5 income persons. 6 2. That DIRECTOR shall periodically evaluate the CITY's progress in 7 complying with the terms of this Contract. CITY shall cooperate fully during such 8 monitoring. DIRECTOR shall report the findings of each monitoring to the CITY. 9 DIRECTOR may, at his discretion, report said findings to the Orange County Board of 10 Supervisors. If it is determined by the Board of Supervisors that CITY performance or 11 progress on performance is unsatisfactory, the Board of Supervisors may terminate 12 this Contract. In addition, the Board of Supervisors may require the CITY to 13 reimburse COUNTY any funds that it determines to be improperly expended or not 14 expended on the project in a timely manner based on applicable CDBG Program 15 Regulations. 16 3. To be responsible for design and inspection, including funding the costs 17 related to those activities, unless funding for design and inspection activities is 18 provided for in Section I.C. of this Contract. 19 4. If this contract is a construction project, submit the Construction Bid 20 Package for this project to DIRECTOR for review and written approval prior to 21 advertising for bids on the construction contract or prior to award of such contract if 22 an alternative method of award is used. CITY shall construct project in accordance 23 with the Construction Bid Package which DIRECTOR approved unless prior written 24 approval is received from DIRECTOR for modification therefrom. 25 5. Comply with all applicable Federal, State and COUNTY regulations 26 concerning labor standards, Davis-Bacon Act, Copeland Act and Section 3 27 requirements, as set forth in Sections III., C.3. and III., CA. of the attached Exhibit "A" 28 (General Conditions). -8- • lontract No. EC41972 1 6. That this Contract is conditional upon COUNTY being funded by HUD, 2 and the release of funds to COUNTY. 3 7. That this Contract is also conditional upon complying with HUD 4 Environmental Review under HUD regulations at 24 CFR, Part 50 which implements 5 Section 102(2)(c) of the National Environmental Policy Act of 1969 and the California 6 Environmental Quality Act. 7 8. That funds may not be disbursed until the required environmental 8 documentation clearance has been issued. 9 9. To provide requested materials to COUNTY for the Environmental 10 Review process requested by HUD. This process may take up to ninety (90) days. 11 10. To comply with all applicable HUD regulations concerning 12 administrative requirements, as set forth in Section II. (ADMINISTRATIVE 13 REQUIREMENTS) of the attached Exhibit "A" (General Conditions), and maintain 14 records as to services provided and total number of persons served through the 15 project, including percentage of: low income persons and very-low income persons as 16 defined by HUD; persons by ethnicity; female-headed households. Such information 17 shall be available for periodic monitoring by representatives of the County or HUD 18 and shall be submitted in report form to COUNTY per County of Orange procedures. 19 E. MODIFICATIONS/TRANSFERS 20 1. Any proposed modification or change in use of real property acquired or 21 improved in whole or in part by CDBG funds from that planned at the time of the 22 acquisition or improvement, including disposition, must be reported by CITY to the 23 COUNTY and receive COUNTY concurrence thereto in advance of implementing the 24 modification or change in use. 25 2. The CITY shall transfer to COUNTY any CDBG funds on hand at the 26 time of Contract expiration and any accounts receivable attributable to the use of 27 CDBG funds. The CITY shall ensure that any real property under the CITY's control 28 that was acquired or improved in whole or in part with CDBG funds in excess of 29 $25,000 is either: -9- Contract No. EC41972 1 (a) Used to meet one of the national objectives in 24 CFR 570.208 2 until five years after expiration of the contract; or, 3 (b) Is disposed of in a manner which results in the COUNTY being 4 reimbursed in the amount of the current fair market value of the property less any 5 portion thereof attributable to expenditures of non-CDBG funds for acquisition of, or 6 improvement to, the property. Such reimbursement is not required after the period 7 of time specified in accordance with 1(a) above. 8 F. AMENDMENTS 9 Any amendment to this contract shall be completed in accordance with 10 Section I.G. (Amendments) of Exhibit "A" attached. 11 G. AUDITS 12 1. The Federal government requires that CITYs receiving $25,000 or more 13 in Federal assistance in a fiscal year must secure an audit. Agencies receiving $25,000 14 or more must meet this requirement through one of the following methods. Failure 15 to meet this requirement will result in the COUNTY denying CITY reimbursement 16 requests. 17 A. If CITY currently conducts audits of all its funding sources, 18 including CDBG, CITY must submit a copy of its most recent audit to the COUNTY. 19 B. If CITY currently conducts audits of its other funding sources but 20 has neither received nor included CDBG in the past, the scope of the audit would be 21 modified to incorporate CDBG audit requirements. 22 C. If CITY does not have a current audit process in place, your agency 23 will be required to develop a process that meets the DIRECTOR's approval. 24 2. CITY agrees to obtain an annual audit within 180 days after the end of 25 each fiscal year. Copies of said audit shall be transmitted to the COUNTY within 30 26 days after being received and approved by the CITY. DIRECTOR shall have the right 27 to ensure that necessary corrective actions are made by the CITY for any audit findings 28 pertinent to CITY handling of funding attributable to the CDBG Program per Federal 29 requirements. -10- Contract No. EC41972 1 3. All CITY records with respect to any matters covered by this Contract 2 shall be made available to the COUNTY or the United States government at any time 3 1 during the normal business hours, as often as the COUNTY deems necessary to audit, 4 lexamine or make excerpts or transcripts of relevant data. Any deficiencies noted in 5 audit reports must be fully cleared by the CITY within 30 days after the receipt by the 6 CITY. Failure of the CITY to comply with the above audit requirements will 7 constitute a violation of this contract and may result in the withholding of future 8 payments. The CITY hereby agrees to have an annual agency audit conducted in 9 accordance with current COUNTY policy concerning CITY audits and, as applicable, 10 OMB Circulars A-133 and OMB Circular A-128. -11- Contract No. EC41972 1 IN WITNESS WHEREOF, CITY has caused this Contract to be executed by its 2 Mayor and attested by its Clerk; COUNTY has caused this Contract to be executed by 3 the Director of EMA/Housing and Redevelopment, all having been duly authorized 4 by the City Council of CITY and the Orange County Board of Supervisors. 5 6 APPROVED AS TO FORM: City of San Juan Capistrano, a municipal 7 corporation in a State of California 8 CITY ORN Y 9 10 By: 11 Dated: / 4 12 G rge S rborough Date 10/15/96 13 Ci y Man ger 14 15 ATTEST: 16 17 18 19 CiVf Clerk' 20 COUNTY OF ORANGE, a political 21 subdivision of the State of California 22 23 24 25 Dated: l >K� �� By: 26 27 EMA-Housing and Redevelopment 28 Bob Wilson, Director 29 30 31 ORIGINAL FORM CONTRACT 32 APPROVED AS TO FORM: May 22, 1996 33 34 COUNTY COUNSEL 35 ORANGE COUNTY, CALIFORNIA 36 37 MC YR XXII 7/28/96 -12- • Exhibit "A" to COUNTVUBRECIPIENT Contract 1 GENERAL CONDITIONS 2 3 I. GENERAL PROVISIONS 4 A. General Compliance 5 The SUBRECIPIENT agrees to comply with all applicable federal, state and local laws 6 and regulations governing the funds provided under this contract. 7 B. Independent Contractor 8 Nothing contained in this Contract is intended to, or shall be construed in any manner, as 9 creating or establishing the relationship of employer/employee between the parties. The 10 SUBRECIPIENT shall at all times remain an independent contractor with respect to the services to 11 be performed under this Contract. The COUNTY shall be exempt from payment of all 12 Unemployment Compensation, FICA, retirement, life and/or medical insurance and Workers' 13 Compensation Insurance as the SUBRECIPIENT is an independent contractor. 14 C. Hold Harmless 15 The SUBRECIPIENT shall hold harmless, defend and indemnify the GRANTEE from 16. any all claims, actions, suits, charges and judgments whatsoever that arise out of the 17 SUBRECIPIENT's performance or nonperformance of the services or subject matter called for in 18 this Contract. 19 D. Workers' Compensation 20 The SUBRECIPIENT shall provide Workers' Compensation Insurance coverage for all 21 employees involved in the performance of this contract. 22 E. Insurance& Bondins 23 The SUBRECIPIENT shall carry sufficient insurance coverage to protect contract assets 24 from loss due to theft, fraud and/or undue physical damage, and as a minimum shall purchase a 25 blanket fidelity bond covering all employees in an amount equal to cash advances from the 26 COUNTY. 27 The SUBRECIPIENT shall comply with the bonding and insurance requirements of 28 Attachment B of OMB Circular A-110, Bonding and Insurance. 29 -I- Exhibit "A" to COUNT',— UBRECIPIENT Contract 1 F. Grantor Recognition 2 The SUBRECIPIENT shall insure recognition of the role of the grantor agency in 3 providing services through this Contract. All activities, facilities and items utilized pursuant to this 4 Contract shall be prominently labeled as to funding source. In addition, the SUBRECIPIENT will 5 include a reference to the support provided herein in all publications made possible with funds made 6 available under this Contract. 7 G. Amendments 8 COUNTY or SUBRECIPIENT may amend this Contract at any time provided that such 9 amendments make specific reference to this Contract, and are executed in writing, signed by a duly 10 authorized representative of both organizations. Such amendments shall not invalidate this Contract, 11 nor relieve or release COUNTY or SUBRECIPIENT from its obligations under this Contract. Any 12 proposed amendment to this Contract shall be submitted to and approved by the COUNTY, prior to 13 commencement by COUNTY of any activity covered by said amendment. 14 COUNTY may, in its discretion, amend this Contract to conform with federal, state or 15 local governmental guidelines, policies and available funding amounts, or for other reasons. If such 16 amendments result in a change in the funding, the scope of services, or schedule of, the activities to 17 be undertaken as part of this Contract, such modifications will be incorporated only by written 18 amendment signed by a duly authorized representative of both organizations. 19 H. Suspension or Termination 20 In the event of SUBRECIPIENT's failure to comply with the provisions of this Contract 21 and pursuant to 24 CFR 85.43 and 85.44, COUNTY may withhold or require SUBRECIPIENT 22 reimbursement of funds, and/or terminate this Contract, and/or allocate funds previously assigned to 23 this Contract to another eligible project(s) within the Urban County. 24 Either party may terminate this Contract at any time by giving written notice to the other 25 party of such termination and specifying the effective date thereof at least 30 days before the effective 26 date of such termination. In the event of any termination for convenience, all finished or unfinished 27 documents, data, studies, surveys, maps, models, photographs, reports or other materials prepared 28 by SUBRECIPIENT under this Contract shall, at the option of the COUNTY become the property of -2- • Exhibit "A" to COUNT VPBRECIPIENT Contract 1 the COUNTY, and SUBRECIPIENT shall be entitled to receive just and equitable compensation for 2 any satisfactory work completed on such documents or materials prior to the termination. 3 COUNTY may also suspend or terminate this Contract, in whole or in part, if 4 SUBRECIPIENT materially fails to comply with any term of this Contract, or with any of the rules, 5 regulations or provisions referred to herein; and the COUNTY may declare the SUBRECIPIENT 6 ineligible for any further participation in COUNTY contracts, in addition to other remedies as 7 provided by law. In the event there is probable cause to believe the SUBRECIPIENT is in 8 noncompliance with any applicable rules or regulations, the COUNTY may withhold contract funds 9 until such time as the SUBRECIPIENT is found to be in compliance by the COUNTY, or is 10 otherwise adjudicated to be in compliance. 11 II. ADMINISTRATIVE REQUIREMENTS 12 A. Financial Management 13 1. Accounting Standards 14 The SUBRECIPIENT agrees to comply with Attachment C of OMB Circular A-110 15 and agrees to adhere to the accounting principles and procedures required therein, utilize adequate 16, internal controls, and maintain necessary source documentation for all costs incurred. 17 2. Cost Principles 18 The SUBRECIPIENT shall administer its program in conformance with OMB 19 Circulars A-122, "Cost Principles for Non-Profit Organizations," or A-21, "Cost Principles for 20 Educational Institutions," (and if the SUBRECIPIENT is a governmental or quasi-governmental 21 agency, the applicable sections of 24 CFR Part 85, "Uniform Administrative Requirements for 22 Grants and Cooperative Agreements to State and Local Governments,") as applicable. These 23 principles shall be applied for all costs incurred whether charged on a direct or indirect basis. 24 B. Documentation and Record-Keeping 25 1. Records to be Maintained 26 The SUBRECIPIENT shall maintain all records required by the Federal regulations 27 specified in 24 CFR Parts 570.503(b)(2), 570.506, 570.507 and 570.508 and that are pertinent to 28 the activities to be funded under this Contract. Such records shall include but not be limited to: 29 30 a. Records providing a full description of each activity undertaken; -3- Exhibit "A" to COUNT`UB RECIPIENT Contract 1 b. Records demonstrating that each activity undertaken meets one of the National 2 Objectives of the CDBG program; 3 c. Records required to determine the eligibility of activities; 4 d. Records required to document the acquisition, improvement, use or disposition 5 of real property acquired or improved with CDBG assistance; 6 e. Records documenting compliance with the fair housing and equal opportunity 7 components of the CDBG program; 8 f. Financial records as required by 24 CFR Part 570.502, and OMB Circular 9 A-110; and 10 g. Other records necessary to document compliance with Subpart K of 11 24 CFR 570. 12 These records shall be kept available at SUBRECIPIENT's office during the project's 13 contract period and thereafter for three (3) years from the date SUBRECIPIENT receives final 14 payment from this contract. 15 2. Retention 16 The SUBRECIPIENT shall retain all records pertinent to expenditures incurred under 17 this contract for a period of three (3) years after the termination of all activities funded under this 18 Contract, or after the resolution of all Federal audit findings, which ever occurs later. Records for 19 non-expendable property acquired with funds under this Contract shall be retained for three (3)years 20 after final disposition of such property. Records for any displaced person must be kept for three (3) 21 years after he/she has received final payment. 22 3. Client Data 23 The SUBRECIPIENT shall maintain client data demonstrating client eligibility for 24 services provided. Such data shall include, but not be limited to, client name,address,income level 25 or other basis for determining eligibility, and description of service provided. Such information shall 26 be made available to COUNTY monitors or their desienees for review upon request. 27 4. Property Records 28 The SUBRECIPIENT shall maintain real property inventory records which clearly 29 identify properties purchased, improved or sold. Properties retained shall continue to meet eligibilityll -4- 0 Exhibit "A" to COUNT&UB RECIPIENT Contract 1 criteria and shall conform with the "changes in use" restrictions specified in 24 CFR Parts 2 570.503(b)(8). 3 5. National Obiectives 4 The SUBRECIPIENT agrees to maintain documentation that demonstrates the 5 activities carried out with funds provided under this Contract meet one or more of the CDBG 6 program's national objectives: 1) benefit low/moderate income persons, 2) aid in the prevention or 7 elimination of slums or blight, 3) meet community development needs having a particular urgency - 8 as defined in 24 CFR Part 570.208. 9 6. Close-Outs 10 SUBRECIPIENT obligation to the COUNTY shall not end until all close-out 11 requirements are completed. Activities during this close-out period shall include, but are not limited 12 to: making final payments, disposing of program assets (including the return of all unused materials 13 and equipment), unspent cash advances, program income balances, and receivable accounts to the 14 COUNTY and determining the custodianship of records. 15 7. Audits & Inspections 16 All SUBRECIPIENT records with respect to any matters covered by this Contract 17 shall be made available to the COUNTY, grantor agency, their designees or the Federal Government, 18 at any time during normal business hours, as often as the COUNTY or grantor agency deems 19 necessary, to audit, examine, and make excerpts or transcripts of all relevant data. Any deficiencies 20 noted in audit reports must be fully cleared by the SUBRECIPIENT within 30 days after receipt by 21 the SUBRECIPIENT. Failure of the SUBRECIPIENT to comply with the above audit requirements 22 will constitute a violation of this Contract and may result in the withholding of future payments. The 23 SUBRECIPIENT hereby agrees to have an annual agency audit conducted in accordance with 24 current COUNTY policy concerning SUBRECIPIENT audits. 25 C. Reporting and Payment Procedures 26 1. Budeets 27 The SUBRECIPIENT shall submit a derailed contract budget (the form and content to 28 be prescribed by the COUNTY) for approval by the COUNTY. The COUNTY and the -5- Exhibit "A" to COUNT` - UBRECIPIENT Contract 1 SUBRECIPIENT may agree to revise the budget from time to time in accordance with existing 2 COUNTY policies. 3 2. Program Income 4 The SUBRECIPIENT shall report quarterly all program income as defined at 24 CFR 5 570.500(a) generated by activities carried out with CDBG funds made available under this Contract. 6 The use of program income by the SUBRECIPIENT shall comply with the requirements set forth at 7 24 CFR 570.504. By way of further limitation, the SUBRECIPIENT may use such income during 8 the contract period for activities permitted under this Contract and shall reduce requests for additional 9 funds by the amount of any such program income balances on hand. All unused program income 10 shall be returned to the COUNTY at the end of the contract period. Any interest earned on cash I 1 advances from the U.S. Treasury is not program income and shall be remitted promptly to the 12 COUNTY. 13 Program income generated from cash advance and/or the mere holding of CDBG 14 funds must be paid to the COUNTY per 24 CFR 570.504(c) for subsequent return to HUD. 15 Any program income generated from the sale, transfer or change in the use of assets 16 (e.g. real property) acquired or improved in whole or in part by CDBG funds must be returned to the 17 COUNTY in proportion to the CDBG contribution thereof. 18 The SUBRECIPIENT may retain all program income provided that program income 19 is used exclusively for eligible activities, as determined by the "DIRECTOR" , and is done so in 20 accordance with all applicable CDBG requirements. 21 SUBRECIPIENT shall keep and maintain appropriate records on the use of any such 22 program income as may be required by EMA staff since the COUNTY has the responsibility of 23 monitoring and repotting program income to HUD. 24 In the event of SUBRECIPIENT close-out or change in status of the participating 25 SUBRECIPIENT in the Urban County CDBG Program, any program income at that time or 26 received subsequent to the close-out or change in status shall be paid by SUBRECIPIENT to the 27 COUNTY within 90 days thereafter. 28 29 -6- • Exhibit "A" to COUNTOUBRECIPIENT Contract 1 3. Indirect Costs 2 If indirect costs are charged, the SUBRECIPIENT will develop an indirect cost 3 allocation plan for determining the appropriate COUNTY share of administrative costs and shall 4 submit such plan to the COUNTY for approval. 5 4. Payment Procedures 6 a. The COUNTY will pay to the SUBRECIPIENT funds available under this 7 Contract based upon information submitted by the SUBRECIPIENT and consistent with any 8 approved budget and COUNTY policy concerning payments. With the exception of certain 9 advances, payments will be made for eligible expenses actually incurred by the SUBRECIPIENT, 10 and not to exceed actual cash requirements. Payments will be adjusted by the COUNTY in 11 accordance with advance fund and program income balances available in SUBRECIPIENT accounts. 12 In addition, the COUNTY reserves the right to liquidate funds available under this Contract for costs 13 incurred by the COUNTY on behalf of the SUBRECIPIENT. 14 b. Payment by the COUNTY to SUBRECIPIENT shall be on a reimbursable basis 15 unless SUBRECIPIENT has been authorized and issued a cash advance at the discretion of the 16 DIRECTOR under this Contract. 17 c. The SUBRECIPIENT is permitted one (1) cash advance under this Contract and 18 it may be made by the DIRECTOR to SUBRECIPIENT if the following conditions are met: 19 (1) SUBRECIPIENT has demonstrated to DIRECTOR through certification 20 in a form prescribed by DIRECTOR and subsequently through performance, its willingness and 21 capacity to establish SUBRECIPIENT financial procedures that will minimize the time elapsing 22 between the receipt of funds and proper disbursement of such funds. 23 (2) SUBRECIPIENT certifies to DIRECTOR, that SUBRECIPIENT's 24 financial management system meets the standards for fund control and accountability as directed in 25 24 CFR 570.502(a), if a governmental Subrecipient, and 24 CFR 570.502(b), if a non- 26 governmental recipient; and as prescribed in Office of Management and Budget Circular A-87, if a 27 governmental Subrecipient, and Office of Management and Budget Circulars A-122 and A-21 if a 28 non-governmental Subrecipient, as periodically amended. -7- Exhibit "A" to COUNT` UBRECIPIENT Contract 1 (3) SUBRECIPIENT complies with EMA financial cash advance procedures, 2 procedures defined by HUD in 24 CFR 85.21 Payment Regulations and the United States Treasury 3 regulations described in 31 CFR Part 205. These procedures require that upon written receipt of 4 funds from the COUNTY, SUBRECIPIENT shall disburse payment(s) to vendor(s) within five (5) 5 working days and submit evidence of such disbursement(s) (i.e., warrant copies, etc.) to the 6 DIRECTOR. 7 d. If SUBRECIPIENT is subsequently found, by DIRECTOR, to be in 8 noncompliance with Section II. C. 4.c.(1) through Section II. C. 4.c.(3), SUBRECIPIENT shall in 9 the future be paid on a reimbursable basis. 10 e. Reimbursable basis payments, as referred to in Section 6.a. and/or cash advance 11 described in Section 6.b. shall be made in accordance with EMA financial procedures. In the event 12 of conflict between EMA financial procedures and any applicable statutes, rules or regulations of 13 HUD, including Office of Management and Budget Circular No. A-87, if a governmental 14 Subrecipient, and Office of Management Budget Circular's A-122 and A-21, if a non-governmental, 15 the latter shall prevail. 16 Where contract funds are withheld, and at the request and expense of SUBRECIPIENT, 17 COUNTY will accept securities equivalent to the amount withheld. Such substituted security, 18 meeting the requirements of Government Code Section 4590, shall be deposited with COUNTY,or 19 with a State or Federally chartered bank as escrow agent. If security is deposited with an escrow 20 agent, it shall be covered by an escrow agreement. 21 5. Progress s Reports 22 The SUBRECIPIENT shall submit regular Progress Reports to the COUNTY in the 23 form, content,and frequency as required by the COUNTY. 24 D. Procurement 25 1. Compliance 26 The SUBRECIPIENT shall comply %% ith current COUNTY policy concerning the 27 purchase of equipment and shall maintain an inventory record of all non-expendable personal 28 property as defined by such policy as may be pros.;ied with funds provided herein. All program -8- / • Exhibit "A" to COUNOSUBRECIPIENT Contract 1 assets (unexpended program income, property, equipment, etc.) shall revert to the COUNTY upon 2 termination of this Contract. 3 2. OMB Standards 4 The SUBRECIPIENT shall procure materials in accordance with the requirements of 5 Attachment O of OMB Circular A-110. Procurement Standards, and shall subsequently follow 6 Attachment N, Property Management Standards, covering utilization and disposal of property. 7 3. Travel 8 The SUBRECIPIENT shall obtain written approval from the COUNTY for any travel 9 outside the metropolitan area with funds provided under this Contract. 10 4. Relocation. Acquisition and Displacement 11 The SUBRECIPIENT agrees to comply with 24 CFR 570.606 relating to the 12 acquisition and disposition of all real property utilizing grant funds, and to the displacement of 13 persons, businesses, nonprofit organizations and farms occurring as a direct result of any acquisition 14 of real property utilizing grant funds. The SUBRECIPIENT agrees to comply with applicable 15 COUNTY Ordinances, Resolutions, and Policies concerning displacement of individuals from their 16 residences. 17 III. PERSONNEL & PARTICIPANT CONDITIONS 18 A. Civil Rights 19 1. Compliance 20 The SUBRECIPIENT agrees to comply with Title VI of the Civil Rights Act of 1964 21 as amended, Title VIII of the Civil Rights Act of 1968 as amended, Section 109 of the Title I of the 22 Housing and Community Development Act of 1974, Section 504 of the Rehabilitation Act of 1973, 23 the Americans with Disabilities Act of 1990, the Age Discrimination Act of 1975, Executive Order 24 11063, and with Executive Order 11246 as amended by Executive Orders 11375 and 12086. 25 2. Nondiscrimination 26 The SUBRECIPIENT will not discriminate against any employee or applicant for 27 employment because of race, color, creed, religion, ancestry, national origin, sex, disability or other 28 handicap, age, marital status, or status with regard to public assistance. The SUBRECIPIENT will 29 take affirmative action to insure that all employment practices are free from such discrimination. -9- Exhibit "A" to COUNT""UBRECIPIENT Contract 1 Such employment practices include but are not limited to the following: hiring, upgrading, demotion, 2 transfer, recruitment or recruitment advertising, layoff, termination, rates of pay or other forms of 3 compensation, and selection for training, including apprenticeship. The SUBRECIPIENT agrees to 4 post in conspicuous places, available to employees and applicants for employment, notices to be 5 provided by the contracting agency setting forth the provisions of this nondiscrimination clause. 6 3. Section 504 7 The SUBRECIPIENT agrees to comply with any federal regulations issued pursuant 8 to compliance with Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. 706) which prohibits 9 discrimination against the handicapped in any federally assisted program. The COUNTY shall 10 provide the SUBRECIPIENT with any guidelines necessary for compliance with that portion of the I 1 regulations in force during the term of this Contract. 12 B. Affirmative Action 13 1. Approved Plan 14 The SUBRECIPIENT agrees that it shall be committed to carry out, in accordance 15 with COUNTY specifications, an Affirmative Action Program that encompasses the principles 16 provided in President's Executive Order 11246 of September 24, 1965. The (Grantee) shall provide 17 Affirmative Action guidelines to the SUBRECIPIENT to assist in the formulation of such program. 18 The SUBRECIPIENT shall submit a plan for an Affirmative Action Program.for approval prior to 19 the award of funds. 20 2. W/MBE 21 The SUBRECIPIENT will use its best efforts to afford minority and women-owned 22 business enterprises the maximum practicable opportunity to participate in the performance of this 23 Contract. As used in this contract, the term "minority and female business enterprise" means a 24 business at least fifty-one (5 1)percent owned and controlled by minority group members or women. 25 For the purpose of this definition, "minority group members" are Afro-Americans, Spanish 26 speaking, Spanish surnamed or Spanish-heritage Americans, Asian-Americans, and American 27 Indians. The SUBRECIPIENT may rely on written representations by SUB-SUBRECIPIENTs 28 regarding their status as minority and female bumness enterprises in lieu of an independent 29 investigation. -10- ' • Exhibit "A" to COUNIS,UBRECIPIENT Contract 1 3. Access to Records 2 The SUBRECIPIENT shall furnish and cause each of its sub-SUBRECIPIENTs to 3 furnish all information and reports required hereunder and will permit access to its books, records 4 and accounts by the COUNTY, HUD or its agents, or other authorized Federal officials for purposes 5 of investigation to ascertain compliance with the rules, regulations and provisions stated herein. 6 4. Notifications 7 The SUBRECIPIENT will send to each labor union or representative of workers with 8 which it has a collective bargaining Contract or other contract or understanding, a notice, to be 9 provided by the agency contracting officer, advising the labor union or worker's representative of the 10 SUBRECIPIENT's commitments hereunder, and shall post copies of the notice in conspicuous I 1 places available to employees and applicants for employment. 12 5. EEO/AA Statement 13 The SUBRECIPIENT will, in all solicitations or advertisements for employees placed 14 by or on behalf of the SUBRECIPIENT, state that it is an Equal Opportunity or Affirmative Action 15 employer. 16 6. Subcontract Provisions 17 The SUBRECIPIENT will include the provisions of Paragraphs VIII A, Civil Rights, 18 and B, Affirmative Action, in every subcontract or purchase order, specifically or by reference, so 19 that such provisions will be binding upon each subSUBRECIPIENT or vendor. 20 C. Emplovment Restrictions 21 1. Prohibited Activity 22 The SUBRECIPIENT is prohibited from using funds provided herein, or personnel 23 employed in the administration of the program, for: political activities, sectarian or religious 24 activities, lobbying,political patronage,and nepotism activities. 25 2. OSHA 26 Where employees are engaged in activities not covered under the Occupational Safety 27 and Health Act of 1970, they shall not be required or permitted to work, be trained, or receive 28 services in buildings or surroundings or under working conditions which are unsanitary, hazardous 29 1 or dangerous to the participants' health or safety. -11- Exhibit "A" to COUNTY iBRECIPIENT Contract 1 3. Labor Standards 2 The SUBRECIPIENT agrees to comply with the requirements of the Secretary of 3 Labor in accordance with the Davis-Bacon Act as amended, the provisions of Contract Work Hours, 4 the Safety Standards Act, the Copeland"Anti-Kickback" Act (40 U.S.C. 276, 327-333) and all other 5 applicable federal, state and local laws and regulations pertaining to labor standards insofar as those 6 acts apply to the performance of this Contract. The SUBRECIPIENT shall maintain documentation 7 which demonstrates compliance with hour and wage requirements of this part. Such documentation 8 shall be made available to the COUNTY for review upon request. 9 The SUBRECIPIENT agrees that, except with respect to the rehabilitation or 10 construction of residential property designed for residential use for less than eight(8) households, all 11 contractors engaged under contracts in excess of$2,000.00 for construction, renovation or repair of 12 any building or work financed in whole or in part with assistance provided under this contract, shall 13 comply with federal requirements adopted by the COUNTY pertaining to such contracts and with the 14 applicable requirements of the regulations of the Department of Labor, under 29 CFR, Parts 3, 1, 5 15 and 7 governing the payment of wages and ratio of apprentices and trainees to journeymen; 16 provided, that if wage rates higher than those required under the regulations are imposed by state or 17 local law, nothing hereunder is intended to relieve the SUBRECIPIENT of its obligation, if any, to 18 require payment of the higher rate. The SUBRECIPIENT shall cause or require to be insetted in 19 full, in all such Contracts subject to such regulations, provisions meeting the requirements of this 20 paragraph, for such Contracts in excess of$10,000.00. 21 4. "Section 3"Clause 22 a. Compliance 23 Compliance with the provisions of Section 3, the regulations set forth in 24 CFR 24 135, and all applicable rules and orders issued hereunder prior to the execution of this Contract, shall 25 be a condition of the federal financial assistance provided under this Contract and binding upon the 26 COUNTY, the SUBRECIPIENT and any subSUBRECIPIENTs. Failure to fulfill these 27 requirements shall subject the COUNTY, the SUBRECIPIENT and any subSUBRECIPIENTs, 28 their successors and assigns, to those sanctions specified by the Contract through which federal -12- 1 • Exhibit "A" to COUN'MUBRECIPIENT Contract 1 assistance is provided. The SUBRECIPIENT certifies and agrees that no contractual or other 2 disability exists which would prevent compliance with requirements. 3 The SUBRECIPIENT further agrees to comply with these "Section 3" 4 requirements and to include the following language in all subcontract executed under this Contract: 5 "The work to be performed under this Contract is a project assigned under a 6 program providing direct federal financial assistance from HUD and is subject to the requirements of 7 Section 3 of the Housing and Urban Development Act of 1968, as amended, 12 U.S.C. 1701. 8 Section 3 requires that to the greatest extent feasible opportunities for training and employment be 9 given to lower income residents of the project area and contracts for work in connection with the 10 project be awarded to business concerns which are located in, or owned in substantial part by 1 I persons residing in the areas of the project." 12 The SUBRECIPIENT certifies and agrees that no contractual or other disability 13 exists which would prevent compliance with the requirements. 14 b. Notifications 15 The SUBRECIPIENT agrees to send to each labor organization or representative 16 of workers with which it has a collective bargaining Contract or other contract or understanding, if 17 any, a notice advising said labor organization or worker's representative of its commitments under 18 this Section 3 clause and shall post copies of the notice in conspicuous places available to employees 19 and applicants for employment or training. 20 c. Subcontracts 21 The SUBRECIPIENT will include Section 3 clause in every subcontract and will 22 take appropriate action pursuant to the subcontract upon a finding that the subSUBRECIPIENT is in 23 violation of regulations issued by the Grantor Agency. The SUBRECIPIENT will not subcontract 24 with any subSUBRECIPIENT where it has notice or knowledge that the latter has been found in 25 violation of regulations under 24 CFR 135 and will not let any subcontract unless the 26 subSUBRECIPIENT has first provided it with a preliminary statement of ability to comply with the 27 requirements of these regulations. 28 29 -13- Exhibit "A" to COUNTY—'J B RECIPIENT Contraci 1 D. Conduct 2 1 . Assignabilitv 3 The SUBRECIPIENT shall not assign or transfer any interest in this Contract without 4 the prior written consent of the COUNTY thereto; provided, however, that claims for money due or 5 to become due to the SUBRECIPIENT from the COUNTY under this Contract may be assigned to a 6 bank, trust company, or other financial institution without such approval. Notice of any such 7 assignment or transfer shall be furnished promptly to the COUNTY. 8 2. Hatch Act 9 The SUBRECIPIENT agrees that no funds provided, nor personnel employed under 10 this Contract, shall be in any way or to any extent engaged in the conduct of political activities in I 1 violation of Chapter 15 of Title V United States Code. 12 3. Conflict of Interest 13 The SUBRECIPIENT agrees to abide by the provisions of 24 CFR 570.611 with 14 respect to conflicts of interest, and covenants that if presently has no financial interest and shall not 15 acquire any financial interest, direct or indirect, which would conflict in any manner or degree with 16 the performance of services required under this,Contract. The SUBRECIPIENT further covenants 17 that in the performance of this Contract no person having such a financial interest shall be employed 18 or retained by the SUBRECIPIENT hereunder. These conflict of interest provisions apply to any 19 person who is an employee, agent, consultant, officer, or elected official or appointed official of the 20 COUNTY or of any designated public agencies or SUBRECIPIENTs which are receiving funds 21 under the CDBG Entitlement program. 22 4. Subcontracts 23 a. Approvals 24 The SUBRECIPIENT shall not enter into any subcontracts with any agency or 25 individual in the performance of this Contract without the written consent of the COUNTY prior to 26 the execution of such Contract. 27 b. Monitoring 28 The SUBRECIPIENT will monitor all subcontracted services on a regular basis 29 to assure contract compliance. Result of monitoring efforts shall be summarized in written reports -14- Exhibit "A" to COUNTOUBRECIPIENT Contract I and supported with documented evidence of follow-up actions taken to correct areas of the 2 noncompliance. 3 c. Content 4 The SUBRECIPIENT shall cause all of the provisions of this Contract in its 5 entirety to be included in and made a part of any subcontract executed in the performance of this 6 Contract. 7 d. Selection Process 8 The SUBRECIPIENT shall undertake to insure that all subcontracts awarded in 9 the performance of this Contract shall be awarded on a fair and open competition basis. Executed 10 copies of all subcontracts shall be forwarded to the COUNTY along with documentation concerning 11 the selection process. 12 5. Copyright 13 If this contract results in any copyrightable material, the COUNTY and/or grantor 14 agency reserves the right to royalty-free, non-exclusive and irrevocable license to reproduce,publish 15 or otherwise use and to authorize others to use, the work for government purposes. 16 6. Religious Oreanization 17 The SUBRECIPIENT agrees that funds provided under this contract will not be 18 utilized for religious activities, to promote religious interest, or for the benefit of a religious 19 organization in accordance with the federal regulations specified in 24 CFR 570.2000). 20 IV. ENVIRON-MENTAL CONDITIONS 21 A. Air and Water 22 The SUBRECIPIENT agrees to comply with the following regulations insofar as they 23 apply to the performance of this Contract: 24 o Clean Air Act, 42 U.S.C., 1857, et seq. 25 o Federal Water Pollution Control Act, as amended, 33 U.S.C. 1251, et seq., as 26 amended 1318 relating to inspection, monitoring, entry, reports, and information, as well as other 27 requirements specified in said Section 114 and Section 308, and all regulations and guidelines issued 28 thereunder. -15- Exhibit "A" to COUNT- 'SUBRECIPIENT Contract 1 o Environmental Protection Agency (EPA) regulations pursuant to 40 C.F.R, Parts 2 50 and 58, as amended. 3 o National Environmental Policy Act of 1969. 4 o HUD Environmental Review Procedures (24 CFR, Part 58). 5 o California Environmental Quality Act 6 B. Flood Disaster Protection 7 The SUBRECIPIENT agrees to comply with the requirements of the Flood Disaster 8 Protection Act of 1973 (P.L. 2234) in regard to the sale, lease or other transfer of land acquired, 9 cleared or improved under the terms of this contract, as it may apply to the provisions of this 10 contract. 11 C. Lead-Based Paint 12 The SUBRECIPIENT agrees that any construction or rehabilitation of residential 13 structures with assistance provided under this contract shall be subject to HUD Lead-Based Paint . 14 Regulations at 24 CFR 570.608, and 24 CFR Part 35, and in particular Sub-Part B thereof. Such 15 regulations pertain to all HUD-assisted housing and require that all owners, prospective owners, and 16 tenants or properties constructed prior to 1978 be properly notified that such properties may include 17 lead-based paint. Such notification shall point out the hazards of lead-based paint and explain the 18 symptoms, treatment and precautions that should be taken when dealing with lead-based paint 19 poisoning. 20 D. Historic Preservation 21 The SUBRECIPIENT agrees to comply with the Historic Preservation requirements set 22 forth in the National Historic Preservation Act of 1966, as amended (16 U.S.C. 470) and the 23 procedures set forth in 36 CFR, Part 800, Advisory Council on Historic Preservation Procedures for 24 Protection of Historic Properties, insofar as they apply to the performance of this contact. 25 In general, this requires concurrence from the State Historic Preservation Officer for all 26 rehabilitation and demolition of historic properties that are fifty years old or older or that are included 27 on a Federal, State, or local historic property list. 28 29 GS/BJGMW5A2-5 30 (4/2/96) 31 -16- rqF ' �,, � E EXHIBIT B e 320.26 � _� 320.22 4t* CITYWIDE BENEFIT . �1 c Q lf Z 4 3.15 ,O \ Z �4 --A26 , 320. e 4 3.12 s + 23.21 423.11 \ 0.23 1 r� r r � r � b r � 04" °0' 8 4 x400 T F'�\ 1111 0 ^,� .JJJ.11L Jl dd ^VIJN I r 422.04 0 422.03 lion 22.Or��� ' 421.05 r 3.11 e, _ ♦" , a t . rp N.¢,&*S , 23.1 o• a 422.03 P �pS RAMBIpS ♦" �pQ,F'S 4, , uwn S, 421.05 422.04 City Boundary SCALE: 7'-3300' Census Trac: Boundary SAN JUAN CAPISTRANO Housing & Redevelopment ENVIP.ON?vSENTA.I. 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