IM I I - - - - - - I - - - I NOTICE OF THE CITY COUNCIL - REGULAR MEETING The City Council for the City of Simonton, Texas, will hold its City Council - Regular Meeting on June 17, 2025, at 6:30 PM at Simonton City Hall, 35011 FM 1093, Simonton, Texas 77476, for the purpose of considering the following: 1. Call to Order 2. Invocation and Pledge 3. Public Comments In accordance with the Texas Open Meetings Act and Texas Government Code 551.007, the City Council may not discuss or take action on any item NOT listed on the Agenda. Each member of the public wishing to speak must sign in prior to the meeting and is limited to 3 minutes. In accordance with the City Council's Adopted Resolution 2023-01, Conduct ofMeeting for Council and Public Comments, all attendees are respectfully reminded of the City Council's commitment to decorum and mutual respect. 4. Consider and take action on the Consent Agenda Items listed under the Consent Agenda are considered routine and are generally enacted in one motion. The exception to this rule occurs when a Council Member requests one or more items removed, from the Consent Agenda for separate discussion and action. a. Minutes ofMay 20th, 3 2025, Regular City Council Meeting b. Monthly Payment Report (Income)- March C. Monthly Council Report (Payments)- March d. Monthly Revenue and Expense Report- March e. Monthly Payment Report (Income)- April f. Monthly Council Report (Payments)- April g. Monthly Revenue and Expense Report- April h. Monthly Sales Tax Report- May i. Consider and take action to Approve the Resolution Designating Authorized Signatories for Contractual and Financial Documents pertaining to the GLO Community Development Block Grant - Mitigation (CDBG-MIT) Method ofDistribution (MOD) Program, Contract # 24-065-168-F083, j. Consider and adopt Local Procurement Policies & Procedures pertaining to the GLO Community Development Block Grant Mitigation (CDBG-MIT) Method of] Distribution (MOD) Program, Infrastructure Contract Number #24-063-168-F083. k. Consider and adopt Local Financial Policy & Procedures pertaining to the GLO Community Development Block Grant - Mitigation (CDBG-MIT) Method of Distribution (MOD) Program, Infrastructure Contract Number #24-065-168-F083 1. Consider and take action to Adopt the Resolution Regarding the Civil Rights Policies for the GLO Community Development Block Grant - Mitigation (CDBG-MIT) Method of Distribution (MOD) Program, Contract 24-065-168-F083. m. Proclamation declaring July 2025 as the City of Simonton's Fair Housing Month. n. Consider, and take action to approve Amendment #1 for the Grant Administration Services contract for the Community Development Block Grant - Mitigation (CDBG-MIT) Method of Distribution (MOD) Program Contract Number # 24-065-168-F083. 5. New Business a. Guest Hollyn Keith representing 2535 of Simonton Community Church, a Christ Clinic Initiative. b. Consider and take action to approve Roadway Clearance Pruning and Tree Removals in Valley Lodge, Section 1 for $12,690.00. 6. Adjourn to Executive (Closed) Session Section 551.071 - Consultation with Legal Counsel Section 551.074 ofthe Texas Government Code to deliberate the appointment, employment, evaluation, reassignment, duties, discipline, or dismissal ofa public officer or employee: the City Secretary and Julie Watts. No action shall be taken during this closed session. 7. Reconvene to Open Session 8. Consider and take action resulting from the Executive Session. 9. Reports a. Mayor b. City Council C. City Attorney d. City Staff 10. Next City Council Meeting July 1, 2025, 6:30 pm. 11. Adjournment I, the undersigned, Mayor of the City of Simonton, do hereby certify that on June 13, 2025 I posted a true and correct copy ofthe above and following notice oft the Regular Meeting oft the City of Simonton Council to be held on June 17, 2025 at 6:30 PM at Simonton City Hall, 35011 FM 1093, Simonton, TX 77476, which posting was done not less than seventy-two (72) hours prior to the date fixed for said meeting. Laurie Laurie Boudreaux, Mayor haubvauyf The City Council may hold an Open or Closed meeting by telephone conference call if an emergency or public necessity exists within the meaning of Section 551.045 of the Open Meetings Act, and the convening at one location of a quorum ofthe City Council is difficult or impossible. The City Council may convene into executive session on any matter related to any of the above agenda items for a purpose, such a closed session is allowed under Chapter 551, Texas Government Code. Reasonable accommodationfor, people with disabilities attending this meeting will be available. Persons with disabilities in need of Regular assistance at the meeting should please contact the City Secretary at 281-533-9809 Agendas are posted on the City Website at tp/simontontexasgov. Payment Report - Income 6/12/2025 1:32:37 PM 4b Payment Date: No date entered Post Date: 3/1/2025 - 3/31/2025 Payment Type. Payment Items Amount Paid Permit Payment 9 $972.91 General Deposit 11 $46,301.21 Payment Method Payments Amount Paid Credit Card 6 $632.91 Check 5 $6,332.98 Other 6 $40,308.23 Permit Payment 100-4650 Other Revenue/Genéral Fund Early Registration Fee $40.00 100-4032 Building Permits Flood Plain Review Trade $176.00 100-4032 Building Permits Residential Demolition $300.00 100-4032 Building Permits Sign - Temporary Sign or Banner $50.00 100-4032 Building Permits Temporary Structure (Tents) $250.00 100-4032 Building Permits Vendor Permit $60.00 100-4032 Building Permits. Vendor Renewal $20.00 100-4032 Building Permits X-Residential (Non Dwelling) $76.91 Total $972.91 General Deposit 100-4002 FBC CAD #8 FBC CAD #8 - FBC CAD #8 $4,992.98 500-4700 Miscellaneousincome Keep Simonton Beautiful - KSB O $1,000.00 100-4003 Mixed Beverage - Mixed Beverage - Mixed Beverai $2,033.74 100-4001 Ad Valorem Property Tax - Ad' Valorem $8,312.67 100-4010 Sales Tax: - City's Portion Sales Tax - Sales Tax- City $14,980.92 100-4013 Sales Tax- EDC: 4A Sales Tax Sales Tax- EDC 4A $3,745.22 100-4012 Sales Tax- EDC 4B Sales Tax - Sales Tax- EDC 4B $7,490.46 100-4011 1/4% Sales Tax (Roads) Sales Tax - Sales Tax- Roads $3,745.22 Total $46,301.21 General Ledger Totals Debit Credit 100-1000 Cash / Due From Consolidated Cash $46,296.27 100-2011 Credit Card Fees $22.15 100-4001 Ad Valorem $8,312.67 100-4002 FBC CAD #8 $4,992.98 100-4003 Mixed Beverage $2,033.74 100-4010 Sales:Tax City's Portion $14,980.92 100-4011 1/4% Sales Tax (Roads) $3,745.22 100-4012 Sales Tax- EDC 4B $7,490.46 100-4013. Sales Tax- EDC 4A $3,745.22 100-4032 Building Permits $932.91 6/12/2025 1:32:37 PM 100-4650 Other Revenue/General Fund $40.00 500-1005 Keep Simonton Beautiful $1,000.00 500-4700 Miscellaneous Income $1,000.00 999-1000 Cash $46,296.27 999-2999 Due To Other Funds $46,296.27 Totals $93,592.54 $93,592.54 4i-1 RESOLUTION AUTHORIZING SIGNATORIES Al RESOLUTION BY THE CITY COUNCIL OF THE CITY OF SIMONTON, TEXAS, DESIGNATING AUTHORIZED SIGNATORIES FOR CONTRACTUAL DOCUMENTS AND DOCUMENTS FOR REQUESTING FUNDS PERTAINING TO THE GENERAL LAND OFFICE COMMUNITY DEVELOPMENT BLOCK GRANT - MITIGATION PROGRAM (CDBG-MIT)! METHOD OF DISTRIBUTION (MOD) CONTRACT NUMBER 24-065-168- F083. WHEREAS, THE CITY OF SIMONTON, Texas has received a GLO Community Development Block Grant- Mitigation MOD award to provide Infrastructure Improvements, and; WHEREAS, it is necessary to appoint persons to execute contractual documents and documents for requesting funds from the General Land Office, and; WHEREAS, an original signed. copy of the CDBG-MIT DeposionyAuthorized Signatories Designation Form is to be submitted with a copy of this Resolution, and; WHEREAS, The CITY OF SIMONTON, Texas acknowledges that in the event that an authorized signatory of the City changes (elections, illness, resignations, etc.), the City must provide GLO with the following: ar resolution stating who the new authorized signatory is; and a revised CDBG-MIT Depository/ Authorized Signatories Designation Form. NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SIMONTON, TEXAS, AS FOLLOWS: The Mayor and Mayor Pro-Tem be authorized to execute contractual documents between the General Land Office and the City/County for the Community Development Block Grant - Mitigation MOD Program. The Mayor and City Council Members be authorized to execute the financial documents required for requesting funds approved in the Community Development Block Grant - Mitigation MOD Program. PASSED AND APPROVED BY THE CITY COUNCIL OF CITY OF SIMONTON, TEXAS on 2025. Laurie Boudreaux, Mayor Attest: Julie Watts, Notary 4i-2 COMMUNITY DEVELOPMENT & REVITALIZATION The Texas General Land Office Depositony/Aulhortzed Signatories Designation Form Subreclplent: CITY OF SIMONTON Contract Number: 24.065-168-F083 The individuals below are. designated by resolution as authorized signatories for contractual. documents. At least two signatories required. Laurie Boudreaux Justin Boudreau Name Name Mayor Mayor Pro Tem Title Title Signature Signature Name Name Title Title Signature Signature The financial lending institution listed here will serve as the depository for the Texas General Land Office-Disaster. Recovery Program Community Development Block Grant (CDBG) funds: SUME a a a a New First Bank Name of Lending Institution Fund Account Number 2214 Avenue H Rosenburg, TX 77471 Address City, State, Zip Code The individuals below are designated by resolution as authorized signatories for financial documents. At least two signatories required. Laurie Boudreaux Kelli Carlson Name Name Mayor City Council Member Title Title : Signature Signature COMMUNITY DEVELOPMENT & REVITALIZATION The Texas General Land Office DeposionylAuthorized. Signatories Designation Form Name Name Title Title Signature Signature NOTE:: A copy of a Resolution passed byt the city council or county commissioners court authorizing the signatories must be submitted along with this form. Disclaimer: The Texas General Land Office has made every effort to ensure the information contained on this) form is accurate and in compliance with the most up-to-date CDBG-DR and/or CDBG-MIT federal rules and regulations, as applicable. It. should be noted that the Texas General Land Office assumes no liability or responsibility; for any error or omission on thisf form that may resultfrom the interim period between the publication of amended and/or revised federal rules and regulations and the Texas GeneralLand Office's standard review and update schedule. HJ CITY OF SIMONTON STATEMENT OF FINANCIAL GOALS AND POLICIES ORGANZATIONAL GOAL STATEMENT The overall financial and service goals of the CITY OF SIMONTON are to provide the full range of statutorily required services to its citizens while maintaining the lowest prudent property tax rate. The CITY OF SIMONTON intends to continue to expand non-tax revenues to allow for budgetary growth as dictated both by the growth in the CITY OF SIMONTON population and the growth in the demand for the County's services. The CITY OF SIMONTON will ensure that budgetary growth is balanced by increases in demand for services. The CITY OF SIMONTON will provide for expansion and renewal ofi its infrastructure through the use of long-term debt when it is considered appropriate and fiscally responsible. I. GENERAL POLICIES The CITY OF SIMONTON will operate on a fiscal year which begins on and ends on . The CITY OF SIMONTON will conduct its financial affairs in conformity with State and Federal laws, and this Statement of Financial Policy, which shall be approved by and reviewed on an annual basis as part of the budget process. II. ACCOUNTING, AUDITING, AND FINANCIAL PLANNING The CITY OF SIMONTON Auditor's Office will continue to maintain records on a basis consistent with accepted principles and standards for local government accounting, as determined by GASB and GFOA. Regular monthly and annual financial reports are issued summarizing financial activity by fund, and department, and comparing actual resources and expenditures with budgeted amounts, as required by Articles 114.022, 114.024, 114.025, 111.091 and 111.092. The Auditor's Office provides monthly reports on the total cost of specific services by type of expenditure and by fund, in accordance with Articles 114.022, 114.024, 114.025, 111.091, and 111.092. A financial audit will continue to be performed annually by an independent public accounting firm and an official opinion and annual financial report will continue to be published and issued, as authorized by Article 115.043. 1 CITY OF SIMONTON will continue to identify areas for evaluation efforts, by either staff, committees, or consultants, in order to judge the effectiveness and efficiencies of CITY OF SIMONTON services. Cost benefit studies will be conducted, where appropriate and applicable, on non-recurring expenditures and capital project. Full disclosure will continue to be provided in the annual financial and budget reports and bond representations, in accordance with Articles 115.045, 114.025, 111.091, and 111.092 of the Revised Statues of Texas. HI. BUDGETING POLICIES Budgetary Basis - The CITY OF: SIMONTON's budgetary basis and accounting records are maintained on a modified accrual basis and organized and operated on a fund basis in accordance with generally accepted accounting principles. Encumbrance accounting is utilized for materials, goods and services documented by purchase orders or contracts. The CITY OF SIMONTON will increase the subsequent year's appropriations, but only, if necessary, to complete these transactions. The approved annual budget with amendments as approved by the CITY COUNCIL is the management. control device utilized by the CITY OF SIMONTON. Annual appropriated budgets are adopted for the General, Special Revenue, and Debt Service funds. All annual appropriations lapse at fiscal year-end. Encumbrance accounting, under which funds are reserved from purchase orders, contracts, and other commitments, is employed in these funds and as of September 30, encumbrances are subject to re-appropriations in the budget of the subsequent year. The CITY OF SIMONTON budgets resources on a fiscal year which begins on October 1 and ends on the following September 30. Budget manuals are distributed; and budget module training sessions are held, for annual budget preparation, which includes forms and instructions are distributed to the CITY OF SIMONTON Departments in June each year. Departments and Elected Officials must return their proposals no later than July in that year. The recommended budget shall be prepared and distributed to the CITY COUNCIL members on or before August 31, of the preceding fiscal year. The proposed budget estimate shall be presented in the following format: Revenue estimates by major item. Operating and maintenance expenditures by object code, major expense categories, functionally related departments, and program summaries. Debt Service is summarized by issues detailing principal, interest, and reserve amount by fund. 2 The proposed budget estimate shall also contain information regarding: Proposed personnel staffing levels. A detailed list of capital equipment to be purchased by each department. A detailed schedule of capital projects. Any additional information, data, or analysis requested of management by the CITY COUNCIL. The proposed budgeted revenues shall be provided by the Auditor's Office including ad valorem taxes, grant revenues, and inter-fund transfers. The CITY COUNCIL shall adopt the budget by Court Order prior to October 1. The CITY OF SIMONTON budgeting procedures attempts to identify distinct functions and activities performed by the CITY OF SIMONTON and to allocate budget resources adequate to perform these functions and activities at a specified level of service. The CITY OF SIMONTON will continue to integrate performance measurement and productivity : indicators with the budget process where appropriate. The committed, but not yet received purchases as of will be re-appropriated in the subsequent fiscal year per a list prepared by the CITY OF SIMONTON Auditor with appropriate Budget Amendment. Only the CITY COUNCIL shall have., authority to transfer expenditure appropriations from any department category of object codes to any other department or non-departmental major object code category. Transfers of such funds amount to a new appropriation and therefore must be adjusted prior to expenditure of such amounts. Any transfer shall ONLY be made when it is submitted on the appropriate Budget Amendment Request or Intra-Departmental Operating Transfer forms. Each amendment request must be signed by an authorized departmental representative with review in the Budget Office. All transfer requests are submitted to the CITY COUNCIL for final approval. IV. BUDGET AMENDMENT POLICY The CITY OF SIMONTON Policy allows a Department Head, Appointed or Elected Official or his/her designees to request budget amendments throughout the fiscal year as follows: BUDGET AMENDMENT STATUTE: Pursuant to Local Government Code Section 111.070, the CITY COUNCIL may spend CITY OF SIMONTON funds only in strict compliance with the budget. The CITY COUNCIL by order may amend the budget to transfer an amount budgeted for one item to another budgeted item without authorizing an emergency expenditure. 3 INTRA-DEPARTMENTAL OPERATING TRANSFER: Transfers may be made up to $1,000 (cumulative total for Intra-Departmental Operating Transfers for the fiscal year) between operating line Items and surplus funds from capital items within an individual departmental budget: This type of amendment will be presented on the standing weekly agenda item for Intra-Departmental Operating Transfers. The amendment summary will be sent to each member oft the CITYCOUNCIL and other affected departments two (2) working days prior to the actual CITY COUNCIL meeting. When a line tem will be increased or decreased by more than $1,000 (cumulative total for Intra-Departmental Operating Transfers for the fiscal year), or if a new capital item is requested, the amendment must be presented to CITY COUNCIL for consideration and action as a separate agenda item. ROUTINE BUDGET AMENDMENTS: Includes transfer of funds within the maintenance and operations line items within the elected official or department head budget(s). These items can be placed directly on the consent agenda. NON-ROUTINE BUDGET AMENDMENTS: Inter-Departmental - Any amendment which moves funds from one elected official or department head's budget to another elected official or department heads budget must be presented to CITY COUNCIL for consideration and action. Inter-Fund - Where permitted by law, any amendment which moves funds from one fund to another fund must be presented to CITY COUNCIL for consideration and action. Personnel - Requests to transfer funds from any salary or benefit account are allowed for the. specific purpose of salary related expenditures such as contract labor. Budget amendment requests for capital and operating accounts from personnel line items are allowed if there are no other funds available in that department's budget and the CITY COUNCIL deems it to be necessary. Capital - Any request for additional capital equipment must be justified and specified in detail with cost estimates. Requests for additional capital items not included in the adopted budgeted or substitution ofone item for another also requires approval from the CITY COUNCIL. Surplus funds inal budgeted capital item can be transferred to cover a shortage up to $1,000 in another budgeted line item with an Intra-Departmental Operating Transfer. Computers - Any request including computer equipment, software, computer maintenance or technological requests requires a written recommendation from Technology Services when submitting the Budget Transfer / Amendment Request Form. The re-appropriation at the beginning of a fiscal year of funds committed under valid Purchase Orders of the CITY OF SIMONTON but unspent by or the prior fiscal year requires a budget amendment from fund balance. These budget amendments have no net effect on spending but simply changes the accounting year for expenditures. Pursuant to Local Government Code, Section 111.014, the CITY COUNCIL may authorize a contingency item. The item must be included in the itemized budget under Section 111.004(a) in the same manner as a project for which an appropriation is established in the budget. Budget amendment(s) may be made against this item during the year in case of grave public necessity 4 to meet an unusual and unforeseen condition that could not have been included in the original budget through the use of reasonably diligent thought and attention. Pursuant to Local Government Code, Sections 111.0105 through 111.0108, when revenues not included in the original budget are received, such as proceeds of bonds or other obligations, grant or aid money, revenue form intergovernmental contract, and pledging revenues as security for bonds and other obligations, a budget amendment is required to expend those funds. The adopted CITY OF SIMONTON-wide budget will increase however the revenues should exceed or equal the expenditure. This type of amendment must be submitted to the CITY COUNCIL for consideration and action. Any transfer that creates an increase in budgetary commitment for the next fiscal year must be presented to the CITY COUNCIL for consideration and action. New employee positions cannot be created without CITY COUNCIL consideration and action. Création of a new position within a departmental budget will require that the CITY COUNCIL declare an emergency. unless the actual line item under which that new position would be categorized currently exists within that specific budget. New employee requests outside of the budget process must include substantial written justification for the position. New line items can only be created for Contracts or Grant-based programs. For any other department, the creation of a new line tem that has not been previously created for the specific department will require that the GITY COUNCIL declare an emergency in order to establish a new line item. RESTRICTED LINE-ITEM TRANSFERS: Certain line items have restrictions, which are only allowed for specific purposes. CITY COUNCIL ordered expenditures can only be transferred to other CITY COUNCIL ordered line items. Vehicle related expenditures can oy be transferred to other vehicle-related line items. Salary related expenditures - See Non-Routine Budget Amendments / Personnel. Body Armor - only excess funds from items requested and purchased can be transferred to another line item. PROCEDURES: Any request for a budget amendment. must be justified and submitted to the Budget Office on the specified Budget / Transfer Amendment Form'. All requests must be submitted to the Budget Office by Friday noon in order to be placed on the following CITY COUNCIL Agenda (approximately seven /7 working days later) by the Budget Office. The Budget Office may hold a request that is not complete until clarified with the appropriate department. Scanned copies are acceptable as long as they all are legible. Budget Amendment transfer authorization may be delegated by the Elected/Appointed Official to other employees. Notification of signature authority must be on file in the Budget Office before requests are accepted. Therefore, the Budget / Transfer Amendment Form' must be personally 5 signed by the Elected/Appointed Official who administers the department budget(s) or their designee(s). The CITY COUNCIL reserves the right on a case-by-case basis, where legally permissible, to curtail a departments right to make Intra-Departmental Operating Transfers if the budget transfers appear to be making a programmatic change that was not approved by the CITY COUNCIL in budget hearings or if the financial condition of the department and/or the CITY OF SIMONTON warrants such a curtailment. Notification of approved Budget Amendments and Intra-Departmental Operating Transfers will be e-mailed to the appropriate department(s) after the amendment is posted. The Budget Office is responsible for posting budget amendments on the financial computer once the court order has all signatures and is received from the CITY OF SIMONTON Clerk's Office. Budget Amendment Requests for new capital equipment must be submitted to the Budget Office for the current fiscal year by This will allow the Purchasing Oficer/Depariment to secure bids and order equipment prior to the end of the fiscal year. Budget Amendment Requests other than capital requests for the current fiscal year must be submitted to the Budget Office no. later than (30 days prior to end of fiscal year). Exceptions to the deadlines will be placed on the agenda for consideration by the CITY COUNCIL. Any request for placement on the agenda of a budget amendment or intra-Departmental Operating Transfers, past the amendment deadlines, request a separate memo from the requesting department stating the urgency of the request. V. REVENUES AND TRANSFERS AND POLICIES CITY OF SIMONTON will maintain a diversified and stable revenue system to shelter it from short- term fluctuations in any one revenue source by doing the following: Establishing user charges and fees as permitted by law at a level related to the cost of providing that service including indirect costs. Pursuing legislative change, where necessary, to permit increases in user charges and fee. Aggressively collecting property tax revenues, including the filing of suit where appropriate and necessary, as authorized by the Texas Property Tax Code. CITY OF SIMONTON will pay for all current expenditures with current resources as required by Article XI, Section 7 of the Constitution, and by Article 111.091-111.092 of the Revised Statutes of Texas. Transfers of monies between funds will only be accomplished after approval of the CITY COUNCIL. The CITY OF SIMONTON will support the majority of operations of the road and Bridge districts from the vehicle registration fee authorized by the Texas Legislature, and property taxes. 6 VI. CONTINGENCY FUND POLICIES The CITY OF SIMONTON will maintain an unappropriated contingency to provide for smali increases in service delivery costs as well as unanticipated needs that may arise throughout the year. THEREFORE, IT WILL BE NECESSARY FOR OFFICALS AND DEPRTMENT HEADS TO REVIEW, AND CONTROL EXPENDITURES SUCH THA THE RATE OF EXPENDITURE DOES NOT EXCEED THE APPROVED BUDGET. Cases of anticipated material deviation should be covered by a request for a budget amendment. This request shall be from the Department Head in writing and include justification for such action. Such requests should be submitted to the Budget Office for initial review, they will then process the request and forward to the CITY COUNCIL for their consideration and approval. Vil. PERSONNEL POLICIES The number of employees on the payroli shall not exceed the total number of positions approved unless authorized by CITY COUNCIL. All personnel actions shall at all times be in strict conformance with applicable federal, state, and CITY OF SIMONTON policies. Deletion and downgrades of positions may occur at any time during the fiscal year at the department head or elected official's request or if a review of workload statistics indicates that a reduction in force. is practical in a department. Reductions in elected official's budgeted positions will only be accomplished with their approval after the budget is adopted. Additions, position reclassifications, reorganizations, and equity adjustments must be presented with the initial budget request. Exceptions to this policy will only be allowed with CITY COUNCIL approval. The CITY COUNCIL may institute a freeze during the fiscal year on hiring, promotions, transfers, and capital equipment purchases. Such action will be used arbitrarily and will allow for exceptions in appropriate areas to comply and emergency needs such as natural disasters and/or loss of major revenue source. VIII. FIXED ASSET POLICES All purchases of physical assets with a value of $5,000 (five thousand dollars) except computer software shali be placed on the CITY OF SIMONTON inventory. The CITY OF SIMONTON will maintain these assets at a level adequate to protect CITY OF SIMONTON's capital investment and to minimize future maintenance and replacement costs by: 7 Providing for adequate maintenance of capital equipment and equipment replacement under the above stated amount in the annual operating budget. Capital expenditures for projects and equipment are budgeted by tem or project and must be spent accordingly. Any request for unbudgeted capital equipment or projects throughout the fiscal year must be submitted to the Budget Office and approved by the CITY COUNCIL as a budget amendment prior to a requisition being presented to Purchasing. Where possible, items in good useable condition placed in surplus will be used: To supplement expenditure for new, budgeted capital purchases. To supplement expenditure for replacementbudgeted capital purchases. To supply needed unbudgeted new and replacement equipment. IX. DEBT MANAGEMENT POLICIES CITY OF SIMONTON recognizes the foundation of any well-managed debt program is a comprehensive debt policy. A debt policy sets forth the parameters for issuing debt and managing outstanding debt, and it, provides guidance to decision makers regarding the timing and purposes for which debt may be issued, types and amounts of permissible debt, method of sale that may be used and structural features that may be incorporated. POLICY SUMMARY CITY OF SIMONTON will adhere tothe following specific policy statements with regards to (1) conditions for debt issuance; (2) restrictions on debt issuance; (3). debt service limitations; (4) limitations on outstanding debt; (5) debt structure; (6) the debt issuance process; and (7) debt maintenance procedures. Conditions for debt issuance -The CITY OF SIMONTON will consider the use of debt financing only for one- time capital improvement projects. Long-term borrowing will not be used to finance current operations or normal maintenance. Debt financing may include general obligation bonds, revenue bonds, certificate of obligation, certificates of participation, tax notes, lease/purchase agreements, and other obligations permitted to be issued or incurred under Texas law. The CITY OF SIMONTON shall consider refunding outstanding bonds if one or more of the following conditions exist: (1) present value savings are at least 3% with certain exceptions, of the par amount of the refunding bonds; (2) the bonds to be refunded have restrictive or outdated covenants; or ((3) restructuring debt is deemed to be desirable. Restrictions on debt issuance - Proceeds from long-term debt will not be used for current ongoing operations. Debt Service Limitations In evaluating debt capacity, general-purpose annual debt service payment should generally not exceed 20% of the CITY OF SIMONTON total budgeted expenditures for all funds. Limitations on Outstanding Debt - As provided in the Constitution of the State of Texas, the Net Bonded Debt of the CITY OF SIMONTON shall not exceed twenty-five percent (25%) of the het value of the taxable real property of the CITY OF SIMONTON. 8 Characteristic of Debt Structure = The CITY OF SIMONTON will design the repayment of its overall debt SO as to recapture rapidly its credit capacity for future use. The CITY OF SIMONTON shall strive to repay at least 20 percent of the principal amount of its general obligation debt within five years and at least 401 percent within ten years. The scheduled maturity of individual debt issued shall not exceed the expected useful life of the capital project of asset(s) financed. Also, the CITY OF SIMONTON shall consider purchasing bond insurance for debt issues when the present value of the estimated debt service savings from insurance (to be derived)) is equal to or greater than the insurance premium. Debt Issuance Process - The CITY OF SIMONTON shall use a competitive bidding process in the sale of debt unless market conditions the nature of the issue, such as refunding bonds, warrants a negotiated sale. The CITY OF SIMONTON will employ outside financial specialists, including financial advisors and bond counsel, to assist it in developing a bond issuance strategy, preparing bond documents and marketing bonds to investors. Debt Maintenance Responsibilities - The CITY OF SIMONTON will seek to maintain and, if possible, improve our current bond ratings to minimize borrowing costs and preserve access to credit. CITY OF SIMONTON will adhere to a policy of full public disclosure with regard to the issuance of debt, and the CITY OF SIMONTON will meet all requirements for continuing disclosure on debt of the CITY OF SIMONTON. X.s BONDED DEBT COMPLIANCE MANAGEMENT POLICY CITY OF SIMONTON acknowledges and will abide by any federal or state law regarding tax- exempt bonds. POLICY SUMMARY CITY OF SIMONTON will adhere to the following specific policy statement with regards (1) separate record keeping per bond issuance; (2) not mingling bond issuance money; (3) the use of bond proceeds only for their approved purposes; (4) the intent to use bond funds within three (3) years of issuance; (5) meeting post-issue reporting requirements; (6) keeping interest earning with bond principal or debt service; (7) maintaining an interest and sinking fund for all tax-exempt debt; and (8) maintaining the tax-exempt status of all outstanding bonded debt of the CITY OF SIMONTON. Separate Accounting à The CITY OF SIMONTON will keep separate financial records of each bond issuance. A construction fund will be maintained for each bond issuance in the CITY OF SIMONTON's general ledger, the fund will be accounted for separately from all other funds of the CITY OF SIMONTON, and the fund will be used solely to pay costs of the projects for which the debt obligations were issued. Not Mingling Bond Funds Bond proceeds will not be co-mingled with any other CITY OF SIMONTON funds. Approved Purposes = Bond proceeds will only be used for allowable purposes as specified by bond election and bond order authorizing the issuance of the bonds. Intent to Use within Three Years of Issuance - CITY OF SIMONTON intends to use bond proceeds for their approved purposes within three (3) years of their issuance. 9 Post-Issue Reporting Requirements The CITY OF SIMONTON will adhere to all reporting requirements and deadlines that are applicable to tax exempt bonds. Specifically, the CITY OF SIMONTON will comply with the requirements of Securities and Exchange Commission Rule 15c2-12 which requires the filing of annual financial reports and otheri financial data and the filing of any required material events notices with each agency designated as an information repository. CITY OF SIMONTON will also comply with US Treasury Regulation Section 148 which requires the computation and payment of any arbitrage rebate owed no less frequent than five (5) years after issuing any tax-free debt. Interest Earned Remains with Principal or Debt Service - Interest earned on bond proceeds will remain with the bond principal and will be used only to pay any cost overruns on approved projects, to fund new projects meeting the usage criteria in the original bond indentures, or it will be specified to go towards the payment of Debt Service. Interest and Sinking Fund - CITY OF SIMONTON will levy a tax on all taxable property in the CITY OF SIMONTON to pay principal of and interest on bonds or debt instruments issued. Amounts collected from the tax levied will be deposited to the credit of the Interest and Sinking Fund maintained in the accounting records of the CITY OF SIMONTON. CITY OF SIMONTON will maintain its Interest and Sinking Fund in a manner to a proper matching of revenues and debt service payments on its debt issues. Specifically, the Interest and Sinking fund will be depleted at least once each bond year to the amount of the allowable carryover, all amounts deposited to the fund will be expended- within twelve months of receipt, and all amounts received from the investment of the fund will be. deposited to the fund and expended within twelve months. Maintenance of Tax-Exempt Status - CITY OF SIMONTON shall not use, permit the use, or omit the use the gross proceeds of any debt issuance in a manner which if allowed or omitted would cause the interest on any bond or debt instrument of the CITY OF SIMONTON to become includable in the gross income ofthe owner ofthe bond for federal income tax purposes The CITY OF SIMONTON specifically will comply with bond covenants which prohibit: (1) private use or private payments of assets constructed or acquired with debt proceeds; 2) private loans of bond proceeds to any person other than' a state or local government; (3) investment of bond proceeds in any investment with a yield that exceeds that of the bonds; (4) taking any actions that would cause the bonds to be federally guaranteed within the meaning of section 149(b) of the Internal Revenue Code; and (5) taking any unauthorized action having the effect of diverting arbitrage profits from payment to the US Treasury, the CITY OF SIMONTON will maintain its financial records until three (3) years after final payment of all bonds to show compliance with federal and state laws regarding tax-exempt debt. XI. INVESTMENT AND CASH MANAGEMENT The Treasurer's Office will continue to collect, disburse, and deposit all funds on a schedule which insures optimum cash availability, in accordance with Article 113.043, 113.065, 113.901, 113.001- 005, 113.021-024, and 113.041-047. The CITY OF SIMONTON Treasurer shall handle all original reconciliation of CITY OF SIMONTON bank accounts with the Depository Bank and shall resolve any financial difference between CITY OF SIMONTON and the Depository Bank. The City Treasurer and City Auditor are Co-Investment Officers of the CITY OF SIMONTON as authorized by the CITY. COUNCIL and shall invest the funds of the CITY OF SIMONTON to 10 achieve the highest and best yield, while at the same time maintaining the security and integrity of said funds. CITY OF SIMONTON shall maintain a written CITY OF SIMONTON Investment Policy, as approved. by the CITY COUNCIL, to achieve the highest and best yield, while at the same time, maintaining the security and integrity of said funds. The City Treasurer will maintain an original copy of all security and/or surety pledges made by the Depository Bank on behalf of CITY OF SIMONTON funds. The City Treasurer will maintain an original copy of all security advice for all CITY OF SIMONTON investment transactions. There shall be a CITY OF SIMONTON investment Committee, consisting of the City Treasurer, City Auditor, Budget Officer, Civil Attorney, and a citizen appointed by the CITY COUNCIL. The City Auditor will continue to provide regular information concerning the cash position and investment performance as required by Articles 114.025, 111.091, and.111.092. CITY OF SIMONTON conducts its treasury activities with financial institution(s) based upon written contracts which specify compensating balances, service charges, term, and other conditions as authorized by the Local Government Code inclusive of the Revised Statues of Texas. XII. GENERAL FUND UNRESERVED FUND BALANCE POLICY GENERAL FUND UNRESERVED FUND BALANCE POLICY It is essential that governments maintain adequate levels of fund balance to mitigate current and future risks (e.g., revenue shortfalls and unanticipated expenditures) and to ensure stable tax rates. Fund balance levels are a crucial consideration, too, in long-term financial planning. In most cases, discussions of fund balance will properly focus on a government's general fund. Credit rating agencies carefully monitor levels of fund balance and unreserved fund balance in a government's general fundt to evaluate a government's continued creditworthiness. Likewise, laws and regulations often govern appropriate levels of fund balance and unreserved fund balance for state and local governments. POLICY The Governmental Accounting Standards Board (GASB) released Statement 54, "Fund Balance Reporting and Governmental Fund Type Definitions". This Statement is intended to improve the usefulness of the amount reported in fund balance by providing more structured classifications. The purpose of this policy is to establish operating and reporting guidelines for the fund balances of the governmental funds for the CITY OF SIMONTON, Texas. 11 The CITY OF SIMONTON governmental-fund financial statements will present fund balances classified in a hierarchy based on the strength of the constraints governing how those balances can be spent. These classifications are listed below in descending order of restrictiveness: Non-spendable Fund Balance: This classification includes amounts that cannot be spent because they: (a) are not in spendable form (e.g., inventories and prepaid items); (b) are expected to be converted into cash within the current period or at all (e.g., long-term receivables); or (c) are legally or contractually required to be maintained intact (e.g., the non-spendable corpus of an endowment). Restricted Fund Balance: This classification includes amounts subject to usage constraints that have either been: (a) externally imposed by creditors (e.g., through a debt covenant), grantors, contributors, or laws or regulations of other governments; or (b) imposed by.l Jaw through constitutional provisions or enabling legislation. Committed Fund Balance: This classification includes amounts that are constrained to use for specific purposes pursuant to formal action oft the CITY COUNCIL. These amounts cannot be used for other purposes unless the CITY COUNCIL removes or changes the constraints via the same a type of action used to initially commit them. Assigned Fund Balance: This classification includes amounts intended by the CITY OF SIMONTON for use. for a specific purpose, but which do not qualify for classification as either restricted or committed. The intent can be expressed by CITY COUNCIL or by a CITY COUNCIL designee (e.g., CITY OF SIMONTON Auditor). This classification applies to the positive unrestricted and uncommitted fund balances of all governmental funds except the General Fund. Unassigned Fund Balance: This classification applies to the residual fund balance of the General Fund and to any deficit fund balances of other governmental funds. Order of Spending: Where appropriate, the CITY OF SIMONTON will typically use restricted, committed, and/or assigned fund balances, in that order, prior to using unassigned resources, but itr reserves the right to deviate from this general strategy. Minimum Fund Balance: CITY OF SIMONTON generally aims to maintain the following minimum fund balance: General Fund: Unassigned fund balance of approximately 2.5 to 4.5 months of budgeted expenditures for the fiscal year, to be used for unanticipated needs. 1. A commitment of fund balance requires formal action as to purpose but not as to amount; the latter may be determined and ratified by the CITY COUNCIL at a later date. This is often important near year-end, when a purpose or need is known but the cost is not. 2. An assignment of fund balance implies intent ofi the CITY COUNCIL, but operationally, the ability to implement the intent may be delegated to one or more persons. 12 PROCEDURES A goal of each year's budgeting process will be to adopt a budget that maintains compliance with the stated General fund unreserved fund balanced policy. Specific CITY OF SIMONTON financial conditions, economic conditions, or special initiatives may be considered reasons for temporary non-compliance with this policy. In the event of either planned or unplanned non-compliance, it is the CITY OF SIMONTON's intention to take action during the annual budget process to reach compliance with two (2) annual budget cycles. Actions in the budget process available to increase the unreserved General Fund balance may include increasing taxes, decreasing spending in specific areas, dedicating one-time revenues to fund reserves, or-making transfers of excess fund oalances form other funds. In the event that the level of unreserved General Fund balance is judged to be in excess of the amount acquired by this policy, amounts over that required may be used to fund one-time, non- recurring expenditures such as acquisition of capital items. Excess fund balances will not be used to fund recurring operating expenditures. XIII. : CAPITAL BUDGET IMPACT ON OPERATING BUDGET All Capital Improvement Program requests must include the operating budget impact of the request including but not limited to. additional staffing, operating expenses as well as any cost savings anticipated if the request is approved and funded. A Capital Improvement request form must be submitted with the overall capital projectjustification and operating expenses data. Projects without sufficient data will not be considered. Operating expenses for capital projects will be funded on a pay-as-you-go basis for annual, recurring maintenance type expenses. XIV. INTERNAL GUIDELINES FOR MANAGEMENT OF FEDERAL AND/OR STATE FUNDS All costs charged by the CITY OF SIMONTON must be necessary, reasonable, allowable, and allocable to all Federal and/or State grant programs received administered by the CITY OF SIMONTON. The CITY OF SIMONTON must assure that all costs are appropriate and eligible including but not limited to the following areas of concern: Administrative requirements Including duplication of benefits requirements, provisions related to charging pre-award costs, conflict of interest, reporting fraud, and distinction oetween agencles.goverment components, contractors, developers, and beneficiaries; Recordkeeping and Reporting requirements = Including records retention and financial reporting requirements; 13 Procurement requirements - Including requirements related to bonding, insurance, suspension, and debarment; Contract conditions; Force Account - Including requirements fort tracking, documenting, and charging personnel costs and applicable fringe benefits and classification, purchasing, tracking, insuring, and disposing of equipment, supplies, and federally purchased tangible and intangible property; Contract amendments; Contract closeout; Monitoring and Quality Assurance - Including requirements related to preventing fraud, waste, and abuse; Audit - Including Single Audit or program-specific audit requirements The following is a list of key federal and state regulations governing financial management of grant programs: 24. CFR S 570 Subpart I- governs the state CDBG-DR program; 2CFR S 200, including all of Subpart E Cost Principles; Uniform Grant Management Standards (UGMS) - Texas Comptroller of Public Accounts and guidance under 2 CFR S 200; Texas Local Government Code Chapter 171 It is the CITY OF SIMONTON's responsibility to be knowledgeable and compliant with these requirements to ensure the appropriate, effective, timely, and eligible use of all funds related to Federal and/or State Programs. The CITY OF SIMONTON is responsible for monitoring vendors and projects and compliance with.applicable financial management standards, for processing payment requests for funds, and for audit review. A cost objective is a pool of related costs, which could be related based on the CITY OF SIMONTON's departments, function, eligible, activity, agreement with State and/or Federal agencies or any other basis. The term is used to capture a variety of scenarios in which costs may be categorized for purposes of cost allocation or eligibility determinations. As per of 2 CFR S 200.303, the CITY OF SIMONTON has established this and other written policies and procedures for internal controls and guidance documentation for responsible financial management of federal and/or state funds and include the adherence to the following: All federal, state, and local conflict of interest provisions, including the requirements of Texas Local Government Code Chapter 171; The CITY OF SIMONTONhas an established internal control system and documented segregation of duties. Including the appropriate segregation of duties as follows: o No person has complete control over every phase of a significant transaction. For example, the person who authorizes payments to contractors should not draft and issue the payment check and the person who writes a payment check should not reconcile associated bank records; 14 Monthly bank reconciliation and/or direct deposit monthly statements are reviewed by someone who is not responsible for handling cash or issuing checks; The person issuing checks for grant expenses does not also handle payroll preparation/issuance of paychecks; The CITY OF SIMONTON will take prompt action when an instance of noncompliance is identified internally or through audit findings; The CITY OF SIMONTON takes reasonable measures to safeguard protected personally identifiable information (PII) and other information that the CITY OF SIMONTON considers sensitive consistent with applicable Federal, state, and local laws regarding privacy and obligations of confidentiality; Per 24 CFR.S 570.502, through established budgets and accounting records, the CITY OF SIMONTON is responsible for énsuring all Federal and/or State expenditures are authorized in an approvéd, documented budget and do not exceed the total budget amount and do not exceed the- amount in the CITY OF SIMONTON's grant agreement(s). The CITY OF SIMONTON will use one of two general methods available to draw federal and/or state grant funds to pay for project and vendor costs: the reimbursement method and the cash advance method. : The reimbursement method entails a transfer of grant funds to the CITY OF SIMONTON based on actual expenditures already incurred by the CITY OF SIMONTON before it requests a draw; The cash advance method entails the transfer of grant funds from the federal and/or state agency based upon the CITY OF SIMONTON's received invoices before the actual cash disbursements have been made by the CITY OF SIMONTON. The CITY OF SIMONTON establishes a separate account for each grant it receives. When using a cash advance basis process, the CITY OF SIMONTON will ensure that all received grant funding is held in an insured; interest-Dearing account (2 CFR S 200.305(b)). Distinct accounting information for each grant is created. Accurate records of enoumbrancecnlgatons against distinct line items within each grantifor vendor contracts are made. Accurate records on grant awards, unobligated balances, assets, liabilities, expenditures, program income (if any) and applicable interest are kept and supported by sources documentation, including vendor contracts, invoices, and purchase orders. Pursuant to 2 CFR S 200.302(a), the CITY OF SIMONTON's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, are sufficient to permit the preparation of reports required to demonstrate compliance with general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the CITY OF SIMONTON's State and/or Federal grant agreement(s). 15 CITY OF SIMONTON through its annual audit process has proven effective control over, and accountability for, all funds, property, and other assets in its possession. The CITY OF SIMONTON makes every effort to adequately safeguard all assets and assure that they are used solely for their intended purpose. Financial Records for all Federal and/or State grant programs include the following: Transaction registry documenting: All invoices assooiated with each Request for Payment; and Source of funds for each invoice. (grant funds by activity, matching funds, and/or other funds) Source documentation, including the following: o Copies of Requests for Payment; o Addendum record of direct deposit payments; o Verification of deposits; Monthly bank statements Check register/ftransaction ledger; Employee time sheets (as applicable); Equipment time record sheets (as applicable); Property inventory; Purchase orders, invoices, and contractor requests for payments; Electronic Transfer Form (ETF); All original source documents The CITY OF SIMONTON for each grant agreement received, establishes Responsible Persons. Through resolution, the CITY OF SIMONTON identifies the Responsible Persons (at least 2, preferably 4 by job title) responsible for both contractual documents (executed CITY OF SIMONTON agreement(s), associated amendments, and various program certifications) and financial documents (requests for payment, issuance of check). The CITY OF SIMONTON, where allowable by the Federal and/or State funding program, will authorize direct deposit to receive payments from the agency(ies) to post directly to the CITY OF SIMONTON's local bank account. The CITY OF SIMONTON will ensure that there exists staff and contractor capacity necessary to manage all grant funds under its control. The CITY OF SIMONTON may procure a Grant administrator to assist with management of grant compliance, subject to 2CFR200 procurement guidelines and requirements. Eligible/Allowable Costs: All costs charged to the CITY OF SIMONTON's grant agreement(s) will be deemed eligible as identified in each Grantor's gleemenmpemenaton manual. Eligible costs are those that conform to the federallstate requirements, Including limitations and waivers described in applicable Federal Register Notices, comply with federal cost principles, and align with all associated cross-cutting federal requirements (Davis Bacons and Related Acts, Environmental requirements, etc.) and State and Local law. 16 The CITY OF SIMONTON will assure pursuant to 2 CFR S 200.403, costs meet the following general criteria to be allowable as a charge against any Federal award: Costs must be necessary and reasonable for the performance of the Federal award and be allocable to that award and not to a different award; Costs must conform to any limitations or exclusions set forth in 2 CFR S 200 or in the Federal award as to types or amount of cost items; Costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the CITY OF SIMONTON; Costs must be accorded consistent treatment; Ad cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; Costs must be determined in accordance with generally accepted accounting principles (GAAP); Costs must be adequately documented Reasonable Costs. (2 CFR S 200.404): A cost is reasonable if, in its nature and amount, it does not exceed that which wouid be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. In determining the reasonableness of a given cost, consideration will be given to: Whether the cost is of a type generally recognized as ordinary and necessary for the operation oft the CITY OF SIMONTON or the proper and efficient performance of the State and/or Federal award; The restraints or requirements imposed by such factors as: sound ousiness practices; arm's-length bargaining; Federal, state, local, and other laws and regulations; and terms and conditions of the State and/or Federal award; Market prices for comparable goods or services for the geographic area; Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the CITY OF SIMONTON, its employees, the public at large, the State Government and/or Federal Government; Whether the CITY OF SIMONTON significantly deviates from its established practices and policiès regarding the incurrence of costs, which may unjustifiably increase the cost The CITY OF SIMONTON will insure that all grant reimbursement requests meet the definition of Allocable Costs (2 CFR S 200.405 and S 200.406) A cost is allocable to a particular grant, CITY OF SIMONTON agreement, vendor contract, program or other cost objective if the goods or services involved are chargeable or assignable to that cost objective in accordance with relative benefits received. This standard is met if the cost: Is incurred specifically for that cost objective; 17 Benefits both that cost objective and other work of the CITY OF SIMONTON and can be distributed in proportions that may be approximated using reasonable methods; and Is necessary to the overall operation of the CITY OF SIMONTON and is assignable in part toi the specified cost objective in accordance with 2 CFR S 200. Any cost allocable to a particular cost objective may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons, However, this prohibition would not preclude the CITY OF SIMONTON from shifting costs that are allowable under two or more cost objectives in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards, If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefited projects on any reasonable documented basis. Costs should only be charged net of all applicable credits. Applicable credits refer to those receipts or reduction-of- expenditure-type transactions that offset or reduce expense items allocable to the cost objective. Examples include: Purchase discounts; Rebates or allowances; Recoveries or ndemnities on losses; Insurance refunds or rebates; and Adjustments of overpayments or erroneous charges To the extent that such credits accruing to or received by the CITY OF SIMONTON relate to allowable costs, they must be credited to the State and/or Federal award either as a cost reduction or cash refund, as appropriate. These credits do not constitute program income. The CITY OF SIMONTON will submit a draw request for eligible costs as often as is needed, subject to limitations in grant agreements and at least quarterly throughout the life of a project. The CITY OF SIMONTON will submit costs to a Grantor for draw within 60 days of receipt of invoices as allowable. The County will ensure Draw requests are submitted timely to the granting agencies. Pursuant to 24 CFR S 570.489(c), 2 CFR S 200.305(b), and 31 CFR S 205, the CITY OF SIMONTONwhen utilizing the cash advance method will minimize the time elapsing between the transfer of funds from the Federal or State agency and the disbursement by the CITY OF SIMONTON for eligible costs. This period must not exceed 3 business days from the date of receipt/deposit of funds. 18 4k CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY The City follows State of Texas and Federal 2CFR 200.318-200.327 and Appendix II to Part 200 procurement law and guidance in the purchasing and contract management of goods and services. Additional policy guidance below addresses federal purchasing requirements as required by 2 CFR 200 pertaining to the expenditure of federal grant funds. Standards of Conduct Public employment is a public trust. It is the policy of the City to promote and balance the objective of protecting government integrity and the objective of façilitating the recruitment and retention of personnel needed by thé City. Such a policy is implemented by prescribing essential standards of ethical conduct without creating unnecessary obstacles to entering public service. Public employees must discharge their duties impartially to ensure fair competitive access to governmental procurement by responsible contractors. Moreover, they should conduct themselves in such a manner as to foster public confidence in the integrity of the City procurement organization. To achieve, the purpose of this Article, it is essential that those doing business with the City also observe the ethical standards prescribed herein. Code of Ethics 1 Personal Gain. It shall be a breach of ethics to attempt to realize personal gain through public employment with the City by any conduct inconsistent with the proper discharge of the employee's duties. 2 Influence. It shall be a breach of ethics to attempt to influence any public employee of the City to breach the standards of ethical conduct set forth in this code. 3 Conflicts of Interest. It shall be a breach of ethics for any employee of the City to participate directly or indirectly in procurement when the employee knows that: 1) the employee of any member of the employee's immediate family has a financial interest pertaining to the procurement. 2) a business or organization in which the employee, or any member of the employee's immediate family, has a financial interest pertaining to the procurement. 3) any other person, business, or organization with which the employee or any members, of the employee's immediate family is negotiating or has an arrangement concerning prospective employmenti isi involved in the procurement. Page 1 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY 1 Gratuities. It shall be a breach of ethics to offer, give, or agree to give any employee or former employee of the City, or for any employee or former employee of the City to solicit, demand, accept, or agree to accept from another person, a gratuity or an offer of employment in connection with any decision, approval, disapproval, recommendation, preparation of any specification or procurement standard, rendering of advice, investigation, auditing or in any other advisory capacity in any proceeding or application, requesting for ruling, determination, claim or controversy, or other particular matter pertaining to any program requirement or a contract or subcontract or to any solicitation or proposal therefore pending before this local government. 2 Kickbacks. It shall be a breach of ethics for any payment, gratuity or offer of employment to be made by or on behalf of a subcontractor under a contract to the prime contractor or higher tier subcontractort for any contract for the City, or any person associated therewith, as an inducement fori the award of a subcontract or order. 3 Contract Clause. The prohibition against gratuities and kickbacks prescribed above shall be conspicuously set forth in every contract and solicitation, therefore. 4 Confidential Information. It shall be a breach of ethics for any employee or former employee oft the City knowingly to use confidential information for actual or anticipated personal gain, or fort the actual or anticipated gain of any person. 5 The non-Federal entity's procedures must avoid the acquisition of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. Where appropriate, an analysis will be made oflease versus purchase alternatives, and any other appropriate analysis to determine the most economical approach. 6 The non-federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. See also $200.214. 7 The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and basis for the contract price. 8 (1) The Non-Federal entity may use a time-and-material type contract only after a determination that no other contract is suitable and if the contract includes a ceiling price that the contractor exceeds at its own risk. Time-and-materials type contract means a contract whose cost to a non-Federal entity is the sum of: () The actual cost of materials; and Page 2 of: 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY (i) Direct labor hours charged at fixed hourly rates that reflect wages, general and administrative expenses, and profit. (2) Since this formula generates an open-ended contract price, a time-and-materials contract provides no positive profit incentive to the contractor for cost control or labor efficiency. Therefore, each contract must set a ceiling price that the contractor exceeds at its own risk. Further, the non-Federal entity awarding such a contract must assert a high degree of oversight in order to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls. 9 The non-Federal entity alone must be responsible, in accordance with good administrative practice and sound business judgment, for the settlement of all contractual and administrative issues arising out of procurements. These issues include but are not limited to, source evaluation, protests, disputes, and claims. These standards do not relieve the non-Federal entity of any contractual responsibilities under its contracts. The Federal awarding agency will not substitute its judgment for that of the non-Federal entity unless the matter is primarily a federal concern. Violations of law will be referred to the local, state, or Federal authority having proper jurisdiction. Competition All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and $200.320. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals must be excluded from competing for such procurements. Some of the situations considered to be restrictive of competition include but are not limited to: (1) Placing unreasonable requirements on firms in order for them to qualify to do business; (2) Requiring unnecessary experience and excessive bonding; (3) Noncompetitive pricing practices between firms or between affiliated companies; (4) Noncompetitive contracts to consultants that are on retainer contracts; (5) Organizational conflicts of interest; Page 3 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY (6) Specifying only a "brand name" product instead of allowing "an equal" product to be offered and describing the performance or other relevant requirements of the procurement, and (7) Any arbitrary action in the procurement process. The non-Federal entity must conduct procurements in a manner that prohibits the use of statutorily or administratively imposed state, local, or tribal geographical preferences in the evaluation of bids or proposals, except in those cases where applicable Federal statutes expressly mandate or encourage geographic preference. Nothing in this section preempts state licensing laws. When contracting for architectural and engineering (A/E) services, geographic location may be a selection criterion provided its application leaves an appropriate number of qualified firms, given the nature and size of the project, to compete for the contract. The non-Federal entity must have written procedures for procurement transactions. These procedures must ensure that all solicitations: (1) Incorporate a clear and accurate description of the technical requirements for thematerial, product, or service to be procured. Such description must not, in competitive procurements, contain features that unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must seti forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. Detailed product specifications should be avoided if at: all possible. When it is impractical or uneconomical to make a clear and accurate description of the technical requirements, a "brand name or equivalent" description may be used as a means to define the performance or other salient requirements of procurement. The specific features of the named brand that must be met by offers must be clearly stated; and (2) Identify all requirements that the offerors must fulfill and all other factors to be used in evaluating bids or proposals. The non-Federal entity must ensure that all prequalified lists of persons, firms, or products that are used in acquiring goods and services are current and include enough qualified sources to ensure maximum open and free competition. Also, the non-Federal entity must not preclude potential bidders from qualifying during the solicitation period. Five Methods for Procuring with Federal Funds 2 CFR $ 200.320 provides for five methods that must be used when making purchases with Federal funds. In some cases; these Federal methods are more restrictive than State requirements; in other cases, the State requirements are more restrictive than these Federal Page 4 of1 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY methods. In all cases, the City affirms the more restrictive requirements or methods that must be followed when making purchases with Federal funds. The type of purchase method and procedures required depend on the cost (and type, in some cases) ofthe item(s) or services being purchased. Micro-purchases Small purchase procedures Sealed bids Competitive proposals Noncompetitive proposals (sole source) Micro-Purchases (Purchases up to $3,000.00) Federal methods provide for procurement by micro-purchase. Micro-purchase is defined in 2 CFR 5 200.320(a) as a purchase of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed $3,000.00. The micro-purchase method is used in order to expedite the completion of its lowest-dollar small purchase transactions and minimize the associated administrative burden and cost. The City utilizes the micro-purchases method for acquiring supplies or services that do not exceed an aggregate amount of $3,000.00 if the price is reasonable. The program manager responsible for the Federal award determines ift the price is reasonable. Quotes are not required but encouraged. If quotes are obtained for items under $3,500.00, they should be kept in the department and attached to the requisition. Small Purchase Procedures (Purchases between $3,000.01 and $149,999.99 in the Aggregate) The Federal threshold for small purchase procedures is $150,000. 2 CFR S 200.320(b). Small purchase procedures (as defined in 2 CFR $ 200.320[b]) may be used in those relatively simple and informal procurement methods for securing non-personal contracted services, supplies, or other property that do not cost more than $149,999.99. For purchases funded from local funds, to obtain the most competitive price, the City, may, at its option, obtain price quotes for items costing less than $150,000. Unlike the mandatory competitive procurement described for purchases over $150,000, if an item to be paid from local funds costs less than $150,000, the City may utilize price quotations or a competitive procurement process (purchasing cooperatives, sole source, an existing RFP/bid or a new RFP/bid) to stimulate competition and to attempt to receive the most favorable pricing. Page 5 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY However, if using State or Federal funds to purchase goods or services, price or rate quotations must be obtained from an adequate number of qualified sources for all purchases between $3,000.01 and $49,999.99 or use the competitive procurement process. The City must obtain more than one price or rate quote unless using a purchasing cooperative, existing Bid/RFP, or sole source vendor, in which case, the prices have already been awarded. If purchasing from a purchasing cooperative or existing Bid/RFP, the departments can elect to obtain only one quote to purchase the goods or servicès although it is recommended to obtain more than one quote. Such price or rate quotations may be obtained orally and/or documented in writing, and the City must demonstrate that price or rate quotations were obtained from an adequate number of qualified sources. Purchases $150,000 or More in the Aggregate According to Texas law, one of the following competitive methods must be used for purchases of $150,000 or more in the aggregate: (1) competitive bidding for services other than construction services; (2) competitive sealed proposals, for services other than construction services; (3) a request for proposals, for services other than construction services; (4) an interlocal contract; (5) a method provided byChapter 2269, Government Code, for construction services; (6) the reverse auction procedure as defined by Section 2155.062(d), Government Code; or (7) the formation of a political. subdivision corporation under Section 304.001, Local Government Code. In addition, one of the three following methods must be used, depending on the circumstance described below, when purchasing with Federal funds: sealed bids (formal advertising); competitive proposals; or noncompetitive proposals (sole source). Sealed Bids (Formai Advertising) Bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming to all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bid method is the preferred method for procuring construction if the following conditions apply: A complete, adequate, and realistic specification or purchase description is available; Two or more responsible bidders are willing and able to compete effectively for the business; and Page 6 of1 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY The procurement lends itself to a firm fixed-price contract and the selection of the successful bidder can be made principally on the basis of price. If sealed bids are used, the following requirements apply: Bids must be solicited from an adequate number of known suppliers, providing them with sufficient response time prior to the date set for opening the bids. The invitation for bids must be publicly advertised. The advertisement will be published at minimum in a newspaper of the city's choosing for 14 days. The invitation for bids, which will include any specifications and pertinent attachments, musb define the items or services in order for the bidder to properly respond. All bids will be opened at the time and place prescribed in the invitation for bids. The bids must be opened publicly. Af firm-fixed-price contract award must be made in writing to the lowest responsive and responsible bidder. Where specified in bidding documents, factors such as discounts, transportation costs, and life cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of. Any or all bids may be rejected if there is a sound documented reason. Competitive Proposals A competitive proposal is normally used with more than one source submitting an offer, and either a: fixed price or a cost-reimbursement type contract is awarded. (A cost reimbursement contract reimburses the contractor for actual costs incurred to carry out the contract.) Competitive proposals are generally used when conditions are not appropriate for the use of sealed bids. If this method is used, the following requirements apply: Requests for proposals must be publicized and must identify all evaluation factors and their relative importance. Any response to publicized requests for proposals must be considered to the maximum extent practical. The advertisement for proposals will be published at minimum in a newspaper of the city's choosing for 14 days. Proposals must be solicited from an adequate number of qualified sources. The City will conduct a techniçal evaluation of all received proposals through a scoring committee composed ofatleast three members. There will be at least one elected official from the Council on the committee. The committee will assess proposals based on the Page 7 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY evaluation criteria outlined in the solicitation to ensure a fair, transparent, and objective selection process. A recommendation based on this scoring will be prepared and submitted by the Committee to the City Council. The City Council is not required to choose the recommended respondent but will take the recommendation into consideration in its decision. Contracts must be awarded to the responsible firm whose proposal is most advantageous totheprogram, with price and other factors considered. The City retains the right to make a selection based on these factors. When using Federal funds, the City will use competitive request for qualifications-based procurement of archtectura/enginerng (A/E) professional services whereby competitors' qualifications are evaluated and the most qualified competitor is selected, subject to negotiation of fair and reasonable compensation. This method, where price is not used as a selection factor, can only be used in the procurement of A/E professional services. It cannot be used to purchase other types of services though A/E firms are a potential source to perform the proposed effort. The advertisement for qualifications will be published at minimum in a newspaper oft the city's choosing for 14 days. Noncompetitive Proposals (Sole Source Procurement) Procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used when using Federal funds only when one or more of the following circumstances apply: The item is available only from a single source and an equivalent cannot be substituted. This must be documented. The public exigency or emergency for the requirement will not permit a delay resuiting from competitive solicitation. After solicitation of a number of sources, competition is determined inadequate. Additionally, State requirements related to sole-source purchasing are, in some ways, more restrictive. In addition to the Federal requirements above, sole source purchases must meet established criteria: Identification and confirmation that competition in providing the item or product to be purchased is precluded by the existence of a patent, copyright, secret process, or monopoly; At film, manuscript, or book; AU utility service, including electricity, gas, or water; and Page 8 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY Ad captive replacement part or component for equipment. According to State requirements, sole source does not apply to mainframe data-processing equipment and peripheral attachments with a single item purchase price in excess of $15,000. In this case, the City must document why only this product can meet their needs and that it is not available from any other vendor. In all cases, the City will obtain and retain documentation from the vendor that clearly delineates the reasons that qualify the purchase to be made on a sole source basis. Contracting with Historically Underutilized Businesses (HUB), Small and Minority Businesses, : Women's Business Enterprises, and Labor Surplus Firms The City will take all necessary steps to affirmatively assure HUBS, small and minority businesses, women's business enterprises, and labor surplus firms are notified of bidding opportunities and utilized whenever possible. Affirmative steps will include the following: Placing qualified small and minority businesses and women's business enterprises on solicitation lists. Assuring that small. and minority businesses, and women's business enterprises are solicited whenever they are potential sources. Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses, and women's business enterprises. Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses, and women's business enterprises. Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and Require the prime contractor, if subcontracts are to be let, to take the affirmative steps listed in parts (1)-(5) above. Domestic preferences for procurements. As appropriate and to the extent consistent with law, the non-Federal entity should, to the greatest extent practicable under a federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States (including but not limited to iron, aluminum, steel, cement, and other manufactured products). The requirements of this section must be included in all subawards including all contracts and purchase orders for work or products under this award. Page 9 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY "Produced in the United States" means, for iron and steel products, that all manufacturing processes, from the initial melting. stage through the application of coatings, occurred in the United States. Manufactured products" means items and construction materials composed in whole or in part of non-ferrous metals. such as aluminum; plastics and polymer-based products such as polyvinyl chloride pipe; aggregates such as concrete; glass, including optical fiber; and lumber. Procurement of recovered materials. Ai non-Federal entity that is a state agency or agency of a political subdivision of a state and its contractors must comply with section 6002 of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act. The requirements of Section 6002 include procuring only items designated in guidelines of the Environmental Protection Agency (EPA) at 40 CFR part 247 that contain the highest percentage of recovered materials practicable, consistent with maintaining a satisfactory level of competition, where the purchase price of the item exceeds $10,000 or the value of the quantity acquired during the preceding fiscal year exceeded $10,000; procuring solid waste management services in a manner that maximizes energy and resource recovery; and establishing an affirmative procurement program for procurement of recovered materials identified in the EPA guidelines. Cost/Price Analysis for Federal Procurements in Excess of $150,000 In accordance with the requirements in 2 CFR 5 200.324, the City will make independent estimates of the goods or services being procured before receiving bids or proposals to get an estimate of how much the goods and services are valued in the current market. To accomplish this, before bids and proposals are received, the City conducts either a price analysis or a cost analysis, depending on the type of contract, in connection with every procurement with Federal funds in excess of $150,000. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation; however, the City will come to an independent estimate prior to receiving bids or proposals, 2 CFR $ 200.324(a). Accordingly, the City performs a cost or price analysis in connection with every Federal procurement action in excess of $150,000, including contract modifications, as follows: Cost Analysis * Non-competitive Contracts: A cost analysis involves a review of proposed costs by expense category, and the Federal cost principles apply, which includes an analysis Page 10 of: 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY of whéther the costs are allowable, allocable, reasonable, and necessary to carry out the contracted services. In general, A cost analysis must be used for all non-competitive contracts, including sole source contracts. The Federal cost principles apply. All non-competitive contracts must also be awarded and paid on a cost- reimbursement basis, and not on a fixed-price basis. In a cost-reimbursement contract, the contractor is reimbursed for reasonable actual costs incurred to carry out the contract. Profit must be negotiated as a separate element of the price in all cases where there is no competition. When performing a cost analysis, the City negotiates profit as a separate element oft the price. To establish a fair and reasonable profit, consideration is given to the complexity of the work to be performed, the risk borne by the contractor, the contractor's investment, the amount of subcontracting, the quality of its record of past performance, and industry profit rates in the surrounding geographical area for similar work, 2 CFR S 200.323(b). Price Analysis à Competitive Contracts: A price analysis determines if the lump sum price is fair and reasonable based on the current market value for comparable products or services. In general, A price analysis can only be used with competitive contracts and is usually used with fixed-price contracts. It cannot be used with non-competitive contracts. Compliance with the Federal cost principles is not required for fixed-price contracts, but total costs must be reasonable in comparison to the current market value for comparable products or services. A competitive contract may be awarded on a fixed-price basis or on a cost- reimbursement basis. If awarded on a cost-reimbursement basis, the Federal cost principles apply and costs are approved by expense category and not a lump sum. Costs or prices based on estimated costs for contracts are allowable only to the extent that costs incurred, or cost estimates included in negotiated prices would be allowable costs under the Federal cost principles. Page 11 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY Federal awarding agency or pass-through entity review. The non-Federal entity must make available, upon request of the Federal awarding agency or pass-through entity, technical specifications on proposed procurements where the Federal awarding agency or pass-through entity believes such review is needed to ensure that the item or service specified is the one being proposed for acquisition. This review generally will take place prior to the time the specification is incorporated into a solicitation document. However, if the non-Federal entity desires to have the review accomplished after a solicitation has been developed, the Federal awarding agency or pass-through entity may still review the specifications, with such review usually limited to the technical aspects of the proposed purchase. The non-Federal entity mustmake available upon request, for the Federal awarding agency or pass-through entity pre-procurement review, procurement documents, such as requests for proposals, or invitations for bids, or independent cost estimates, when: (1) Thé Non-Federal entity's procurement procedures or operation fails to comply with the procurement standards in this part; (2) The procurement is expected to exceed the Simplified Acquisition Threshold and is to be awarded without.competition or only one bid or offer is received in response to a solicitation; (3) The procurement, which is expected to exceed the Simplified Acquisition Threshold, specifies a "brand name" product; (4) The proposed contract is more than the Simplified Acquisition Threshold and is to be awarded to other than the apparent low bidder under a sealed bid procurement; or (5) A proposed contract modification changes the scope of a contract or increases the contract amount by more than the Simplified Acquisition Threshold. The non-Federal entity is exempt from the pre-procurement review in paragraph (b) oft this section if the Federal awarding agency or pass-through entity determines that its procurement systems comply with the standards of this part. The non-federal entity may request that its procurement system be reviewed by the Federal awarding agency or pass-through entity to determine whether its system meets these standards in order for its system to be certified. Generally, these reviews must occur where there is continuous high-dollar funding, and third-party contracts are awarded on a regular basis. Page 12 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY The non-Federal entity may self-certify its procurement system. Such self-certification must not limit the Federal awarding agency's right to survey the system. Under a self-certification procedure, the Federal awarding agency may rely on written assurances from the non-Federal entity that it is complying with these standards. The non-Federal entity must cite specific policies, procedures, regulations, or standards as being in compliance with these requirements and have its system available for review. Bondingrequirements. For construction or facility improvement contracts or subcontracts exceeding the Simplified Acquisition Threshold, the Federal awarding agency or pass-through entity may accept the bonding policy and requirements of the non-Federal entity provided that the Federal awarding agency or pass-through entity has made a determination that the Federal interest is adequately protected. If such a determination has not been made, the minimum requirements must be as follows: (a). A bid guarantee from each bidder equivalent to five percent of the bid price. The "bid guarantee" must consist of a firm commitment such as a bid bond, certified check, or other negotiable instrument accompanying a bid as assurance that the bidder will, upon acceptance of the bid, execute such contractual documents as may be required within the time specified. (b). A performance bond on the part of the contractor for 100 percent ofthe contract price. A "performance bond" is one executed in connection with a contract to secure fulfillment of all the contractor's requirements under such contract. (c). A: payment bond on the part of the contractor for 100 percent of the contract price. A "payment bond" is one executed in connection with a contract to assure payment as required by law of all persons supplying labor and material in the execution of the work provided for in the contract. Contract Administration The City maintains the following oversights to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders, 2 CFR $ 200.318(b). The program manager/director of the Federal award is responsible for monitoring contractor performance. The manager/director will compare the actual performance of the contract against the projected performance and have the contractor explain any differences. They may also compare fees paid to date to the contractor versus how far along the contractor Page 13 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY is in performing the contractual duties. The manager/director may establish surveys of those who directly benefited from the contractor's work for feedback purposes. To ensure proper administration of contracts and any subgrants that may be awarded by the City, the City uses the following guidelines to determine whether each agreement it makes for the disbursement of Federal funds is a contract, whereby funds are awarded to a contractor or a sub- award, whereby funds are awarded to a sub-recipient. The substance of the relationship is more important than the form of the written agreement, 2 CFR S 200.330. Subawar4s/Subgrants As sub-award/subgront is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the sub-recipient. The City determines who is eligible to receive what Federal assistance, and a subrecpenvsubgronte: Has its performance measured in relation to whether the objectives of a Federal program are met Has responsibility for programmatic decision-making Isr responsible for adhering to applicable Federal program requirements, and In accordance with the subgrant agreement, uses the Federal funds to carry out a program for a public purpose specified in the authorizing statute, as opposed to providing goods or services for the City. Contracts A contract is for the purpose of obtaining goods or services for the City's own use and creates a procurement relationship with the contractor. A contractor: Provides goods and services within normal business operations Provides similar goods or services to many different purchasers Normally operates in a competitive environment Provides goods or seryices that are ancillary to the operation of the Federal program, and Is not subject to compliance requirements of the Federal program as a result of the contract, though similar requirements may apply for other reasons Page 14 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY Documentation, for Contracts The City maintains the following written documentation, at a minimum, for each contract paid with Federal funds: 1. A copy of the written, signed contract/agreement for services to be performed 2. The rationale or procedure for selecting a particular contractor 3. Evidence the contract was made only to a contractor or consultant possessing the ability to perform successfully under the terms and conditions of the contract or procurement 4. Records on the services performed - date of service, purpose of service - ensuring that services are consistent and satisfactorily performed as described in the signed contract or purchase order 5. Documentation that the contractor was not paid before services were performed, and 6, Records of all payments made (such as a spreadsheet or report generated from the general ledger), including the total amount paid to the contractor Payment Only After Services Are Performed For both State and Federally funded contracts, it is not permissible under Texas law to pay a contractor or consultant in advance of performing services. Advance payment to contractors is considered "lending credit" to the contractor and is prohibited under the Texas Constitution, Article 3, SS 50 and 52. For ongoing services that occur monthly, payment can be made at the end of every month (based on a. proper invoice submitted by the contractor and verification of work performed) for services performed during the month, or some other similar arrangement. Consultants and contractors will not be paid without having a properly signed and dated contract or other written agreement in place that clearly defines the scope of work to be performed, the beginning and ending dates of the contract, and the agreed-upon price. The contract should also include a description of the payment procedures. Upon performance of services (at contract milestones or upon completion of services), the contractor is required to submit an invoice to the City that contains at a minimum the following: a clear identification of the contractor/consutant, including name and mailing address ac corresponding contract (or written agreement) number, if applicable the dates (beginning and ending date) during which the services were performed (i.e., billing period) a description of the services/activities completed during the billing period the total amount due to the contractor for the billing period Page 15 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY By submitting a properly prepared invoice, the contractor is certifying that it is true and correct. Verification of Receipt of Goods and Services Provided by Contractors If the purpose of the contract or purchase order is to deliver goods, the City will designate the appropriate staff or consultant to- verify that the quantity and quality of goods are as specified in the contract/purchase order. The receiving report and procedures used in all other State/local purchases will be used for all Federal purchases. If the purpose of the contract is to purchase services, the contract manager along with the City Mayor will verify that the quality and scope of services were received as specified in the contract. Avoiding the Purchase of Unnecessary or Non-duplicative Items The City will ensure that all procurements are necessary and do not include duplicative items. Prior to issuing a solicitation, the City Manager or designated staff will review procurement documents to confirm compliance with this requirement. To promote cost efficiency; the City will evaluate opportunities to consolidate or break out procurements to achieve the most economical purchase. Where appropriate, an analysis will be conducted to compare lease versus purchase options and other relevant alternatives to determine the most cost-effective approach. Prompt Payment to Vendors/Contractors The City pays all vendors/contractors within thirty (30) days of receipt of a proper invoice and the receipt of the goods or services in accordance with the Texas Prompt Payment Act. Government Code, Chapter 2251, Subchapter A, for all contractors, and Property Code, Chapter 28 for Construction Contractors. Suspension and Debarment The City will ensure, prior to award, that all contractors have met all the eligibility requirements outlined in state and Federal law. The following steps will be taken to ensure contractor eligibility for all services procured. Contractors: All contractors, including professional consulting and engineering firms, must be cleared and registered via a search of the Federal System of Award Management ('SAM') to. ensure the contractor is in good standing and has not been debarred. The SAM portal can be found here: nttps://sam.gov/sAM/pages/puDliç/searchRecords/search.st. Page 16 of 17 CITY OF SIMONTON FEDERAL GRANT PROCUREMENT POLICY Subcontractors: Subrecipients must notify the selected prime contractors that it is the sole responsibility of the prime contractor to verify subcontractor eligibility based on factors such as past performance, proof ofliability insurance, possession of a federal tax number, debarment, and state licensing requirements, Page 17 of 17 41-1 RESOLUTION No. Regarding Civil Rights - The CITY OF SIMONTON, Texas Whereas, the CITY OF SIMONTON, Texas, (hereinafter referred to as "CITY OF SIMONTON") has been awarded CDBG-Mitigation (MIT). funding through a CDBG-MIT Method of Distribution (MOD) grant from the Texas General Land Office (hereinafter referred to as "GLO"); Whereas, the CITY OF SIMONTON, in accordance with Section 109 of the Title 1 of the Housing and Community Development Act. (24 CFR 6); the Age Discrimination Act of 1975 (42 U.S.C. 6101-6107); and Section 504 ofthe Rehabilitation Actof:1973 (29 U.S.C. 794) and for construction contracts greater than $10,000, must take actions to ensure-that no person or group is denied benefits such as employment, training, housing, and: contracts generated by the CDBG activity, on the basis of race, : color, religion, sex, national origin, age, or disability; Whereas, the CITY OF SIMONTON, in consideration for the receipt and acceptance of federal funding, agrees to comply with all federal rules and regulations including those rules and regulations governing citizen participation and civil rights protections; Whereas, the CITY. OF SIMONTON, in accordance with Section 3 of the Housing and Urban Development Act of 1968, as amended, and 24 CFR Part 135, is required, to the greatest extent feasible, to provide training and employment opportunities to lower income residents and contract opportunities to businesses in the CDBG project area; Whereas, the CITY OF SIMONTON, in accordance with Section 104(1) of the Housing and Community Development Act, as amended, and State's. certification requirements at 24 CFR 91.325(b)(6), must adopt an excessive force policy that prohibits the use of excessive force against non-violent civil rights demonstrations; Whereas, the CITY OF SIMONTON, in accordance with Section 504 of the Rehabilitation Act of 1973, does not discriminate on the basis of disability and agrees to ensure that qualified individuals with disabilities have access to programs and activities that receive federal funds; and Whereas, the CITY OF SIMONTON, in accordance with Section 808(e)(5) of the Fair Housing Act (42 USC 3608(e)(5)) that requires HUD programs and activities be administered in a manner affirmatively to further the policies of the Fair Housing Act, agrees to conduct at least one activity during the contract period of the CDBG contract, to affirmatively further fair housing; 10/19/2023 Whereas, the CITY OF SIMONTON, agrees to maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SIMONTON, TEXAS, that the CITY OF SIMONTON ADOPTS THE FOLLOWING: 1: Citizen Participation Plan and Grievance Procedures; 2. Section 3 Policy; 3. Excessive Force Policy; 4. Section 504 Policy and Grievance Procedures; 5. Fair Housing Policy. Passed and approved this day of 2025. Laurie Boudreaux, Mayor Date CITY OF SIMONTON 10/19/2023 41-2 CITIZEN PARTICIPATION PLAN THE CITY OF SIMONTON REGARDING THE USE: OF GRANT FUNDS FROM THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT This Citizen Participation Plan was prepared in accordance with Section 104(a) of the Housing and Community Development Act of 1974, as amended. The 24 CFR 91.105 federal regulations outline the "citizen participation" requirements. The plan is to be used to address citizen participation in the Community Development Block Grant (CDBG) Program. With, recelpt of HOME Investment Partnerships (HOME) Program funds, the program will be included under this Citizen Participation Plan. The Citizen Participation Plan (CPP) sets forth policies and procedures for citizen participation in the development of project specific applications and substantial amendments to these projects with funding. CERTIFICATION OF COMPLIANCE The CITY OF SIMONTON is certifying to the U. S. Department of Housing and Urban Development (HUD) and State Agencies administering HUD programs that they have an approved Citizen Participation Plan, which: provides for and encourages citizen participation with emphasis on participation by persons who are residents of slum and blighted areas, by residents in low- and moderate-income neighborhoods, or targeted revitalization areas. provides for and encourages citizen participation of residents of public and assisted housing developments; as well as provides information to the public housing authorities within our jurisdiction activities related to these programs. provides for and encourages citizen participation of persons with disabilities as well as provides documents in a format accessible to persons with disabilities, upon request. provides for and encourages citizen participation of all citizens, including minorities and non-English speaking persgns, and identifies how the needs of non-English speaking residents will be met in the case of public hearings where a significant number of non- English speaking residents can be reasonably expected to participate. provides citizens with reasonable and timely notification and access to local meetings, information, and records relating to the CITY OF SIMONTON's proposed and actual . use of federal Community Development Block Grant funds. provides for public hearings and/or public postings to obtain citizen views; to respond to proposals and questions at all stages of the community development program, including at least the development of needs; and the review of proposed activities, and review of program annual performance. If hearings are held, they shall be after adequate- notice; at times and locations convenient to potential or actual beneficiaries, and with accommodations for the disabled; and, provides for a timely written response to written complaints and grievances where applicable. 1 Note to Grant Recipients regarding Limited English Proficiency (LEP) requirements: In accordance with federal law, if there is a significant number of the population who are non- English speaking residents and are affected by the CDBG project, such citizens should have meaningful access' to all aspects of the CDBG project. To provide 'meaningful access', Grant Recipients may need to provide. interpreter services at public hearings or provide non-English written materials that are routinely. provided in English. Examples of such vital documents may nclude Citizen Participation notices (e.g., complaint procedures, hearings notices), civil rights notices, and any other published notice that may allow an eligible person with limited English proficiency to participate in discussing proposed CDBG activities. For more information, see LEP.gov. COMPLAINT PROCEDURES These complaint proçedures comply with the requirements ofHUD's CDBG Program and Local Government Requirements found in 24 CFR $570.486 (Code of Federal Regulations). Citizens can obtain a copy of these procedures at the CITY OF SIMONTON, PO Box 7, Simonton, TX 77476-0007, 281-533-9809, during regular business hours. Below are the formal complaint and grievance procedures regarding the services provided under the CDBG program. 1. A person who has à complaint or grievance about any services or activities with respect to the CDBG project, whether it is a proposed, ongoing, or completed CDBG project, may during regular business hours submit such complaint or grievance, in writing to the CITY OF SIMONTON Civil Rights Officer, at PO Box 7, Simonton, TX 77476-0007 or may call 281-533-9809. 2. A copy of the complaint or grievance shall be transmitted by the Civil Rights Officer to the person/division that is the subject of the complaint or grievance and to the Mayor within five (5) working days after the date of the complaint or grievance was received. 3. The. Mayor or their representative shall complete an investigation of the complaint or grievance, if practicable, and provide a timely written answer to person who made the complaint or grievance within fifteen (15) days. The response may be ai time extension to further review the complaint or grievance. 4. If the investigation cannot be completed within fifteen (15) working days per 3 above, the person who made the grievance or complaint shall be notified, in writing, within twenty (20) days where practicable after receipt of the originai complaint or grievance and shall detail when the investigation should be completed. 5. If necessary, the grievance and a written copy of the subsequent investigation shall be forwarded to the CDBG Program Manager for their further review and comment. If appropriate, provide copies of grievance procedures and responses to grievances in both English and Spanish, or other appropriate language. 2 TECHNICAL ASSISTANCE When requested, the CITY OF SIMONTON shall provide technical assistance to groups that are representative of persons of low- and moderate-income in developing proposals for the use of CDBG funds. The CITY OF SIMONTON, based upon the specific needs of the community's residents at the. time of the request, shall determine the level and type of assistance. PUBLIC OUTREACH AND INVOLVEMENT Citizens will be provided reasonable advance notice of, and opportunity to comment on proposed activities in an application to the state and for grants already made regarding activities which, are proposed to be. added, deleted, or substantially changed from the entity's application to the state. The public outreach and notification will be accomplished through one or more of the following methods: a) Publicationt of notice in a local newspaper-a published newspaper article may also be used sO long as it provides sufficient information regarding program activities and relevant dates. b) Notices prominently posted in public buildings and distributed to local Public Housing Authorities and other interested community groups. c) Posting of notice on the local entity website (if available). d) Public Hearing; or e) Individual notice to eligible cities and other entities as applicable using one or more of the following methods: Certified mail, Electronic mail or fax, First class (regular mail), Personal delivery (e.g., at a Council of Governments meeting). These details will be included in the Public Comment Version of the Application, prior to submission. Citizens, with emphasis on persons of low- and moderate-income who are residents of slum ànd blight areas, shall be. encouraged to submit their views and proposals regarding community development and housing needs. Citizens shall be made aware of the location where they may submit their views and proposals. PUBLIC COMMENT PROVISIONS AS REQUIRED BY CERTAIN STATE AGENCIES IN THE ADMINISTRATION OF FEDERAL PROGRAMS When public notice is the sole required notification process for the submission of an application from a State agency, the following provisions shall be observed the CITY OF SIMONTON A copy of a substantially complete application will be made available to allow for 14 days of public comment, but are not limited to: 1. The amount of CDBG funds expected to be made available for the current fiscal year (including the grant and any anticipated program income). 2. The range of activities that may be undertaken with the CDBG funds. 3 3, The estimated amount of the CDBG- funds proposed to be used for activities that will meet the national objective of benefit to low- and moderate- income persons. 4. The proposed CDBG activities likely to result in displacement and the unit of general local government's anti-displacement and relocation plans required under $ 570.488. 5. The development of housing and community development needs When a public hearing is required for submission of an application from a State agency, the following provisions shall be observed by the CITY OF SIMONTON: 1. As stated in the COVID-19 Disaster Declaration Proclamation dated March 13th, 2020; public hearings may be held virtually or in person, pursuant to Section 418.017 of the code; "authorization to use all available resources of state government and of political subdivisions that are reasonably necessary to cope with this disaster. 1 Public notice of all hearings must be posted at least seventy-two (72) hours prior to the scheduled hearing. 2. When a significant number of non-English speaking residents are a part of the potential service area of the CDBG project, vital documents such as notices should be published in the predominant language of these non-English speaking citizens. An interpreter should be present to accommodate the needs of the non-English speaking residents at all public hearing where applicable. 3. Each public hèaring shall be held at a time and location convenient to potential or actual beneficiaries anid will include accommodation for persons with disabilities. Persons with disabilities must be able to attend the hearings and the CITY OF SIMONTON must plan for individuals who require auxiliary aids or services if contacted at least two days prior to the hearing. 4. A public hearing, when required by a Federal Program, shall be held after 5:00 PM on a weekday or at a convenient time on a Saturday or Sunday. 5. If the agency requires a public hearing for submission, then a public notice shall be posted at City Hall and the community's website notifying the public of the project selected at least 5 days prior to the submission of the application. The CITY. OF SIMONTON shal! retain documentation of the hearing notice(s), a listing of persons attending the hearing(s), minutes of the hearing(s), and any other records concerning the proposed use of funds for three (3) years from closeout of the grant to the state. Such records shall be made available to the public in accordance with Chapter 552, Texas Government Code. Laurie Boudreaux, Mayor Date 4 41-3 Excessive Force Policy In accordance with 24 CFR 91.325(b)(6), the CITY OF SIMONTON hereby adopts and will enforce the following policy with respect to the use of excessive force: 1. Iti is thé policy of the CITY OF SIMONTON to prohibit the use of excessive force by the law enforcement agencies within its jurisdiction against any individual engaged in non-violent civil rights demonstrations; 2. It is also the policy of the CITY OF SIMONTON to enforce applicable State and local laws against physically barring entrance to or exit from a facility or location that is the subject of such non-violent civil rights demonstrations within its jurisdiction. 3. The CITY OF. SIMONTON will introduce and pass a resolution adopting this policy. As officers and representatives of the CITY OF SIMONTON, we the undersigned have read and fully agree to this plan and become a party to the full implementation of this program. , Laurie Boudreaux, Mayor Date 09/01/2019 41-4 A1004 Section 504 Policy Against Discrimination based on Handicap and Grievance Procedures In accordance with 24 CFR: Section 8, Nondiscrimination based on Handicap in federally assisted programs and activities of the Department of Housing and Urban Development, Section 504 oft the Rehabilitation Act of 1973, as amended (29 U.S.C. 794), and Section 109 of the Housing and Community Development Act of 1974, as amended (42 U.S.C. 5309), CITY OF SIMONTON hereby adopts the following policy and grievance procedures: 1. Discrimination prohibited. No otherwise qualified individual with handicaps in the United States shall, solely by reason of his or her handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance from the Department of Housing and Urban Development (HUD). 2. CITY OF SIMONTON does not discriminate on the basis of handicap in admission or access to, or treatment or employment in, its federally assisted programs and activities. 3. CITY OF SIMONTON's recruitment materials or publications shall include a statement oft this policy in 1. above. 4. CITY OF SIMONTON shall take continuing steps to notify participants, beneficiaries, applicants and.employees, including those with impaired vision or hearing, and unions or professional organizations holding collective bargaining or professional agreements with the recipients that it does not discriminate on the basis of handicap in violation of 24 CFR Part 8. 5. For hearing and visually impaired individuals eligible to be served or likely to be affected by the CDBG program, CITY OF SIMONTON shall ensure that they are provided with the information necessary to understand and participate in the CDBG program. 6. Grievances and Complaints a. Any person who believes she or he has been subjected to discrimination on the basis of disability may file a grievance under this procedure. It is against the law for CITY OF SIMONTON to retaliate against anyone who files a grievance or cooperates in the investigation of a grievance. b. Complaints should be addressed to: Laurie Boudreaux, Mayor, 281-533- 9809, PO Box- 7, Simonton, TX 77476-0007, who has been designated to coordinate Section 504 compliance efforts. 09/1/2020 C. A complaint should be filed in writing or verbally, contain the name and address of the person filing it, and briefly describe the alleged violation of the regulations. d. A. complaint should be filed within thirty (30) working days after the complainant becomes aware of the alleged violation. e. An investigation, as may be appropriate, shall follow a filing of a complaint. The investigation will be conducted by Laurie Boudreaux, Mayor. Informal but thorough investigations will afford all interested persons and their representatives, if any, an opportunity to submit evidence relevant to a complaint. f. A written determination as to the validity of the complaint and description of resolution, if any, shall be issued by Laurie Boudreaux, Mayor, and a copy forwarded to the complainant with fifteen (15) working days after the filing of the complaint where practicable. g. The Section 504 coordinator shall maintain the files and records of the CITY OF SIMONTON relating to the complaints files. h. The complainant can request a reconsideration of the case in instances where he or she is dissatisfied with the detemination/resolution as described in f. above. The rèquest for reconsideration should be made to the CITY OF SIMONTON within ten working days after the receipt of the written deteminatonresoluton. i. The right of a person to a prompt and equitable resolution of the complaint filed hereunder shall not be impaired by the person's pursuit of other remedies such as the filing of a Section 504 complaint with the U.S. Department of Housing and Urban Development. Utilization of this grievance procedure is not a prerequisite to the pursuit of other remedies. j. These procedures shall be construed to protect the substantive rights of interested persons, to meet appropriate due process standards and assure that the CITY OF SIMONTON complies with Section 504 and HUD regulations. Laurie Boudreaux/Mayor Date 09/1/2020 4L-5 Section 3 Policy In accordance with 12 U.S.C. 1701u the CITY OF SIMONTON agrees to implement the following steps, which, to the greatest extent feasible, will provide job training, employment and contracting opportunities for Section 3 residents and Section 3 businesses of the areas In which the program/project is being carried out. A. introduce and pass a resolution adopting this plan as a policy to strive to attain goals for compliance to Section 3 regulations by increasing opportunities for employment and contracting for Section 3 residents and businesses. B. Assign duties related to implementation of this plan to the designated Civil Rights Officer. C. Notify Section 3 residents and business concerns of potential new employment and contracting opportunities as they are triggered by CDBG grant awards through the use of: Public Hearings and related advertisements; public notices; bidding advertisements and bid documents; notification to local business organizations such as the Chamber(s) of Commerce or the Urban League; local advertising media including public signage; project area committees and citizen advisory boards; local HUD offices; regional planning agencies; and all other appropriate referral sources. Include Section 3 clauses in all covered solicitations and contracts. D. Maintain a list of thosé businesses that have identified themselves as Section 3 businesses for utilization in CDBG funded procurements, notify those businesses of pending contractual opportunities, and make this list available for general Grant Recipient procurement needs. E. Maintain a list of those persons who have dentified themselves as Section 3 residents and contact those persons when hiring/training opportunities are available through either the Grant Recipient or contractors. F. Require that all Prime contractors and subcontractors with contracts over $100,000 commit to this plan as part of their contract work. Monitor the contractors' perrormance with respect to meeting Section 3 requirements and require that they submit reports as may be required by HUD or GLO to the Grant Recipient. G. Submit reports as required by HUD or GLO regarding contracting with Section 3 businesses and/or employment as they occur; and submit reports within 20 days of the federal fiscal year end (by October 20) which identify and quantify Section 3businesses and employees. H. Maintain records, including copies of correspondence, memoranda, etc., which document all actions taken to comply with Section 3 regulations. As officers and representatives of CITY OF SIMONTON, we the undersigned have read and fully agree to this plan and become a party to the full implementation of this program. Laurie Boudreaux, Mayor Date 09/01/2019 41-0 Fair Housing Policy In accordance with Fair Housing Act, the CITY OF SIMONTON hereby adopts the following policy with respect to the Affirmatively Furthering Fair Housing: 1. The CITY OF SIMONTON agrees to affirmatively further fair housing choice for all seven protected classes (race, color, religion, sex, disability, familial status, and national origin). 2. The CITY. OF SIMONTON agrees to plan at least one activity during the contract term to affirmatively further fair housing. 3. The CITY OF SIMONTON will introduce and pass a resolution adopting this policy. As officers and representatives of the CITY OF SIMONTON, we the undersigned have read and fully agree to this plan and become a party to the full implementation of this program. Laurie Boudreaux, Mayor Date 09/01/2019 m. Fair Housing Month Proclamation Proclamation of July as Fair Housing Month WHEREAS Title VIII of the Civil Rights Act of 1968, as amended, prohibits discrimination in housing and declares it a national policy to provide, within constitutional limits, for fair housing in the United States; and WHEREAS The principle of Fair Housing is not only national law and national policy, but a fundamental human concept and entitlement for all Americans; and WHEREAS The National Fair Housing Law, during the month of [Month], provides an opportunity for all Americans to recognize that complete success in the goal of equal housing opportunity can only be accomplished with the help and cooperation of all Americans. NOW, THEREFORE, WE, the CITY COUNCIL of CITY OF SIMONTON, do proclaim July as Fair Housing Month in the CITY OF SIMONTON and do hereby urge all the citizens of this locality to become aware of and support the Fair Housing law. IN WITNESS WHEREOF we have affixed our signatures and seal on this the day of 2025. Witness: Title: Witness; Title: 09/01/2019 n. AMENDMENT NO. 1 CITY OF SIMONTON Grant Administration & Environmental Services Contract As pre-procurement required the CITY OF SIMONTON to contractually enter into an agreement prior to the establishment of the project; the contract agreement was based on a percentage (%) figure. Federal Regulations require that with funding; the Grant Administration & Environmental Services Contract must be amended to include a dollar figure. The contract amounts are as follows: Contract Amount for Non-Housing Project (Infrastructure): Administrative Services: $115,928.00 Environmental Services: $12,000.00 Contract # 24-065-168-F083 Contract Billing Milestones: Not-To-Exceed, Budget Gate Percentages by Budget Category (Subrecipient may draw up to, butnot exceed, the identified percentage ofheBudger category, untistated Project Phaser Deliverable) àresubmitted to and approvedhytre GLO Actions and) Deliverables a N & A Project Delivery Grant Administration Funds - Environmertal: Eunds w Action: Start-up Phase Deliverable: Contract kick- offmeetings sign-ins sheet; all required Start-Up Documentation reviewed and accepted 0-15% by the GLO; executed grant administration service provider contract in PDF format. Action: Commencementofl Environmental: Phase Deliverable: Executed environmental service provider 15.01-30% 0-30% contract in PDF: format] provided during start-ip phasez as applicable. Action: Completion of Environmental Record Review 30.01-50% 30.01-100% Dellverable: GLO-signed AUGF Action: Commencementofl Bid) Phase Deliverable: Firstp publishedbidnotice: and publisher's 50,01-60% affidavit* Action: Commencement: of Construction Phase Deliverable: Signed! NTP 60.01-85% Action: Completion of Construction' Phase Deliverable: Signed and sealed complete As-Built Plans in PDF format; executed COCC accepted by the GLO; signed 85.01-95% FWCR accepted by the GLO Action: Grant Completion Report Approval Deliverable: GCR approved by the GLO 95.01-100% - Laurie Boudreaux angford 5 Mayor ingford Community Management Services Date: Date: 05/30/25