ORANGE COUNTY TRANSPORTATION AUTHORITY (2)

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FY05 HOMELAND SECURITY GRANT PROGRAM - VERSION 2.0. 12-22-2004 local laws and regulations regarding the release of information, which should be considered when reporting sensitive matters in the grant application, needs assessment and strategic planning process. Applicants may also consult their ODP Preparedness Officer regarding concerns or questions about the release of information under state and local laws. Services to Limited Enalish Proficient (LEPI Persons Recipients of ODP financial assistance are required to comply with several federal civil rights laws, including Title VI of the Civil Rights Act of 1964, as amended, These laws prohibit discrimination on the basis of race, color, religion, national origin, and sex in the delivery of services. National origin discrimination includes discrimination on the basis of limited English proficiency. To ensure compliance with Title VI, recipients are required to take reasonable steps to ensure that LEP persons have meaningful access to their programs. Meaningful access may entail providing language assistance services, including oral and written translation, where necessary, Grantees are encouraged to consider the need for language services for LEP persons served or encountered both in developing their proposals and budgets and in conducting their programs and activities, Reasonable costs associated with providing meaningful access for LEP individuals are considered allowable program costs. For additional information, please see httD://www.leD.QOv. C. Allowable Costs Guidance HSGP allowable costs are divided into planning, organization, equipment, training, and exercises categories. In addition, M&A costs are allowable and certain operational costs under UASI and LETPP are also allowable. Specific focus for each program's allowable costs is included in the program's respective section of this solicitation. Examples of allowable costs and activities can be found in Appendix A: Authorized Program Expenditures. The following provides general HSGP allowable costs guidance: Manaaement and Administrative (M&AI Costs Guidance All programs within HSGP have allowable M&A costs for both the state-level as well as the local unit of government, urban area, or designated subgrantee. . SHSP, UASI, LETPP, CCP, MMRS: No more than 3% of the total amount allocated to the state for each program within HSGP may be retained at the state level and used for M&A purposes. These state M&A funds must be included in the total funds retained by the state, In addition, local jurisdiction subgrantees may retain and use up to 2.5% of their subaward from the state for local M&A purposes. States may pass through a portion of the state M&A allocation to local subgrantees in order to supplement the 2.5% M&A allocation allowed on subgrants. However, no more than 3% of the total subaward may be expended by subgrantees on M&A costs. Note: M&A costs are not allowed for either the state or designated recipients for VAS/ allocations to nonprofit organizations. DEPARTMENT OF HOMELAND SECUR(TY I OFF(CE FOR DOMEST(C PREPAREDNESS 25