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AGENDA STAFF REPORT
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DATE: June 25, 2018
TO: Honorable Mayor and City Council
THRU: Jill R. Ingram, City Manager
FROM: Joe Miller, Chief of Police
SUBJECT: Acceptance of 2018 -2019 State Department of Alcoholic
Beverage Control Grant Monies
SUMMARY OF REQUEST:
That the City Council adopt Resolution 6837 approving an agreement between
the City of Seal Beach and the State of California Department of Alcoholic
Beverage Control to provide grant funding for Seal Beach Police Department
education and enforcement activities; and authorizing the Chief of Police to
execute on behalf of the City of Seal Beach all contracts and proposals including
any extensions or amendments thereof and any subsequent contract with the
State in relation thereto.
BACKGROUND AND ANALYSIS:
The Seal Beach Police Department monitors crime and quality of life conditions
relative to the 64 State of California Department of Alcoholic Beverage Control
(ABC) licensees within the City. For FY 2018 - 2019, the Police Department
applied to ABC for a grant in non - supplanting funds - designed to aid in alcohol
license, abuse, and enforcement, and the City was awarded a grant amount of
$42,571.
The predominant section most readily identified for this grant would be the
downtown commercial /residential district known as "Old Town" and the actual
roadway named Main Street. Main Street has 22 ABC licensees within its three -
block length. In several years past, the City of Seal Beach has applied for and
received grants from the ABC under their Grant Assistance Program (GAP). The
current GAP will focus on alcohol and drug education for licensees, alcohol
related crime prevention for merchants, briefing training for City of Seal Beach
personnel, underage minor decoy operations — to include shoulder tapping of
people to buy alcohol for underage minors and similarly physical attempts by
minor decoys to purchase alcohol inside establishments. There will be several
directed enforcement efforts when police officers will respond to predetermined
locations, which are known for habitual public intoxication arrests.
Agenda Item J
The Seal Beach Police Department evaluated calls for service generated during
2017 within the 100 -300 blocks of Main Street. During this evaluation, it was
learned that there were approximately 500 alcohol related calls for service
citywide and nearly 350 were generated from the "Old Town" area. There are
four ABC licensed locations, all within approximately 100 yards of each other on
Main Street, which alone generated nearly 100 calls for service related to
alcohol. These four locations consistently generate the highest number of calls
for service of all on -sale locations within the city.
These quality of life issues can be significantly improved by using these grant
funds to implement the above listed measures, as well as specifically targeting
areas that generate the highest number of calls for service.
Lastly, the Chief of Police will be authorized to execute, on behalf of the City of
Seal Beach, a contract with the State of California Alcoholic Beverage Control for
the stated purposes in the contract and authorize acceptance of the monies.
ENVIRONMENTAL IMPACT:
There is no environmental impact related to this item
LEGAL ANALYSIS:
The City Attorney has reviewed and approved as to form.
FINANCIAL IMPACT:
There is no fiscal impact. Both revenue and expenditures were included in the
FY 2018 -2019 Budget in Fund 075 — Police Grants.
RECOMMENDATION:
That the City Council adopt Resolution 6837 approving an agreement between
the City of Seal Beach and the State of California Department of Alcoholic
Beverage Control to provide grant funding for Seal Beach Police Department
education and enforcement activities; and authorizing the Chief of Police to
execute on behalf of the City of Seal Beach all contracts and proposals including
any extensions or amendments thereof and any subsequent contract with the
State in relation thereto.
•..- .
SUBMITTED BY:
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Joe Miller, Chief of Police
Prepared by: David Barr, Sergeant
NOTED AND APPROVED:
5t. Ag4am
Jill R. Ingram, City Manager
ATTACHMENTS:
A. Resolution 6837
B. Standard Agreement between the City of Seal Beach and the State of
California Department of Alcoholic Beverage Control
Page 3
Attachment "A"
RESOLUTION 6837
A RESOLUTION OF THE SEAL BEACH CITY COUNCIL
ACCEPTING CALIFORNIA DEPARTMENT OF ALCOHOLIC
BEVERAGE CONTROL GRANT ASSISTANCE PROGRAM
MONIES
THE SEAL BEACH CITY COUNCIL DOES HEREBY RESOLVE:
Section 1. The City Council hereby approves authorizing the City of Seal
Beach, through the Seal Beach Police Department, to enter into a contract
between the City of Seal Beach and the State of California Department of
Alcoholic Beverage Control.
Section 2. The Council hereby authorizes the Chief of Police to execute on
behalf of the City of Seal Beach all contracts and proposals including any
extensions or amendments thereof and any subsequent contract with the State in
relation thereto.
PASSED, APPROVED AND ADOPTED by the Seal Beach City Council at a
regular meeting held on the 25th day of June, 2018 by the following vote:
AYES:
Council Members:
NOES:
Council Members:
ABSENT:
Council Members:
ABSTAIN:
Council Members:
Mike Varipapa, Mayor
ATTEST:
Robin L. Roberts, City Clerk
STATE OF CALIFORNIA }
COUNTY OF ORANGE } SS
CITY OF SEAL BEACH }
I, Robin L. Roberts, City Clerk of the City of Seal Beach, do hereby certify that
the foregoing resolution is the original copy of Resolution 6837 on file in the
office of the City Clerk, passed, approved, and adopted by the City Council at a
regular meeting held on the 25th day of June, 2018.
Robin L. Roberts, City Clerk
Attachment "B"
STATE OF CALIFORNIA
STANDARD AGREEMENT
STD 213 (Rev 06103)
AGREEMENT NUMBEP.
ISG•LA48
REGISTRATION NUMBER
1. This Agreement is entered into between the State Agency and the Contractor named below:
DEPARTMENT OF ALCOHOLIC BEVERAGE CONTROL
CONTRACTOR'S NAME
City of Seal Beach through the Seal Beach Police Department
2, The term of this July 1, 2018 through June 30, 2019
Agreement is:
3. The maximum amount $42,571
of this Agreement is:
4. The parties agree to comply with the terms and conditions of the following exhibits which are by this reference made a
part of the Agreement.
Exhibit A — Scope of Work 4 page(s)
Exhibit B — Budget Detail and Payment Provisions
Exhibit C* — General Terms and Conditions
Check mark one item below as Exhibit D:
M Exhibit - D Special Terms and Conditions
Exhibit - D* Special Terms and Conditions
Exhibit E — Additional Provisions
3 page(s)
GTC 0412017
(Attached hereto as part of this agreement) 1 page(s)
page(s)
Items shown with an Asterisk (J, are hereby incorporated by reference and made part of this agreement as if attached hereto.
These documents can be viewed at www, dgs. ca. gov/ of s/ Hesrres !Stano�ardContracrLargu�e. as oz
IN WITNESS WHEREOF, this Agreement has been executed by the parties hereto.
CONTRACTOR
CONTRACTOR '$ NAME ff olher than an )ndiveual, State whether a Corporation, partnership, etc.)
City of Seal Beach through the Seal Beach Police Department Iryl
BY (AuMcrtzee Scneture) DATE SIGNEDiUn nnny/+e)
5
PRINTED NA AND TITLE OF PERSON SIGNING
Joseph Miller, Chief
ADDRESS
911 Seal Beach Boulevard
Seal Beach, CA 90740
STATE OF CALIFORNIA
AGENCY NAME
of Alcoholic Beverage Control
DATE SIGNEDfl) nm mpr)
09INTED NAME AND TITLE OF PERSON SIGNING
Nelson, Chief, Business Management Branch
ADDRESS
3927 Lennane Drive, Suite 100, Sacramento CA 95834
services Use Only
® Exempt per: SCM 4.04.(A)(3)
Approved as to Form:
By: � �4
Craig Steele, City Attorney
SCOPE OF WORK
Summary —
Exhibit A
Agency Description - The Seal Beach Police Department employs 33 swom officers, 27 support staff, and over
100 civilian volunteers in our VIPS, RACES and CERT programs. We are a full service law enforcement
agency. Our command staff consists of a Chief of Police and two Commanders who oversee the Support and
Operations Divisions. There are 16 Officers and four Sergeants assigned to uniformed patrol providing first
responder services. We have two Motor Officers who comprise the traffic unit. Our Detective Bureau consists
of four Detectives and one Detective Sergeant providing both proactive and reactive investigative support to
address crimes occurring in our city. One Detective is assigned to a Federal Drug Taskforce. We have an
Administrative Sergeant who handles training, professional standards and recruitment. Additionally there is a
Sergeant assigned to supervise our Seal Beach Police Detention Center. Our Type I jail facility is staffed by six
Detention Officers.
The City of Seal Beach Seal Beach is located in the northwest comer of Orange County. To the southeast is the
city of Huntington Beach. To the east are the cities of Westminster and Garden Grove. To the north are the city
of Los Alamitos and the unincorporated community of Rossmocr. To the northwest we are bordered by the city
of Long Beach in Los Angeles County. Seal Beach is often described as a quaint seaside village. The
predominant section most readily identified by this description would be the eclectic downtown residential /
commercial district affectionately known as "Old Town." Main Street is, by definition, the main road into and
out of this area. It is a two lane road that runs between Pacific Coast Hwy and the city pier and is comprised of
numerous densely packed businesses including clothing, confectioners, specialty shops, bars and restaurants.
Seal Beach comprises a total area of 12.96 square miles and has a population of 24,440 comprising over 13,000
households and 5,900 families. It is home to the first major planned retirement community in the United States,
Leisure World, boasting a population of over 9,000 and encompassing nearly one square mile. We are home to
The United States Navy's primary West Coast ordnance storage, loading and maintenance installation facility
where they service cruisers, destroyers, frigates and medium -sized amphibious assault ships is located at the
Naval Weapons Station Seal Beach. We have seen significant growth in both our commercial development near
the center of the city and in the large multiuse retail centers in the north end of town. As a tourist destination our
population swells significantly during the summer months and whenever pleasant weather is forecast.
The Funding Requested is $42,571. Our Goals and Objectives will be to strategically address the alcohol
related "Quality of Life" issues within our community. The alcohol related problems in our community which
are directly related to, or originating from, ABC licensee locations range from underage drinking, serving and
providing alcohol to minors, the serving of obviously intoxicated patrons, noise complaints, fights, assaults.
DUI's and homicide. We intend to conduct a total of 14 enforcement operations to include; Minor Decoy,
Shoulder Tap and specifically targeted General Enforcement efforts. We will also engage in partnership based
prevention and educational efforts by hosting ABC provided educational training for our licensees and their
employees as well as conducting IMPACT inspections at all of our licensee establishments. Additionally we
would readily publicize our efforts via social media, local news publications and local community television.
We would continue to maintain and nurture the healthy relationship we currently enjoy with ABC through in
service roll -call training and operational collaboration.
The Number of ABC Licensed Locations within the city of Seal Beach is 64. This includes 50 on -sale general,
beer and wine, and Bona Fide Public Eating Places and 14 off -sale general as well as beer and wine.
SCOPE OF WORK
Problem Statement —
Exhibit A
The City of Seal Beach has experienced significant change in a very short period of time. In the past 22 months
we have hired 10 police officers with.seven in the last 11 months. These officers brought exceptional experience
and enthusiasm to our agency. However, during this transitionary period our entire swom contingent was taxed.
All command staff and specialty positions took on additional collateral assignments as well as working in
patrol. By February of this year we filled every open position and all of our personnel were off of training.
While we were responsive to the challenges presented to our agency we were also unable to fully engage in
proactive measures to temper many of the more specific issues with which we were confronted. Our general
calls for service has increased significantly in recent years. Many of these calls were found to be alcohol related
and a significant number of those were directly attributed to the ABC licensed locations in our community.
These incidents result in a significant drain on both our financial resources and tax the available personnel
needed to handle other important calls for service. Providing our officers with the training and resources
available under this grant will be a significant force multiplier in addressing many of these concerns.
Our Main Street is 2,100 feet long and runs through the heart of our "Old Town" District. The concentration of
ABC licensees has benefited our local economy in many ways. It has provided a destination for our significant
visitor population and supported many excellent restaurants and businesses. However, we made nearly 1,000
arrests during all of 2017 to the present day and of those there were over 200 for alcohol related offenses. That
equates to approximately 20% of all arrests generated. We evaluated the number of calls for service during this
same time frame and found there were over 500 alcohol related calls for service citywide with nearly 70% were
generated in the "Old Town" area relating to ABC licensees, alcohol offenses and quality of life issues. Within
Old Town 34% of our total licensees are located on Main Street within 1,600 feet of each other. Moreover, 20%
of our licensees are located within a 685 foot block of Main Street just steps from the ocean. Four of these
licensees are comprised of popular Irish themed restaurants and bars generating a constant need to direct police
resources to the area to mitigate noise, assaults, fights, and other complaints that occur by their 2:00am closings.
Clancy's Saloon — Located in the 100 block of Main Street. We have responded to well over 250 calls for in the
immediate area of this licensee and over 50 calls directly to this establishment. These incidents have resulted in
arrests for fights with and between intoxicated patrons, patrons arrested for Driving Under the Influence after
leaving the establishment. minors within the premises and consuming alcohol, drunk in public, narcotics
violations, and noise complaints. The owner's brother was involved in an assault with a deadly weapon incident
With the suspect being an intoxicated patron. In a separate incident, a manager at the location, who was
intoxicated and related to the owner, was arrested and charged in the assault of a patron resulting in their death.
Irisher Bar — Located in the 100 block of Main Street approximately 100 feet from Clancy's Saloon. We have
responded to well over 250 calls for service around this licensee and over 15 calls directly to this establishment.
These incidents have included fights with and between intoxicated patrons, drunk in public, and patrons arrested
for Driving Under the Influence after leaving the establishment, and noise complaints from adjacent residents.
O_Malley_s on Main. — Located in the 100 block of Main Street approximately 400 feet from Clancy's Saloon.
We have responded to well over 250 general calls for service around this licensee and over 10 calls directly
related to this establishment. These incidents have included fights, assaults, overserving of obviously
intoxicated patrons and complaints of excessive noise committed by their patrons.
Exhibit A
SCOPE OF WORK
Hannesscy's Tavern — Located in the 100 block of Main Street approximately 325 feet from Clancy's Saloon.
We have responded to over 20 calls around or directly related to this establishment. These incidents have
included fights with and between intoxicated patrons and drunk in public, reported DUI's, urinating in public
and noise complaints from residents.
Pro meet Description —
It is our desire to be truly effective as we work to address the issues we have outlined. To this end we have
employed additional strategies with our criminal justice partners. Our Project Director has spoken with our local
District Attorney's office to elicit specific support for the efforts we are engaging in as they pertain to alcohol
related criminal activity in our community. To further address these issues our agency will employ the
following strategies to achieve our identified Goals and Objectives.
LEAD (Licensee Education on Alcohol and Drugs) —
One aspect of our educational Goal will be the hosting of an ABC LEAD class. Our Objective is to partner with
Licensees as responsible stakeholders in the community by employing the "Target Hardening" philosophy. The
ABC facilitated LEAD training presents information to the Licensees within our city on ABC regulations,
related laws and best practice strategies. By hosting this training we reinforce our desire to build strong
relationships with licensees and ABC. Although our licensees have expressed their desire to be proactive in
identifying alcohol related issues they face, with an emphasis on avoiding the selling or serving of alcohol to
minors, experience has shown that many are not as successful as they could be. We will work together to
prevent future violations and transgressions. We will offer and host the LEAD training at our department for all
our ABC Licensees within the first quarter.
IMPACT (Informed Merchants Preventing Alcohol- Related Crime Tendencies) —
It is our goal to inform and educate all of our licensees. That objective will be met by conducting IMPACT
inspections at all of our Licensee locations, both on -sale and off -sale, to help identify and address potential
problem areas at these locations in a directed effort aimed at reducing crime and disorder at their establishments
and the surrounding area. This program fosters a community oriented approach to problem solving by
generating positive interactions between the relevant stakeholders. We will conduct IMPACT inspections on all
on -sale and off -sale licensees in the city during the first quarter. During the last quarter we will conduct follow -
up inspections locations where deficiencies were identified. This allows licensees time to rectify identified
problems and promotes positive interactions.
ROLL CALL TRAINING —
Our Goal is to educate our patrol officers and investigators. We will conduct roll call briefing trainings for all of
our patrol personnel, presented by our investigators, during each quarter of the grant to meet that Objective. The
trainings will provide the latest information on relevant ABC regulations and effective enforcement strategies
wherein our personnel will gain timely knowledge of ABC laws, operations and practical experiences.
SHOULDER TAP —
It is the Goal of our agency and community to curtail the procurement of alcohol by minors in our city. We will
conduct four Shoulder Tap operations, one each quarter, throughout the city. Our Objective is to not only
discourage those irresponsible persons who would purchase or provide alcohol to minors but also to reduce one
avenue of opportunity minors have been known to utilize to obtain and consume alcohol.
Exhibit A
SCOPE OF WORK
MINOR DECOY —
Continuing to address our Goal of curtailing the procurement of alcohol by minors in our community we will
conduct four Minor Decoy operations, one each quarter, throughout the city. Our Objective is to discourage
licensees; or their employees from providing alcohol to underage minors. We will visit both on -sale and off -sale
ABC licensed locations. We will specifically visit new licensee locations as well as locations where previous
ABC violations were documented. Additionally, during the last quarter, we will revisit those licensees who
were unsuccessful during one of the previous three quarters operations. We look to encourage the licensee's
diligence by personally presenting their letter of success reinforcing our community partnership.
DIRECTED ENFORCEMENT —
Maintaining our Goal of curtailing underage drinking and addressing associated quality of life issues involving
our licensees, we will conduct six Directed Enforcement Operations. These Objectives will be met by
conducting three Directed Enforcement Operations during our summer season, primarily between the Fourth of
July and Labor Day, and three additional operations during the winter and spring seasons. During the summer
our community experiences a surge in population due to beautiful beaches and inviting Main Street shops, bars
and restaurants. We consistently receive increased calls for service on our beaches and in and around our beach
parking lots. Many of these incidents involve alcohol violations including minors possessing and consuming
alcoholic beverages. We will also focus our efforts by addressing Quality of Life issues. By providing specific,
directed attention, to the areas commonly generating calls for service we can address commonly raised concerns
such as the serving of obviously intoxicated patrons, persons who are drunk in public, curtailing excessive
noise, and providing a force presence to dissuade fights and assaults. The teams will meet with licensees,
engage in active citizen contacts and take proactive enforcement action. We promote our efforts by highlighting
our activities on social media as well as with our local media to provide our residents, businesses, visitors and
followers with a direct and tangible understanding of our efforts at addressing their concerns.
Project Personnel —
The Seal Beach Detective Bureau with the Seal Beach Special Enforcement Team (SET) will be actively
engaged in implementing this grant. The following personnel will be directly involved in conducting this grant.
Sergeant Dave Ban- will serve as the project director. He has been a police officer over 29 years and has a
Bachelor's degree. Over his career he has worked a number of assignments including; Detective, Watch
Commander, Emergency Services Coordinator and Detention Center Supervisor. He has worked with ABC
Investigators and Supervisors both here and as a Faculty member at Golden West College. He has previously
served as a grant project director. Sergeant Rick Ransdell is the Detective Sergeant and has been a police officer
for over 50 years working variety of assignments including narcotics and, vice. Detective Samantha Mathias has
been an officer for over 8 years, a detective for over 4 years and has earned a Bachelor's degree. Detective Jeff
Gibson has been a police officer for over 12 years and a detective for 2 years. Detective Pete Krok has been a
police officer for over 8 years and a detective for over 4 years. Detective Chris Fisher has been a police officer
for over 5 years and is our newest detective. Our SET unit consists of patrol personnel tasked with mission
specific assignments. The team comprises 1 Sergeant, 1 Corporal and 3 Officers with law enforcement tenure
ranging between 10 and 30 years. The majority of our officers in uniformed patrol have over 12 years of law
enforcement experience. All of our department personnel have routinely represented this agency with the
highest level of personal character and professionalism. Our agency has successfully worked with ABC
Investigators,on previous occasions and we look forward to continuing that valuable relationship into the future.
BUDGET DETAIL
Exhibit B
BUDGET CATEGORY AND LINE-ITEM DETAIL
COST
(Round budget amounts
to nearest dollar)
A. Personnel Services (Straight Time Salaries, Overtime, and Benefits),
A.1 Straight Time
A.2 Overtime 450 hours @ $82.38
$37,071
A.3 Benefits
TOTAL PERSONNEL SERVICES
$37,071
B. Operating Expenses (maximum $2,500)
Minor Decoy Operations, Shoulder Tap Operations and Directed Enforcement
Operations `Buy Money"
$500
TOTAL OPERATING EXPENSES
$500
C. Equipment (maximum $2,500)
(Attach receipts for all equipment purchases to monthly billing invoice)
Covert Audio Surveillance System
$1.500
Covert Audio Surveillance Earpieces
$1,000
TOTAL EQUIPMENT
$2,500
D. Travel Expense/Registration Fees (maximum $2,500)
(Registration fee for July 2018 GAP Conference attendee is $325 each)
Registration for July 2018 GAP Conference for two Attendees at $325 each
$650
Travel, per them and Lodging for the July GAP Conference
S1,850
TOTAL TRAVEL EXPENSE
$2,500
TOTAL BUDGET DETAIL COST, ALL CATEGORIES
$42,571
PAYMENT PROVISION
Page 1 of 2
Exhibit B
INVOICING AND PAYMENT: Payments of approved reimbursable costs (per Budget Detail
attached) shall be in arrears and made via the State Controller's Office. Invoices shall be
submitted in duplicate on a monthly basis in a format specified by the State. Failure to submit
invoices and reports in the required format shall relieve the State from obligation of payment.
Payments will be in arrears, within 30 days of Department acceptance of Contractor
performance, pursuant to this agreement or receipt of an undisputed invoice, whichever occurs
last. Nothing contained herein shall prohibit advance payments as authorized by Item 2100-
101 -3036, Budget Act, Statutes of 2018.
2. Revisions to the "Scope of Work' and the "Budget Detail' may be requested by a change
request letter submitted by the Contractor. If approved by the State, the revised Grant
Assistance Scope of Work and /or Budget Detail supersede and replace the previous documents
bearing those names. No revision can exceed allotted amount as shown on Budget Detail. The
total amount of the contract must remain unchanged.
3. Contractor agrees to refund to the State any amounts claimed for reimbursement and paid to
Contractor which are later disallowed by the State after audit or inspection of records
maintained by the Contractor.
4. Only the costs displayed in the "Budget Detail" are authorized for reimbursement by the State to
Contractor under this agreement. Any other costs incurred by Contractor in the performance of
this agreement are the sole responsibility of Contractor.
5. Title shall be reserved to the State for any State- furnished or State - financed property authorized
by the State which is not fully consumed in the performance of this agreement. Contractor is
responsible for the care, maintenance, repair, and protection of any such property. Inventory
records shall be maintained by Contractor and submitted to the State upon request. All such
property shall be returned to the State upon the expiration of this contract unless the State
otherwise directs.
6.. If travel is a reimbursable item, the reimbursement for necessary traveling expenses and per
diem shall be at rates set in accordance with Department of Personnel Administration rates set
for comparable classes of State employees. No travel outside of the State of California shall be
authorized. No travel shall be authorized outside of the legal jurisdiction of Contractor without
prior authorization by the State.
Exhibit D
Special Terms and Conditions
1. Dis mites: Any dispute concerning a question of fact arising under this contract which is not
disposed of by agreement shall be decided by the Director, Department of Alcoholic
Beverage Control, or designee, who shall reduce his decision to writing and mail or
otherwise furnish a copy thereof to the Contractor. The decision of the Department shall be
final and conclusive unless: within 30 days from the date of receipt of such copy, the
Contractor mails or otherwise furnishes to the State a written appeal addressed to the
Director, Department of Alcoholic Beverage Control. The decision of the Director of
Alcoholic Beverage Control or his duly authorized representative for the determination of
such appeals shall be final and conclusive unless determined by a court of competent
jurisdiction to have been fraudulent, capricious; arbitrary, or so grossly erroneous as
necessarily to imply bad faith, or not supported by substantial evidence. In connection with
any appeal proceeding under this clause, the contractor shall be afforded an opportunity to
be heard and to offer evidence in support of its appeal. Pending final decision of a dispute
hereunder, Contractor shall proceed diligently with the performance of the contract and in
accordance with the decision of the State.
2. Termination Without Cause: Either party
reason upon ten (10) days written notice.
contract termination.
may terminate this agreement at any time for any
No penalty shall accrue to either party because of
Contract Validitv: This contract is valid and enforceable only if adequate funds are
appropriated in Item 2100 -101 -3036, Budget Act of 2018, for the purposes of this program.
Contractor Certifications: By signing this agreement. Contractor certifies compliance with
the provisions of CCC 04/2017, Standard Contractor Certification Clauses. This document
may be viewed at htt r./ wtww. des. ca. ju�'/u ls/ ftc_ sourcesj5tundordContrsctLanuua�c .ash .
-� - --
S. If the State determines that the grant project is not achieving its goals and objectives on
schedule, funding may be reduced by the State to reflect this lower level of project activity.
undated 12/6/17