03-18Council File # �3 _\g
Green Sheet # 203492
RESOLUTION
OF
Presented By:
Referred To:
PAUL, MIl�TNESOTA
as
1
2 WHEREAS, the U.S. Department of Justice has awarded a$200,000 Value Based Initiafive Grant
3 to the City of Saint Paul, Police Department, for the period beginning September 1, 2001, and ending
4 September 30, 2003; and
5
6 WHEREAS, the purpose oFthis grant is to develop and coordinate community partnerships with the
7 faith community; and
8
9 BE IT RESOLVED, that the City Council accepts this grant and authorizes the City of Saint Paul to enter
10 into, and Chief WiUiam Fynney to implement, the attached agreement with the U.S. Department of
11 Justice.
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Requested by Deparhnent of:
Adopted by Council:Date: . � �-�c73
Adopfion Certified by Counci ecretary:
By: � _ k�
Approv Mayor: Date: (� _
✓�
By: K�B�'���� r
VBI grant acceptance.cr.02
By:
Committee:Date:
Approval Reco ended b,� Finan 'al Servlces:
By: ' 1 UA��.&� � ���� " p C�
Form
By:
by City
for
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U. S. Department of Justice
Offzce of Community Oriented Policing Services
COPS Training and Technical Assistance Award
Pmj¢M'IYUe: Value Based Inifiative Convnuation
ORI #: MI306209
Awazdee: St Paul, City of
Vendor#: 41�005521
Law Enforcement Eaecutive: Cluef Williaw K Finney
Address: 100 Fast l lth S4cet
Address 2:
Ciry, State, Zip Code: St. Paul, MN 55101
Telephone: (651)2923588
p� (651)292-3542
Government Eaecutive: Mayor Randy Kelly
Address: 390 City Hall
Address 2:
Ciry. Sta1e, Zip Code:
Telephone:
Far:
St Paul, MI7 55701
(651)266-8510
(651)266-8513
� ��$
Cooperative Agreement Condifions:
This project is approvedaubject to such condilions or limitations as aze set forth on ihe attached pages.
Statntory Anthority for Cooperative Agreement Award:
The Public SafeTy Partnership and Cotnmunity Policing Act of 1994, 42 U.S.C.§ 3796dd(1994).
Award Date:
Award Period:
Awazd Amount:
9/1/2001
Fmm: 9/1/2001
$ 200,000.00
To: 9/30/2003
Agency Appmva!
��I°^-� � ��� � �
\ �WV
Cad R Peed
Director
Signature of Law Enforcemegt Official with the
Authority to Accept this Grant Award
Signature of Govermnent Off"icial with the Authozitq
to Accept this Grant Awazd
�' '` I F '
Typed Name and Title of Law F�forcement
Official
Typed Name and Tifle of Govemment Official
Date
Date
False statements or claims made in connection with COPS grants may resuit in fines, impr
federat grants or contracts, and/or any remedy available by law to the Federat Government.
;�. ��` =
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U. S. Deparlment of Jus6ce
Office of Community Orierrted Po&cing Services
Award Terms
1. For grants of $500,000 or more, the grantee aclmowledges that Failnre to snbmit an acceptabk Eqnal Employment
Opport�ity Plan (9f graatee is tequired to snbmit one ander 28 CFR 42302) that is approved by the Office of Justice
Programs, Office for Ctivil Rights, is a violation of its Asanrances and may result in the saspension of the drawdosvn of
f�ds.
For grAUts nnder $500,000� the grantee must sabmit a completed EEOP Certification form and return it to the Office of
Jostice Prograws, Office for GYv1 Rights �vithin 120 days of the grant awazd.
2. The recipient sLalt snbmit one copp of all repor[s and proposed pnblica&ons resulting from this graut 20 days prior
to public reiease. Any pn6&cations (inclad"mgwritten, software, visnal, or sound, b� eaclnd"mg press teleases,
ne�vsletters, and issae analyses), whether published at the recipien£s ar Governmert's ezpenae shall rnntain #he
followIDg statemenk
"This Docnment was prepated 6y St Panl, CSty of supported by 2001CKWRK075, awazded by the U S. Department of
Jnstice. The opmions, fin�lings, and conclusions or recommendations eapressed 'm �is doc�rment are those of the
author(s) and do not necessarilp represeM the officiat position or policies of fhe U.S. DepaRment of Jastice. "
3. The COPS office may conduM a national evalnation of the Commanity Oriented PoHcing Services (COPS'� Program.
The recipient agrees to cooperate with the evalaators, as reqnested.
4. The grant may be terminated, in whole or in part, at any time before the date of complefion, by the Department of
Justice if the Recipient fa�s to comply with these terms and conditions, with any of the Assurances sabmiffed with the
app&eation or with the pmject goaLs, plans, and methodology set forth in the appmved application, or due to anp eaigent
circimuctances the Government may face. The recipient will be no 'UCied of any decision to termmate for the reasons
desen7�ed a6ove and be allowed reasonable time, not to eaceed 45 days, to terminate pmject operations. No tern�ina6on
shaIl affect the obligation of funds incarred in good faith prior to the receipt of notificaHon of termination Otherwise
aliowable funds shaII not be considemd obligated solely bp vittue of recipicnt commitment to par�cipating agencics or
project rnMractors for work or services not yet performed.
5. In order to assist the COPS Office m the monitoring of the awazd, your agency w�l be responsible for sabmitling
quar[erly pmgress reports and quarterly fmaucial reports. Before those reports become due, COPS staff wiIl pmvide
out�mes to assist you with these reporks.
6. Upon grant terminarion, the grantee agrees that computer-madabk copies and adequate documentafion of all
databases and pmgrams developed or acquired in connection with the auatyses m the pmject w71 be snbmitted to fhe
COPS Office at no additionai cost The data may be ased bp the government, or �ssemina#ed to otLers for their nse, for
any pnrposes deemed appmpriate by the COPS Office, witho� further compensation to the grantee. Consistent with 28
CFR, Part 22, the grantee must remove individnal identifiers from any data bases and pmgraws prior to their
submission to the COP5 Office.
7. If any part of the fimded pmject contams reseazch or statisticat acrivities wluch involve hnman sabjects that are not
covered by an esemPtion set forth in 28 CFR section 46.101(b)(1-�, the grantee must meet the pmvision of the
Depactmeut of Justice's Common Ru1e regazd'mg Human Subjects Research Protections, 28 CFR Part 46, prior to the
ezpendih�re of Federal f�ds to pedorm snch activityCes). The grantee also agrees to comply to with 28 CFR Part 22
segazding the safegaarding of individually identi6able infotmation coIlected fmm research participants.
=���:,-,
F ��f i
rioo �e�,,,�„�av�, rvw
Warhingloq DC20530
Memorandam
$200,000.00
$0.00
To; VJiliiam K Finney, Chief
St. Paul, City of
From: Beverly Alf ssistaat r, Traiaing and Technicai Assisrance Division �
Katherine cQuay, Project Manager, Training and'['echnical Assistance Division � '�
Bobbie Butler, Staff Accountant, Finance Division Q� �, ��,�
/a
Re: Training and Technical Assistance Financial Clearance Memo
p� -1 Y
A fmancial analysis of budgeted costs has been completed. Costs under this awazd appeaz reasonable, allowable, and
consistent with existing guidelines. Exceptions / Adjustments aze noted below.
Vendor #: 416005521
Benefits
Proposed Bud¢et
$40,0OO.OQ
$0.00
$4,000.00
$16,000.00
$138,000.00
$2,000.00
Costs:
Total
Grand Total:
Cieared Date:
U. S. Department of Justice
Office of Commanity Oriented Policing Services (COPS�
$200,000.00
Total Award:
August 13, 2002
ORI #: MN06209 Grant #: 2QO1CI{�'XK075
Approved Bud¢et
$40,000.00
$0.00
$a,000.00
$16,000.00
$138,000.00
$2,000.00
Adjustments Disatlowed Reasons/Comments
$0.00
$0.00
$o.00
$0.00
$0.00
$0.00
$Z00,000.00 $0.00
$0.00 $0.00
___=„_________________________________ ____
$200,000.00 $0.00
$ 200,000.00
Overalf Comments:
�Y
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,:
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03`��
U.S. Department of Jus6ce
Office of Community Oriented Policing Seivices (COPS)
1 I W Vermont Avenue, NW
Washuy�ton, D.C. 20�30 �
Cooperative Agreement #2001CKWXK075
5aint Paul Police Department
I. Statement of Authority
This Cooperative Agreement between the St. Paul Police Department, "the Awardee," and the U.S.
Depaztrnent of Justice Office of Community Oriented Policing Services (COPS Office), is hereby
entered into under the authority of 42 USC Section 3796 dd (�. The purposes of this Cooperative
Agreement are described below.
II. Statement of Background and Purpose
BACKGROITND:
The U. S. Department of Justice Office of Community Oriented Policing Services has been chazged
with the implementation of the Public Safety Partnerships and Community Policing Act of 1994.
Under this law, the Office of Community Oriented Policing Seroices provides �ants, cooperative
agreements, and technical assistance to increase police presence, unprove police and community
partnerships designed to address crime and disorder, and enhance public safety. The Off"ice of
Community Oriented Policing Services is providing researchers, policing agencies, law enforcement
professionals, community leaders, and legai experts opportunities to undertake and produce programs,
independent reseazch, evaluations, training, and policy support activities on topics supporting the
enhancement of community policing, coliaborative problem-solving, police integrity, and
organizational transformation.
The Value Based Initiative (VBn is a COPS strategy that emphasizes training and technical assistance
for problem solving on a community level through collaborative partuerships betwaen local law
enforcement, faith-based entities and community organizations. This training and technical assistance
is designed to identify and meet the individual needs of residents, thereby promoting the overall health
of a community. The Office of Community Oriented Policing Services has expanded its VBI program
because it encourages law enforcement agencies to create or strengthen local projects that build trust
between the police and their faith-based communities.
PIZIMARY OBJECTIVE:
Under this Cooperative Agreement, the St. Paul Police Department will design a police/faith-leader
training program and conduct two such programs during the course of the year. The department will
also provide three safe haven community learning centers for youth and hire and manage staff to run
these facilities. In addition, the department wiil create an eualuation tool to measure the success of
both the safe havens and the trauung activities.
COPS O�ce Cooperative Agreememt-St Paul Police Depanmeni VBI- 200ICKWXKOiS
III. Scope of Work
o .�_�r
For a period hereinafter set forth, the COPS Office and the Awardee will cooperatively furnish the
necessary personnel, travel, suppiies, and otherwise perfoim all things necessary for, or incident to, the
perfonnance of work (the accomplishment of functional objectives) as set forth below:
A. SpeciFcaily, the COPS OfSice will:
1. Designate a Program Manager to participate in the planning and mana�ement of this Cooperative
Agreement and to coordinate activities;
2. Provide information and technical assistance from government sources within available resources
and as determined appropriate by the Program Manager;
3. Provide guidance to the Awardee in the planning and development of strategies used in the project
and in the coordination of the project with law enforcement agencies and organizations interested in
contributing their support;
4. Work with the Awardee to ensure that all training and technical assistance providers utilized by
this initiative have demonstrated expeztise in the subject matter azea and aze able to perform specific
training and technical assistance tasks successfully as required under this Cooperative An eement. The
Program Director will submit for approval or disapproval to the Office of Community Oriented
Policing Services, lists of proposed training and technical assistance providers, inciuding their
curricula vitae, at least twenty (20) calendar days prior to the proposed date of utilization;
5. Review and approve quarterly reports submitted to the Office of Community Oriented Policing
5ervices Program Manager on the progress of the implementation timeline and any progrunmatic or
budgetary modifications (with the Program manager receiving both quarterly programmatic and
copies of financial reports; and,
6. Reserve a royalty-free, nonexclusive and irrevocable license to reproduce, publish or othenvise use,
and to authorize others to use, for Federal govemment purposes: (1) the copyright in any work
developed under this Cooperative Agreement, subgrant, or conuact; and (2) any rights of copyright to
which an Awardee, subgrantee, or a contractor purchases ownership with support from a cooperative
agreement.
B. Specificaily, the Awardee will:
1. Work closely with the COPS Office and Program Manager to achieve the tasks specified in the
Cooperative A�reement;
2. Provide further detail on pro}ect plans as requested by the Program Manager;
3. Adhere to the requirements or tasks specified in this Cooperative Agreement and not deviate from
them unless requested adjustments are first presented to and approved by the Program Manager,
4. Submit for prior approval or disapproval to the Program Manager any proposed changes in key staff
assignments to this project and any si�ificant changes in any partner's role or responsibilities;
5. Obtain written approval from the COPS Office prior to the expenditure of Agreement funds for the
awazd of non-competitive contracts (including equipment purchases) in excess of $100,000;
COPS O�ce Cooperative Agreement-St Paul PoliceDepanment VBI- 2001CK4VXK075
6. Submit one copy of all reports and proposed publications resulting from this agreement twenty (ZO) �\`/
days prior to public release. Any publications (written, visual, or sound) or computer programs, oa
whether or not published at government expense, shall contain the following statement;
This project was supported by Cooperative Agreement #2001CKWXK075 by
the L3.S. Department of 3ustice Office of Community Oriented Policing
Services. Points of view or opinions contained in this document aze those of the
author and do not necessarily represent the official position or policies of the
U.S. Department of Justice.
7. Comply with the COPS Office policy on contact with the news media. The policy establishes the
COPS Office Communications Division as the principal point of contact for the news media for issues
relevant to the COPS Office and/or parameters of the Cooperative Agreement. The Awardee agrees to
refer all media inquiries on these topics directly to the COPS Communications Division (202-616-
1728);
8. ffrequired, submit all surveys, intervlew protocols, and other infonnation collections to the COPS
Office for submission to the Office of Management and Budget (OMB) for clearance under the
Paperwork Reduction Act (PWRA) of 1995; and,
9. Agree to cooperate with the evaluator if an evaluation of this project is to be undertaken by the
COPS Office or a third party and in consultation with the COPS Office, and agree to make reasonable
adjustments to programs and activities in recognition of significant points of evaluation or feedback.
C. The Awardee acknowledges that:
1. If any part of ihe fixnded project contains reseazch or staxistical activities which invoive human
subjects that aze not covered by an �emption set forth in 28 CFR Section 46.101(b)(i-6), the
Awardee must meet the provisions of the Department of 7ustice's common iule regarding Human
Subjects Research Risk Protections, 28 CFR Part 46, prior to the expendihue of Federal funds to
perform such activity(ies). The Awardee also ab ees to comply with 28 CFR Part 22 regarding the
safeguazding of individually identifiable information collected from reseazch participants;
2. Impiementation of this awazd shall be subject to Federal monitoring, auditing, and/or evaluation
and/or a Single Audit Act audit (see OMB Circulaz A-133) and agrees to cooperate with such activities
by providing access to and copies of, as appropriate, all project-related records, documents and
personnel;
3. Failure to comply with the terms and conditions o£this award may result in legal sanctions
including, but not Innited to, suspension and termination of funds, repayment of expended funds, and
ineligibility to receive additional COPS funding;
4. A hold may be placed on this award if it is deemed that the Awardee is not in compliance with
Federal civil rights laws and/or is not cooperating with an ongoinn Federal civil rights investigation;
and,
5. False statements or claims made in connection with COPS awards may result in fines,
imprisonment, debazment from participating in Federal grants or contracts, and/or any other remedy
available by law to the Federal Government.
COPS O�ce Cooperative Agreement-St PriulPolice Department VB!- 2001CK6PXK07i
D. Specific Requirements
At a minimwn, the following specific requirements shall be fulfilled by the Awardee during the
specified timeframe.
Task 1
o �.1i�
Hire a VBI project director who will serve as the point-of-contact with the COPS Office, oversee and
coordinate a11 VBI activities, and deliver all necessary materials to COPS in a timely fashion.
Task 2
Design a police/faith-leader training program and conduct a minimum of two such pro�ams in the
course of the yeu.
Task 3
Provide three safe haven community learning centers for area youth.
Task 4
Hire and train staff to manage and provide services in the safe havens.
Task 5
Establish a VBI Governing Boazd.
Task 6
Complete a community safety plan and develop a plan for dissemination.
E. Performance Time Line and Deliverables
The performance time Jine for all deliverables and their due dates (based upon an awazd date of
09/Ol/Ol), which are considered to be significant in the performance of ttus Cooperative Agreement,
shall be subject to the timetable outlined in the Awazdee's Pmject Nanative and Implementation Pian.
Three hard copies and one electronic copy of deliverable items shall be delivered to the COPS Office
(20) days prior to public release.
The Awardee's Project Narrative and Implementation Plan (attached to this agreement) shall be
incorporated into this aD eement and the Awazdee will be responsible for fulfilling all of the goals,
objectives and tasks contained in the Project Narrative and Implementation Plan.
COPS O�ce Coope>ative Agreemsnt-SL Parel Police Depanment VBI- 200lCKWXK0�5
Deliverables
All deliverabie items sha11 be furnished to the following project manager (20) days prior to public
release.
Katherine McQuay
U.S. Deparhnent of Justice
Office of Community Oriented Policing Services
1100 Vermont Ave. NW
Washington DC 20530
F. Financial Status Reports
o� •�
The Awazdee will provide quarterly reports of project activity and expenditures. Specifically, the
Awazdee will submit quarterly financial status reports on the standard government form (fozm number
SF269A). These should be received by the COPS Office within 45 days of the end of each of the
following quarters (Januazy 1-Mazch 31 / April 1-June 30 / July 1-September 30 / October 1-December
31). The Awazdee wall submit a final SF269A form.
IV. Period of Performance
Tile period of performance of this Cooperative Agreement is 25 months from the Cooperative
Agreement Awazd Start Date (award period 09/Ol/O1 to 09/30/03) to include no-cost extensions. This
includes a no-cost extension through 9/30/2003.
v. Financial Administration
A. Fundin : The total not-to-exceed amount of Federal funding to be provided under this Cooperative
Agreement is $200,000 as specifaed in the official budget clearance memo tliat accompanies this
doctunent.
B. Travel: All travel plans related to the Cooperative Agreement and to the development of the
deliverables should be submitted to the Program Manager for review by the COPS Office.
(1) Crrantee Travel Cost reimbursement rates are governed by the grantee's own written travel
policy. If the Awardee's written travel policy establishes reimbursement rates which exceed the
applicable Federal rates, the Awardee must justify those rates as cost effective and obtain prior
approval from the COPS Office. If the Awardee does not have a written travel policy, ar if the
Awardee's rates aze deemed unreasonable, the allowable h�avel costs will be reimbursed based
on the applicable Federal rates for the relevant geographic area.
(2) If the Awazdee is using awazded funds to pay for travel for non-grantees, the reimbursement
rates for the approved project-related travel costs aze governed by the applicable Federal rate
for the relevant geographic azea.
C. Consultin¢ Rates: Special authorization must be obtained from the COPS Office for daily
consultant rates higher than $450. Authorization requires submitting a detailed written justification of
the consultant rate to the Program Manager. Specific and detailed written justification for each
additional consultant must be submitted to and approved by the COPS Office prior to obligation or
expenditure of such funds.
COPS O�ce Coopera[ive Agreement-S! Pau[ PoGce Department VB]- 2001 CKWXKO%5
D. Project Budget: The approved project budget, dated 09/13/Oi, is incorporated herein and made a��,�
part of this Cooperative Agreement. Movement of dollazs between approved budget cate�ories is
allowed up to 10 percent (10%) of the total award amount as last appcoved by the COPS Office,
providing there is no change in project scope. When the cumulative changes exceed 10 percent (10%)
of the total award amount or change the scope of the project, prior approval from the COPS Office is
required. The Awardee must give prompt notification in writing to the COPS Office of events or
proposed changes in excess of 10% of the total award amount. In requesting an adjustrnent, the
Awazdee will set forth the reasons and the basis for the proposed change and any other information
deemed helpful for review by the COPS Office.
E_ Payment: All costs claimed for reimbursement, and payment, including the fmal payment, shall be
submitted via the PAPRS system.
F. Employment: Awardee acknowledges that nothing in this Cooperative Agreement shall be
construed to create an employment relationship with the COPS Office or with the Federal government
or to require provision of any benefits incident to employment.
VI. Project OffScer(s)
A. COPS Office
Beverly Alford, Assistant Director
COPS Office
U.S. Department ofJustice
1100 Vermont Avenue, NW
Washington, DC 20530
202-514-5775
B. Awardee
Chief William K. Finney
St. Paul Police Department
100 E. Eleventh St
St. Paul, Minnesota 55101
VII. General Provisions
The Awazdee of record must follow all requirements imposed by the Department of 7ustice as a
condition or administrative requirement of the grant, including but not limited to: the requirements of
OMB Circulars A-87, A-21, A-122 or the Federal Acquisition Regulations, as applicabie (goveming
cost principles); OMB Circulars A-102 or A-110, as applicable (ITniform Administrative
Requirements for Grants and Cooperative Agreements); OMB Circulars A-133 (goveming audits); the
applicable provisions of the Omnibus Crime Control and Safe Streets Act of 1968, as amended; the
current edition of the Office of Justice Prograsns Financial and Administrative Guide for Grants; and
with all other applicable program requirements, laws, orders, regulations, or circulars.
VIII. Modifications
Modifications to this Cooperative Agreement may be proposed at any time during the period of
performance by either party, and shall become effective upon approval by both parties.
COPS O�re Coaperative Agreement-SG Paul Police Depmament VBI- 2001CKWXK075
a � _�Y
IN WI'INESS THEREOF, the parties hereto have caused this Cooperative Agreement to be executed
as of the date therein written.
Signature(s):
�
e , ire
Office of Community Oriented Policing Services
Date: � � � � � ����
Signature of the Law Enforcement Fxecutive/Program Official with the authoriiy to accept ihis grant
award. �
Chief William K. Finney
St. Paul Police Department
Date:
Signature of the
award.•
Ivlayor Randy Kelly
Mayor, St. Paul, Minnesota
Date:
��- ��.
Official with the authority to accept this gr�ant
� tC`nav�
�
COPS Office Cooperative Agreement 10/23l02 9:4I AM
, I�
� DEPARTMENT/OFFICE/COUNCIL DATE INITIATED
Poli� ����s�oz GREEN SHEET No. 203492 `
� CONTACT PERSON & PHONE 1tsmAUDA INmAUDATE
Chief Willi2m Finney 292-3588 � DEPARTMEM DIREttOR 5 cou�_�3 �
MUST BE ON COUNCIL AGENDA BY (DATE) �� r
Please process ASAP �nnow,Er � ' ��RK
�RII1pNCNLSERNCE$qR,_ �FBNNCW.SERV/ACCTG
�TOR (OR ASSIS�AM) �ww N6Xf5
TOTAL # OF SIGNATURE PAGES 1 (CLfP ALL LOCATIONS FOR SIGNATURE)
' CTION REQUESTED
, Approval of the attached council tesolution accepting a grant from the U.S. Department of 3ustice, and authorizing
the City of Saint Paul to enter into, and Chief William Finney to implement, the attached agreement with the
U.S. Department of Justice.
,
. RECOMMENDATIONAppfove(A)orRejett(R) PERSONALSERVICECONTRACTSMUSTANSWERTHEFOLLOWINGQUESTIONS:
� L Has this personffirtn ever worked under a contrect for this depaAment?
' PLANNING COMMISSION YES NO
CIB COMMITfEE 2. Has ihis personlfirm ever been a city employee?
'� CNIL SERVICE COMMISSION YE5 NO
� 3 Does this personffrm possess a skill not normally possessetl by any curtent aty employee?
YES NO
4. Is this persoNfirm a targeted vendoR
YES NO
' Explain all yes answers on separate sheet and attach to green sheet
� INITIATING PROBLEM ISSUE, OPPORTUNITY (WHO, WMAT, WHEN, WHERE, WHY)
The U. S. Department of Justice has awazded a$200,000 Value Based Inifiafive Grant to the City of Saint Paul,
Police Department, for the period beginning September 1, 2001, and ending September 30, 2003. The purpose
of this grant is to develop and coordinate community partnerships with the faith community.
(Attached is a copy of the gient awazd agreementJ
� ADVANTAGESIFAPPROVED
' The building of relationslups between the faith community, law enforcement, community, and other
' community associations. The relationships will work to impact safety in the community, provide safe
havens for young people, build and add assets to youth lives, and have a broader community network
' to respond to a local and/or national crisis. This grant is a continuation of the community policing
effort that is the Saint Paul Police D artmenYs hiloso h.
,, DISADVANTAGESIFAPPROVED
None.
� DISADVANTAGES IF NO7 APPROVED
Lost opportuniry to work with faith-based communities and other aspects of the community to help
youth and decrease at-risk youth.
�� �c���
��^ � 7 �
m ,�
TO7AL AMOUNT OF TRANSACTION $ 200,000.00 COST/REVENUE BUDGE7ED (CIRCLE ONE) YES NO
FUNDING SOURCE U.S. Department of Justice ACTIVITY NUMBER 436-34057
,,,� FINANCIAL INFORMATION (EXPWN)
VBI grarrt accepance.gs.2002