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HomeMy WebLinkAbout5205 RESOLUTION NO. 5 2 0 5 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF AUBURN, WASHINGTON, ADOPTING THE 2016 COMMUNITY DEVELOPMENT BLOCK GRANT ACTION PLAN FOR THE CONSOLIDATED PLAN YEARS 2015-2019 WHEREAS, the City of Auburn was designated as an entitlement community by the U.S. Department of Housing and Urban Development (HUD) for its Community Development Block Grant (CDBG) Program; and WHEREAS, the primary objective of the Consolidated Plan and CDBG Program is the development of viable urban communities by providing decent housing and a suitable living environment and expantling economic opportunities, principally for persons of low-income and moderate-income; and WHEREAS, to be eligible for funding, the City of Auburn must annually update the action plan for its Consolidated Plan that serves as a federally required planning document to guide the City of Auburn's human service and community development efforts; and WHEREAS, the planning process to develop the Consolidated Plan involved citizen participation and guidance from non-profit and governmental agencies serving low income residents in the community; and WHEREAS, the City Council of the City of Auburn heard and considered public comment about its proposed 2016 Action Plan. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF AUBURN, HEREBY RESOLVES as follows: ------------------------- Resolution No. 5205 January 13, 2016 Page 1 of 2 Executive Summary AP-05 Executive Summary - 91.200(c), 91.220(b) 1. Introduction Each year the City of Auburn executes specific actions to implement the goals and strategies of the Consolidated Plan for Years 2015-2019. Actions that will be undertaken in 2016 are outlined in this Annual Action Plan. The City of Auburn anticipates the receipt of approximately$519,114 in Community Development Block Grant (CDBG) funds in 2016. Auburn's CDBG funds will be combined with approximately$550,000 of General Funds which totals the city's Human Sercies budget. Human Sevices oversees and is responsible for providing and managing financial resources to more than 30 non-profit agencies that serve the Auburn community, adminsitering the local housing repair program, and developing collaborations among community partners to strengthen the reponse to residents in need. The 2016 Action Plan proposes to allocate $77,500 of CDBG funds to public services. Most of those funds ($62,500) will be used to provide dental and medical care to uninsured. low income Auburn residents and $15,000 for employment training. Approximately$100,000 of the CDBG funds will be allocated to program administration,which includes planning. The remaining$341,164 will be allocated to housing repair($249,500), economic development ($40,000), and support of youth outreach ($51,644). The City of Auburn is committed to focusing more on achieving solutions to recurring social problems and achieve a greater collaboration among service providers. Overall the implementation of the 2015 Action Plan is progressing as planned and most of the activities listed are underway. 2. Summarize the objectives and outcomes identified in the Plan This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan. With the overall goal of reducing the number of people living in poverty within the City of Auburn, the following objectives and outcomes will be employed: 1. Support the development and preservation of affordable housing rental and ownership Annual Action Plan 1 2016 OMB Control No:2506-0117(exp.07/31/2015) 2. Support job training activities as part of an anti-poverty strategy 3. Support low- and moderate-income neighborhoods, and populations with economic and neighborhood development activities, including physical infrastructure. 4. Support accessibility to affordable health care To accomplish these outcomes and objectives, the City invests in programs that meet the community basic needs, increase self sufficiency, provide economic opportunity and develop a safe community. 3. Evaluation of past performance This is an evaluation of past performance that helped lead the grantee to choose its goals or projects. During the past year Auburn has accomplished significant achievement on its programs and impacted the lives of thousands of residents. In 2015 alone, projects funded by the City completed the following: • Over 18,000 low income residents in Auburn received free meals through emergency food programs, food banks and hot meals sites. • Over 40 Auburn residents received shelter for over 2,700 nights. • Over 10,000 Auburn residents received free medical or dental care. • Over 40 senior and/or disabled homeowners received housing repair services. 4. Summary of Citizen Participation Process and consultation process Summary from citizen participation section of plan. Drafts of the Consolidated Plan were made available for public review on the City of Auburn website and notices of its public view were sent out through email and other vehicles of communication. The City of Auburn in conjunction with the Consortium consulted with multiple public and private agencies during the development of the consolidated plan. Agencies that participated in consultations included: the King County Housing Authority, King County All Home, other government human service providers and nonprofit agencies delivering services in Auburn and the subregion. In addition to conducting consultations during the development of the plan, the City of Auburn collaborates and works closely with numerous coalitions, committees and government entities. 5. Summary of public comments This could be a brief narrative summary or reference an attached document from the Citizen Participation section of the Con Plan. Annual Action Plan 2 2016 OMB Control No:2506-0117(exp.07/31/2015) One comment received during the public hearing for the 2016 Action Plan applauded the City's work with CDBG funds and encouraged a stronger participation from city council with the program. A detailed transcript of the comment can be found attached to the Cititzen Participation section of the Plan. No written comments were received. 6. Summary of comments or views not accepted and the reasons for not accepting them All comments and views provided were taken into consideration during the Action Plan process. 7. Summary Auburn residents along with stakeholders, community partners, service providers and others were consulted during the development of the Action Plan.They provided valuable input that supported to the development of the outcomes and objectives listed in the plan. The City of Auburn will continue to use all of its funds to support residents of low/moderate income while maintaining a focus on underserved and special populations. Annual Action Plan 3 2016 OMB Control No:2506-0117(exp.07/31/2015) PR-05 Lead & Responsible Agencies - 91.200(b) 1. Agency/entity responsible for preparing/administering the Consolidated Plan The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsibl each grant program and funding source. Agency Role Name Depai Lead Agency AUBURN CDBG Administrator ESG Administrator Table 1—Responsible Agencies Narrative Consolidated Plan Public Contact Information Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) AP-10 Consultation - 91.100, 91.200(b), 91.215(1) 1. Introduction The City of Auburn consulted with multiple public and private agencies during the development of the Action Plan. Agencies that participated in consultations included: the King County Department of Community and Human Services, nonprofit agencies delivering services in Auburn and the subregion and King County All Home. In addition to conducting consultations during the development of the plan, the City of Auburn collaborates and works closely with numerous coalitions, committees and government entities throughout the duration of the plan in efforts to enhance strategies and systems to meet established goals and objectives on the plan. Provide a concise summary of the jurisdiction's activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(l)). The City of Auburn works closely with partnering King County jurisdictions, public housing authorities and health providers to develop systems in order to improve the quality of service and access for low- income residents as well as the community as a whole within the city and throughout the region. Additionally, the City participates in monthly meetings with King County Community and Human Services, Public Health King County, Valley Cities, the Multi-Service Center and King County Housing Authority to review program progress and delivery of services funded through regional efforts.This group has worked collaboratively to fund a full-time position to address housing and homeless related issues in the South King County region. Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children,veterans, and unaccompanied youth) and persons at risk of homelessness. In Coordination with the King County CoC, Auburn supported funding programs such as the Valley Cities Landing, Auburn Youth Resources Severson House and the YWCA Auburn Transitional Housing Program. All programs provide housing and supportive services to homeless persons (including homeless Veterans,families, chronically homeless individuals and unaccompanied youth). Coordinating the CoC is critical to our region's implementation of the King County All Home ten year strategic plan on homelessness which in turn will help homeless persons meet three goals: • achieve residential stability • increase their skill levels and/or incomes Annual Action Plan 5 2016 OMB Control No:2506-0117(exp.07/31/2015) • strengthen their ability to influence decisions that affect their lives Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS All projects receiving CoCfunding are required by HUD to apply for support through a local Continuum of Care. For King County, the Continuum of Care encompasses programs and activities within the borders of King County. Each continuum sets funding priorities and need for its community. The King County CoC priorities are set by All Home King County. Auburn staff contribute to the CoC by working collaboratively with All Home on efforts for King County to ensure coordination efforts between the two entities. 2. Agencies, groups, organizations and others who participated in the process and consultations Annual Action Plan 6 2016 OMB Control No:2506-0117(exp.07/31/2015) Table 2—Agencies,groups,organizations who participated 1 Agency/Group/Organization KING Agency/Group/Organization Type Other What section of the Plan was addressed by Consultation? Housii Public Home home] Home childn Home Home Unacc Home Non-F. Briefly describe how the Agency/Group/Organization was consulted.What are the anticipated outcomes of the consultation or areas for improved coordination? Identify any Agency Types not consulted and provide rationale for not consulting The City of Auburn consulted with all types of organizations that primarily serve the populations focused on in the Acti programs that addressed the greatest need in the community. The only types of organizations not consulted with were corrections facilities and homeless shelters.The rationale for facilities is that the City does not host either type of organization in the region. Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the The goals of Auburn's Strategic Plan overlap with the goals of the c Continuum of Care King County homeless residents in the community and reduce the risk of home Table 3-Other local/ regional/federal planning efforts Narrative Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) AP-12 Participation - 91.401, 91.105, 91.200(c) 1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting Citizen participation plays a crucial role in the success of the City's Annual Action Plan.The goals are to hear the comm recommendations on how CDBG funds should be invested and how services can coordinate to achieve the greatest im Citizen Participation Outreach Sort Order Mode of Outreach Target of Outreach Summary of Summary of Summary of c response/attendance comments received not accei and real. Non- No comments were 1 Newspaper Ad targeted/broad received. community Table 4—Citizen Participation Outreach Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Expected Resources AP-15 Expected Resources — 91.420(b), 91.220(c) (1, 2) Introduction The City of Auburn anticipates funding for the duration of the Consolidated Plan from • CDBG • City of Auburn General Fund allocation for Community Services Anticipated Resources Program Source of Uses of Funds Expected Amount Available Year 1 Expect Funds Annual Program Prior Year Total: Amou Allocation: Income:$ Resources: $ Availal $ $ Remin of ConF CDBG public- Acquisition federal Admin and Planning Economic Development Housing Public Improvements Public Services 519,114 0 0 519,114 2,076, General Fund public- local Public Services 500,000 j 0 0 500,000 2,000, Table 5-Expected Resources—Priority Table Explain how federal funds will leverage those additional resources (private, state and local funds), includir Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) matching requirements will be satisfied The City of Auburn relies on CDBG funds to support community and economic development projects and activities in e moderate income populations become self sufficient and sustain affordable housing. However,CDBG funds are not th( City uses to support community projects and activities.The City's general funds are used to support community projec funds. CDBG funds do not require matching funds. If appropriate, describe publically owned land or property located within the jurisdiction that may be used identified in the plan N/A Discussion The City of Auburn will use CDBG funds to support all eligible projects and activities that align with CDBG guidelines an Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Annual Goals and Objectives AP-20 Annual Goals and Objectives - 91.420, 91.220(c)(3)&(e) Goals Summary Information Sort Goal Name Start End Category Geographic Needs Addressed Fundin Order Year Year Area 1 Ensure a Suitable 2015 2019 Non-Housing Homeless Prevention CD Living Environment Community I and Intervention $66, Development Economic 1 Opportunity 2 End Homelessness 2015 2019 Homeless Homeless Prevention CD and Intervention $62, 3 Ensure Decent, 2015 2019 Affordable Housing Affordable Housing CD Affordable Housing Public Housing Development and $289, Preservation Neighborhood Revitalization 4 Planning and 2015 2015 Planning and CD Administration Administration $100, Table 6-Goals Summary Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Goal Descriptions 1 Goal Name Ensure a Suitable Living Environment Goal Description 2 Goal Name End Homelessness Goal Description 3 Goal Name Ensure Decent, Affordable Housing Goal Description 4 Goal Name Planning and Administration Goal Description Table 7—Goal Descriptions Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) AP-35 Projects - 91.420, 91.220(d) Introduction Auburn's Annual Action Plan provides descriptions of proposals of how funds will be prioritized to achieve goals identified in the Consolidated Plan. Projects funded by the City will address the priority needs ofA providing assistance to preventA homelessness, ensure affordable housing andA a suitable living environment.A Projects and programs are selected through a competitive application process to ensure optimal quality services is provided to the community in use of the funds. # Project Name 1 HOUSING REPAIR 3 ADMINISTRATION 4 HEALTHPOINT 5 Employment Training Program 6 Youth Outreach Center 7 GRCC SMALL BUSINESS ASSISTANCE Table 8—Project Information Annual Action Plan 14 2016 OMB Control No:2506-0117(exp.07/31/2015) Describe the reasons for allocation priorities and any obstacles to addressing underserved needs The allocations proposed are based on the assessment of Auburn's needs, the resources available in the region, the availability of other funds also focusing on needs, and the purpose of Consolidated Plan funds. Should CDBG revenues exceed the proposed amount, the additional resources shall be allocated in accordance to the following guidelines: • Fill gaps in human services primarily healthcare, homeless prevention and intervention and affordable housing accessibility. • Increase funding for physical development activities including housing, community facilities and economic development. If increases are not significant enough to enhance projects or activitities funds may be placed in contingency for programming later in the year or the following program year. Should CDBG revenues come in lower than anticipated; the City will continue with its planned policy and to the extent allowed reduce funding allocations in physical development projects and administrative activities. Public service project funds will not be decreased. Should CDBG revenues come in less than originally proposed, the City will continue managing the programs with decreased resources to the extent possible and reduce funding allocations in administrative activities and not public services. If exceeded revenues are not significant enough to enhance or fund a project, funds may be placed in contingency for programming later in the year or in the next program year. Annual Action Plan 15 2016 OMB Control No:2506-0117(exp.07/31/2015) AP-38 Project Summary Project Summary Information 1 Project Name HOUSING REPAIR Target Area Goals Supported Ensure a Suitable Living Environment Needs Addressed Affordable Housing Development and Preservation Neighborhood Revitalization Funding CDBG: $249,950 Description Maintain the affordability of decent housing for very low-income Auburn residh necessary to maintain suitable housing for 55 Auburn homeowners, including senior citizens and 5 homeowners who lack safe access in or out of their home. disabilities or impairment. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Activities include minor home repairs. 2 Project Name ADMINISTRATION Target Area Goals Supported Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Needs Addressed Funding CDBG: $100,000 Description General administration and project management Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities 3 Project Name HEALTHPOINT Target Area Goals Supported Ensure a Suitable Living Environment End Homelessness Needs Addressed Homeless Prevention and Intervention Neighborhood Revitalization Funding CDBG: $62,500 Description Create a suitable living environment by making the availability of health care al low-income, Auburn residents by allocating$62,500 to HealthPoint for the ope Auburn.This project is a public service. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Planned Activities Activities include medical and dental services to residents of Auburn. 4 Project Name Employment Training Program Target Area Goals Supported Ensure a Suitable Living Environment End Homelessness Needs Addressed Homeless Prevention and Intervention Economic Opportunity Funding CDBG: $15,000 Description Create economic opportunities by providing training to approximately 15 very- residents so that at least half of them can find and sustain a job.This project is Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Planned activities include employment assistance to Auburn residents. 5 Project Name Youth Outreach Center Target Area Goals Supported Ensure a Suitable Living Environment Needs Addressed Neighborhood Revitalization Funding CDBG: $51,664 Description Create a suitable living environment by making available a youth center for Aul Target Date Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Activities intended to be provided at the Community Center include but are no activities health,fitness and wellness programs, art, craft and music, communil classes, expanded youth and pre-school programs, 6 Project Name GRCC SMALL BUSINESS ASSISTANCE Target Area Goals Supported Ensure a Suitable Living Environment Needs Addressed Economic Opportunity Funding CDBG: $40,000 Description Create economic opportunities by providing the availability and access to coun approximately 25 Auburn residents who are either trying to sustain or create a collectively generate 10 or more jobs. Target Date Estimate the number and type of families that will benefit from the proposed activities Location Description Planned Activities Business classes and other supportive assistance for business owners in Auburr businesses. Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) AP-50 Geographic Distribution - 91.420, 91.220(f) Description of the geographic areas of the entitlement (including areas of low-income and minority concentration)where assistance will be directed The City of Auburn intends on distributing funds throughout the jurisdiction. Geographic Distribution Target Area Percentage of Funds Table 9-Geographic Distribution Rationale for the priorities for allocating investments geographically n/a Discussion Due to the fact that areas of low-income and minority concentrations are dispersed throughout all of Auburn, the City intends on investing throughout the entire jurisdiction to ensure that all populations throughout the region have access to beneficial programs and housing opportunitites. Annual Action Plan 20 2016 OMB Control No:2506-0117(exp.07/31/2015) Annual Action Plan 2016 OMB Control No:2506-0117(exp.07/31/2015) AP-85 Other Actions - 91.420, 91.220(k) Introduction The City of Auburn will continue to work with service providers throughout the region in coordination to develop systems and strategies to promote their efforts in providing optimal, easily accessible services. The City will work to reduce the number of families in poverty, sustain relationships with employment training agencies, and work to preserve the affordable housing stock in our community. Actions planned to address obstacles to meeting underserved needs By establishing a strong foundation of networks between local service providers, stakeholders and government agencies through committees and coalitions, the City will work in partnership to address obstacles and ameliorate barriers to meeting underserved needs.The collaborated organizations will develop detailed strategic plans that will delegate tasks, build systems and ongoing assessment of service delivery. Actions planned to foster and maintain affordable housing The City will continue to maintain the affordability of decent housing for low income Auburn residents by allocating $249,950 of CDBG funds to the City's Housing Repair Program. The program provides emergency repairs necessary to maintain safe housing for up to 55 Auburn homeowners, many of whom are senior citizens and/or are experiencing barriers safely accessing their homes due to physical disabilities or impairment. In addition to Auburn's Housing Repair program, the City will maintain affordable housing by continuing to engage and partner with coalitions, committees and other government agencies to integrate and enhance efforts on the issue. Actions planned to reduce lead-based paint hazards The City of Auburn will continue to implement U.S. Department of Housing Urban Development (HUD) regulations to protect residents from lead-based paint hazards in housing that is financially assisted by the federal government.The requirements apply only to housing built prior to 1980, the year lead-based paint was banned nationwide for consumers. Actions planned to reduce the number of poverty-level families The City of Auburn's actions planned to reduce the number of poverty- level families include but are not limited to: • Supporting programs and maintaining relationships with Auburn schools Annual Action Plan 22 2016 OMB Control No:2506-0117(exp.07/31/2015) • Allocating more than $15,000 to employment and training programs • Allocating more than $60,000 to emergency assistance and basic need programs such as food, financial assistance, clothing and healthcare • Participate and partner with coalitions, committees and agencies that provide antipoverty services to develop and enhance strategies and efforts to reduce poverty level families • Allocate more than $45,000 to emergency shelters and transitional housing programs Actions planned to develop institutional structure The City's planned actions to address the gaps and weaknesses identified in the strategic plan include: • Addressing the gaps in Veterans services by working closely with regional Veteran service providers, the WDVA, Seattle King County Veterans Consortium and the King County Veterans program to consolidate and improve accessibility and visibility of Veteran supportive programs. In 2014 the City of Auburn hired its first Veterans/Human Services Coordinator and Veteran Service AmeriCorps member to address these needs with an end goal of establishing a One Stop Center to support current Veterans as well as Veterans who will be entering civiling life in the near future. • Maintaining partnerships with and participating in the South King County Homeless Coalition, the Committee to End Homelessness of King County and other regional human service providers, coalitions and committees who address homeless issues.The City will also continue to work collaboratively with partnering organizations and groups to integrate and enhance services to provide optimal services to individuals and families currently experiencing or at risk of homelessness. In addition the City will allocate more than $45,000 to emergency shelters and transitional housing and more than $60,000 to emergency services such as food, financial assistance, clothing and healthcare. Actions planned to enhance coordination between public and private housing and social service agencies The City of Auburn has heavily contributed and intends to continue cultivating relationships between public and private housing and social service agencies. In addition the City will continue to participate in collaborations with the South King County Homeless Forum,the South King County Council of Human Services, King County Housing Development Consortium and the Seattle-King County Joint Planners Meeting. Discussion The expressed goal of the City's Consolidated Plan is to reduce the number of people living in poverty within Auburn. The City intends to give funding priority to programs that in addition to complying with federal regulations and address a priority a outlined in the Consolidated Plan are consistent with all of Annual Action Plan 23 2016 OMB Control No:2506-0117(exp.07/31/2015) the goals and objectives identified. Annual Action Plan 24 2016 OMB Control No:2506-0117(exp.07/31/2015) Program Specific Requirements AP-90 Program Specific Requirements - 91.420, 91.220(1)(1,2,4) Introduction The City of Auburn will use all CDBG funds to support projects and activities benefiting low and moderate income residents. The full allowable amount of funds will be used for Public Services and Planning and Administration with the remaining balance intended for housing rehab services and economic development. Community Development Block Grant Program (CDBG) Reference 24 CFR 91.220(1)(1) Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table.The following identifies program income that is available for use that is included in projects to be carried out. 1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 0 2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0 3. The amount of surplus funds from urban renewal settlements 0 4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0 5. The amount of income from float-funded activities 0 Total Program Income: 0 Other CDBG Requirements 1. The amount of urgent need activities 0 2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income.Overall Benefit-A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan. 100.00% Annual Action Plan 25 2016 OMB Control No:2506-0117(exp.07/31/2015) Discussion The City of Auburn will continue to use all of its funds to support residents of low/moderate income while maintaining a focus on underserved and special populations. Annual Action Plan 26 2016 OMB Control No:2506-0117(exp.07/31/2015) Annual Action Plan 27 2016 OMB Control No:2506-0117(exp.07/31/2015) Section 1. Pursuant to the provisions of 24CFR91, the City hereby adopts the 2016 Action Plan for the Consolidated Plan for Years 2015-2019. Section 2. That the Mayor is authorized to implement such administrative procedures as may be necessary to carry out the directives of this legislation. Section 3. That this Resolution shall take effect and be in full force upon passage and signatures hereon. Dated and Signed this�day of , 2016. CI OF AUBURN N ACI U , A%� ��R�d—' ATTEST: /I U Danielle . Daskam, City Clerk APPRO ,ED AS TO FORM: D ' I B. Hei , 'ty Attorney Resolution No. 5205 January 13, 2016 Page 2 of 2