HomeMy WebLinkAbout2021 Ordinance No. 020
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BY AUTHORITY
ORDINANCE NO. 20 COUNCIL BILL NO. 17
SERIES OF 2021 INTRODUCED BY COUNCIL
MEMBER ANDERSON
AN ORDINANCE APPROVING AND AUTHORIZING A THREE
YEAR INTER-GOVERNMENTAL COOPERATION AGREEMENT
BETWEEN ARAPAHOE COUNTY, COLORADO AND THE CITY
OF ENGLEWOOD, COLORADO RELATING TO THE CONDUCT
OF COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) AND
HOME INVESTMENT PARTNERSHIP (HOME) PROGRAMS FOR
PROGRAM GRANT YEARS 2022 THROUGH 2024.
WHEREAS, the City Council of the City of Englewood approved the
execution of an Intergovernmental Agreement between the City of Englewood
and Arapahoe County by passage of Ordinance No. 39, Series of 1994, covering
the City’s participation in the Arapahoe County CDBG Entitlement Program as
extended by Amendment No. 3, for funding years 2004 through 2006;
WHEREAS, the Englewood City Council passed Ordinance No. 13, Series
of 2006 and that was modified by Amendment No. 1 dated February, 2007
relating to participation in the Urban County Entitlement Program for CDBG and
HOME funds for 2007 through 2009;
WHEREAS, the Englewood City Council passed Ordinance No. 38, Series
of 2006 authorizing Amendment No. 1 to the Urban County Entitlement Program
for CDBG and HOME funds for 2007 through 2009;
WHEREAS, the Englewood City Council passed Ordinance No. 22, Series
of 2009 authorizing participation in the Urban County Entitlement Program for
CDBG and HOME funds for 2010 through 2012;
WHEREAS, the Englewood City Council passed Ordinance No. 25, Series
of 2012 authorizing participation in the Urban County Entitlement Program for
CDBG and HOME Funds for 2013 through 2015;
WHEREAS, the Englewood City Council passed Ordinance No. 19, Series
2015 authorizing participation in the Urban County Entitlement Program for
CDBG and HOME Funds for 2015 thorough 2018;
WHEREAS, the Englewood City Council passed Ordinance No. 12, Series
2018, authorizing participation in the Urban County Entitlement Program for
CDBG and HOME funds for 2019 through 2021; and
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WHEREAS, the passage of this Ordinance authorizes the execution of a
three-year Intergovernmental Cooperation Agreement between Arapahoe
County and Englewood relating to the conduct of Community Development Block
Grant (CDBG) and HOME Investment Partnership (HOME) programs for
program grant years 2022 through 2024;
WHEREAS, the Community Development Block Grant (CDBG) and
HOME Investment Partnership (HOME) programs incorporate funds from the
U.S. Department of Housing and Urban Development (HUD).
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF
THE CITY OF ENGLEWOOD, COLORADO, THAT:
Section 1. The attached “Intergovernmental Joint Cooperation
Agreement and Home Consortium Agreement Between Arapahoe County,
Colorado and the City of Englewood, Colorado Relating To The Conduct Of
Community Development Block Grant (CDBG) And Home Investment
Partnerships (HOME) Program and HOME Investment Partnerships Program for
program grant years 2022 through 2024” attached hereto as Exhibit A, is hereby
accepted and approved by the Englewood City Council.
Section 2. The Mayor and City Clerk are hereby authorized to sign and
attest said Agreement for and on behalf of the City of Englewood, Colorado.
Section 3. The City Manager shall be authorized to further extend and/or
amend the Intergovernmental Cooperation Agreement for the program grant
years 2022 through 2024.
Introduced, read in full, and passed on first reading on the 3rd day of May,
2021.
Published by Title as a Bill for an Ordinance in the City’s official newspaper
on the 6th day of May, 2021.
Published as a Bill for an Ordinance on the City’s official website beginning
on the 5th day of May, 2021.
Read by Title and passed on final reading on the 17th day of May, 2021.
Published by Title in the City’s official newspaper as Ordinance No. 20,
Series of 2021, on the 20th day of May, 2021.
Published by title on the City’s official website beginning on the 19th day of
May, 2021 for thirty (30) days.
This Ordinance shall take effect thirty (30) days after publication following
final passage.
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Linda Olson, Mayor
ATTEST:
Stephanie Carlile, City Clerk
I, Stephanie Carlile, City Clerk of the City of Englewood, Colorado, hereby
certify that the above and foregoing is a true copy of the Ordinance passed on
final reading and published by Title as Ordinance No. 20, Series of 2021.
Stephanie Carlile
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INTERGOVERNMENTAL JOINT COOPERATION AGREEMENT
AND HOME CONSORTIUM AGREEMENT
BETWEEN
ARAPAHOE COUNTY, COLORADO
AND
CITY OF ENGLEWOOD, COLORADO
RELATING TO THE CONDUCT OF
COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM
AND
HOME INVESTMENT PARTNERSHIPS PROGRAM
FOR GRANT YEARS 2022 THROUGH 2024
THIS AGREEMENT is entered into and shall be effective as of ________________, 2021, by
and between Arapahoe County, Colorado (the “County”), a body corporate and politic of the
State of Colorado, and the City of Englewood (the “City”), a municipal corporation of the State
of Colorado located in Arapahoe County.
RECITALS
A. In 1974 the U.S. Congress enacted the Housing and Community Development Act of
1974, as since amended (42 U.S.C. 5301 et seq.) (“HCDA”), permitting and
providing for the participation of the United States government in a wide range of
local housing and community development activities and programs under Title I of
HCDA which activities and programs are administered by the U.S. Department of
Housing and Urban Development (“HUD”); and the Home Investment Partnerships
Program (“HOME”) was enacted under Title II (42 U.S.C. 12701-12839) of the
Cranston-Gonzalez National Affordable Housing Act (“NAHA”) which activities and
programs are administered by HUD;
B. The primary objective of Title I of HCDA is the development of viable urban
communities, by providing decent housing and a suitable living environment and
expanding economic opportunities, principally for persons of low and moderate
income, and the primary objective of the HOME program is to expand the supply of
decent, safe, sanitary and affordable housing for low and moderate income
Americans. These objectives are to be accomplished by the federal government
providing financial assistance pursuant to HCDA and NAHA in the form of
Community Development Block Grant (“CDBG”) funds and HOME funds to the
state and local governments to be used in the conduct and administration of housing
and community development activities and projects as contemplated by the primary
objectives of the CDBG and HOME Programs;
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C. To implement the policies, objectives and other provision of HCDA and NAHA,
HUD has issued rules and regulations governing the conduct of CDBG programs,
published in 24 Code of Federal Regulations (CFR), Part 570 (the “Regulations”),
which regulations provide that a county may qualify as an “urban county”, as defined
in Section 570.3 of the regulations, and thereby become eligible to receive entitlement
grants from HUD for the conduct of CDBG and HOME Programs as an urban county
and also in 24 CFR, Part 92, governing the HOME program, which regulations
provide that an urban county may form a consortium with a metropolitan city within
the county, as outlined in Section 92.101, and that a metropolitan city that qualifies
for a separate entitlement grant may be included as a part of the urban county and
HOME consortium by entering into a cooperation and consortium agreement with the
urban county in accordance with the requirements of the Regulations;
D. The County has heretofore qualified under the Regulations as an “urban county” and
will receive CDBG and HOME funds from HUD by annual grant agreements, and the
City of Englewood located in the County will receive a separate community
development entitlement grant and will be included as a part of the County in its
CDBG Programs and through the consortium will be able to participate in the HOME
program;
E. In 1981, and again since then, HUD amended the Regulations, pursuant to
amendments of HCDA, revising the qualification period for urban counties by
providing that the qualifications by HUD of an urban county and/or HOME
consortium shall remain effective for three successive grant years regardless of
changes in its population during that period, except for failure of an urban county to
receive a grant during any year of that period, and also providing that during the three
year period of qualification, no included city or other unit of general local
government may withdraw or be removed from the urban county or HOME
consortium for HUD’s grant computation purposes, and no city or other unit of
general local government covering an additional area may be added to the urban
county during that three-year period except in the case where a city or other unit loses
its designation as a metropolitan city; however, the HOME consortium may add
members during the three year qualification period at the discretion of the lead entity
through the execution of a consortium agreement;
F. In 2018, the County is submitting to HUD the required documentation to qualify as
an urban county, including the Consolidated Plan and the One Year Action Plan,
pursuant to Section 570.307 of the regulations, so as to become eligible to receive
annual CDBG and HOME funds for the next three Program Years from Grant Years
2022, 2023, and 2024 appropriations, and if the City approves and authorizes this
agreement, an executed copy thereof will be included in the documentation for this
ensuing period of qualification and, if the County qualifies, the City will thereby be
included as a part of the urban county and HOME consortium and be eligible to
participate in the County’s CDBG and HOME Programs for the next three Program
Years;
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G. The County recognizes and understands that it does not have independent legal
authority to conduct community development and housing assistance activities within
the boundaries of the City and therefore, its ability to conduct the CDBG and HOME
Program in the City is limited by the requirement that it must obtain permission from
the City to perform activities therein, and accordingly, in order for the City to be
considered a part of the urban county and HOME consortium and be included in the
County’s annual request to HUD for CDBG and HOME funds, it is required by the
Regulations that the City and the County enter into a cooperation agreement whereby
the City authorizes the County to undertake or to assist in undertaking essential
community development and housing assistance activities within the City as may be
specified in the “Consolidated Plan” to be submitted to HUD annually by the County
to receive its annual CDBG and HOME entitlement grant;
H. Under general provisions of Colorado law governing contracting between
governmental entities and by virtue of specific authority granted in Part 2 of Article I
of Title 29, C.R.S., any two or more political subdivisions of the state may enter into
agreements with one another for joint cooperative action and any one or more
political subdivisions may contract with another or with a legal or administrative
entity created pursuant to that act to perform any governmental service, activity or
undertaking which each political subdivision entering into the contract is authorized
by law to perform, and
I. Accordingly, the parties hereto have determined that it will be mutually beneficial
and in the public interest of both parties to enter into this intergovernmental
agreement regarding the conduct of the County’s CDBG and HOME Programs,
THEREFORE, in consideration of the premises and cooperative actions contemplated hereunder,
the parties agree as follows:
1. By entering into this intergovernmental joint cooperation agreement with the County,
the City shall be included as a part of urban Arapahoe County’s HOME consortium
for qualification and grant calculation purposes upon the qualification by HUD of the
County to receive CDBG and HOME Program entitlements as an urban county and
HOME consortium for the next three successive Program Years, May 1, 2022 through
April 30, 2024.
2. As required by the Consolidated Plan final rule, 24 CRF part 91, the HOME
consortium is on the same program year as the urban county CDBG program, May 1
through April 30. As provided in Section 570.307 of the Regulations, the
qualification of the County as an urban county shall remain effective for the next
three successive grant years, May 1, 2022 through April 30, 2024, regardless of
changes in its population during that period of time and the parties agree that the City
may not withdraw from nor be removed from inclusion in the urban county for
HUD’s grant computation purposes during the period of qualification. As provided in
Section 92.101 of the Regulations, the qualification of the County as a HOME
consortium shall remain effective for three successive grant years, regardless of
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changes in its population during that period of time and the Parties agree that the City
may not withdraw from nor be removed from inclusion in the HOME consortium
during the period of qualification.
3. A fully executed copy of this cooperation agreement, together with the approving
resolutions of both the City and the County, shall be submitted to HUD by the County
as part of its qualification documentation and the City does hereby give the County
the authority to carry out CDBG and HOME Program activities and projects which
will be funded from annual CDBG and HOME funds from grant years 2022, 2023,
and 2024 appropriations and from any Program income generated from the
expenditures of those funds.
4. The City and the County agree to, and shall cooperate in, the preparation of detailed
CDBG and HOME Program activities and projects to be conducted or performed in
the City during each of the three program years covered by the Agreement and these
finalized activities and projects will be included in the County’s Consolidated Plan
and requests for funds for those program years. The city understands and agrees,
however, that the County shall have final responsibility for selecting the program
activities and projects to be included in each annual grant request and project grant
request and for filing the Consolidated Plan with HUD on an annual basis.
5. The parties recognize and understand that the County, as a qualified HOME recipient
and urban county, will be the lead entity required to execute all grant agreements
received from HUD pursuant to the County’s annual request for CDBG and HOME
Program funds and that as the lead entity it assumes overall responsibility for
ensuring that the consortium’s CDBG and HOME Program is carried out in
compliance with the requirements of the CDBG and HOME program, including
requirements concerning the Consolidated Plan. Further, the County, as lead entity,
will to the extent required by HUD, be the responsible entity under such grant
agreements for the overall administration and performance of the CDBG and HOME
programs, including the projects and activities conducted within the City.
Accordingly, the City agrees that as to all projects and activities performed or
conducted in the City under any HOME or CDBG grant agreement, which includes
the City, that the County shall have the ultimate supervisory and administrative
control.
6. The City shall cooperate fully with the County in all CDBG and HOME Program
efforts planned and performed hereunder and does hereby allow and permit the
County to undertake or assist in undertaking essential community development and
housing assistance activities within the City as may be approved and authorized in the
County’s agreements, including the Consolidated Plan. The City and the County also
agree to cooperate to undertake, or assist in undertaking, community development
housing assistance activities for the CDBG and HOME Program, as they may be
planned and specified in the County’s Consolidated Plan submitted annually to HUD
for the three Program years specified herein and for such additional time as may be
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required for the expenditure of CDBG and HOME funds granted by the County for
such activities.
7. The County, as the lead entity, is authorized to act in a representative capacity as the
lead entity for all members of the consortium for the purposes of administering the
HOME Program. The County will accept project recommendations from all HOME
consortium members, but reserves the right to make final funding decisions. No
project within the boundaries of the City of Englewood will be considered for
inclusion in the Consolidated Plan unless first approved by the City of Englewood.
8. The HOME funds may be accessed by the City in two ways; the City may approve a
project or activity, carried out be a third entity, as appropriate for the needs of the
City, and endorse the application, or; the City may originate a grant or loan request on
its own behalf for an eligible project or activity. If the City applies for HOME funds
itself, then the provisions in paragraph 9 apply. For example, if the City opts to create
an eligible homeowners rehabilitation program, the City would be subject to the same
requirements as a subrecipient, including a written agreement. If the City approves or
endorses a third party application, then the City’s continuing participation in the
project or activity is not required.
9. Pursuant to 24 CFR 570.501(b) and 24 CRF 92.504, the City is subject to the same
requirements applicable to subrecipients, including the requirement of a written
agreement as set forth in 24 CFR 570.503 and 24 CRF 92.504.
10. The City understands that pursuant to Section 570.503 and Section 92.504 of the
Regulations, it will be necessary for the City to enter into separate project agreements
or sub-grants in writing with the County with respect to the actual conduct of the
projects and activities approved for performance in the City for the three HOME and
CDBG Program years covered be the cooperation agreement and that the funds
designated in the County’s Consolidated Plan for those projects and activities will
also be funded to the City under those separate project agreements or sub-grants.
Subject to the provisions of Paragraph 5 above, the City will administer and control
the performance of the projects and activities specified in those separate project
agreements, and will be responsible for the expenditure of the funds allocated for
each such project or activity and will conduct and perform the projects and activities
in compliance with the Regulations and all other applicable federal laws and
requirements relating to the CDBG and/or HOME Programs. The City also
understands and agrees that it shall also comply with the requirements of Section
570.503 prior to disbursing any CDBG funds to a subrecipient of the City.
11. All HOME and/or CDBG Program funds that are approved by HUD for expenditure
under the County’s grant agreements for the three Program years covered by this
Agreement, including those that are identified for projects and activities in the City,
will be budgeted and allocated to the specific projects and activities described and
listed in the County’s Consolidated Plan and One Year Action Plan to the
Consolidated Plan submitted annually to HUD and those allocated funds shall be used
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and expended only for the projects or activities to which the funds are identified. No
project or activity nor the amount allocated therefore may be changed, modified,
substituted or deleted by the City with respect to any project of activity without the
prior written approval of the County and the approval of HUD when that approval is
required by the regulations.
12. Because the City will be included as part of the urban county and HOME consortium
for the three Program Years covered by this Cooperation Agreement, it will do all
things that are appropriate and required of it to comply with the applicable provisions
of the grant agreements received by the County from HUD in which the City is
included, and with the provisions of HCDA and NAHA and all Rules and
Regulations, guidelines, circulars, and other requisites promulgated by the various
federal departments, agencies, administrations and commissions relating to the
CDBG and HOME Programs. In addition, the City and the County shall each take all
actions necessary to assure compliance with the certification required of the County
by Section 104(b) of Title I of HCDA including the National Environmental Policy
Act of 1969, Title VI of the Civil Rights Act of 1964, Title VIII of the Civil Rights
Act of 1968, the Fair Housing Act, Section 109 of Title I of HCDA and other laws
applicable to the conduct of the HOME and CDBG Programs. In addition, the parties
hereto understand and agree that the County may not provide any HOME or CDBG
funding for activities in, or in support of, the City if the City does not affirmatively
further fair housing within its jurisdiction or impedes the County’s actions to comply
with its fair housing certification.
13. During the period of performance of this Agreement, as provided in Paragraph 18
below, the City shall:
(a) Inform the County of any income generated by the expenditure of
CDBG and/or HOME Program funds received by the City;
(b) Pay over to the County any Program Income received by the City, or
retain and use that Program Income subject to, and in accordance with,
the requirements and provisions of the separate HOME or CDBG
project agreements that will be entered into between the City and the
County for the actual conduct of the HOME and/or CDBG Programs;
(c) Use any Program Income the City is authorized by the County to retain
only for eligible activities in accordance with all HOME and CDBG
Program requirements as may then apply and as will be specifically
provided for in the separate project agreements between the City and
the County;
(d) Keep appropriate records regarding the receipt of, use of, or
disposition of all Program Income and make reports therein to the
County as will be required under the separate project agreements
between the City and the County, and
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(e) Pay over to the County any Program Income that may be on hand in
the event of close-out or change in status of the City of that may be
received subsequent to the close-out or change in status as will be
provided for in the separate project agreements mentioned above.
14. The separate project agreements or sub-grants that will be entered into between the
County and the City for the conduct of the CDBG and HOME Programs, as
mentioned and referred to elsewhere in this agreement, shall include provisions
setting forth the standards which shall apply to any real property acquired or
improved by the City, in whole or in part, using CDBG and HOME Program Funds.
These standards will require the City to:
(a) Notify the County in a timely manner of any modification or change in
the use of that property from that which was planned at the time of
acquisition or improvement and this notice requirement shall include
any disposition of such property.
(b) Reimburse the County in an amount equal to the current fair market
value of property acquired or improved with CDBG or HOME funds
(less any portion thereof attributable to expenditures of non-CDBG or
HOME funds) that is sold or transferred for a use which does not
qualify under the Regulations, and
(c) Pay over to the County any Program Income that is generated from the
disposition or transfer of property either prior to, or subsequent to, any
close-out, change of status or termination of this cooperation
agreement that is applicable.
15. The City, by execution of this agreement understands that it may not apply for grants
under the small cities or state CDBG Programs for appropriations for fiscal years
during the period in which it is participation in the urban county’s CDBG Program;
and may not participate in a HOME consortium except through the urban county,
regardless of whether the urban county receives a HOME formula allocation. The
City may, however, apply for State HOME funds.
16. The County may, in accordance with the applicable requirements of 24 C.F.R. Part
570, collect an administrative fee for the performance of its duties administering the
CDBG program, pursuant to this agreement. In no event shall the administrative fee
exceed twenty percent (20%) of the overall annual City CDBG allocation. In the
event that the County’s total actual administrative costs are less than 20% of the
annual City CDBG allocation, the County shall notify the City of the amount of any
unused administrative fee, and the City shall decide how to allocate or apply the
unused administrative fees. The County may provide recommendations to the
City regarding the use of such unused administrative fees.
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17. The County may, in accordance with the applicable requirements of 24 CFR Part 92,
collect an administrative fee for the performance of its duties administering the
HOME program, pursuant to this agreement.
18. The period of performance of this Agreement shall cover three HOME and CDBG
Program years consisting of the County’s 1st, 2nd, and 3rd Program years from this
Agreement, beginning May 1, 2022 and ending April 30, 2024. The HOME and
CDBG program years are the same, as is required. As stated herein, however, the
Agreement is intended to cover activities to be carried out with annual CDBG and
HOME funds from grant year 2022, 2023, and 2024 appropriations and shall be and
remain in full force and effect until all projects and activities approved and authorized
to be performed and funded for those grant years have been completed and any
program income earned has been remitted to the County or used by the City in
accordance with the criteria described in paragraph 13.
19. The Agreement will be automatically renewed for participation for successive three-
(3) year qualification periods, unless a party provides written notice to the other party
that it elects not to participate in a new qualification period.
The County must notify the other party in writing of the election of its right not to
participate. A copy of the notification must be sent to both the other party and the
HUD Region 8 field office by the party electing not to participate. Notices and
responses must be sent according to the schedule specified in HUD’s HOME
consortia qualification notice and the urban county qualification notice for the next
qualification period.
Each party is required to adopt any amendment to the agreement incorporating
changes necessary to meet the requirements for cooperation agreements set forth in
the HOME consortia qualification notice and the urban county qualification notice
applicable for a subsequent three-year HOME consortia and urban county
qualification period, and to submit such amendment to HUD. Failure to comply will
void the automatic renewal for such qualification period.
20. Pursuant to the provisions of 24 C.F.R. § 507 and/or 24 C.F.R. § 91.225 the County
and the City shall take all actions necessary to assure compliance with the Urban
County’s Certification under Section 104(b) of Title 1 of the Housing and
Community Development Act of 1974, as amended, regarding the National
Environmental Policy Act of 1969, The Uniform Relocation Act, The American with
Disabilities Act of 1990, Title VI of the Civil Rights Act of 1964, the Fair Housing
Act, affirmatively furthering Fair Housing, Title VIII of the Civil Rights Act of 1968,
Executive Order 11988, Section 109 of title I of the Housing and Community
Development Act of 1974 (which incorporates Section 504 of the Rehabilitation Act
of 1973 and the Age Discrimination Act of 1975), and other applicable laws. Use of
Urban County funds for activities in, or in support of, any cooperating City that does
not affirmatively further fair housing within its own jurisdiction or that impedes the
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County’s action to comply with the County’s Fair Housing Certification shall be
prohibited. Pursuant to 24 CFR 570.501(b), City is subject to the same requirements
applicable to subrecipients, including the requirement of a written agreement as
described in 24 CFR 570.503.
21. The County and the cooperating unit of general local government agree to
cooperate to undertake, or assist in undertaking, community renewal and
lower-income housing assistance activities and the grantee or unit of general
local government that directly or indirectly receives CDBG or HOME funds
may not sell, trade, or otherwise transfer all or any such portion of such funds
to another metropolitan city, urban county, unit of general local government,
or Indian tribe, or insular area that directly or indirectly receives CDBG funds
in exchange for any other funds, credits or non-Federal considerations, but
must use such funds for activities eligible under Title I of the Housing and
Community Development Act of 1974, as amended. .
22. Pursuant to the provisions of 24 C.F.R. § 507 and/or 24 C.F.R. § 91.225 the City has
adopted and is enforcing the following policies:
(a) Prohibiting the use of excessive force by law enforcement agencies
within its jurisdiction against any individuals engaged in nonviolent
civil rights demonstrations, and;
(b) Enforcing applicable State and local laws against physically barring
entrance to or exit from a facility or location which is the subject of such
nonviolent civil rights demonstration within its jurisdiction.
23. Any changes and modifications to this Agreement shall be made in writing and shall
be executed by both parties prior to the performance of any work or activity involved
in the change and be approved by HUD, if necessary, to comply with the Regulations.
23.
(a) This Agreement shall be and remain in force and effect for the period
of performance specified in Paragraph 18 hereof and, when the County
has been qualified by HUD as a HOME consortium and urban county,
neither the County nor the City may terminate this agreement or
withdraw therefrom during that period of performance.
(b) During the three Program Years for which the County has qualified,
the parties agree not to veto or otherwise obstruct the implementation
of the approved Consolidated Plan during that three year period and
for such additional time as may be required for the expenditure of
funds granted for that period.
IN WITNESS WHEREOF, the parties hereto have caused this agreement to be duly authorized
and executed by each on the date specified as follows:
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ARAPAHOE COUNTY, COLORADO
By: _____________________________
Nancy Jackson,
Chair of the Board of County Commissioners
ATTEST:
By: ______________________________
Clerk to the Board of County Commissioners
CITY OF ENGLEWOOD, COLORADO
By: _______________________________
Linda Olson, Mayor
ATTEST: ________________________________
City Clerk or Deputy City Clerk
Approved as to form
___________________________
City Attorney
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