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If the Subrecipient anticipates spending less than the indicated amount, a budget amendment is <br /> required. <br /> c. The maximum percentage of the Grant Agreement Amount that may be used for personnel <br /> expenses under this Agreement is identified in the Budget. If the Subrecipient anticipates <br /> spending more on personnel costs, an amendment is required. Additional approval steps may <br /> also be required before the personnel percentage can be increased. <br /> 3. If funding is allocated to emergency communications, the Subrecipient must ensure that all projects <br /> comply with SAFECOM Guidance on Emergency Communications Grants ensuring the investments <br /> are compatible, interoperable, resilient, and support national goals and objectives for improving <br /> emergency communications. <br /> 4. If funding is allocated to a Fusion Center investment, the Subrecipient must ensure all Fusion Center <br /> analytical personnel demonstrate qualifications that meet or exceed competencies identified in the <br /> Common Competencies for state, local, and tribal Intelligence Analysts, which outlines the minimum <br /> categories of training needed for intelligence analysts. A certificate of completion of such training <br /> must be submitted to the Department Key Personnel as applicable. <br /> 5. If funding is allocated to non-DHS FEMA training, the Subrecipient must request prior approval from <br /> the Department Key Personnel before attending the training. The Department will coordinate <br /> approval with the State Training Point of Contact. Pursuant to DHS/FEMA Grant Programs <br /> Directorate Policy FP 207-008-064-1 (https://www.fema.gov/media- <br /> library/assets/documents/34856), the training must fall within the FEMA mission scope and be <br /> included in the Subrecipient's Emergency Operations Plan. This requirement only applies to training <br /> courses and does not include attendance at conferences. Furthermore, additional federal approvals <br /> are required for courses that relate to Countering Violent Extremism prior to attendance. <br /> 6. Subrecipients are required to complete the 2019 Nationwide Cybersecurity Review (NCSR) <br /> https://www.cisecurity.orq/ms-isac/services/ncsr to benchmark and measure progress of improving <br /> their cybersecurity posture before December 31, 2019. <br /> 7. In support of efforts to enhance capabilities for detecting, deterring, disrupting, and preventing acts <br /> of terrorism and other catastrophic events, operational overtime costs are allowable for increased <br /> protective security measures at critical infrastructure sites or other high-risk locations and to enhance <br /> public safety during mass gatherings and high-profile events. However, except for an elevated <br /> National Terrorism Advisory System alert, prior written approval is required before SHSP and UASI <br /> funds may be used for operational overtime. Requests must be submitted to the Department Key <br /> Personnel in advance of the expenditure to ensure all additional approval steps can be met. <br /> 8. Subrecipients are encouraged to participate in the State's annual Training and Exercise Planning <br /> Workshop (TEPW) or may conduct their own local/regional TEPW. <br /> C. DHS TERMS AND CONDITIONS <br /> As a subrecipient of 19HSGP program funding, the Subrecipient shall comply with all applicable DHS <br /> terms and conditions of the 19HSGP Award Letter and its incorporated documents for DHS Grant No. <br /> EMW-2019-SS-00044-S01, which are incorporated in and made a part of this Agreement as Attachment <br /> 1. <br /> DHS-FEMA-HSGP-UASI-FFY19 Page 9 of 38 City of Seattle, E20-095 <br />