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HomeMy WebLinkAboutDocumentation_Regular_Tab 07_5/14/2020Agenda Item #7. Regular Council STAFF MEMO a Meeting: Regular Council - May 14 2020 Staff Contact: Jeremy Allen, Village Manager Department: Manager M Approve Palm Beach County Urban Qualification Process FY 20-21 Letter and Agreement Amendment Palm Beach County's Department of Housing and Economic Stability is requesting the Village consider its continued participation in the Urban County Qualification Process for FY 2021-2023 with an amendment to the original agreement as outlined in the attached letter. PBC Urban Qualification Process FY 2021-2023 Letter Agreement Amendment001_ (002� Agreement Interlocal 07 10 2014 Page 244 of 308 2> O 7» 2 0 2 3 k a t \ 0 Z) 2 0o f 71, 0 . 3 CD cj j / cc J k �u� ci k � ��a. / \ ( ]■ / % \ � \ § ] e \ I § �I�I � o 0o m co��o w U Agenda Item #7. AMENDMENT 001 TO THE AGREEMENT WITH VILLAGE OF TEQUESTA Amendment 001, effective as of , by and between Palm Beach County (County), and the Village of Tequesta (Municipality). WITNESSETH: WHEREAS, Palm Beach County entered into an Interlocal Cooperation Agreement (R2014-1172) (the "Agreement") with the Village of Tequesta on August 19, 2014, to formalize the Village of Tequesta's participation in the urban county qualification process for Federal Fiscal Years 2014, 2016, and 2017; and WHEREAS, the Agreement is renewable every three years and is now due for renewal; and WHEREAS, the Department of Housing and Urban Development (HUD) has expressed in its most recent Instructions for Urban County Participation in Community Development Block Grant (CDBG) Program for FY 2021-2023 that all interlocal agreements should contain specific language regarding Section 3 of the Housing and Community Development Act of 1968; and WHEREAS, the Interlocal Cooperation Agreements between Palm Beach County and the municipalities participating in the urban county program did not contain this specific language; and WHEREAS, both parties desire to amend the Agreement approved on August 19, 2014, to comply with HUD's requirements. NOW, THEREFORE, in consideration of the mutual covenants and agreements hereinafter set forth, and various other good and valuable considerations, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: The foregoing recitals are true and correct and incorporated herein by reference. Terms not defined herein shall have the same meaning as ascribed to them in the Agreement. A. DELETE THE FOLLOWING CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance with the County's certification required by Section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 1964, the Fair Housing Act, and affirmatively furthering fair housing. The Municipality and the County shall comply with Section 109 of Title I of the Housing and Community Development Act of 1974, which incorporates Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975), the Americans with Disabilities Act of 1990 and other applicable laws. The County shall not fund any activities in, or in support of, the Municipality should the Municipality not affirmatively further fair housing within its jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. B. REPLACE DELETED CLAUSE WITH REVISED CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance Agenda Item #7. jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. IN WITNESS HEREOF, the Municipality and the County have caused this Amendment 001 to be executed on the date first written above: (MUNICIPAL SEAL BELOW) ATTEST: Lori McWilliams, Village Clerk (COUNTY SEAL BELOW) ATTEST: SHARON R. BOCK, Clerk & Comptroller By: Deputy Clerk Approved as to Form and Legal Sufficiency By: Howard J. Falcon, III, Chief Assistant County Attorney VILLAGE OF TEQUESTA, a municipality duly organized and existing by virtue of the laws of the State of Florida A-- 0 Abby Brennan, Mayor Jeremy Allen, Village Manager PALM BEACH COUNTY, FLORIDA, a Political Subdivision of the State of Florida BOARD OF COUNTY COMMISSIONERS Dave Kerner, Mayor Document No.: Approved as to Terms and Conditions Dept. of Housing and Economic Sustainability in Sherry Howard Deputy Director Agenda Item #7. AMENDMENT 001 TO THE AGREEMENT WITH VILLAGE OF TEQUESTA Amendment 001, effective as of , by and between Palm Beach County (County), and the Village of Tequesta (Municipality). WITNESSETH: WHEREAS, Palm Beach County entered into an Interlocal Cooperation Agreement (R2014-1172) (the "Agreement") with the Village of Tequesta on August 19, 2014, to formalize the Village of Tequesta's participation in the urban county qualification process for Federal Fiscal Years 2014, 2016, and 2017; and WHEREAS, the Agreement is renewable every three years and is now due for renewal; and WHEREAS, the Department of Housing and Urban Development (HUD) has expressed in its most recent Instructions for Urban County Participation in Community Development Block Grant (CDBG) Program for FY 2021-2023 that all interlocal agreements should contain specific language regarding Section 3 of the Housing and Community Development Act of 1968; and WHEREAS, the Interlocal Cooperation Agreements between Palm Beach County and the municipalities participating in the urban county program did not contain this specific language; and WHEREAS, both parties desire to amend the Agreement approved on August 19, 2014, to comply with HUD's requirements. NOW, THEREFORE, in consideration of the mutual covenants and agreements hereinafter set forth, and various other good and valuable considerations, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: The foregoing recitals are true and correct and incorporated herein by reference. Terms not defined herein shall have the same meaning as ascribed to them in the Agreement. A. DELETE THE FOLLOWING CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance with the County's certification required by Section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 1964, the Fair Housing Act, and affirmatively furthering fair housing. The Municipality and the County shall comply with Section 109 of Title I of the Housing and Community Development Act of 1974, which incorporates Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975), the Americans with Disabilities Act of 1990 and other applicable laws. The County shall not fund any activities in, or in support of, the Municipality should the Municipality not affirmatively further fair housing within its jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. B. REPLACE DELETED CLAUSE WITH REVISED CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance Agenda Item #7. jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. IN WITNESS HEREOF, the Municipality and the County have caused this Amendment 001 to be executed on the date first written above: (MUNICIPAL SEAL BELOW) ATTEST: VILLAGE OF TEQUESTA, a municipality duly organized and existing by virtue of the laws of the State of Florida am By: By: Lori McWilliams, Village Clerk (COUNTY SEAL BELOW) ATTEST: SHARON R. BOCK, Clerk & Comptroller By: Deputy Clerk Approved as to Form and Legal Sufficiency By: Howard J. Falcon, III, Chief Assistant County Attorney Abby Brennan, Mayor Jeremy Allen, Village Manager PALM BEACH COUNTY, FLORIDA, a Political Subdivision of the State of Florida BOARD OF COUNTY COMMISSIONERS Dave Kerner, Mayor Document No.: Approved as to Terms and Conditions Dept. of Housing and Economic Sustainability Sherry Howard Deputy Director Agenda Item #7. AMENDMENT 001 TO THE AGREEMENT WITH VILLAGE OF TEQUESTA Amendment 001, effective as of , by and between Palm Beach County (County), and the Village of Tequesta (Municipality). WITNESSETH: WHEREAS, Palm Beach County entered into an Interlocal Cooperation Agreement (R2014-1172) (the "Agreement") with the Village of Tequesta on August 19, 2014, to formalize the Village of Tequesta's participation in the urban county qualification process for Federal Fiscal Years 2014, 2016, and 2017; and WHEREAS, the Agreement is renewable every three years and is now due for renewal; and WHEREAS, the Department of Housing and Urban Development (HUD) has expressed in its most recent Instructions for Urban County Participation in Community Development Block Grant (CDBG) Program for FY 2021-2023 that all interlocal agreements should contain specific language regarding Section 3 of the Housing and Community Development Act of 1968; and WHEREAS, the Interlocal Cooperation Agreements between Palm Beach County and the municipalities participating in the urban county program did not contain this specific language; and WHEREAS, both parties desire to amend the Agreement approved on August 19, 2014, to comply with HUD's requirements. NOW, THEREFORE, in consideration of the mutual covenants and agreements hereinafter set forth, and various other good and valuable considerations, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: The foregoing recitals are true and correct and incorporated herein by reference. Terms not defined herein shall have the same meaning as ascribed to them in the Agreement. A. DELETE THE FOLLOWING CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance with the County's certification required by Section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 1964, the Fair Housing Act, and affirmatively furthering fair housing. The Municipality and the County shall comply with Section 109 of Title I of the Housing and Community Development Act of 1974, which incorporates Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975), the Americans with Disabilities Act of 1990 and other applicable laws. The County shall not fund any activities in, or in support of, the Municipality should the Municipality not affirmatively further fair housing within its jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. B. REPLACE DELETED CLAUSE WITH REVISED CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance Agenda Item #7. jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. IN WITNESS HEREOF, the Municipality and the County have caused this Amendment 001 to be executed on the date first written above: (MUNICIPAL SEAL BELOW) ATTEST: VILLAGE OF TEQUESTA, a municipality duly organized and existing by virtue of the laws of the State of Florida M By: By: Lori McWilliams, Village Clerk (COUNTY SEAL BELOW) ATTEST: SHARON R. BOCK, Clerk & Comptroller By: Deputy Clerk Approved as to Form and Legal Sufficiency By: Howard J. Falcon, III, Chief Assistant County Attorney Abby Brennan, Mayor Jeremy Allen, Village Manager PALM BEACH COUNTY, FLORIDA, a Political Subdivision of the State of Florida BOARD OF COUNTY COMMISSIONERS Dave Kerner, Mayor Document No.: Approved as to Terms and Conditions Dept. of Housing and Economic Sustainability 1-3 Sherry Howard Deputy Director Agenda Item #7. AMENDMENT 001 TO THE AGREEMENT WITH VILLAGE OF TEQUESTA Amendment 001, effective as of , by and between Palm Beach County (County), and the Village of Tequesta (Municipality). WITNESSETH: WHEREAS, Palm Beach County entered into an Interlocal Cooperation Agreement (R2014-1172) (the "Agreement") with the Village of Tequesta on August 19, 2014, to formalize the Village of Tequesta's participation in the urban county qualification process for Federal Fiscal Years 2014, 2016, and 2017; and WHEREAS, the Agreement is renewable every three years and is now due for renewal; and WHEREAS, the Department of Housing and Urban Development (HUD) has expressed in its most recent Instructions for Urban County Participation in Community Development Block Grant (CDBG) Program for FY 2021-2023 that all interlocal agreements should contain specific language regarding Section 3 of the Housing and Community Development Act of 1968; and WHEREAS, the Interlocal Cooperation Agreements between Palm Beach County and the municipalities participating in the urban county program did not contain this specific language; and WHEREAS, both parties desire to amend the Agreement approved on August 19, 2014, to comply with HUD's requirements. NOW, THEREFORE, in consideration of the mutual covenants and agreements hereinafter set forth, and various other good and valuable considerations, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: The foregoing recitals are true and correct and incorporated herein by reference. Terms not defined herein shall have the same meaning as ascribed to them in the Agreement. A. DELETE THE FOLLOWING CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance with the County's certification required by Section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 1964, the Fair Housing Act, and affirmatively furthering fair housing. The Municipality and the County shall comply with Section 109 of Title I of the Housing and Community Development Act of 1974, which incorporates Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975), the Americans with Disabilities Act of 1990 and other applicable laws. The County shall not fund any activities in, or in support of, the Municipality should the Municipality not affirmatively further fair housing within its jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. B. REPLACE DELETED CLAUSE WITH REVISED CLAUSE 11: The Municipality and the County shall take all actions necessary to assure compliance Agenda Item #7. jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. IN WITNESS HEREOF, the Municipality and the County have caused this Amendment 001 to be executed on the date first written above: (MUNICIPAL SEAL BELOW) ATTEST: Lori McWilliams, Village Clerk (COUNTY SEAL BELOW) ATTEST: SHARON R. BOCK, Clerk & Comptroller By: Deputy Clerk Approved as to Form and Legal Sufficiency By: Howard J. Falcon, III, Chief Assistant County Attorney VILLAGE OF TEQUESTA, a municipality duly organized and existing by virtue of the laws of the State of Florida M Abby Brennan, Mayor Jeremy Allen, Village Manager PALM BEACH COUNTY, FLORIDA, a Political Subdivision of the State of Florida BOARD OF COUNTY COMMISSIONERS am Dave Kerner, Mayor Document No.: Approved as to Terms and Conditions Dept. of Housing and Economic Sustainability in Sherry Howard Deputy Director Agenda Item #7. INTERLOCAL COOPERATION AGREEMENT BETWEEN PALM BEACH COUNTY AND VILLAGE OF TEQUESTA THIS AGREEMENT made and entered into on AUG 19 2014 by and between Palm Beach County, a political subdivision of the State of Florida, hereinafter referred to as the "County", and Village of Tequesta, a municipality duly organized and existing by virtue of the laws of the State of Florida, hereinafter referred to as the "Municipality". WHEREAS, the parties hereto have the common power to perform Community Development Block Grant (CDBG) Program, Emergency Solutions Grant (ESG) Program and Home Investment Partnerships (HOME) Program activities within their jurisdictions, said common powers being pursuant to Section 125.01, Florida Statutes, and Chapter 163, Part III, Florida Statutes; and WHEREAS, Section 163.01, Florida Statutes, known as the "Florida Interlocal Cooperation Act" authorizes local governments to make the most efficient use of their powers by enabling them to cooperate with other localities on a basis of mutual advantage and thereby to provide services and facilities that will harmonize geographic, economic, population and other factors influencing the needs and development of local communities; and WHEREAS, Title I of the Housing and Community Development Act of 1974, as amended, mandates that a county must enter into interlocal cooperation agreements with municipalities in its jurisdiction for the purposes of implementing CDBG activities within said municipalities; and WHEREAS, such interlocal cooperation agreements are also required to implement the HOME Program under Title II of the National Affordable Housing Act of 1990, as amended, and the ESG Program under the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act); and WHEREAS, the County desires to join with the Municipality in order to carry out the planning and professional services necessary to implement the CDBG, ESG and HOME Programs during Federal Fiscal Years 2015, 2016 and 2017, and during subsequent Federal Fiscal Years; and WHEREAS, the County and the Municipality agree to cooperate to undertake or assist in undertaking community renewal and lower income housing assistance activities; and WHEREAS, the County and Municipality wish to cooperate in the implementation of the goals and objectives of the County's Consolidated Plan, as approved by the U.S. Department of Housing and Urban Development (HUD); and WHEREAS, the Municipality desires to cooperate with the County for the purpose of implementing the CDBG, ESG and HOME Programs; and WHEREAS, the governing bodies of the County and the Municipality have each authorized this Agreement. Agenda Item #7. Village of Tequesta received (with respect to activities carried out during the Qualification Period and during any subsequent three-year qualification periods covered by any renewal of this Agreement) are expended and the funded activities are completed. Neither the Municipality nor the County may terminate, or withdraw from, this Agreement while it remains in effect. 2. This Agreement shall be automatically renewed for a three-year qualification period at the end of the Qualification Period and at the end of each subsequent qualification period unless either party provides the other party a written notice in which it elects not to participate in a new qualification period. If such notice be given, the party electing not to participate shall also send a copy of the written notice to the HUD field office with jurisdiction over the County. The County shall, by the date specified in HUD's Urban County Qualification Notice for the next qualification period, notify the Municipality in writing of its right not to participate, and the County shall provide a copy of such written notice to the HUD field office with jurisdiction over the County by the date specified in the Urban County Qualification Notice. 3. While this Agreement is in full force and effect, during the Qualification Period and during any subsequent three-year qualification periods covered by any renewal of this Agreement, the County and the Municipality agree to amend this Agreement to incorporate any changes necessary to meet the requirements for cooperation agreements as set forth by HUD in its Urban County Qualification Notices applicable to all subsequent three-year qualification periods, and to provide HUD such amendments as provided in the Urban County Qualification Notices. Failure to comply with the aforesaid shall void the automatic renewal of this Agreement. 4. The Municipality, by executing this Agreement, understands that: (a) It may not apply for any grants from appropriations under the State of Florida CDBG Program for fiscal years during the period in which it participates in the County's CDBG Program. (b) It may receive a formula allocation under the HOME Program only through the County. Even if the County does not receive a HOME formula allocation, the Municipality understands that it may not receive HOME Program funds from a HOME consortium with other local governments. This, however, does not preclude the County or the Municipality from applying to the State of Florida for HOME Program funds if the State of Florida so allows. (c) It may receive a formula allocation under the ESG Program only through the County. This, however, does not preclude the County or the Municipality from applying to the State of Florida for ESG Program funds if the State of Florida so allows. 5. This Agreement is contingent upon the County's qualification as an "urban county" under the CDBG Program as determined by HUD, as well as HUD's award of funds under the CDBG, ESG and HOME Programs, 6. The County and the Municipality agree to cooperate to undertake, or assist in undertaking, community renewal and lower income housing assistance activities. The County and the Municipality also agree to cooperate to enable the County to expend CDBG, ESG and HOME Program funds on eligible activities within the RA. al— — 1%.--1e9-.--i!-- M--'--1 ---1 ­ --- Agenda Item #7. Village of Tequesta County and the Municipality agree that the County is hereby permitted to undertake or assist in undertaking essential community development and housing assistance activities within the Municipality's jurisdiction. 8. The County, through its Department of Economic Sustainability, shall assist the Municipality in undertaking all professional and administrative services necessary for the purposes of implementing activities of the CDBG, ESG and HOME Programs, including preparation of all applications and other necessary documents, planning and other administrative activities, as required. 9. Pursuant to 24 CFR 570.501(b), the Municipality is subject to the same requirements applicable to subrecipients, including the requirements of a written agreement as described in 24 CFR 570.503. 10. The Municipality may not sell, trade, or otherwise transfer all or any portion of CDBG Program funds to another metropolitan city, urban county, unit of general local government, or Indian tribe, or insular area that directly or indirectly receives CDBG Program funds in exchange for any other funds, credits or non -Federal considerations, but must use such CDBG Program funds for activities under Title I of the Housing and Community Development Act of 1974, as amended. 11. The Municipality and the County shall take all actions necessary to assure compliance with the County's certification required by Section 104(b) of Title I of the Housing and Community Development Act of 1974, as amended, regarding Title VI of the Civil Rights Act of 1964, the Fair Housing Act, and affirmatively furthering fair housing. The Municipality and the County shall comply with Section 109 of Title I of the Housing and Community Development Act of 1974, which incorporates Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975), the Americans with Disabilities Act of 1990 and other applicable laws. The County shall not fund any activities in, or in support of, the Municipality should the Municipality not affirmatively further fair housing within its jurisdiction or should the Municipality impede the County's actions to comply with the County's fair housing certification. 12. The Municipality agrees that no person shall on the grounds of race, color, religion, disability, sex, age, national origin, ancestry, marital status, familial status, sexual orientation, gender identity or expression, or genetic information, be excluded from the benefits of, or be subjected to discrimination under, any activity carried out by the performance of this Agreement. Upon receipt of evidence of such discrimination, the County shall have the right to terminate this Agreement. 13. The Municipality has adopted, and is enforcing, a policy prohibiting the use of excessive force by law enforcement agencies within its jurisdiction against any individuals engaged in non-violent civil rights demonstrations; and the Municipality has adopted, and is enforcing, a policy of enforcing applicable State and local laws against physically barring entrance to, or exit from, a facility or location which is the subject of such non-violent civil rights demonstrations within jurisdictions. 14. Palm Beach County has established the Office of Inspector General in Palm Beach County Code, Section 2-421 - 2-440, as may be amended. The Inspector General's authority includes, but is not limited to, the power to review past, present and proposed County contracts, transactions, accounts and records, to require the Agenda Item #7. I Village of Tequesta 15. No provision of this Agreement is intended to, or shall be construed to, create any third party beneficiary or to provide any rights to any person or entity not a party to this Agreement, including but not limited to any citizen or employees of the County and/or the Municipality. 16. Nothing contained herein shall be deemed to authorize the delegation of the constitutional or statutory duties of the state, county or municipal officers. 17. A copy of this Agreement shall be filed with the Clerk and Comptroller in and for Palm Beach County. 18. Any prior agreements or contracts regarding the duties and obligations of the parties enumerated herein are hereby declared to be null and void. IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed by their duly authorized officials. (MUNICIPAL SEAL BELOW) AT] M Lori McWilliams, Village Clerk (COUNTY SEAL BELOW) T Y -"it ATTEST: SHARON Clerk & Comptroller-fk:: � ` Z ee P co T By: e 15 eputy Cler Approved as to Form and Legal Sufficiency VILLAGE OF TEQUESTA, a municipality duly organized and existing by virtue of the laws of the State of Florida 6y: y Bre an, yor By. -� Michael R. Couzzo, Village Manager (if applicable) PALM BEACH COUNTY, FLORIDA, a Political Subdivision of the State of Florida BOARD OF COUNTY COMMISSIONERS By: ;1"iriscilla A. Taylor, �. Document No.: R 2 014 1 1 7 2 AUG19 2.014 Approved as to Terms and Conditions Department of Economic Sustainability By: By: � ields, Sher ow hief Assistant Countv Attornev npniity lair _c tr Agenda Item #7. LEGAL CERTIFICATION BY PALM BEACH COUNTY Village of Tequesta As Legal Counsel for Palm Beach County, Florida,, I e9by state that the terms and provisions of this Agreement entered into on C' by and between Palm Beach County and Village of Tequesta are fully a tho ized under State and local law, and that the Agreement provides full legal authority for Palm Beach County to undertake, or assist in undertaking, community renewal and lower income housing assistance activities. Tammy s, Chief "ssistant County Attorney Palm Be County, Florida Agenda Item #7. �,��c�2 PALM BEACH COUNTY a c DEPARTMENT OF ECONOMIC SUSTAINABILITY �ORI9A RECEIVED DATE: September 4, 2014 SEP 0 9 20% TO: Village of Tequesta VILLAGE CLERKS OFFICE RE: INTERLOCAL COOPERATION AGREEMENT You previously sent us four executed Interlocal Cooperation Agreements indicating your approval to participate in Palm Beach County's Community Development Block Grant Program, Emergency Solutions Grant Program and Home Investment Partnerships Program during Federal Fiscal Years 2015, 2016 and 2017. On August 19, 2014, the Palm Beach County Board of County Commissioners approved your Interlocal Cooperation Agreement. We are accordingly hereby transmitting to you a fully executed Agreement for your records. This Agreement shall be automatically renewed for a three-year qualification period at the end of the above mentioned three-year qualification period and at the end of each subsequent qualification period unless either party provides the other party a written notice in which it elects not to participate in a new qualification period. This office will notify you in writing prior to the next three-year qualification period to provide you an opportunity to withdraw your participation. Thank you very much for your cooperation. We appreciate your participation in our programs. Please contact me at 561-233-3612 should you have any questions regarding the above. Sincerely, Betsy Barr, Director Contract Development and Quality Control Page 260 of 308