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2026 FIFA WORLD CUPTM
MUTUAL AID INTERLOCAL AGREEMENT
between
The City of RENTON
and
The City of KENT
WHEREAS, Chapter 39.34 RCW, the Interlocal Cooperation Act, authorizes
public agencies to contract with other public agencies to perform governmental
activities and deliver public services; and
WHEREAS, the City of Renton (RENTON) and the City of Kent (PARTICIPANT) are
Washington public agencies as defined in RCW 39.34.020 (hereafter collectively, the
“Parties”); and
WHEREAS, the authority of the cooperating agencies entering into this
Agreement is that authority provided to them by Washington law including the
Washington Interlocal Cooperation Act as codified in RCW Chapter 39.34, and the
Washington Mutual Aid Peace Officers Powers Act as codified in RCW Chapter 10.93;
and
WHEREAS, RENTON hosts a practice facility for Major League Soccer (MLS) and
will host international soccer/futbol clubs during the FIFA World Cup TM in 2026 at such
facility; and
WHEREAS, these gatherings of spectators and visitors within the City of Renton
shall be identified as “Special Events” throughout this Agreement; and
WHEREAS, the Renton Police Department (RPD) has requested additional law
enforcement resources from PARTICIPANT to assist in providing a sufficient law
enforcement presence in the City of Renton during the duration of the Special Event to
maintain public safety as it relates to the additional spectators and visitors expected to
visit the City of Renton; and
WHEREAS, PARTICIPANT is qualified to provide and agrees to provide law
enforcement resources and additional law enforcement officer presence for the City of
Renton during the Special Events, the dates and times of which will be established in the
future;
NOW THEREFORE, it is agreed that the foregoing PURPOSE statement and
corresponding recitals are hereby ratified and accepted as part of this AGREEMENT,
and, in consideration of the mutual promises and covenants herein contained, the
Parties agree as follows:
CAG-26-170
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I. RESPONSIBILITIES OF RENTON:
A. RENTON will be responsible for administering and overseeing this
Agreement in accordance with RCW 39.34.030, by designating an Incident
Commander for the Special Event, as described in additional detail in
Section III – Command Structure, below.
B. RENTON shall provide PARTICIPANT the specific dates, times, number of
hours, and the number of commissioned officers requested and/or needed
to provide mutual aid during the Special Events (cumulatively referred to as
“Event Opportunities”).
C. RENTON will report to PARTICIPANT any absence, or tardiness of a
committed PARTICIPANT officer who fails to report to the Event
Opportunities.
II. RESPONSIBILITIES OF PARTICIPANT:
A. PARTICIPANT will notify and/or advertise the mutual aid Event Opportunities
to all certified and commissioned police officers who are in good standing
and who are then eligible to perform all necessary duties of a law
enforcement officer with their employing agency.
B. If PARTICIPANT’S officers volunteer to fill the Event Opportunities,
PARTICIPANT’s project manager will e-mail the RENTON Special Event
Commander the availability to fill the requested mutual aid request in
accordance with Section 10, below. RENTON will provide in the e-mail, the
Special Event dates/times and number of police officers that are available.
RENTON will respond to the e-mail to confirm the commitment of the
number of PARTICIPANT’S officers needed. Once confirmed, PARTICIPANT
commits to fulfilling the mutual aid request for the confirmed number of
officer(s).
C. Once committed for the specified date, PARTICIPANT will make all
reasonable attempts to provide the committed number of officers for that
date. However, RENTON understands that PARTICIPANT must first
reasonably staff its own jurisdiction with a sufficient number of officers,
which may reduce the number of officers PARTICIPANT is able to ultimately
make available to RENTON on any given day or at any particular time.
Additionally, other unusual law enforcement occurrences or demands could
arise, which may prevent PARTICIPANT from staffing at the committed levels
needed to fulfill RENTON’S request. Further, after PARTICIPANT’S officers
arrive for their committed shifts in RENTON, it may become necessary for
PARTICIPANT to recall those committed officers to serve PARTICIPANT’S
needs in its own jurisdiction. Should any of these circumstances occur,
RENTON and PARTICIPANT will work together as soon as practicable to find
a mutually agreeable solution.
D. PARTICIPANT’S Officers assigned to support RENTON in this agreement shall
provide law enforcement services for specified Special Event. Such services
shall include but are not limited to addressing issues of public safety and
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security. Officers are expected to serve as a visual deterrent, positively
engage with community, enforce necessary law violations, and report
unusual or suspicious activity occurring at Special Event. Officers
performing these services shall wear the fully marked duty uniform of
PARTICIPANT, in accordance with their department’s policy and RCW
10.116.050.
E. PARTICIPANT is responsible for time-keeping and tracking the hours worked
by its officers at the Special Event.
III. COMMAND STRUCTURE: All law enforcement personnel assigned to the Special
Event will be integrated into an overall Unified Command system commanded by
the Renton Police Department. RENTON shall take charge of the Special Event
operations utilizing the Incident Command System unless it specifically requests
that a different agency or unit fulfill this responsibility, or unless the scope of the
situation becomes multi-jurisdictional, in which case the provisions of the
Washington State Mutual Aid Powers Act (RCW 10.93) becomes operative. Taking
charge of an operation shall include directing the assignment of all personnel and
equipment. The assigning of duties to officers employed by PARTICIPANT shall be
made by the supervising officer of the RENTON Police Department unless that
responsibility is delegated to a different agency. PARTICIPANT’S officers assigned
to specific tasks and/or posts and will perform their work under the direction of a
RENTON Police supervisor. The RENTON incident commander is in charge and
responsible for overall coordination with PARTICIPANT’S supervisors and/or
officers in support of the Special Event.
IV. REPORTING
A. Reimbursement. PARTICIPANT must submit to RENTON a reimbursement
request for services performed no later than thirty (30) calendars days
following the month in which services were performed.
B. Reimbursement Submissions. Each reimbursement submission will
include the name, rank, overtime compensation rate, number of
reimbursable hours claimed, and the dates those hours were worked by
each officer. These numbers should be provided or supported by accounting
system reports in a format approved by RENTON. This submission must be
accompanied by a signed certification by an appropriate supervisor within
PARTICIPANT’S department verifying that the information in the request has
been personally reviewed, is accurate, and the personnel included in the
reimbursement were working overtime hours to carry out the performance of
this Agreement. All submissions for reimbursement must be sent to the
attention of the contact person listed in Section X – Notices, below.
C. Approved Expenditures. RENTON shall pay PARTICIPANT for work
performed in proportion to reimbursement submission requests as approved
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by RENTON as specified in this Agreement. Reimbursable expenditures
pursuant to this agreement are restricted to:
1. The scheduled dates and number of hours authorized by RENTON in
advance; and
2. Satisfying the goal of providing adequate law enforcement presence
within the City of Renton during the duration of each assigned Special
Event.
D. Unpermitted Expenditures. RENTON reserves the right not to reimburse
PARTICIPANT for:
1. Any hours worked which exceed RENTON’S request for mutual aid in
accordance with the Event Opportunities without RENTON’S prior
approval; and
2. Any expenses incurred by PARTICIPANT other than officer overtime
pay will be the sole responsibility of PARTICIPANT.
E. Final Invoice. PARTICIPANT agrees to submit a final invoice to RENTON no
later than thirty (30) calendar days after the expiration of this AGREEMENT
and will label the reimbursement request as the “Final Bill”.
V. COMPENSATION: PARTICIPANT’S officers will be compensated at their hourly rate
for work of this type, as determined by PARTICIPANT’S agency and its policies. Such
payment schedule is attached hereto as Exhibit 1, which is incorporated by this
reference.
VI. LIABILITY, INDEMNIFICATION & HOLD HARMLESS
A. No Liability for Responding Agency. Except as expressly provided herein,
neither Party shall be liable for: (i) failure to comply with any provision of this
Agreement; or (ii) providing or refusing to provide aid under this Agreement.
B. Mutual Release(s). Except as specifically provided herein, each Party
hereby forever releases or discharges the other Party, its elected officials,
employees, officers, volunteers and/or agents from any claim related to this
Agreement or providing aid hereunder.
C. Liability to Other Parties. Except as expressly provided herein, the Parties
shall not be obligated to pay any of the other Parties to this Agreement for
any damage to or destruction of any apparatus or equipment used in the
performance of this Agreement. This provision shall not apply to the extent
this provision would void applicable casualty insurance available to provide
payment for the damage or loss of such apparatus or equipment. It is the
intent of the Parties that the risk of loss to apparatus or equipment will be
addressed by each Party through that Party’s casualty insurance as opposed
to seeking reimbursement from other Party.
D. Liability to Third Parties. The term "third party" means any person or entity
other than the Parties hereto. With regard to the aid provided hereunder,
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each Party shall be responsible for all liability arising from or related to the
negligent acts or willful conduct of that Party, its elected officials,
employees, officers, volunteers and/or agents which causes damage to third
parties, to the extent and in proportion that such liability is caused by the
negligent acts or willful misconduct of that Party, its elected officials,
employees, officers, volunteers, and/or agents.
E. Cross Indemnification. To the extent permitted by law, each Party agrees to
indemnify, defend and hold harmless the other Party, and its officers,
officials, employees, volunteers and/or agents from any and all claims,
demands, causes of action, lawsuits, costs, including attorneys' fees,
losses, judgments, awards or liabilities to any third party, arising out of the
negligent acts or willful conduct of the indemnifying Party, its officers,
officials, employees, volunteers and/or agents in connection with the
performance of this Agreement. This indemnity obligation shall not apply to
claims arising from the sole negligence or willful misconduct of the
indemnified Party. In the event of concurrent negligence of the Parties, each
Party shall be responsible only for the proportionate share of the claim that
results from its own negligence.
F. Survival. The provisions of this Section 6 shall survive the expiration or
termination of this Agreement, by any Party.
VII. INSURANCE:
A. Liability and Casualty Insurance. For the duration of this Agreement, each
Party shall maintain its own public liability and property damage insurance
with amounts of coverage as solely determined by each respective Party
against claims for injuries to persons or damage to property, which may arise
from or in connection with the performance of this Agreement by its officers,
officials, employees or volunteers. This insurance requirement may be
satisfied by a policy or policies of insurance or a self-insurance retention
program adopted by a Party.
B. Waiver of Subrogation. To the extent permitted by the applicable insurance
policies, each Party hereby waives any right of subrogation against the other
Parties. In this regard each Party utilizing a self-insurance retention program
waives subrogation for any payment thereunder.
VIII. POLICE POWERS: In accordance with the authority under RCW 10.93.070(1),
the City hereby consents to the full exercise of peace powers, within the City of
RENTON, Washington, by any and all properly certified or exempted police
officers employed by PARTICIPANT in accordance with this Agreement.
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IX. DURATION: This Agreement is effective upon signature by all parties and shall
extend through September 30, 2026, at which point it will automatically
terminate unless otherwise agreed to in writing.
X. NOTICES: Any notice required under this Agreement must be in writing, and
delivered personally to the Agreement’s Project Manager using the contact
information which appears below (as modified in writing from time to time by
such party), by registered or certified mail, return receipt requested, or by
nationally recognized overnight courier service. Time period for notices shall be
deemed to have commenced upon the date of receipt. Email and telephone
may be used for purposes of administering the Agreement, but should not be
used to give any formal notice required by the Agreement.
PARTICIPANT
Chief Rafael Padilla
Kent Police Department
220 4th Ave S
Kent, WA 98032
(253) 856-5890
PoliceChief@KentWA.gov
CITY OF RENTON
Commander Dan Figaro
Renton Police Department
1055 S Grady Way
Renton, WA 98057
(425) 430-7506
dfigaro@rentonwa.gov
XI. TERMINATION: Either Party may terminate this Agreement for any reason upon
sixty (60) days prior written notification to the other Party.
XII. DISPOSAL OF PROPERTY: No real or personal property will be acquired, held, or
used solely for the purpose of this Agreement. Each agency will be responsible
for acquiring, holding, using, and disposing of its own property upon the
expiration or termination of this Agreement.
XIII. ENTIRE AGREEMENT: The Parties agree that the Agreement is the complete
expression of the terms hereto and any oral representations or understanding not
incorporated herein are excluded.
XIV. MODIFICATIONS: This Agreement may only be modified, as needed, by written
amendment with the approval of all Parties. For purposes of this section, after
this Agreement is executed, the Parties’ governing bodies agree to delegate their
authority to modify this Agreement to the Police Chiefs of the participating
agencies.
XV. NO THIRD-PARTY BENEFICIARIES: There are no third-party beneficiaries to this
Agreement, and this Agreement shall not impart any rights enforceable by any
person or entity that is not a party hereto.
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XVI. SEVERABILITY: If any part, paragraph, section, or provision of this agreement is
held to be invalid by any court of competent jurisdiction in the State of
Washington, such adjudication shall not affect the validity of any remaining
section, part, or provision of this agreement
XVII. ACKNOWLEDGEMENT: The parties acknowledge that they have had an
opportunity to fully examine this Agreement and completely understand its
terms, and that they approve the same including all of the terms and conditions.
XVIII.SIGNATURE AUTHORITY: By signing below, the signers of this Agreement certify
that for each Party they have all proper authority necessary to bind the Party
hereto, pursuant to its Articles, Bylaws, statutory or other charter, ordinances,
laws, or any other rules governing such authority.
XIX.FEDERAL FUNDING COMPLIANCE
A.Grant Agreement. The Parties hereby acknowledge that the expenses
incurred as a result of the Special Events are subject to federal
reimbursement pursuant to Grant Agreement FWCGP-15 (hereafter,
Grant Agreement). Accordingly, the Parties hereby agree to abide by the
terms and conditions of the Grant Agreement, which is attached hereto
as Exhibit 2, and incorporated by this reference. Exhibit 2 does not alter
the operational mutual-aid terms of this Agreement. If any term
contained within Exhibit 2 conflicts with this Agreement, Exhibit 2
controls for purposes of federally funded reimbursements.
B.Federal Grant Requirements. The Parties agree to abide by the terms and
conditions imposed by the federal government on all recipients,
subrecipients, and contractors of federal grants, including, but not limited
to, 2 CFR Part 200, and its Appendix II (which can be accessed as follows:
https://www.ecfr.gov/current/title-2/part-200/appendix-Appendix II to Part
200), which is hereby adopted by this reference and incorporated into this
Agreement, as those requirements now exist or as they may be hereafter
amended, as applicable.
IN WITNESS WHEREOF, each of the Parties has executed this Agreement effective as
of the date and year first set forth above.
PARTICIPANT CITY OF RENTON
_________________________________
Dana Ralph, Mayor
__________________________________
Armondo Pavone, Mayor
6/2/2026
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ATTEST:
_________________________________
Kimberley A. Komoto, City Clerk
APPROVED AS TO FORM:
__________________________________
Tammy White, City Attorney
ATTEST:
___________________________________
Jason Seth, City Clerk
APPROVED AS TO FORM:
__________________________________
Shane Moloney, City Attorney
Approved by Alex Tuttle via memo 5/28/2026
EXHIBIT 1
Compensation for Kent’s Participant Officers
City of Kent PD
2026 Pay Scale Step A Step B Step C Step D Step E Step F
Officer Annual
Hourly
OT
97,296.00
46.78
70.17
100,632.00
48.38
72.57
105,636.00
50.79
76.18
111,708.00
53.71
80.56
118,788.00
57.11
85.66
126,636.00
60.88
91.32
Sergeant Annual
Hourly
OT
152,064.00
73.11
109.66
Commander Annual
Hourly
190,212.00
91.45
EXHIBIT 2
Grant Agreement FWCGP-15
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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AGREEMENT FACE SHEET
FY 2026 FIFA World Cup Grant Program (FY 2026 FWCGP)
1. Subrecipient Name and Address:
Renton Police Department
1055 S. Grady Way
Renton, WA 98057
2. Grant Agreement Amount:
378,412.00
3. Grant Agreement Number:
FWCGP-15
4. Subrecipient Contact,
phone/email:
Ryan Rutledge
425-430-7512
rrutledge@rentonwa.gov
5. Grant Agreement Start Date:
July 4, 2025
6. Grant Agreement End
Date:
August 31, 2026
7. Organization Contact,
phone/email:
Casey Broom, 360-202-3001,
caseyb@sea2026.org
8. Unique Entity Identifier (UEI) :
UG2PSBS6UJJ3
9. UBI (state revenue):
177-000-094
10. Funding Authority:
Washington Military Department (the Department) and the U.S. Department of Homeland
Security (DHS)
11. Federal Funding ID #:
EMW-2026-WC-05005
12. Federal Award Date:
03/18/2026
13. Assistance Listings &
Title:
97.160 - FY 2026 FWCGP
14. Total Federal Award Amount:
$32,252,845
15. Contract Type (check all that
apply):
☐ Contract ☒ Grant ☒
Agreement ☐
Intergovernmental (RCW 39.34)
☐ Interagency
16. Subrecipient Type (check
all that apply):
☐ Private
Organization/Individual ☐
For-Profit ☒ Public
Organization/Jurisdiction
☐ non-profit ☐
CONTRACTOR ☒
SUBRECIPIENT ☐
OTHER
17. PURPOSE & DESCRIPTION:
The objective of the Federal Fiscal Year (FFY) 2026 FIFA World Cup (FY 2026 FWCGP) grant
program is to provide targeted funding to enhance security and preparedness for the 2026 FIFA
World Cup events hosted in the United States. It will provide Federal resources to help Host Cities in
implementing the necessary security measures and strengthen capabilities required for this series of
high-risk events. FWC grant funds will enhance the ability of local law enforcement, emergency
responders, and public safety officials to prepare for, protect against, and respond to threats and
emergencies during the World Cup matches.
The Organization is a sub-recipient and Pass-through Entity of the FY 2026 FWCGPC Award Letter
for Grant No. EMW-2026-W-05005 ("the Grant"), which is incorporated in and attached hereto as
Attachment C, and has made a subaward of Federal award funds to the Subrecipient pursuant to
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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this Agreement. The Subrecipient is accountable to the Organization for use of Federal award funds
provided under this Agreement.
IN WITNESS WHEREOF, the Organization and Subrecipient acknowledge and accept the terms of this
Agreement, including all referenced attachments which are hereby incorporated, and have executed this
Agreement as of the date below. This Agreement Face Sheet; Special Terms & Conditions (Attachment A);
General Terms and Conditions (Attachment B); DHS Award Letter EMW-026-W-05005 (Attachment C); Work
Plan, (Attachment D); Timeline (Attachment E); Budget (Attachment F); Build America, Buy America Act Self-
Certification (Attachment G), and all other documents and attachments expressly referenced and
incorporated herein contain all the terms and conditions agreed upon by the parties and govern the rights
and obligations of the parties to this Agreement. No other understandings, oral or otherwise, regarding the
subject matter of this Agreement shall be deemed to exist or to bind any of the parties.
In the event of an inconsistency among the provisions of the above-described Attachments, unless otherwise
provided herein, the inconsistency shall be resolved by giving precedence in the following order:
1. Applicable Federal and State Statutes and Regulations
2. DHS/FEMA Award and program documents
3. Work Plan, Timeline, and Budget
4. Special Terms and Conditions
5. General Terms and Conditions
6. Other provisions of the Agreement incorporated by reference
WHEREAS, the parties have executed this Agreement on the day, and year last specified below.
FOR THE ORGANIZATION: FOR THE SUBRECIPIENT:
____________________________________
Signature Date
Ann Kawasaki Romero
SeattleFWC26
BOILERPLATE APPROVED TO FORM:
5/08/2026
____________________________________
Signature Date
Ryan Rutledge, Deputy Chief of Police
Renton Police Department
APPROVED AS TO FORM (if applicable):
____________________________________
Signature Date
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ATTACHMENT A
SPECIAL TERMS AND CONDITIONS
FY 2026 FIFA World Cup Grant Program
ARTICLE I. KEY PERSONNEL
The individuals listed below shall be considered key personnel for point of contact under this Agreement. Any
substitution for key personnel by either party shall be made by written notification to the current key
personnel.
SUBRECIPIENT ORGANIZATION
Name Ryan Rutledge Name Casey Broom
Title Deputy Chief of Police Title VP, Security
Email RRutledge@rentonwa.gov Email Caseyb@sea2026.org
Phone 425-430-7512 Phone 360-202-3001
Name Name George Dugdale
Title Title SVP Business Operations
Email Email georged@sea2026.org
Phone Phone 206-390-2012
ARTICLE II. ADMINISTRATIVE AND/OR FINANCIAL REQUIREMENTS
The Subrecipient shall comply with all applicable state and federal laws, rules, regulations, requirements and
program guidance identified or referenced in this Agreement and the informational documents published by
DHS/FEMA applicable to the FY 2026 FWCGP grant program, including, but not limited to, all criteria,
restrictions, and requirements of "The Department of Homeland Security (DHS) Notice of Funding
Opportunity (NOFO) Fiscal Year 2026 FIFA World Cup Grant Program" (hereafter "the NOFO"), the
Preparedness Grants Manual FM 207-23-0001 August 2025 (hereafter "the Manual"), the DHS Award Letter
for the Grant, and the federal regulations commonly applicable to DHS/FEMA grants, all of which are
incorporated herein by reference. The DHS Award Letter is incorporated in this Agreement as Attachment C.
The Subrecipient acknowledges that since this Agreement involves federal award funding, the period of
performance may begin prior to the availability of appropriated federal funds. The Subrecipient agrees that it
will not hold the Organization, the state of Washington, or the United States liable for any damages, claim for
reimbursement, or any type of payment whatsoever for services performed under this Agreement prior to
distribution of appropriated federal funds.
A. STATE AND FEDERAL REQUIREMENTS FOR DHS/FEMA PREPAREDNESS GRANTS
The following requirements apply to all DHS/FEMA Preparedness Grants.
1. SUBAWARDS & CONTRACTS BY SUBRECIPIENTS
a. The Subrecipient must make a case-by-case determination whether each agreement it makes for the
disbursement of FY 2026 FWCGP funds received under this Agreement casts the party receiving the funds
in the role of a subrecipient or contractor in accordance with 2 CFR 200.331.
b. If the Subrecipient becomes a pass-through entity by making a subaward to a subrecipient:
i. The Subrecipient must comply with all federal laws and regulations applicable to pass-through
entities of FY 2026 FWCGP funds, including, but not limited to, those contained in 2 CFR 200.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ii. The Subrecipient shall require its subrecipient(s) to comply with all applicable state and federal
laws, rules, regulations, requirements and program guidance identified or referenced in this
Agreement and the informational documents published by DHS/FEMA applicable to the FY 2026
FWCGP grant program, including, but not limited to, all criteria, restrictions, and requirements of the
NOFO, the Manual, the Grant, and the federal regulations commonly applicable to DHS/FEMA
grants.
iii. The Subrecipient shall be responsible to the Organization for ensuring that all FY 2026 FWCGP
federal award funds provided to its subrecipients are used in accordance with applicable federal and
state statutes and regulations, and the terms and conditions of the federal award set forth in this
Agreement.
iv. The Subrecipient must follow their own policies and procedures to eliminate or reduce the impact
of conflicts of interest when making subawards, adhering to any applicable federal or state statutes
or regulations. Any real or potential conflicts of interest must be reported to the Organization in
writing upon discovery.
2. BUDGET, REIMBURSEMENT, AND TIMELINE
a. Within the total Grant Agreement Amount, travel, subcontracts, salaries, benefits, printing, equipment, and
other goods and services or other budget categories will be reimbursed on an actual cost basis upon
completion unless otherwise provided in this Agreement.
b. The maximum amount of all reimbursement requests permitted to be submitted under this Agreement,
including the final reimbursement request, is limited to and shall not exceed the total Grant Agreement
Amount.
c. If the Subrecipient chooses to include indirect costs within the Budget (Attachment F), additional
documentation is required based on the applicable situation, as described in 2 CFR 200.414 and Appendix
VII to 2 CFR 200:
i. If the Subrecipient receives direct funding from any Federal agency(ies): (A) More than $35 million,
the approved indirect cost rate agreement negotiated with its federal cognizant agency; (B) Less
than $35 million, the indirect cost proposal developed in accordance with Appendix VII of 2 CFR 200
requirements.
ii. If the Subrecipient does not receive direct federal funds (i.e., only receives funds as a
subrecipient), the Subrecipient must either elect to charge a de minimis rate of fifteen percent (15%)
of modified total direct costs or choose to negotiate a higher rate with the Organization.
iii. Indirect costs must be expressly identified in the Budget using a single, consistent methodology and
shall not be adjusted or modified without prior written approval from the Organization.
d. For travel costs, the Subrecipient shall comply with 2 CFR 200.475 and should consult their internal
policies, state rates set pursuant to RCW 43.03.050 and RCW 43.03.060, and federal maximum rates set
forth at https://www.gsa.gov, and follow the most restrictive. All international travel requires prior FEMA
approval.
e. Reimbursement requests will include a properly completed Reimbursement Spreadsheet detailing the
expenditures for which reimbursement is sought. Reimbursement requests must be submitted to
FWCGP@sea2026.org no later than the due dates listed within the Timeline (Attachment E).
f. Receipts and/or backup documentation for any approved items must be maintained by the Subrecipient
consistent with record retention requirements and be made available upon request.
g. The Subrecipient must request prior written approval from Organization Key Personnel to waive or extend
a due date in the Timeline (Attachment E).
h. All work under this Agreement must end on or before the Grant Agreement End Date, and the final
reimbursement request must be submitted before the date notated in the Timeline (Attachment E).
i. All costs for equipment and supplies must be incurred, and items received before the Grant Agreement
End Date.
j. Failure to submit timely, accurate, and complete reports and reimbursement requests will prohibit the
Subrecipient from being reimbursed until such reports are submitted and reviewed.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
5
k. Final reimbursement requests will not be approved for payment until the Subrecipient is current with all
reporting requirements.
l. A written amendment will be required if the Subrecipient expects cumulative transfers among solution area
totals to exceed ten percent (10%) of the Grant Agreement Amount.
m. Subrecipients shall only use federal award funds under this Agreement to supplement existing funds and
will not use them to replace (supplant) non-federal funds.
3. REPORTING REQUIREMENTS
a. With each reimbursement request, the Subrecipient shall report how the expenditures relate to the Work
Plan (Attachment D) activities in the format provided by the Organization.
b. With the final reimbursement request, the Subrecipient shall submit a final report to
FWCGP@sea2026.org describing all completed activities under this Agreement.
c. The Subrecipient shall comply with the Federal Funding Accountability and Transparency Act (FFATA)
and related OMB Guidance consistent with Public Law 109-282 as amended and complete and return to the
Organization an Audit Certification/FFATA Form.
4. EQUIPMENT AND SUPPLY MANAGEMENT
a. The Subrecipient and any subrecipient to which the Subrecipient makes a subaward shall comply with 2
CFR 200.317 through 200.327, and all Washington State procurement statutes, when procuring any
equipment or supplies under this Agreement.
b. All equipment and supplies purchased through this Agreement will be recorded and maintained in the
Subrecipient's inventory system. Inventory records shall include: description, serial/model number, Federal
Award Identification Number (FAIN), Assistance Listings Number, title holder, acquisition date, cost and
federal participation percentage, location/use/condition, and disposition data.
c. The Subrecipient shall take a physical inventory of equipment and reconcile with property records at least
once every two years.
d. Records for equipment shall be retained for a period of six (6) years from the date of the disposition,
replacement, or transfer.
e. Effective August 13, 2020, FEMA recipients and subrecipients may not obligate or expend any FEMA
award funds to procure equipment, systems, or services that use covered telecommunications equipment or
services as defined in section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year
2019 (FY 2019 NDAA), Pub. L. No. 115-232 (2018). Covered entities include Huawei Technologies
Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology
Company, and Dahua Technology Company, or any subsidiary or affiliate of such entities.
5. ENVIRONMENTAL AND HISTORICAL PRESERVATION
a. The Subrecipient shall ensure full compliance with the DHS/FEMA Environmental Planning and Historic
Preservation (EHP) Program. EHP program information can be found at
https://www.fema.gov/grants/guidance-tools/environmental-historic.
b. Projects that have historical impacts or the potential to impact the natural or built environment must
participate in the DHS/FEMA EHP review process prior to project initiation. The EHP review process must be
completed, and FEMA approval must be received by the Subrecipient before any work is started for which
reimbursement will be later requested.
6. PROCUREMENT
The Subrecipient shall comply with all procurement requirements of 2 CFR 200.317 through 200.327.
a. For all contracts expected to exceed the simplified acquisition threshold, the Subrecipient must notify the
Organization. The Organization may request pre-procurement documents such as requests for proposals,
invitations for bids, and independent cost estimates.
b. For all sole source contracts expected to exceed the micro-purchase threshold per 2 CFR 200.1, the
Subrecipient must submit justification to the Organization
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c. The Subrecipient as well as its contractors and subcontractors must comply with the Build America, Buy
America Act (BABAA), which was enacted as a part of the Infrastructure Investment and Jobs Act §§ 70901-
70297, Pub. L. No. 117-58 (2021), requiring that infrastructure projects use iron, steel, and manufactured
products produced in the United States. The Build America, Buy America Act Self-Certification form is
included herein as Attachment G.
7. SUBRECIPIENT MONITORING
a. The Organization will monitor the activities of the Subrecipient from award to closeout. The goal of the
Organizations monitoring activities will be to ensure that subrecipients receiving federal pass-through funds
are in compliance with this Agreement, federal and state audit requirements, federal grant guidance, and
applicable federal and state financial regulations, as well as 2 CFR Part 200 Subpart F.
b. Monitoring activities may include but are not limited to: review of financial and performance reports;
monitoring and documenting completion of Agreement deliverables; documentation of phone calls, meetings,
emails and correspondence; review of reimbursement requests; observation of Agreement-related activities
such as exercises, training, events, and equipment demonstrations; and on-site visits to review equipment
records and inventories.
8. LIMITED ENGLISH PROFICIENCY (CIVIL RIGHTS ACT OF 1964 TITLE VI)
a. The Subrecipient must comply with the Title VI of the Civil Rights Act of 1964 prohibition against
discrimination on the basis of national origin, which requires that subrecipients of federal financial assistance
take reasonable steps to provide meaningful access to persons with limited English proficiency (LEP) to their
programs and services.
b. Subrecipients are encouraged to perform and document their analysis of the most appropriate language
assistance services. The analysis should consider: the number or proportion of LEP individuals eligible to be
served; the frequency with which LEP individuals come in contact with the program; the nature and
importance of the program to people's lives; and the resources available to the program and costs.
B. FWC SPECIFIC REQUIREMENTS
The objectives of the FWC are to enhance security and preparedness for the 2026 FIFA World Cup events in
the United States.
1. The Subrecipient shall use the federal funds authorized under this Agreement only to perform tasks as
described in the Work Plan (Attachment D) and the Subrecipient's approved application for funding,
incorporated into this Agreement.
2. Funding may not be used to replace or supplant non-federal funding of emergency management
programs.
3. The Subrecipient shall report on the following performance measures and targets per the NOFO:
x Number of FWCGP-funded operational overtime hours tracked and reported by the
recipient in support of security and public safety operations for FIFA World Cup-related
planning and event execution.
x Number of DHS/FEMA-sponsored and approved Training Sessions completed for law
enforcement, emergency responders, and security personnel using FWCGP funds.
x Number of Homeland Security Exercise and Evaluation Program (HSEEP)-compliant
Exercises completed for law enforcement, emergency responders, and security personnel
using FWCGP funds.
x Number of FWCGP-funded Emergency Response Teams deployed to FIFA venues,
hotels, and transportation hubs.
x The number of security incidents successfully managed or mitigated during the World
Cup events.
x Collect feedback from international visitors, FIFA officials, and local stakeholders on the
overall security and preparedness of the events.
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C. DHS TERMS AND CONDITIONS
As a Subrecipient of FY 2026 FWCGP funding, the Subrecipient shall comply with all applicable DHS terms
and conditions of the Award Letter and its incorporated documents for the Grant, which are incorporated and
made a part of this Agreement as Attachment C.
ATTACHMENT B
GENERAL TERMS AND CONDITIONS
SeattleFWC26 | DHS/FEMA Grants
Department of Homeland Security (DHS) / Federal Emergency Management Agency (FEMA)
1. DEFINITIONS
As used throughout this Agreement, the terms will have the same meaning as defined in 2 CFR 200 Subpart
A (which is incorporated herein by reference), except as otherwise set forth below:
a. "Agreement" means this Grant Agreement.
b. "Organization" means SeattleFWC26, a private not for profit organization that serves as the Local
Organizing Committee hosting and staging the FIFA World Cup 2026 games in Seattle, Washington, or any
of the officers or other officials lawfully representing that Organization. The Organization is a sub-recipient of
a federal award from a federal awarding agency and is the pass-through entity making a subaward to a
Subrecipient under this Agreement.
c. "Monitoring Activities" means all administrative, financial, or other review activities that are conducted to
ensure compliance with all state and federal laws, rules, regulations, authorities and policies.
d. "Subrecipient" when capitalized is primarily used throughout this Agreement in reference to the non-
federal entity identified on the Face Sheet of this Agreement that has received a subaward from the
Organization.
2. ADVANCE PAYMENTS PROHIBITED
The Organization shall make no payments in advance or in anticipation of goods or services to be provided
under this Agreement. The Subrecipient shall not invoice the Organization in advance of delivery and
invoicing of such goods or services.
3. AMENDMENTS AND MODIFICATIONS
The Subrecipient or the Organization may request, in writing, an amendment or modification of this
Agreement. However, such amendment or modification shall not be binding, take effect or be incorporated
herein until made in writing and signed by the authorized representatives of the Organization and the
Subrecipient. No other understandings or agreements, written or oral, shall be binding on the parties.
The Agreement performance period shall only be extended by (1) written notification of DHS/FEMA approval
of the Award performance period, followed up with a mutually agreed written amendment, or (2) written
notification from the Organization to the Subrecipient to provide additional time for completion of the
Subrecipient's project(s).
4. AMERICANS WITH DISABILITIES ACT (ADA) OF 1990
Except as provided herein, the Subrecipient must comply with the ADA (Public Law 101-336, 42 U.S.C.
12101 et seq., 28 CFR Part 35), which provides comprehensive civil rights protection to individuals with
disabilities in the areas of employment, public accommodations, state and local government services, and
telecommunication.
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5. ASSURANCES
The Organization and Subrecipient agree that all activity pursuant to this Agreement will be in accordance
with all the applicable current federal, state and local laws, rules, and regulations.
6. CERTIFICATION REGARDING DEBARMENT, SUSPENSION, OR INELIGIBILITY
As federal funds are a basis for this Agreement, the Subrecipient certifies that the Subrecipient is not
presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from
participating in this Agreement by any federal department or agency. The Subrecipient shall complete, sign,
and return a Certification Regarding Debarment, Suspension, Ineligibility, and Voluntary Exclusion form. The
Subrecipient certifies that it will ensure that potential contractors or subrecipients or any of their principals are
not debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from
participation in "covered transactions" by any federal department or agency.
7. CERTIFICATION REGARDING RESTRICTIONS ON LOBBYING
As required by 44 CFR Part 18, the Subrecipient hereby certifies that to the best of its knowledge and belief:
(1) no federally appropriated funds have been paid or will be paid to any person for influencing or attempting
to influence an officer or employee of an agency, a Member of Congress, or an employee of a Member of
Congress in connection with the awarding of any federal contract or the making of any federal grant; (2) if
any funds other than federal appropriated funds have been paid to any person for influencing activities, the
Subrecipient will complete and submit Standard Form-LLL; and (3) the Subrecipient will require the language
of this certification be included in the award documents for all subawards at all tiers.
8. COMPLIANCE WITH APPLICABLE STATUTES, RULES AND DEPARTMENT POLICIES
The Subrecipient and all its contractors and subrecipients shall comply with, and the Organization is not
responsible for determining compliance with, any and all applicable federal, state, and local laws,
regulations, executive orders, OMB Circulars, and/or policies. This obligation includes, but is not limited to:
nondiscrimination laws, Energy Policy and Conservation Act, the ADA, Age Discrimination Act of 1975, Title
VI of the Civil Rights Act of 1964, Civil Rights Act of 1968, the Robert T. Stafford Disaster Relief and
Emergency Assistance Act, Ethics in Public Service (RCW 42.52), Public Records Act (RCW 42.56),
Prevailing Wages on Public Works (RCW 39.12), State Environmental Policy Act (RCW 43.21C), and safety
and health regulations.
9. CONFLICT OF INTEREST
No officer or employee of the Organization; no member, officer, or employee of the Subrecipient or its
designees or agents; no member of the governing body of the jurisdiction in which the project is undertaken
or located; and no other official of the Subrecipient who exercises any functions or responsibilities with
respect to the project during his or her tenure, shall have any personal or pecuniary gain or interest, direct or
indirect, in any contract, subcontract, or the proceeds thereof, for work to be performed in connection with
the project assisted under this Agreement.
10. CONTRACTING & PROCUREMENT
a. The Subrecipient shall use a competitive procurement process in the procurement and award of any
contracts with contractors or subcontractors in accordance with 2 CFR Part 200.318 through 200.327.
All contracts entered into by the Subrecipient must include the following provisions, as applicable:
administrative/contractual/legal remedies for contracts over the simplified acquisition threshold ($250,000);
termination for cause and for convenience for contracts in excess of $10,000; Equal Employment
Opportunity; Davis-Bacon Act compliance where required; Contract Work Hours and Safety Standards Act
compliance; Rights to Inventions; Clean Air Act and Federal Water Pollution Control Act compliance for
amounts over $150,000; Debarment and Suspension; Byrd Anti-Lobbying Amendment; Procurement of
recovered materials; access to records; retention of required records for six years; and energy efficiency
standards.
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b. The Organization reserves the right to review the Subrecipient's procurement plans and documents and
require the Subrecipient to make changes to bring its plans and documents into compliance with 2 CFR Part
200.317 through 200.327.
c. All contracting agreements entered into pursuant to this Agreement shall incorporate this Agreement by
reference.
11. DISCLOSURE
The use or disclosure by any party of any information concerning the Organization for any purpose not
directly connected with the administration of the Organization's or the Subrecipient's responsibilities with
respect to services provided under this Agreement is prohibited except by prior written consent of the
Organization or as required to comply with the state Public Records Act, other law or court order.
12. DISPUTES
Except as otherwise provided in this Agreement, when a bona fide dispute arises between the parties and it
cannot be resolved through discussion and negotiation over a 30-day period, either party may request a
dispute resolution board to resolve the dispute. The board shall consist of a representative appointed by the
Organization, a representative appointed by the Subrecipient, and a third party mutually agreed upon by both
parties. The determination of the dispute resolution board shall be final and binding on the parties. The laws
of the state of Washington and all applicable federal laws shall apply to all disputes hereunder. The venue to
resolve all such disputes shall be Seattle, Washington.
13. LEGAL RELATIONS
It is understood and agreed that this Agreement is solely for the benefit of the parties to the Agreement and
gives no right to any other party. No joint venture or partnership is formed as a result of this Agreement.
To the extent allowed by law, the Subrecipient, its successors or assigns, will protect, save and hold
harmless the Organization, the state of Washington, and the United States Government and their authorized
agents and employees, from all claims, actions, costs, damages or expenses of any nature whatsoever by
reason of the acts or omissions of the Subrecipient, its subcontractors, subrecipients, assigns, agents,
contractors, consultants, licensees, invitees, employees or any person whomsoever arising out of or in
connection with any acts or activities authorized by this Agreement.
44 CFR 206.9 Non-liability: The Federal government shall not be liable for any claim based upon the
exercise or performance of, or the failure to exercise or perform a discretionary function or duty on the part of
a federal agency or an employee of the Federal government in carrying out the provisions of the Stafford Act.
14. LIMITATION OF AUTHORITY – AUTHORIZED SIGNATURE
The signatories to this Agreement represent that they have the authority to bind their respective
organizations to this Agreement. Only the Organization's Authorized Signature representative and the
Authorized Signature representative of the Subrecipient shall have the express, implied, or apparent
authority to alter, amend, modify, or waive any clause or condition of this Agreement.
15. LOSS OR REDUCTION OF FUNDING
In the event funding from state, federal, or other sources is withdrawn, reduced, or limited in any way after
the effective date of this Agreement and prior to normal completion or end date, the Organization may
unilaterally reduce the work plan and budget or unilaterally terminate all or part of the Agreement as a
"Termination for Cause" without providing the Subrecipient an opportunity to cure.
16. NONASSIGNABILITY
Neither this Agreement, nor any claim arising under this Agreement, shall be transferred or assigned by the
Subrecipient.
17. NONDISCRIMINATION
During the performance of this agreement, the Subrecipient shall comply with all federal and state
nondiscrimination statutes and regulations. The Subrecipient shall not discriminate against any employee or
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applicant for employment because of race, color, sex, sexual orientation, religion, national origin, creed,
marital status, age, Vietnam era or disabled veteran status, or the presence of any sensory, mental, or
physical handicap.
18. NOTICES
The Subrecipient shall comply with all public notices or notices to individuals required by applicable local,
state and federal laws and regulations and shall maintain a record of this compliance.
19. OCCUPATIONAL SAFETY/HEALTH ACT AND WASHINGTON INDUSTRIAL
SAFETY/HEALTH ACT (OSHA/WISHA)
The Subrecipient represents and warrants that its workplace does now or will meet all applicable federal and
state safety and health regulations that are in effect during the Subrecipient's performance under this
Agreement.
20. OWNERSHIP OF PROJECT/CAPITAL FACILITIES
The Organization makes no claim to any capital facilities or real property improved or constructed with funds
under this Agreement, and by this subaward of funds does not and will not acquire any ownership interest or
title to such property of the Subrecipient. The Subrecipient shall assume all liabilities and responsibilities
arising from the ownership and operation of the project.
21. POLITICAL ACTIVITY
No portion of the funds provided herein shall be used for any partisan political activity or to further the
election or defeat of any candidate for public office or influence the approval or defeat of any ballot issue.
22. PROHIBITION AGAINST PAYMENT OF BONUS OR COMMISSION
The assistance provided under this Agreement shall not be used in payment of any bonus or commission for
the purpose of obtaining approval of the application for such assistance or any other approval or concurrence
under this Agreement.
23. PUBLICITY
The Subrecipient agrees to submit to the Organization prior to issuance all advertising and publicity matters
relating to this Agreement wherein the Organization's name is mentioned or implied. The Subrecipient may
copyright original work it develops in the course of or under this Agreement; however, pursuant to 2 CFR
Part 200.315, FEMA reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, publish or
otherwise use, and to authorize others to use the work for government purposes.
24. RECAPTURE PROVISION
In the event the Subrecipient fails to expend funds under this Agreement in accordance with applicable
federal, state, and local laws, regulations, and/or the provisions of the Agreement, the Organization reserves
the right to recapture funds in an amount equivalent to the extent of noncompliance. Such right of recapture
shall exist for the life of the project following Agreement termination. Repayment by the Subrecipient of funds
under this recapture provision shall occur within 30 days of demand.
25. RECORDS
a. The Subrecipient agrees to maintain all books, records, documents, receipts, invoices and all other
electronic or written records necessary to sufficiently and properly reflect the Subrecipient's contracts,
subawards, grant administration, and payments.
b. The Subrecipient's records related to this Agreement and the projects funded may be inspected and
audited by the Organization or its designee, by the Office of the State Auditor, DHS, FEMA or their
designees, by the Comptroller General of the United States or its designees, or by other state or federal
officials authorized by law.
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c. The Subrecipient shall retain and allow access to all records related to this Agreement and the funded
project(s) for a period of at least six (6) years following final payment and closure of the grant under this
Agreement.
26. RESPONSIBILITY FOR PROJECT/STATEMENT OF WORK/WORK PLAN
While the Organization undertakes to assist the Subrecipient with the project/statement of work/work plan by
providing federal award funds pursuant to this Agreement, the project itself remains the sole responsibility of
the Subrecipient. The responsibility for the design, development, construction, implementation, operation and
maintenance of the project is solely that of the Subrecipient.
27. SEVERABILITY
If any court of rightful jurisdiction holds any provision or condition under this Agreement or its application to
any person or circumstances invalid, this invalidity does not affect other provisions, terms or conditions of the
Agreement, which can be given effect without the invalid provision.
28. SINGLE AUDIT ACT REQUIREMENTS (INCLUDING ALL AMENDMENTS)
Subrecipients of a federal award that expend $1,000,000 or more in one fiscal year of federal funds from all
sources are required to have a single or a program-specific audit conducted in accordance with 2 CFR Part
200 Subpart F. Subrecipients that spend less than $1,000,000 a year in federal awards are exempt from
federal audit requirements for that year. After the single audit has been completed, and if it includes any
audit findings, the Subrecipient must send a full copy of the audit and its Corrective Action Plan to the
Organization no later than the earlier of within 30 calendar days of receiving the auditor’s report of nine (9)
months after the end of the Subrecipient's fiscal year(s), addressed to: Contracts Office, Washington Military
Department, Finance Division, Building #1 TA-20, Camp Murray, WA 98430-5032, or
Contracts.Office@mil.wa.gov.
29. SUBRECIPIENT NOT EMPLOYEE
The Subrecipient, and/or employees or agents performing under this Agreement, are not employees or
agents of the Organization in any manner whatsoever. The Subrecipient will not be presented as nor claim to
be an officer or employee of the Organization or of the state of Washington by reason hereof.
30. TAXES, FEES AND LICENSES
Unless otherwise provided in this Agreement, the Subrecipient shall be responsible for, pay and maintain in
current status all taxes, unemployment contributions, fees, licenses, assessments, permit charges and
expenses of any other kind for the Subrecipient or its staff required by statute or regulation that are
applicable to Agreement performance.
31. TERMINATION FOR CONVENIENCE
Notwithstanding any provisions of this Agreement, the Subrecipient may terminate this Agreement by
providing written notice of such termination to the Organization Key Personnel identified in the Agreement,
specifying the effective date thereof, at least thirty (30) days prior to such date.
Except as otherwise provided in this Agreement, the Organization, in its sole discretion and in the best
interests of the state of Washington, may terminate this Agreement in whole or in part ten (10) business days
after emailing notice to the Subrecipient.
32. TERMINATION OR SUSPENSION FOR LOSS OF FUNDING
The Organization may unilaterally terminate or suspend all or part of this Grant Agreement, or may reduce its
scope of work and budget, if there is a reduction in funds by the source of those funds. The Organization will
email the Subrecipient ten (10) business days prior to termination.
33. TERMINATION OR SUSPENSION FOR CAUSE
In the event the Organization, in its sole discretion, determines the Subrecipient has failed to fulfill in a timely
and proper manner its obligations under this Agreement, is in an unsound financial condition, is in violation of
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any laws or regulations, or has violated any of the covenants, agreements or stipulations of this Agreement,
the Organization has the right to immediately suspend or terminate this Agreement in whole or in part.
34. TERMINATION PROCEDURES
In addition to the procedures set forth below, if the Organization terminates this Agreement, the Subrecipient
shall follow any procedures specified in the termination notice. Upon termination of this Agreement, the
Organization may require the Subrecipient to deliver to the Organization any property specifically produced
or acquired for the performance of such part of this Agreement as has been terminated.
After receipt of a notice of termination, and except as otherwise directed by the Organization in writing, the
Subrecipient shall: stop work under the Agreement; place no further orders or contracts for materials or
services; assign rights to the Organization; settle all outstanding liabilities; transfer title to the Organization;
complete performance of such part of the work not terminated; and take action for the protection and
preservation of the property related to this Agreement.
35. MINORITY AND WOMEN-OWNED BUSINESS ENTERPRISES
In accordance with Chapter 39.19 RCW, the state of Washington encourages participation in all its contracts
by MWBE firms certified by the Office of Minority and Women's Business Enterprises (OMWBE). Voluntary
numerical MWBE participation goals have been established: Minority Business Enterprises (MBE's): 10%
and Women's Business Enterprises (WBE's): 6%.
36. VENUE
This Agreement shall be construed and enforced in accordance with, and the validity and performance shall
be governed by, the laws of the state of Washington and all applicable federal laws. Except as provided
otherwise herein, venue for any dispute between the parties arising out of this Agreement shall be in King
County, Washington.
37. WAIVERS
No conditions or provisions of this Agreement can be waived unless approved in advance by the
Organization in writing. The Organization's failure to insist upon strict performance of any provision of the
Agreement or to exercise any right based upon a breach thereof shall not constitute a waiver of any right
under this Agreement.
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ATTACHMENT C
DHS AWARD LETTER
Award Number: EMW-2026-WC-05005
The DHS Award Letter for Grant No. EMW-2026-WC-05005 is incorporated herein by reference. This award
consists of funding in the amount of $32,252,845.00 to the SeattleFWC26 as Recipient and Pass-through
Entity for the FY 2026 FIFA World Cup Grant Program.
Award LeƩer
U.S. Department of Homeland Security
Washington, D.C. 20472
EffecƟve date: 03/18/2026
Kathryn Zetzer
MILITARY DEPARTMENT, WASHINGTON STATE
BUILDING 1 MILITIA DR STATE FINANCIAL SERVICES CAMP MURRAY, WA
98430
EMW-2026-WC-05005
Dear Kathryn Zetzer,
CongratulaƟons on behalf of the Department of Homeland Security, your applicaƟon submiƩed for the FIFA World Cup
Grant Program, has been approved in the amount of $32,252,845.00 in Federal funding. This award of federal assistance
is executed as a Grant.
Before you request and receive any of the Federal funds awarded to you, you must establish acceptance of the award
through the FEMA Grants Outcomes (FEMA GO) system. By accepƟng this award, you acknowledge that the terms of the
following documents are incorporated into the terms of your award:
Award Summary - included in this document
Agreement ArƟcles - included in this document
ObligaƟng Document - included in this document
FIFA World Cup Grant Program (FWCGP) NoƟce of Funding Opportunity The Preparedness
Grant Manual (PGM)
Please make sure you read, understand, and maintain a copy of these documents in your official file for this award.
Sincerely,
David Gudinas
Deputy Assistant Administrator (AcƟng)
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Grant Programs Directorate | Resilience
Award Summary
Program: Fiscal Year 2026 FIFA World Cup Grant Program
Recipient: MILITARY DEPARTMENT, WASHINGTON STATE
UEI-EFT: D2EJRGZ2PLG8 Award number: EMW-
2026-WC-05005
Summary descripƟon of award
In 2026, the United States, Canada, and Mexico will host the 2026 World Cup. This event will be hosted across 11 ci Ɵes in
the United States with 78 U.S.-based matches making up an extensive series of highrisk events. The FIFA World Cup Grant
Program (FWCGP) makes funds available to host ciƟes through governor-designated State AdministraƟve Agencies (SAA),
to carry out the extensive security acƟviƟes required to protect players, staff, aƩendees, venues, and criƟcal
infrastructure across the host ciƟes strengthening them against potenƟal terrorist aƩacks.
Amount awarded table
The amount of the award is detailed in the aƩached ObligaƟng Document for Award.
The following are the budgeted esƟmates for object classes for this award (including Federal share plus your cost share, if
applicable):
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Approved scope of work
AŌer review of your applicaƟon, FEMA has approved the below scope of work. JusƟficaƟons are provided for any
differences between the scope of work in the original applicaƟon and the approved scope of work under this award. You
must submit scope or budget revision requests for FEMA's prior approval, via an amendment request, as appropriate per
2 C.F.R. § 200.308 and the FY2026 FWCGP NOFO.
Approved request details:
Investment
Developing and enhancing plans and protocols
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DESCRIPTION
Planning: Funds will support a mulƟ-agency effort to develop, refine, and exercise jurisdicƟonal
Concepts of OperaƟons (CONOPS) and venue specific security plans for SeaƩle’s six 2026 FIFA World Cup
matches and associated fan acƟviƟes. The planning and execuƟve steering commiƩees will conƟnue to
convene to guide work, resolve cross cuƫng issues, and conduct final reviews of all major planning
documents. JurisdicƟonal CONOPS and venue specific security plans will be finalized, approved, and tested
through exercises to ensure they are operaƟonally sound and to surface any residual gaps requiring
adjustments to plans, staffing, or mutual aid arrangements. Together, these completed and planned ac ƟviƟes
demonstrate why advance planning is essenƟal and how the region is systemaƟcally building the plans,
protocols, and assessments needed to deliver a safe and secure World Cup.
QUANTITY UNIT PRICE TOTAL
1 $1,838,174.00 $1,838,174.00
BUDGET CLASS
Other
OperaƟonal support
DESCRIPTION
OrganizaƟon: Funds will be used for operaƟonal overƟme for law enforcement and emergency responders,
overƟme and backfill for EOC/ICP/JIC/Fusion Center staff, EMAC/PNEMA mutual aid deployments, and staffing
to sustain mulƟ agency governance and coordinaƟon structures Ɵed to World Cup operaƟons.
QUANTITY UNIT PRICE TOTAL
1 $22,192,382.00 $22,192,382.00
BUDGET CLASS
Other
Other Authorized Equipment
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DESCRIPTION
Equipment: Planned and completed acƟviƟes for allowable equipment focus on hardening tournament
venues, supporƟng safe crowd movement, and enabling rapid response to emergencies, with equipment
deployed during defined World Cup operaƟonal periods. Based on venue assessments and security
planning, the jurisdicƟon is idenƟfying specific equipment and resource requirements needed to ensure
safe and secure tournament events at stadiums, fan acƟvaƟons, pracƟce faciliƟes, base camps, hotels, and
key transporta Ɵon nodes.
QUANTITY UNIT PRICE TOTAL
1 $6,309,647.00 $6,309,647.00
BUDGET CLASS
Other
Training workshops and conferences
DESCRIPTION
Training: Funds will support a mix of DHS/FEMA sponsored courses, specialized summits and conferences, and
World Cup–focused workshops that build the knowledge, skills, and partnerships needed to prepare for,
protect against, and respond to threats and emergencies during tournament operaƟons. Training acƟviƟes
will target law enforcement, fire/EMS, emergency management, public health, transportaƟon, and venue
security personnel who will play direct operaƟonal and planning roles for World Cup events.
QUANTITY UNIT PRICE TOTAL
1 $150,000.00 $150,000.00
BUDGET CLASS
Other
Hiring of full- or part-Ɵme staff or contractors/consultants to assist with the
management of the respecƟve grant program, applicaƟon requirements, and
compliance with reporƟng and data collecƟon requirements
Design, Develop, Conduct, and Evaluate an Exercise
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DESCRIPTION
Exercise: AcƟviƟes will test and strengthen mass casualty, stadium, and transportaƟon response plans that
support World Cup operaƟons, using allowable exercise costs to ensure each exercise is fully designed,
conducted, and evaluated in a standardized way. All exercises will be managed as Homeland Security Exercise
and EvaluaƟon Program (HSEEP)–compliant acƟviƟes to produce acƟonable aŌer-acƟon reports and
improvement plan that directly inform updates to plans, procedures, and training priori Ɵes. FWCGP funds will
provide flexibility to support addiƟonal HSEEP compliant exercises that are idenƟfied through ongoing
planning and operaƟonal needs, provided they align with FWCGP NOFO requirements.
QUANTITY UNIT PRICE TOTAL
1 $150,000.00 $150,000.00
BUDGET CLASS
Other
Agreement ArƟcles
Program: Fiscal Year 2026 FIFA World Cup Grant Program
Recipient: MILITARY DEPARTMENT, WASHINGTON STATE
UEI-EFT: D2EJRGZ2PLG8 Award number: EMW-
2026-WC-05005
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
19
Table of contents
ArƟcle Assurance, AdministraƟve Requirements, Cost Principles, RepresentaƟons, and
CerƟficaƟons
1
ArƟcle General Acknowledgements and Assurances
2
ArƟcle Acknowledgement of Federal Funding from DHS
3
ArƟcle AcƟviƟes Conducted Abroad
4
ArƟcle Age DiscriminaƟon Act of 1975 5
ArƟcle Americans with DisabiliƟes Act of 1990
6
ArƟcle Best PracƟces for CollecƟon and Use of Personally IdenƟfiable InformaƟon
7
ArƟcle CHIPS and Science Act of 2022, Public Law 117-167 CHIPS
8
ArƟcle Civil Rights Act of 1964 – Title VI
9
ArƟcle Civil Rights Act of 1968
10
ArƟcle CommunicaƟon and CooperaƟon with the Department of Homeland Security and
11
ImmigraƟon Officials
ArƟcle Copyright
12
ArƟcle Debarment and Suspension
13
ArƟcle Drug-Free Workplace RegulaƟons 14
ArƟcle DuplicaƟve Costs
15
ArƟcle EducaƟon Amendments of 1972 (Equal Opportunity in EducaƟon Act) – Title IX 16
ArƟcle Energy Policy and ConservaƟon Act 17
ArƟcle Equal Treatment of Faith-Based OrganizaƟons 18
ArƟcle AnƟ-DiscriminaƟon
19
ArƟcle False Claims Act and Program Fraud Civil Remedies 20
ArƟcle Federal Debt Status
21
ArƟcle Federal Leadership on Reducing Text Messaging while Driving 22
ArƟcle Fly America Act of 1974
23
ArƟcle Hotel and Motel Fire Safety Act of 1990 24
ArƟcle John S. McCain NaƟonal Defense AuthorizaƟon Act of Fiscal Year 2019 25
ArƟcle Limited English Proficiency (Civil Rights Act of 1964, Title VI) 26
ArƟcle Lobbying ProhibiƟons 27
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
20
ArƟcle NaƟonal Environmental Policy Act
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
21
28
ArƟcle NaƟonal Security PresidenƟal Memorandum-33 (NSPM-33) and provisions of the
29 CHIPS and Science Act of 2022, Pub. L. 117-167, SecƟon 10254
ArƟcle Non-SupplanƟng Requirement
30
ArƟcle NoƟce of Funding Opportunity Requirements
31
ArƟcle Patents and Intellectual Property Rights
32
ArƟcle PresidenƟal ExecuƟve Orders
33
ArƟcle Procurement of Recovered Materials
34
ArƟcle RehabilitaƟon Act of 1973
35
ArƟcle ReporƟng Recipient Integrity and Performance MaƩers
36
ArƟcle ReporƟng Subawards and ExecuƟve CompensaƟon 37
ArƟcle Required Use of American Iron, Steel, Manufactured Products, and ConstrucƟon
38 Materials
ArƟcle SAFECOM
39
ArƟcle Subrecipient Monitoring and Management
40
ArƟcle System for Award Management and Unique EnƟty IdenƟfier Requirements 41
ArƟcle TerminaƟon of a Federal Award
42
ArƟcle Terrorist Financing
43
ArƟcle Trafficking VicƟms ProtecƟon Act of 2000(TVPA)
44
ArƟcle UniƟng and Strengthening America by Providing Appropriate Tools Required to
45 Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001, Pub. L. 107-56
ArƟcle Use of DHS Seal, Logo and Flags
46
ArƟcle Whistleblower ProtecƟon Act
47
ArƟcle Environmental Planning and Historic PreservaƟon (EHP) Review 48
ArƟcle Applicability of DHS Standard Terms and CondiƟons to Tribal NaƟons 49
ArƟcle Acceptance of Post Award Changes
50
ArƟcle DisposiƟon of Equipment Acquired Under the Federal Award 51
ArƟcle Prior Approval for ModificaƟon of Approved Budget 52
ArƟcle Indirect Cost Rate
53
ArƟcle Build America, Buy America Act (BABAA) Required Contract Provision & Self54 CerƟficaƟon
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
22
ArƟcle Summary DescripƟon of Award 55
ArƟcle Non-Applicability of Specific Agreement ArƟcles 56
ArƟcle Non-Applicability of Specific Terms and Agreement ArƟcles Pursuant to County of 57 Santa Clara, et al.
v. Noem, et al.
ArƟcle Non-Applicability of Specific Terms and Agreement ArƟcles Pursuant to City of 58 Chicago et al.
v. Noem, et al.
ArƟcle Non-Applicability of Specific Terms and Agreement ArƟcles Pursuant to City of SeaƩle 59 v. Trump,
et al.
ArƟcle Expedited Review of Amendments 60
ArƟcle Reducing Pass-Through Time
61
ArƟcle ProhibiƟon on Covered Foreign Unmanned AircraŌ Systems (UAS) 62
ArƟcle Award Compliance Hold 63
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 1
Assurance, AdministraƟve Requirements, Cost Principles, RepresentaƟons, and CerƟficaƟons
I. Recipients must complete either the Office of Management and Budget (OMB)
Standard Form 424B Assurances – Non- ConstrucƟon Programs, or OMB Standard Form 424D
Assurances – ConstrucƟon Programs, as applicable. Certain assurances in these documents
may not be applicable to your program and the DHS financial assistance office (DHS FAO) may
require applicants to cerƟfy addiƟonal assurances.
Applicants are required to fill out the assurances, as instructed.
ArƟcle 2
General Acknowledgements and Assurances
Recipients are required to follow the applicable provisions of the Uniform
AdministraƟve Requirements, Cost Principles, and Audit Requirements for Federal
Awards in effect as of the federal award date and located in Title 2, Code of Federal
RegulaƟons, Part 200 and adopted by DHS at 2 C.F.R. § 3002.10. All recipients and
subrecipients must acknowledge and agree to provide DHS access to records, accounts,
documents, informaƟon, faciliƟes, and staff pursuant to 2 C.F.R. § 200.337. I. Recipients must
cooperate with any DHS compliance reviews or compliance invesƟgaƟons. II. Recipients must
give DHS access to examine and copy records, accounts, and other documents and sources of
informaƟon related to the federal award and permit access to faciliƟes and personnel. III.
Recipients must submit Ɵmely, complete, and accurate reports to the appropriate DHS
officials and maintain appropriate backup documentaƟon to support the reports. IV.
Recipients must comply with all other special repor Ɵng, data collecƟon, and evaluaƟon
requirements required by law, federal regulaƟon, NoƟce of Funding Opportunity, federal
award specific terms and condiƟons, and/or DHS Component program guidance.
OrganizaƟon costs related to data and evaluaƟon are allowable. The definiƟon of data and
evaluaƟon costs is in 2 C.F.R. § 200.455(c), the full text of which is incorporated by reference.
V. Recipients must complete DHS Form 3095 within 60 days of receipt of the NoƟce of Award
for the first award under which this term applies. For further instrucƟons and to access the
form, please visit: hƩps://www.dhs.gov/civil-rightsresources-recipientsdhs-financial-
assistance.
ArƟcle 3
Acknowledgement of Federal Funding from DHS
Recipients must acknowledge their use of federal award funding when issuing statements,
press releases, requests for proposal, bid invitaƟons, and other documents describing
projects or programs funded in whole or in part with federal award funds.
ArƟcle 4
AcƟviƟes Conducted Abroad
Recipients must coordinate with appropriate government authoriƟes when performing project
acƟviƟes outside the United States obtain all appropriate licenses, permits, or approvals.
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ArƟcle 5 Age DiscriminaƟon Act of 1975
Recipients must comply with the requirements of the Age DiscriminaƟon Act of 1975, Pub. L.
No. 94-135 (codified as amended at Title 42, U.S. Code § 6101 et seq.), which prohibits
discriminaƟon on the basis of age in any program or acƟvity receiving federal financial
assistance.
ArƟcle 6
Americans with DisabiliƟes Act of 1990
Recipients must comply with the requirements of Titles I, II, and III of the Americans with
DisabiliƟes Act, Pub. L. No. 101-336 (1990) (codified as amended at 42 U.S.C. §§ 12101–
12213), which prohibits recipients from discriminaƟng on the basis of disability in the
operaƟon of public enƟƟes, public and private transportaƟon systems, places of public
accommodaƟon, and certain tesƟng enƟƟes.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 7 Best PracƟces for CollecƟon and Use of Personally IdenƟfiable InformaƟon (1) Recipients
who collect personally idenƟfiable informaƟon (PII) as part of carrying out the scope of work
under a federal award are required to have a publicly available privacy policy that describes
standards on the usage and maintenance of the PII they collect. (2) DefiniƟon. DHS defines
“PII” as any informaƟon that permits the idenƟty of an individual to be directly or indirectly
inferred, including any informaƟon that is linked
or linkable to that individual. Recipients may also find the DHS Privacy Impact Assessments:
Privacy Guidance and Privacy Template as useful resources respecƟvely.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 8
CHIPS and Science Act of 2022, Public Law 117-167 CHIPS
(1) Recipients of DHS research and development (R&D) awards must report to the DHS
Component research program office any finding or determinaƟon of sex based and sexual
harassment and/or an administraƟve or disciplinary acƟon taken against principal
invesƟgators or co-invesƟgators to be completed by an authorized organizaƟonal
representaƟve (AOR) at the recipient insƟtuƟon. (2) NoƟficaƟon. An AOR must disclose the
following informaƟon to agencies within 10 days of the date/the finding is made, or 10 days
from when a recipient imposes an administraƟve acƟon on the reported individual,
whichever is sooner. Reports should include: (a)
Award number, (b) Name of PI or Co-PI being reported, (c) Awardee name, (d) Awardee
address, (e) AOR name, Ɵtle, phone, and email address, (f) IndicaƟon of the report type: (i)
Finding or determinaƟon has been made that the reported individual violated awardee
policies or codes of conduct, statutes, or regulaƟons related to sexual harassment, sexual
assault, or other forms of harassment, including the date that the finding was made. (ii)
ImposiƟon of an administraƟve or disciplinary acƟon by the recipient on the reporƟng
individual related to a finding/determinaƟon or an invesƟgaƟon of an alleged violaƟon of
recipient policy or codes of conduct, statutes, or regulaƟons, or other forms of harassment.
(iii) The date and nature of the
administraƟve/disciplinary acƟon, including a basic explanaƟon or descripƟon of the event,
which should not disclose personally idenƟfiable informaƟon regarding any complaints or
individuals involved. Any descripƟon provided must be consistent with the Family
EducaƟonal Rights in Privacy Act. (3) DefiniƟons. (a) An “authorized organizaƟonal
representaƟve (AOR)” is an administraƟve official who, on behalf of the proposing insƟtuƟon,
is empowered to make cerƟficaƟons and representaƟons and can commit the insƟtuƟon to
the conduct of a project that an agency is being asked to support as well as adhere to various
agency policies and award requirements. (b) “Principal invesƟgators and co-principal
invesƟgators” are award personnel supported by a grant, cooperaƟve agreement, or contract
under Federal law. (c) A “reported individual” refers to recipient personnel who have been
reported to a federal agency for potenƟal sexual harassment violaƟons. (d) “Sex based
harassment” means a form of sex discriminaƟon and includes harassment based on sex, sex
stereotypes, sex characterisƟcs, pregnancy or related condiƟons, sexual orientaƟon, and
gender idenƟty. (e) “Sexual harassment” means unwelcome sexual advances, requests for
sexual favors, and other verbal or physical conduct of a sexual nature when this conduct
explicitly or implicitly affects an individual’s employment, unreasonably interferes with an
individual’s work performance, or creates an inƟmidaƟng, hosƟle, or offensive work
environment, whether such acƟvity is carried out by a supervisor or by a co-worker,
volunteer, or contractor.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 9 Civil Rights Act of 1964 – Title VI
Recipients must comply with the requirements of Title VI of the Civil Rights Act of 1964, Pub.
L. No. 88-352 (codified as amended at 42 U.S.C. § 2000d et seq.), which provides that no
person in the United States will, on the grounds of race, color, or naƟonal origin, be excluded
from parƟcipaƟon in, be denied the benefits of, or be subjected to discriminaƟon under any
program or acƟvity receiving federal financial assistance. DHS implemenƟng regulaƟons for
the Act are found at 6 C.F.R. Part 21. Recipients of a federal award from the Federal
Emergency Management Agency
(FEMA) must also comply with FEMA’s implemenƟng regulaƟons at 44 C.F.R. Part 7.
ArƟcle 10
Civil Rights Act of 1968
Recipients must comply with Title VIII of the Civil Rights Act of 1968, Pub. L. No. 90284
(codified as amended at 42 U.S.C. § 3601 et seq.) which prohibits recipients from
discriminaƟng in the sale, rental, financing, and adver Ɵsing of dwellings, or in the provision
of services in connecƟon. therewith, on the basis of race, color, naƟonal origin, religion,
disability, familial status, and sex, as implemented by the U.S. Department of Housing and
Urban Development at 24 C.F.R. Part 100. The prohibiƟon on disability discriminaƟon
includes the requirement that new mulƟfamily housing with four or more dwelling units—
i.e., the public and common use areas and individual apartment units (all units in buildings
with elevators and ground-floor units in buildings without elevators)—be designed and
constructed with certain accessible features. (See 24 C.F.R. Part 100, Subpart D.)
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 11 CommunicaƟon and CooperaƟon with the Department of Homeland Security and
ImmigraƟon Officials
(1) All recipients and other recipients of funds under this award must agree that they will
comply with the following requirements related to coordinaƟon and cooperaƟon with the
Department of Homeland Security and immigraƟon officials: (a) They must comply with the
requirements of 8 U.S.C. §§ 1373 and 1644. These statutes prohibit restricƟons on
informaƟon sharing by state and local government enƟƟes with DHS regarding the ciƟzenship
or immigraƟon status, lawful or unlawful, of any individual. AddiƟonally, 8 U.S.C. § 1373
prohibits any person or agency from prohibiƟng, or in any way restricƟng, a Federal, State, or
local government enƟty from doing any of the following with respect to informaƟon
regarding the immigraƟon status of any individual: 1) sending such informaƟon to, or
requesƟng or receiving such informaƟon from, Federal immigraƟon officials; 2) maintaining
such informaƟon; or 3) exchanging such informaƟon with any other Federal, State, or local
government enƟty; (b) They must comply with other relevant laws related to immigraƟon,
including prohibiƟons on encouraging or inducing an alien to come to, enter, or reside in the
United States in violaƟon of law, 8 U.S.C. § 1324(a)(1)(A)(iv), prohibiƟons on transporƟng or
moving illegal aliens, 8 U.S.C. § 1324(a)(1)(A)(ii), prohibi Ɵons on harboring, concealing, or
shielding from detecƟon illegal aliens, 8 U.S.C. § 1324(a)(1)(A)(iii), and any applicable
conspiracy, aiding or abeƫng, or aƩempt liability regarding these statutes; (c) That they will
honor requests for cooperaƟon, such as parƟcipaƟon in joint operaƟons, sharing of
informaƟon, or requests for short term detenƟon of an alien pursuant to a valid detainer. A
jurisdicƟon does not fail to comply with this requirement merely because it lacks the
necessary resources to assist in a parƟcular instance; (d) That they will provide access to
detainees, such as when an immigraƟon officer seeks to interview a person who might be a
removable alien; and (e) That they will not leak or otherwise publicize the existence of an
immigraƟon enforcement operaƟon. (2) The recipient must cerƟfy under penalty of perjury
pursuant to 28 U.S.C. § 1746 and using a form that is acceptable to DHS, that it will comply
with the requirements of this term. AddiƟonally, the recipient agrees that it will require any
subrecipients or contractors to cerƟfy in the same manner that they will comply with this
term prior to providing them with any funding under this award. (3) The recipient agrees that
compliance with this term is material to the Government’s decision to make or con Ɵnue with
this award and that the Department of homeland Security may terminate this grant, or take
any other allowable enforcement acƟon, if the recipient fails to comply with this term.
ArƟcle 12
Copyright
Recipients must affix the applicable copyright no Ɵces of 17 U.S.C. §§ 401 or 402 to any work
first produced under federal awards and also include an acknowledgement that the work was
produced under a federal award (including the federal award number and federal awarding
agency). As detailed in 2 C.F.R. § 200.315, a federal awarding agency reserves a royalty-free,
nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for
federal purposes and to authorize others to do so.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 13 Debarment and Suspension
Recipients must comply with the non-procurement debarment and suspension regulaƟons
implemenƟng ExecuƟve Orders 12549 and 12689 set forth at 2 C.F.R. Part 180 as
implemented by DHS at 2 C.F.R. Part 3000. These regulaƟons prohibit recipients from
entering into covered transacƟons (such as subawards and contracts) with certain parƟes
that are debarred, suspended, or otherwise excluded from or ineligible for parƟcipaƟon in
federal assistance programs or acƟviƟes.
ArƟcle 14
Drug-Free Workplace RegulaƟons
Recipients must comply with drug-free workplace requirements in Subpart B (or
Subpart C, if the recipient is an individual) of 2 C.F.R. Part 3001, which adopts the
Government- wide implementaƟon (2 C.F.R. Part 182) of the Drug-Free Workplace Act of
1988 (41 U.S.C. §§ 8101-8106).
ArƟcle 15
DuplicaƟve Costs
Recipients are prohibited from charging any cost to this federal award that will be included as
a cost or used to meet cost sharing requirements of any other federal award in either the
current or a prior budget period. See 2 C.F.R. § 200.403(f). However, recipients may shiŌ costs
that are allowable under two or more federal awards where otherwise permiƩed by federal
statutes, regulaƟons, or the federal award terms and condiƟons.
ArƟcle 16
EducaƟon Amendments of 1972 (Equal Opportunity in EducaƟon Act) – Title IX
Recipients must comply with the requirements of Title IX of the EducaƟon
Amendments of 1972, Pub. L. No. 92-318 (codified as amended at 20 U.S.C. § 1681 et seq.),
which provide that no person in the United States will, on the basis of sex, be excluded from
parƟcipaƟon in, be denied the benefits of, or be subjected to discriminaƟon under any
educaƟonal program or acƟvity receiving federal financial assistance. DHS implemenƟng
regulaƟons are codified at 6 C.F.R. Part 17. Recipients of a federal award from the Federal
Emergency Management Agency (FEMA) must also comply with FEMA’s implemenƟng
regulaƟons at 44 C.F.R. Part 19.
ArƟcle 17 Energy Policy and ConservaƟon Act
Recipients must comply with the requirements of the Energy Policy and Conserva Ɵon Act, Pub.
L. No. 94-163 (1975) (codified as amended at 42 U.S.C. § 6201 et seq.), which contain policies
relaƟng to energy efficiency that are defined in the state energy conservaƟon plan issued in
compliance with this Act.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 18
Equal Treatment of Faith-Based OrganizaƟons
It is DHS policy to ensure the equal treatment of faith-based organizaƟons in social service
programs administered or supported by DHS or its component agencies, enabling those
organizaƟons to parƟcipate in providing important social services to beneficiaries. Recipients
must comply with the equal treatment policies and requirements contained in 6 C.F.R. Part 19
and other applicable statutes, regulaƟons, and guidance governing the parƟcipaƟons of faith-
based organizaƟons in individual DHS programs.
ArƟcle 19
AnƟ-DiscriminaƟon
Recipients must comply with all applicable Federal anƟ-discriminaƟon laws material to the
government’s payment decisions for purposes of 31 U.S.C. § 372(b)(4). (1) DefiniƟons. As
used in this clause – (a) DEI means “diversity, equity, and inclusion.” (b) DEIA means
“diversity, equity, inclusion, and accessibility.” (c) Discriminatory equity ideology has the
meaning set forth in SecƟon 2(b) of ExecuƟve Order 14190 of January 29, 2025. (d) Federal
anƟ-discriminaƟon laws mean Federal civil rights law that protect individual Americans from
discriminaƟon on the basis of race, color, sex, religion, and naƟonal origin. (e) Illegal
immigrant means any alien, as defined in 8 U.S.C. § 1101(a)(3), who has no lawful
immigraƟon status in the United States.(2) Grant award cerƟficaƟon. (a) By accepƟng the
grant award, recipients are cerƟfying that: (i) They do not, and will not during the term of this
financial assistance award, operate any programs that advance or promote DEI, DEIA, or
discriminatory equity ideology in violaƟon of Federal anƟ-discriminaƟon laws; and (ii) They
do not engage in and will not during the term of this award engage in, a discriminatory
prohibited boycoƩ. (iii) They do not, and will not during the term of this award, operate any
program that benefits illegal immigrants or incenƟvizes illegal immigraƟon. (3) DHS reserves
the right to suspend payments in whole or in part and/or terminate financial assistance
awards if the Secretary of Homeland Security or her designee determines that the recipient
has violated any provision of subsecƟon (2). (4) Upon suspension or terminaƟon under
subsecƟon (3), all funds received by the recipient shall be deemed to be in excess of the
amount that the recipient is determined to be enƟtled to under the Federal award for
purposes of 2 C.F.R. § 200.346. As such, all amounts received will cons Ɵtute a debt to the
Federal Government that may be pursued to the maximum extent permiƩed by law.
ArƟcle 20
False Claims Act and Program Fraud Civil Remedies
Recipients must comply with the requirements of the False Claims Act, 31 U.S.C. §§ 3729-
3733, which prohibit the submission of false or fraudulent claims for payment to the Federal
Government. (See 31 U.S.C. §§ 3801-3812, which details the administraƟve remedies for false
claims and statements made.)
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ArƟcle 21 Federal Debt Status
All recipients are required to be non-delinquent in their repayment of any federal debt.
Examples of relevant debt include delinquent payroll and other taxes, audit disallowances, and
benefit overpayments. See OMB Circular A-129.
ArƟcle 22
Federal Leadership on Reducing Text Messaging while Driving
Recipients are encouraged to adopt and enforce policies that ban text messaging while
driving recipient-owned, recipient-rented, or privately owned vehicles when on official
government business or when performing any work for or on behalf of the Federal
Government. Recipients are also encouraged to conduct the ini ƟaƟves of the type described
in SecƟon 3(a) of ExecuƟve Order 13513.
ArƟcle 23
Fly America Act of 1974
Recipients must comply with Preference for U.S. Flag Air Carriers (a list of cer Ɵfied air carriers
can be found at: CerƟficated Air Carriers List | US Department of
TransportaƟon, hƩps://www.transportaƟon.gov/policy/aviaƟon-policy/cerƟficatedaircarriers-
list)for internaƟonal air transportaƟon of people and property to the extent that such service
is available, in accordance with the InternaƟonal Air TransportaƟon Fair CompeƟƟve PracƟces
Act of 1974, 49 U.S.C. § 40118, and the interpretaƟve guidelines issued by the Comptroller
General of the United States in the March 31, 1981, amendment to Comptroller General
Decision B-138942.
ArƟcle 24
Hotel and Motel Fire Safety Act of 1990
Recipients must ensure that all conference, meeƟng, convenƟon, or training space funded
enƟrely or in part by federal award funds complies with the fire prevenƟon and control
guidelines of SecƟon 6 of the Hotel and Motel Fire Safety Act of 1990, 15 U.S.C. § 2225a.
ArƟcle 25
John S. McCain NaƟonal Defense AuthorizaƟon Act of Fiscal Year 2019
Recipients, subrecipients, and their contractors and subcontractors are subject to the
prohibiƟons described in secƟon 889 of the John S. McCain NaƟonal Defense AuthorizaƟon
Act for Fiscal Year 2019, Pub. L. No. 115-232 (2018) and 2 C.F.R. §§ 200.216, 200.327, 200.471,
and Appendix II to 2 C.F.R. Part 200. The statute – as it applies to DHS recipients, subrecipients,
and their contractors and subcontractors – prohibits obligaƟng or expending federal award
funds on certain telecommunicaƟons and video surveillance products and contrac Ɵng with
certain enƟƟes for naƟonal security reasons.
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ArƟcle 26 Limited English Proficiency (Civil Rights Act of 1964, Title VI)
Recipients must comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.)
prohibiƟon against discriminaƟon on the basis of naƟonal origin, which requires that
recipients of federal financial assistance take reasonable steps to provide meaningful access
to persons with limited English proficiency (LEP) to their programs and services. For
addiƟonal assistance and informaƟon regarding language access obligaƟons, please refer to
the DHS Recipient Guidance:
hƩps://www.dhs.gov/guidance-published-help- department-supportedorganizaƟonsprovide-
meaningful-access-people-limited and addiƟonal resources on hƩp://www.lep.gov.
ArƟcle 27
Lobbying ProhibiƟons
Recipients must comply with 31 U.S.C. § 1352 and 6 C.F.R. Part 9, which provide that none of
the funds provided under a federal award may be expended by the recipient to pay any
person to influence, or aƩempt to influence an officer or employee of any agency, a Member
of Congress, an officer or employee of Congress, or an employee of a Member of Congress in
connecƟon with any federal acƟon related to a federal award or contract, including any
extension, conƟnuaƟon, renewal, amendment, or modificaƟon. Per 6 C.F.R. Part 9, recipients
must file a lobbying cerƟficaƟon form as described in Appendix A to 6 C.F.R. Part 9 or
available on Grants.gov as the Grants.gov Lobbying Form and file a lobbying disclosure form
as described in Appendix B to 6 C.F.R. Part 9 or available on Grants.gov as the Disclosure of
Lobbying AcƟviƟes (SF-LLL).
ArƟcle 28
NaƟonal Environmental Policy Act
Recipients must comply with the requirements of the NaƟonal Environmental Policy Act of
1969, Pub. L. No. 91-190 (1970) (codified as amended at 42 U.S.C. § 4321 et seq.) (NEPA) and
the Council on Environmental Quality (CEQ) RegulaƟons for ImplemenƟng the Procedural
Provisions of NEPA, which require recipients to use all pracƟcable means within their
authority, and consistent with other essenƟal consideraƟons of naƟonal policy, to create and
maintain condiƟons under which people and nature can exist in produc Ɵve harmony and
fulfill the social, economic, and other needs of present and future generaƟons of Americans.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ArƟcle 29
NaƟonal Security PresidenƟal Memorandum-33 (NSPM-33) and provisions of the CHIPS and
Science Act of 2022, Pub. L. 117-167, SecƟon 10254
(1) Recipient research insƟtuƟons (“covered insƟtuƟons”) must comply with the requirements
in NSPM-33 and provisions of Pub. L.117-167, SecƟon 10254 (codified at 42 U.S.C. § 18951)
cerƟfying that the insƟtuƟon has established and operates a research security program that
includes elements relaƟng to: (a) cybersecurity; (b) foreign travel security; (c) research security
training; and (d) export control training, as appropriate. (2) Defini Ɵon. “Covered insƟtuƟons”
means recipient research insƟtuƟons receiving federal Research and Development (R&D)
science and engineering support
“in excess of $50 million per year.”
ArƟcle 30
Non-SupplanƟng Requirement
Recipients of federal awards under programs that prohibit supplanƟng by law must ensure
that federal funds supplement but do not supplant non-federal funds that, in the absence of
such federal funds, would otherwise have been made available for the same purpose.
ArƟcle 31 NoƟce of Funding Opportunity Requirements
All the instrucƟons, guidance, limitaƟons, scope of work, and other condiƟons set forth in
the NoƟce of Funding Opportunity (NOFO) for this federal award are incorporated by
reference. All recipients must comply with any such requirements set forth in the NOFO. If a
condiƟon of the NOFO is inconsistent with these terms and condiƟons and any such terms of
the federal award, the condiƟon in the NOFO shall be invalid to the extent of the
inconsistency. The remainder of that condiƟon and all other condiƟons set forth in the NOFO
shall remain in effect.
ArƟcle 32
Patents and Intellectual Property Rights
Recipients are subject to the Bayh-Dole Act, 35 U.S.C. § 200 et seq. and applicable regulaƟons
governing invenƟons and patents, including the regulaƟons issued by the
Department of Commerce at 37 C.F.R. Part 401 (Rights to InvenƟons Made by
Nonprofit OrganizaƟons and Small Business Firms under Government Awards, Contracts, and
CooperaƟve Agreements) and the standard patent rights clause set forth at 37 C.F.R. § 401.14.
ArƟcle 33
PresidenƟal ExecuƟve Orders
Recipients must comply with the requirements of PresidenƟal ExecuƟve Orders related to
grants (also known as federal assistance and financial assistance), the full text of which are
incorporated by reference.
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ArƟcle 34 Procurement of Recovered Materials
States, poliƟcal subdivisions of states, and their contractors must comply with Sec Ɵon
6002 of the Solid Waste Disposal Act, Pub. L. No. 89-272 (1965) (codified as
amended by the Resource ConservaƟon and Recovery Act at 42 U.S.C. § 6962) and 2 C.F.R. §
200.323. The requirements of SecƟon 6002 include procuring only items designated in
guidelines of the Environmental ProtecƟon Agency (EPA) at 40 C.F.R. Part 247 that contain the
highest percentage of recovered materials pracƟcable, consistent with maintaining a
saƟsfactory level of compeƟƟon.
ArƟcle 35
RehabilitaƟon Act of 1973
Recipients must comply with the requirements of SecƟon 504 of the RehabilitaƟon Act of
1973, Pub. L. No. 93-112 (codified as amended at 29 U.S.C. § 794), which provides that no
otherwise qualified handicapped individuals in the United States will, solely by reason of the
handicap, be excluded from parƟcipaƟon in, be denied the benefits of, or be subjected to
discriminaƟon under any program or acƟvity receiving federal financial assistance.
ArƟcle 36 Repor Ɵng Recipient Integrity and Performance MaƩers
If the total value of any currently acƟve grants, cooperaƟve agreements, and procurement
contracts from all federal awarding agencies exceeds $10,000,000 for any period of Ɵme
during the period of performance of the federal award, then the recipient must comply with
the requirements set forth in the government-wide federal award term and condiƟon for
Recipient Integrity and Performance MaƩers is in 2 C.F.R. Part 200, Appendix XII, the full text
of which is incorporated by reference.
ArƟcle 37 Repor Ɵng Subawards and ExecuƟve CompensaƟon
For federal awards that total or exceed $30,000, recipients are required to comply with the
requirements set forth in the government-wide federal award term and condiƟon on
ReporƟng Subawards and ExecuƟve CompensaƟon set forth at 2 C.F.R. Part 170, Appendix A,
the full text of which is incorporated by reference.
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ArƟcle 38
Required Use of American Iron, Steel, Manufactured Products, and ConstrucƟon Materials
(1) Recipients of a federal award from a financial assistance program that provides funding
for infrastructure are hereby noƟfied that none of the funds provided under this federal
award may be used for a project for infrastructure unless: (a) all iron and steel used in the
project are produced in the United States—this means all manufacturing processes, from the
iniƟal melƟng stage through the applicaƟon of coaƟngs, occurred in the United States; (b) all
manufactured products used in the project are produced in the United States—this means
the manufactured product was manufactured in the United States; and the cost of the
components of the manufactured product that are mined, produced, or manufactured in the
United States is greater than 55 percent of the total cost of all components of the
manufactured product, unless another standard for determining the minimum amount of
domesƟc content of the manufactured product has been established under applicable law or
regulaƟon; and (c) all construcƟon materials are manufactured in the United States—this
means that all manufacturing processes for the construcƟon material occurred in the United
States. (2) The Buy America preference only applies to arƟcles, materials, and supplies that
are consumed in, incorporated into, or affixed to an infrastructure project. As such, it does
not apply to tools, equipment, and supplies, such as temporary scaffolding, brought to the
construcƟon site and removed at or before the compleƟon of the infrastructure project. Nor
does a Buy America preference apply to equipment and furnishings, such as movable chairs,
desks, and portable computer equipment, that are used at or within the finished
infrastructure project but are not an integral part of the structure or permanently affixed to
the infrastructure project. (3) Waivers When necessary, recipients may apply for, and the
agency may grant, a waiver from these requirements. The agency should noƟfy the recipient
for informaƟon on the process for requesƟng a waiver from these requirements. (a) When
the Federal agency has determined that one of the following excepƟons applies, the federal
awarding official may waive the applicaƟon of the domesƟc content procurement preference
in any case in which the agency determines that: (i) applying the domesƟc content
procurement preference would be inconsistent with the public interest; (ii) the types of iron,
steel, manufactured products, or construcƟon materials are not produced in the United
States in sufficient and reasonably available quanƟƟes or of a saƟsfactory quality; or (iii) the
inclusion of iron, steel, manufactured products, or construcƟon materials produced in the
United States will increase the cost of the overall project by more than 25 percent. (b) A
request to waive the applicaƟon of the domesƟc content procurement preference must be in
wriƟng. The agency will provide instrucƟons on the format, contents, and supporƟng
materials required for any waiver request. Waiver requests are subject to public comment
periods of no less than 15 days and must be reviewed by the Made in America Office. (c)
There may be instances where a federal award qualifies, in whole or in part, for an exisƟng
waiver described at “Buy America” Preference in FEMA Financial Assistance Programs for
Infrastructure | FEMA.gov. (4) DefiniƟons. The definiƟons applicable to this term are set forth
at 2 C.F.R. § 184.3, the full text of which is incorporated by reference.
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ArƟcle 39 SAFECOM
Recipients receiving federal awards made under programs that provide emergency
communicaƟon equipment and its related acƟviƟes must comply with the SAFECOM Guidance
for Emergency CommunicaƟon Grants, including provisions on technical standards that ensure
and enhance interoperable communicaƟons. The SAFECOM
Guidance is updated annually and can be found at Funding and Sustainment | CISA.
ArƟcle 40
Subrecipient Monitoring and Management
Pass-through enƟƟes must comply with the requirements for subrecipient monitoring and
management as set forth in 2 C.F.R. §§ 200.331-333.
ArƟcle 41
System for Award Management and Unique EnƟty IdenƟfier Requirements Recipients are
required to comply with the requirements set forth in the
governmentwide federal award term and condiƟon regarding the System for Award
Management and Unique EnƟty IdenƟfier Requirements in 2 C.F.R. Part 25, Appendix A, the
full text of which is incorporated reference.
ArƟcle 42
TerminaƟon of a Federal Award
(1) By DHS. DHS may terminate a federal award, in whole or in part, for the following reasons:
(a) If the recipient fails to comply with the terms and condi Ɵons of the federal award; (b)
With the consent of the recipient, in which case the par Ɵes must agree upon the terminaƟon
condiƟons, including the effecƟve date, and in the case of parƟal terminaƟon, the porƟon to
be terminated; or (c) Pursuant to the terms and condiƟons of the federal award, including, to
the extent authorized by law, if the federal award no longer effectuates the program goals or
agency prioriƟes. (3) By the Recipient. The recipient may terminate the federal award, in
whole or in part, by sending wriƩen noƟficaƟon to DHS staƟng the reasons for such
terminaƟon, the effecƟve date, and in the case of parƟal terminaƟon, the porƟon to be
terminated. However, if DHS determines that the remaining porƟon of the federal award will
not accomplish the purposes for which the federal award was made, DHS may terminate the
federal award in its enƟrety. (4) NoƟce. Either party will provide wriƩen noƟce of intent to
terminate for any reason to the other party no less than 30 calendar days prior to the
effecƟve date of the terminaƟon. (5) Compliance with Closeout Requirements for Terminated
Awards. The recipient must conƟnue to comply with closeout requirements in 2 C.F.R. §§
200.344200.345 aŌer an award is terminated.
ArƟcle 43
Terrorist Financing
Recipients must comply with ExecuƟve Order 13224 and applicable statutory prohibiƟons on
transacƟons with, and the provisions of resources and support to, individuals and
organizaƟons associated with terrorism. Recipients are legally responsible for ensuring
compliance with the ExecuƟve Order and laws.
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ArƟcle 44
Tra fficking VicƟms ProtecƟon Act of 2000(TVPA)
Recipients must comply with the requirements of the government-wide federal award term
and condiƟon which implements Trafficking VicƟms ProtecƟon Act of 2000, Pub. L. No. 106-
386, § 106 (codified as amended at 22 U.S.C. § 7104). The federal award term and condiƟon
is in 2 C.F.R. § 175.105, the full text of which is incorporated by reference.
ArƟcle 45 UniƟng and Strengthening America by Providing Appropriate Tools Required to Intercept
and Obstruct Terrorism (USA PATRIOT) Act of 2001, Pub. L. 10756
Recipients must comply with the requirements of Pub. L. 107-56, SecƟon 817 of the USA
PATRIOT Act, which amends 18 U.S.C. §§ 175–175c.
ArƟcle 46
Use of DHS Seal, Logo and Flags
Recipients must obtain wriƩen permission from DHS prior to using the DHS seals, logos, crests,
or reproducƟons of flags, or likenesses of DHS agency officials. This includes use of DHS
component (e.g., FEMA, CISA, etc.) seals, logos, crests, or reproduc Ɵons of flags, or likenesses
of component officials.
ArƟcle 47
Whistleblower ProtecƟon Act
Recipients must comply with the statutory requirements for whistleblower protecƟons in 10
U.S.C § 470141 U.S.C. § 4712.
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ArƟcle 48 Environmental Planning and Historic PreservaƟon (EHP) Review DHS/FEMA funded
acƟviƟes that could have an impact on the environment are subject to the FEMA EHP
review process. This review does not address all federal, state, and local requirements.
Acceptance of federal funding requires the recipient to comply with all federal, state, and
local laws. DHS/FEMA is required to consider the potenƟal impacts to natural and cultural
resources of all projects funded by DHS/FEMA grant funds, through its EHP review process,
as mandated by: the
NaƟonal Environmental Policy Act; Endangered Species Act; NaƟonal Historic
PreservaƟon Act of 1966, as amended; Clean Water Act; Clean Air Act; NaƟonal Flood
Insurance Program regulaƟons; and any other applicable laws, regulaƟons and execuƟve
orders. General guidance for FEMA’s EHP process is available on the DHS/FEMA Website.
Specific applicant guidance on how to submit informaƟon for EHP review depends on the
individual grant program. Applicants should contact their grant Program Officer to be put
into contact with EHP staff responsible for assisƟng their specific grant program. The FEMA
EHP review process must be completed before funds are released to carry out the proposed
project, otherwise, DHS/FEMA may not be able to fund the project due to noncompliance
with EHP laws, execuƟve orders, regulaƟons, and policies. DHS/FEMA may also need to
perform a project closeout review to ensure the applicant complied with all required EHP
condiƟons idenƟfied in the iniƟal review. If ground disturbing acƟviƟes occur during
construcƟon, the applicant will monitor the ground disturbance, and if any potenƟal
archaeological resources are discovered, the applicant will immediately cease work in that
area and noƟfy the pass-through enƟty, if applicable, and DHS/FEMA. EO 11988, Floodplain
Management, and EO 11990, ProtecƟon of Wetlands, require that all federal acƟons in or
affecƟng the floodplain or wetlands be reviewed for opportuniƟes to relocate, and be
evaluated for social, economic, historical, environmental, legal, and safety consideraƟons.
FEMA’s regulaƟons at 44 C.F.R. Part 9 implement the EOs and require an eight-step review
process if a proposed acƟon is in a floodplain or wetland or has the potenƟal to affect or be
affected by a floodplain or wetland. The regulaƟon also requires that the federal agency
provide public noƟce of the proposed acƟon at the earliest possible Ɵme to provide the
opportunity for public involvement in the decision-making process (44 C.F.R. § 9.8). Where
there is no opportunity to relocate the federal acƟon, FEMA is required to undertake a
detailed review to determine what measures can be taken to minimize future damages to
the floodplain or wetland.
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ArƟcle 49
Applicability of DHS Standard Terms and CondiƟons to Tribal NaƟons The DHS Standard
Terms and CondiƟons are a restatement of general requirements imposed upon recipients
and flow down to sub-recipients as a maƩer of law, regulaƟon, or execuƟve order. If the
requirement does not apply to Tribal NaƟons, or there is a federal law or regulaƟon
exempƟng its applicaƟon to Tribal NaƟons, then the acceptance by Tribal NaƟons, or
acquiescence to DHS Standard Terms and
CondiƟons does not change or alter its inapplicability to a Tribal NaƟon. The execuƟon of grant
documents is not intended to change, alter, amend, or impose addiƟonal liability or
responsibility upon the Tribal NaƟons where it does not already exist.
ArƟcle 50
Acceptance of Post Award Changes
In the event FEMA determines that an error in the award package has been made, or if an
administraƟve change must be made to the award package, recipients will be noƟfied of the
change in wriƟng. Once the noƟficaƟon has been made, any subsequent requests for funds
will indicate recipient acceptance of the changes to the award. Please email FEMA Grant
Management OperaƟons at: ASK-GMD@fema.dhs.gov for any quesƟons.
ArƟcle 51
DisposiƟon of Equipment Acquired Under the Federal Award
When original or replacement equipment acquired under this award is no longer needed for
the original project or program or for other acƟviƟes currently or previously supported by a
federal awarding agency, the non-state recipient or subrecipient (including subrecipients of a
State or Tribal NaƟon), must request instrucƟons from
FEMA to make proper disposiƟon of the equipment pursuant to 2 C.F.R. secƟon 200.313(e).
State recipients must follow the disposiƟon requirements in accordance with State laws and
procedures. 2 C.F.R. secƟon 200.313(b). Tribal NaƟons must follow the disposiƟon
requirements in accordance with Tribal laws and procedures noted in 2 C.F.R. secƟon
200.313(b); and if such laws and procedures do not exist, then Tribal NaƟons must follow the
disposiƟon instrucƟons in 2 C.F.R. secƟon 200.313(e).
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ArƟcle 52 Prior Approval for ModificaƟon of Approved Budget
Before making any change to the FEMA approved budget for this award, a wriƩen request
must be submiƩed and approved by FEMA as required by 2 C.F.R. secƟon 200.308. For
purposes of non-construcƟon projects, FEMA is uƟlizing its discreƟon to impose an addiƟonal
restricƟon under 2 C.F.R. secƟon 200.308(i) regarding the transfer of funds among direct cost
categories, programs, funcƟons, or acƟviƟes. For awards with an approved budget where the
federal share is greater than the simplified acquisiƟon threshold (currently $250,000) and
where the cumulaƟve amount of such transfers exceeds or is expected to exceed ten percent
(10%) of the total budget FEMA last approved, transferring funds among direct cost
categories, programs, funcƟons, or acƟviƟes is unallowable without prior wriƩen approval
from FEMA. For purposes of awards that support both construcƟon and non-construcƟon
work, 2 C.F.R. secƟon 200.308((f)(9) requires the recipient to obtain prior wriƩen approval
from FEMA before making any fund or budget transfers between the two types of work. Any
deviaƟons from a FEMA approved budget must be reported in the first Federal Financial
Report (SF-425) that is submiƩed following any budget deviaƟon, regardless of whether the
budget deviaƟon requires prior wriƩen approval.
ArƟcle 53
Indirect Cost Rate
2 C.F.R. secƟon 200.211(b)(16) requires the terms of the award to include the indirect cost rate
for the federal award. If applicable, the indirect cost rate for the award is stated in the budget
documents or other materials approved by FEMA and included in the award file.
ArƟcle 54
Build America, Buy America Act (BABAA) Required Contract Provision & SelfCerƟficaƟon
In addiƟon to the DHS Standard Terms & CondiƟons regarding Required Use of American Iron,
Steel, Manufactured Products, and ConstrucƟon Materials, recipients and subrecipients of
FEMA financial assistance for programs that are subject to BABAA must include a Buy America
preference contract provision as noted in 2
C.F.R. secƟon 184.4 and a self-cerƟficaƟon as required by the FEMA Buy America
Preference in FEMA Financial Assistance Programs for Infrastructure (FEMA Interim Policy
#207-22-0001). This requirement applies to all subawards, contracts, and purchase orders for
work performed, or products supplied under the FEMA award subject to BABAA.
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ArƟcle 55
Summary DescripƟon of Award
The purpose of the FY 2026 FWCGP is to enhance security and preparedness for the 2026 FIFA
World Cup events in the United States. This standalone grant program supports the safe
execuƟon of the largest sporƟng event in history, co-hosted with Canada and Mexico, which is
expected to aƩract over five million internaƟonal visitors and generate tens of billions of
dollars in economic acƟvity across 11 U.S. host ciƟes over 38 days. The program addresses
significant security challenges, with all 78 U.S.based matches designated as Special Event
Assessment RaƟng (SEAR) I and II events, building on historical federal support for major
events like the Olympics. This FWCGP award consists of funding in the amount of
$32,252,845.00. This grant program funds a range of acƟviƟes, including planning,
organizaƟon, equipment purchase, training, exercises, and management and administraƟon.
ArƟcle 56 Non-Applicability of Specific Agreement ArƟcles
Notwithstanding their inclusion in this award package, the following Agreement
ArƟcles do not apply to this grant award: 1. CommunicaƟon and CooperaƟon with the
Department of Homeland Security and ImmigraƟon Officials. 2. Paragraph (2)(a)(iii) of AnƟ-
DiscriminaƟon. 3. TerminaƟon of a Federal Award This provision is consistent with the terms
of the NoƟce of Funding Opportunity which state that Paragraphs C.IX (CommunicaƟon and
CooperaƟon with the Department of Homeland Security and ImmigraƟon Officials),
C.XVII(2)(a)(iii) (AnƟ-DiscriminaƟon Grant Award CerƟficaƟon regarding immigraƟon), and
C.XL (TerminaƟon of a Federal Award) of the FY 2025 DHS Standard Terms and CondiƟons do
not apply to this award.
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ArƟcle 57
Non-Applicability of Specific Terms and Agreement ArƟcles Pursuant to County of Santa
Clara, et al. v. Noem, et al.
Pursuant to the preliminary injuncƟon order issued on November 21, 2025, in County of
Santa Clara et al. v. Noem, et al., No. 25-cv-08330-WHO (N.D. Cal.), the following terms and
condiƟons do not apply to awards or subawards issued to any of the plainƟffs subject to the
preliminary injuncƟon order while the order remains in effect: (1) SecƟon C.XVII of the DHS
Standard Terms and CondiƟons Ɵtled "AnƟ-
DiscriminaƟon" and the Agreement ArƟcle Ɵtled “AnƟ-DiscriminaƟon” in this award package;
and (2) SecƟon C.XXXI of the DHS Standard Terms and CondiƟons Ɵtled
"PresidenƟal ExecuƟve Orders" and the Agreement ArƟcle Ɵtled “PresidenƟal ExecuƟve
Orders” in this award package. If the preliminary injuncƟon is stayed, vacated, or
exƟnguished, SecƟon C.XVII of the DHS Standard Terms and CondiƟons Ɵtled "AnƟ-
DiscriminaƟon", the “AnƟ-DiscriminaƟon” Agreement ArƟcle, SecƟon C.XXXI of the DHS
Standard Terms and CondiƟons Ɵtled "PresidenƟal ExecuƟve Orders," and the Agreement
ArƟcle Ɵtled “PresidenƟal ExecuƟve Orders” will immediately become effecƟve. As stated in
the Agreement ArƟcle Ɵtled “NonApplicability of Specific Agreement ArƟcles, Paragraph
2(a)(iii) of the “AnƟDiscriminaƟon” Agreement ArƟcle and Paragraph 2(a)(iii) of SecƟon C.XVII
of the DHS Standard Terms and CondiƟons will not apply even if the preliminary injuncƟon is
stayed, vacated, or exƟnguished.
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ArƟcle 58 Non-Applicability of Specific Terms and Agreement ArƟcles Pursuant to City of Chicago et al.
v. Noem, et al.
Pursuant to the preliminary injuncƟon order issued on November 21, 2025, in City of Chicago
et al. v. Noem, et al., No. 25-CV-12765 (N.D. Ill.), the following terms and condiƟons do not
apply to awards or subawards issued to any of the plainƟffs subject to the preliminary
injuncƟon order while the order remains in effect: (1) SecƟon C.XVII of the DHS Standard
Terms and CondiƟons Ɵtled "AnƟ-DiscriminaƟon" and the Agreement ArƟcle Ɵtled “AnƟ-
DiscriminaƟon” in this award package; and (2) SecƟon
C.XXXI of the DHS Standard Terms and CondiƟons Ɵtled "PresidenƟal ExecuƟve Orders" and
the Agreement ArƟcle Ɵtled “PresidenƟal ExecuƟve Orders” in this award package. If the
preliminary injuncƟon is stayed, vacated, or exƟnguished, SecƟon C.XVII of the DHS Standard
Terms and CondiƟons Ɵtled "AnƟ-DiscriminaƟon", the “AnƟ-DiscriminaƟon” Agreement
ArƟcle, SecƟon C.XXXI of the DHS Standard Terms and Condi Ɵons Ɵtled "PresidenƟal ExecuƟve
Orders," and the Agreement ArƟcle Ɵtled “PresidenƟal ExecuƟve Orders” will immediately
become effecƟve. As stated in the
Agreement ArƟcle Ɵtled “Non-Applicability of Specific Agreement ArƟcles, Paragraph
2(a)(iii) of the “AnƟ-DiscriminaƟon” Agreement ArƟcle and Paragraph 2(a)(iii) of SecƟon C.XVII
of the DHS Standard Terms and CondiƟons will not apply even if the preliminary injuncƟon is
stayed, vacated, or exƟnguished.
ArƟcle 59
Non-Applicability of Specific Terms and Agreement ArƟcles Pursuant to City of SeaƩle v.
Trump, et al.
Pursuant to the preliminary injuncƟon order issued on October 31, 2025, in City of SeaƩle v.
Trump, et al., No. 2:25-cv-01435-BJR (W.D. Wa.), the following terms and condiƟons do not
apply to awards or subawards issued to any of the plainƟffs subject to the preliminary
injuncƟon order while the order remains in effect: SecƟon C.XVII of the DHS Standard Terms
and CondiƟons Ɵtled "AnƟ-DiscriminaƟon" and the
Agreement ArƟcle Ɵtled “AnƟ-DiscriminaƟon” in this award package. If the preliminary
injuncƟon is stayed, vacated, or exƟnguished, SecƟon C.XVII of the DHS Standard Terms and
CondiƟons Ɵtled "AnƟ-DiscriminaƟon" and the “AnƟ-DiscriminaƟon”
Agreement ArƟcle will immediately become effecƟve. As stated in the Agreement ArƟcle
Ɵtled “Non-Applicability of Specific Agreement ArƟcles, Paragraph 2(a)(iii) of the “AnƟ-
DiscriminaƟon” Agreement ArƟcle and Paragraph 2(a)(iii) of SecƟon C.XVII of the DHS
Standard Terms and CondiƟons will not apply even if the preliminary injuncƟon is stayed,
vacated, or exƟnguished.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
44
ArƟcle 60
Expedited Review of Amendments
For any amendment submiƩed by the Host City CommiƩee Task Force that requires prior
approval by the State government pass-through enƟty under 2 CFR part 200, the pass-through
enƟty must take acƟon on that request within 10 business days and report the request and
change to FEMA.
ArƟcle 61
Reducing Pass-Through Time
Notwithstanding the 45 day pass-through requirement in the NOFO, FEMA recognizes the
urgency in which the grant’s stakeholders require access to the funding to enhance the
security and preparedness for the 2026 World Cup events in the United States, the recipient
must pass-through 100% of funds to the Host
CommiƩee Task Force subrecipients within ten (10) business days aŌer receipt of the funds in
a manner that is otherwise consistent with the requirements described within the FWCGP
NOFO.
ArƟcle 62
ProhibiƟon on Covered Foreign Unmanned AircraŌ Systems (UAS)
As a condiƟon of this award, recipients, subrecipients, and their contractors or subcontractors
must comply with SecƟon 1825 of the American Security Drone Act of 2023, as enacted in the
NaƟonal Defense AuthorizaƟon Act for Fiscal Year 2024 (Pub.
L. No. 118-31 §§ 1821-33, 41 U.S.C. 3901 note prec.). Federal funds may not be used to
procure, operate, or otherwise support any covered unmanned aircraŌ system (UAS) that is
manufactured or assembled by a covered foreign enƟty, or in connecƟon with the operaƟon
of such a system. For further guidance, refer to Public Law 118-31 and OMB Memorandum
M-26-02, Ensuring Government Use of Secure Un-manned AircraŌ Systems and SupporƟng
United States Producers. Failure to comply with these requirements may result in the
withholding of funds, suspension, or terminaƟon of the award.
ArƟcle 63
Award Compliance Hold
Please note that FEMA may reinstate budget or program funding holds if submiƩed
documentaƟon is incomplete or inconsistent with program requirements. All costs charged to
the federal award remain subject to FEMA review and must comply with the terms and
condiƟons of the award. If issues arise, we will no Ɵfy you promptly and work with you to
resolve them.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
45
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
46
ATTACHMENT D
WORK PLAN
FY 2026 FIFA World Cup Grant Program
The purpose of this attachment is to identify the activities planned by the Subrecipient under this Grant
Agreement.
The Subrecipient's approved Work Plan is incorporated herein by reference and attached to this Agreement.
Activities must align with the requirements of the NOFO, the Manual, and the approved application for
funding.
PROJECT DESCRIPTION
PURPOSE and NEED: Explain the overall goal of the project and the specific public safety and security need it addresses. Why is the project
needed?
Project Description – Purpose and Need
The City of Renton’s FIFA World Cup 2026 Public Safety Project is designed to enhance public safety, protect critical infrastructure, and
strengthen emergency preparedness for high-profile international events within the city and surrounding jurisdictions. The overall goal of the
project is to ensure a safe, secure, and coordinated environment for participants, spectators, and staff at two designated venues (team hotel,
practice facility), and transportation corridors during World Cup activities.
This project addresses critical public safety and security needs identified through operational assessments, interagency planning, and planning
with the Seattle FIFA security team. Key challenges include limited staffing capacity to sustain high-visibility operations across multiple venues,
complex communication and coordination requirements across multiple agencies, predictable vulnerabilities during team transportation, and
emerging aerial threats from unmanned aircraft systems (UAS). Without dedicated resources, advanced operational planning, and interagency
coordination, these gaps could increase the risk of incidents and reduce response effectiveness during mass gatherings and high-profile events.
The project is needed to provide dedicated staffing, operational oversight, and advanced capabilities while enhancing interagency
communication, planning, and situational awareness. By addressing these needs proactively, the City of Renton will reduce risk, improve
response times/coverage, strengthen coordination among law enforcement, fire, and emergency management, while ensuring a safe and flexible
operational environment for FIFA World Cup 2026 events.
PLANNED WORK: Describe the activities, services, and/or equipment purchases included.
Planned Work
The project will fund staffing, operational support, planning, and management, and training to enhance public safety for FIFA World Cup 2026
events. Activities include: deployment of dedicated personnel for external security, crowd management, access control, traffic management;
team bus escort operations and training; and coordination with police and emergency management for unified command and situational
awareness during World Cup operations.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
47
OUTCOME
Outcome – Enhancing Response to FIFA World Cup 2026 Threats
The City of Renton’s project strengthens its ability to prevent, prepare for, and respond to potential threats during FIFA World Cup 2026 events
through expanded staffing, operational coverage, and enhanced capabilities by training personnel for vehicle escorts. By addressing gaps in
staffing, communication, pre-planning, and coordination identified through operational assessments and the City of Renton’s October 2025 full-
scale World Cup Exercise, the project ensures a proactive, unified, and effective public safety response.
Expected Outcomes and Operational Enhancements:
•Rapid, Unified Response:
oDedicated staffing for external security, crowd control, access control, traffic management, and team escorts
oImproved coordinaƟon among police, fire, and Emergency Management to reduce response Ɵmes and streamline incident management
•Expanded Coverage:
oConƟnuous operaƟonal oversight at two venues, team hotels, pracƟce faciliƟes, and key transportaƟon routes
oComprehensive monitoring for crowd management, general security, and safe transport of team
•Enhanced OperaƟonal CapabiliƟes:
oUAS detecƟon and aerial overwatch for emerging aerial threats
oStructured pre-planning and lessons learned from prior exercises to reduce reacƟonary response and increase situaƟonal awareness
•Improved CommunicaƟon and CoordinaƟon:
oReal-Ɵme informaƟon sharing and command-and-control across all parƟcipaƟng agencies
oStrengthened operaƟonal protocols (coordinaƟon, communicaƟons, situaƟonal assessment)
oOperaƟons: RPD command staff member and emergency management liaison staff member dedicated to World Cup operaƟons for planning
and management purposes through regional events
These enhancements directly align with FIFA World Cup 2026 Safety and Security Planning Lines of Effort, ensuring Renton meets standards for
Emergency Preparedness, Intelligence & Threat Analysis, Physical Security & Access Control, Crowd Management, Transport Security & Escorts,
and Crisis Management & Tactical Coordination. The project increases organizational readiness, mitigates risk, and ensures safe and secure
operations for participants, spectators, and the broader community.
Explain how the project will improve your organization's ability to respond to threats related to the FIFA World Cup 2026 games. Include
expected performance improvements, coverage expansion, and/or operational enhancements.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ATTACHMENT E
TIMELINE
FY 2026 FIFA World Cup Grant Program
The purpose of this attachment is to identify applicable and agreed upon due dates for Grant Agreement
milestones to include deliverables that must be submitted to the Organization. Both the Organization and the
Subrecipient shall monitor adherence with the dates below.
The Subrecipient must request prior written approval from Organization Key Personnel to waive or extend
the due date in the above Timeline.
For waived or extended reimbursement due dates, all allowable costs should be submitted on the next
scheduled reimbursement submission due date contained in the above Timeline.
PROJECT SCHEDULE
MILESTONE START DATE END DATE
6/8/2026 7/8/2026
6/8/2026 7/8/2026
4/1/2026 6/2/2026
6/8/2026 7/8/2026
6/8/2026 7/8/2026
7/8/2026PROJECT COMPLETION (no later than 8/31/2026)
Planning and Management
Project / Grant Management
PROJECT START (no earlier than 7/4/2025)
Venue security (Hyatt Hotel and Longacres/Seattle Sounders FC practice facility
Transports - vehicle escorts, team movemement
Training - vehicle escort training
INSTRUCTIONS: Enter the major milestones for the project. Please include at least 2 milestones.
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
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ATTACHMENT F
BUDGET
FY 2026 FIFA World Cup Grant Program
The purpose of this attachment is to identify how the funding is budgeted for the identified activities in the
Work Plan. If funding is identified as not being required, contact the Organization Key Personnel as soon as
possible so funding can be reallocated.
PLANNING ORGANIZATION EQUIPMENT TRAINING EXERCISE M&A TOTAL
Salaries & Benefits 22,095$ 332,751$ 20,950$ 375,797$
Supplies -$
Travel/Per Diem -$
Contractor/Consultant -$
Other 2,616$ 2,616$
Equipment -$
SUBTOTAL 22,095$ 332,751$ -$ 20,950$ -$ 2,616$
Indirect
TOTAL 378,412$
AGREEMENT AMOUNT $378,412
PROJECT BUDGET
DHS-FEMA-FWC-FY26 RENTON POLICE DEPARTMENT, FWCGP-15
50
ATTACHMENT G
BUILD AMERICA, BUY AMERICA ACT SELF-CERTIFICATION
The undersigned certifies, to the best of their knowledge and belief, that:
The Build America, Buy America Act (BABAA) requires that no federal financial assistance for "infrastructure"
projects is provided "unless all of the iron, steel, manufactured products, and construction materials used in
the project are produced in the United States." Section 70914 of Public Law No. 117-58, §§ 70901-52.
The undersigned certifies that for the _____________________ [Insert Project Name and Location] that the
iron, steel, manufactured products, and construction materials used in this contract are in full compliance
with the BABAA requirements including:
1. All iron and steel used in the project are produced in the United States. This means all
manufacturing processes, from the initial melting stage through the application of coatings, occurred
in the United States.
2. All manufactured products purchased with FEMA financial assistance must be produced in the
United States. For a manufactured product to be considered produced in the United States, the cost
of the components that are mined, produced, or manufactured in the United States is greater than
55% of the total cost of all components.
3. All construction materials are manufactured in the United States. This means that all
manufacturing processes for the construction material occurred in the United States.
"The [Contractor or Subcontractor], ________________________, certifies or affirms the truthfulness and
accuracy of each statement of its certification and disclosure, if any. In addition, the [Contractor or
Subcontractor] understands and agrees that the provisions of 31 U.S.C. Chap. 38, Administrative Remedies
for False Claims and Statements, apply to this certification and disclosure, if any."
____________________________________________________________
Signature of [Contractor's or Subcontractor's] Authorized Official
____________________________________________________________
Name and Title of [Contractor's or Subcontractor's] Authorized Official
____________________________________________________________
Date