Agmt 2009 US Department of Housing and Urban Development HUD

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5 (1) Through its signing of this Agreement, the City certifies that it has taken steps to ensure that all future notices regarding the citizen participation process, commencing with the 2009 funding cycle, as related to its administration of CDBG-funded programs and activities will affirmatively specify that the locations of upcoming public meetings and hearings are accessible to persons with physical disabilities. E. Limited English Proficient Needs Assessment &Language Assistance Plan(24 CFR 1.6) (1) Within 240 days of execution of a VCA, the City will undertake and complete a four factor analysis of LEP needs,pursuant to the enclosed LEP guidance, to determine if a need for expanded services to LEP populations in its jurisdiction is warranted. (2)Within 270 days of execution of a VCA, the City will develop a written Language Assistance Plan if the four factor analysis identifies a need for additional efforts. (3) Within 270 days of execution of a VCA, the City will submit to HUD-FHEO in accordance with paragraph IV below, a summary of the results of its four factor analysis and a copy of its Language Assistance Plan, if one is required pursuant to its four-factor analysis. F. Analysis and Actions to Affirmatively Further Participation by Least Likely Groups (24 CFR 1.6) (1)Within 180 days of execution of a VCA, the City will develop a procedure that assures that reports submitted by sub-recipients are routinely reviewed and analyzed to assure that participation is equitable based on race, color,national origin, gender and disability. The procedures will include provisions for providing assistance to sub-recipients in instances wherein the City identifies under-representation by particular groups, and identification of appropriate methods to conduct affirmative marketing and outreach to groups which the analysis indicates may be or are likely to be under-served relative to their representation in the income-eligible population of the City. (2) Within 180 days of execution of a VCA, the City will provide a report to HUD-FHEO in accordance with paragraph IV below to summarize actions it has taken in compliance with this provision. G. Staff training on Section 504 Reasonable Accommodations Policy(24 CFR 8.4, 8.33) (1)Within 120 days of execution of a VCA, the City will amend its Reasonable Accommodation Policy to incorporate reference to applicants and beneficiaries of federally assisted programs and activities and to members of the public;