f:r1 - la city clerkclkrep.lacity.org/onlinedocs/2010/10-2440_misc_02-15-2011.pdf · 15.02.2011...

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City ofLos Angeles Mail -Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Ac... https://mail.google.com/a!lacity.or&'?ui=2&ik='4b4e91617e&view=pt&q=dillardjoyce@yaho ... 1 f:R1 LA Deborah Wood <deborah.mwood@lacity .org> Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Action Plan due 2.15.2011 2 messages Joyce Dillard <[email protected]> Tue, Feb 15,2011 at 4:57PM To: [email protected], Julie Oleary <[email protected]>, Deborah Wood <[email protected]> Cc: 'William G. Vasquez" <[email protected]>, "Wayne S. !toga" <[email protected]>, The Honorable Carmen Trutanich <[email protected]>, The Honorable Richard Alarc6n <[email protected]>, The Honorable Tony Cardenas <[email protected]>, The Honorable Eric Garcetti <[email protected]>, The Honorable Janice Hahn <councilmember. hahn@lacity .erg>, The Honorable Jose Huizar <councilmember.huizar@lactty .org>, The Honorable Paul Koretz <[email protected]>, The Honorable Paul Krekorian <[email protected]>, The Honorable Tom LaBonge <[email protected]>, "The Honorable Bernard C. Parks" <[email protected]>, The Honorable Jan Perry <[email protected]>, "The Honorable Ed P. Reyes" <[email protected]>, The Honorable Bi!! Rosendahl <[email protected]>, The Honorable Greig Smith <[email protected]>, "The Honorable Herb J. Wesson Jr." <[email protected]>, ''The Honorable Dennis P. Zine" <councilmember.zine@Jacity .org> Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Action Plan due 2.15.2011 This is a plan about deception. First off, the Mayor and City Council allowed the agreement for a Citizens Participation Plan and Citizen Unit for Participation to be changed without going through the motions of amendment. They simply just approved Ordinance 181192 that changed governance to a Commission with subpoena powers that is appointed by the Mayor. State Brown Act rules govern and the Commission allows up to 2 minutes speaking. The Citizens Participation Plan is to encourage participation, which is not the case in the Commission's by-laws. The Commissioners were reviewed by the Arts, Parks, Health and Aging Committee. The actions of this commission are no longer under review of the Housing, Community and Economic Development Committee. The Commissioners are subject to Conflict-of-Interest codes and regulations. So, the direction of Citizen Participation is for the service aspect of the Consolidated Plan which can amount to no more than 15%. Housing is not the Commission's key consideration-the ending of poverty is their direction. The regulations around the Consolidated Plan do not direct the ending of poverty, but the financing of projects and services in low-to-moderate census tracts. This flaw in the direction of the regulations lends those who live in these census tracts value in their geography, not in their quality of life or improvement of living conditions. The banking industry needs to lend to projects in this area to satisfy the Community Reinvestment Act. The City is in the process of creating a Banking Development District CFI 09-1219. The Community Reinvestment Act also directs the Consolidated Plan in that housing becomes more valuable than job creation. Job creation becomes valuable with construction jobs, not with long-term employment creation. Over the last few years, the opportunities for projects created by the public are not considered. The application process has been dealt to control by the Mayor. He invites City agencies and any outside entities to apply. There is not a Request for Proposals RFP process established to replace the Open Application Process. The Mayor can dictate the political direction of the voters in these precincts that are also low-moderate qualifying census tracts. Political favor trumps voter representation. The non-profit corporation world has more voice than an individual voter because projects are chosen without their approvaL So, this Plan has become a tool of the Municipal Government to receive Special Funds to govern the City of Los Angeles with federal funded taxpayer monies all under the control of the Mayor. There a few checks and balances and poor attempts to notify the public and especially those living in the qualified census tracts. The use of newspapers not widely distributed, like the Metropolitan News, and not available in the collection of the libraries across the City is the practice of the City, as regulations do not require that the affected public have even a 50-50 chance of seeing thee opportunity to comment.. The Early Notification System of the Neighborhood Councils is not used properly. The Neighborhood Councils was forrned by the Vote of the People in a Charter Revision on June

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  • City ofLos Angeles Mail -Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Ac... https://mail.google.com/a!lacity.or&'?ui=2&ik='4b4e91617e&view=pt&q=dillardjoyce@yaho ...

    1 ~.C'"

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    f:R1 LA Deborah Wood ~GEECS

    Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Action Plan due 2.15.2011 2 messages

    Joyce Dillard Tue, Feb 15,2011 at 4:57PM To: [email protected], Julie Oleary , Deborah Wood Cc: 'William G. Vasquez" , "Wayne S. !toga" , The Honorable Carmen Trutanich , The Honorable Richard Alarc6n , The Honorable Tony Cardenas , The Honorable Eric Garcetti , The Honorable Janice Hahn , The Honorable Jose Huizar , The Honorable Paul Koretz , The Honorable Paul Krekorian , The Honorable Tom LaBonge , "The Honorable Bernard C. Parks" , The Honorable Jan Perry , "The Honorable Ed P. Reyes" , The Honorable Bi!! Rosendahl , The Honorable Greig Smith , "The Honorable Herb J. Wesson Jr." , ''The Honorable Dennis P. Zine"

    Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Action Plan due 2.15.2011

    This is a plan about deception.

    First off, the Mayor and City Council allowed the agreement for a Citizens Participation Plan and Citizen Unit for Participation to be changed without going through the motions of amendment. They simply just approved Ordinance 181192 that changed governance to a Commission with subpoena powers that is appointed by the Mayor.

    State Brown Act rules govern and the Commission allows up to 2 minutes speaking. The Citizens Participation Plan is to encourage participation, which is not the case in the Commission's by-laws.

    The Commissioners were reviewed by the Arts, Parks, Health and Aging Committee. The actions of this commission are no longer under review of the Housing, Community and Economic Development Committee. The Commissioners are subject to Conflict-of-Interest codes and regulations.

    So, the direction of Citizen Participation is for the service aspect of the Consolidated Plan which can amount to no more than 15%.

    Housing is not the Commission's key consideration-the ending of poverty is their direction.

    The regulations around the Consolidated Plan do not direct the ending of poverty, but the financing of projects and services in low-to-moderate census tracts. This flaw in the direction of the regulations lends those who live in these census tracts value in their geography, not in their quality of life or improvement of living conditions.

    The banking industry needs to lend to projects in this area to satisfy the Community Reinvestment Act. The City is in the process of creating a Banking Development District CFI 09-1219. The Community Reinvestment Act also directs the Consolidated Plan in that housing becomes more valuable than job creation. Job creation becomes valuable with construction jobs, not with long-term employment creation.

    Over the last few years, the opportunities for projects created by the public are not considered. The application process has been dealt to control by the Mayor. He invites City agencies and any outside entities to apply. There is not a Request for Proposals RFP process established to replace the Open Application Process.

    The Mayor can dictate the political direction of the voters in these precincts that are also low-moderate qualifying census tracts. Political favor trumps voter representation. The non-profit corporation world has more voice than an individual voter because projects are chosen without their approvaL

    So, this Plan has become a tool of the Municipal Government to receive Special Funds to govern the City of Los Angeles with federal funded taxpayer monies all under the control of the Mayor. There a few checks and balances and poor attempts to notify the public and especially those living in the qualified census tracts. The use of newspapers not widely distributed, like the Metropolitan News, and not available in the collection of the libraries across the City is the practice of the City, as regulations do not require that the affected public have even a 50-50 chance of seeing thee opportunity to comment..

    The Early Notification System of the Neighborhood Councils is not used properly. The Neighborhood Councils was forrned by the Vote of the People in a Charter Revision on June

  • City of Los Angeles Mail- Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Ac... https://mail.google.comla/lacity.or!if?ui=2&ik=4b4e91617e&view=pt&q=dillardjoyce@yaho ...

    8, 1999:

    "To promote more citizen participation in government and make government more responsive to local needs, a citywide system of neighborhood councils, and a Department of Neighborhood Empowerment is created. Neighborhood councils shall include representatives of the many diverse interests in communities and shall have an advisory role on issues of concern to the neighborhood."

    With that the Mayor's letter dated December 30, 2010 states:

    "City's economic strategy that focuses on four strategic objectives: 1. Existing Small Business Support and Capacity Building 2. New Business Development in Strategic Technology Sectors 3. Gap Financing to Accelerate Private Investment 4. Business Attraction and Retention"

    "Funding for high-priority projects and programs to support these provide five important economic results in the years to come:

    1. New Construction Jobs 2. New Permanent Jobs 3. New Business Creation 4. Increased Private Sector Capital Investment 5. Increase in the City's Tax Base"

    Business creation is controlled by agencies such as the Community Redevelopment Agency and the Clean Tech Business Incubator Project 58 was approved by the Community Redevelopment Agency without a bid process and given to Community Partners (January 20, 2011 Board of Directors meeting). SBAhas pending regulations SBA-2011-0001-0001 for Cleantech business financing and this market is captured already. Their goal is to finance businesses:

    ""primarily engaged" in business activities that reduce the use or consumption of non-renewable energy sources ("Energy Saving Activities').~

    The geography becomes important in relationship to the Consolidated plan funding.

    In fact a 20-year contract was awarded to Valley Economic Development Center Inc. to assist q ua!ified small business borrowers, a contract that outlives the terms of the Mayor and Counci!members.

    The Port Tech Business Incubator Project 60 is a Public-Private Partnership, not a bid project.

    The Department of Treasury's CDFI Capital Magnet Fund CDFI_FRDOC_0001-0002 is designed to finance projects in these areas. Missing is the requirement that the City release inventory of affordable housing already under covenant. The State of California requires a 5wyear Housing Element, but the City does not release a full list of properties, by address or parcel number, of the totals listed in that plan.

    We, as citizens and residents, cannot see the true need or overstock of affordable housing.

    Again ,we question the Mayor stating:

    "The current economic climate requires our commitment to create and retain jobs and is in alignment with the legislative intent of the CDBG program."

    The legislative intent, per Council File 11-0002-S? states:

    "WHEREAS, the CDBG is a primary funding source for the City's Family Source Centers, AIDS prevention, Homeless assistance programs, Domestic Violence shelter operations, OR YD Summer Night Lights, and affordable Housing programs;"

    "2/""lf'if\11 0·110 A'l\A

  • City ofLos Angeles Mail- Comments to Consolidated Plan PY 37 2011-2012 Fourth-Year Ac... https://rnail.google.comla/Iaci1y.org'?ui~2&ik=4b4e9161 7e&view=pt&q~dillardjoyce@yaho ...

    "NOW, THEREFORE, BE IT RESOLVED, with the concurrence of the Mayor, that by the adoption of this Resolution, the City of Los Angeles hereby includes in its 2011-2012 Federal Legislative Program:

    1) SUPPORT for full funding of the Community Development Block Grant (CDBG) program directly allocated by the federal government to entitlement communities, like the City of Los Angeles, which are expended at the local government level to serve disadvantaged communities and help grow local economies and create jobs;

    2) Urge the President and the Administration to PROPOSE full funding of the CDBG program; and,

    3) OPPOSITION to any reduction to the CDBG program."

    We emphasize, again, that this funding finances government and not aid people to see their communities elevate from being disadvantaged into being productive.

    Reprogrammed funds should be through Substantial Amendments. The process has been reduced to City Council motion, sometimes through a public hearing in the committee process and sometimes by Special Meetings (24-hours notices) in the City CounciL

    In whatever manner, the purpose is not to obtain Citizen Participation to the projects approved and financed in the communities, but to satisfy the developers financing needs.

    Programming becomes a placeholder, not a productive economic producing project. Projects can exist up 20 years, so there is no effect on the community. This practice needs to cease.

    The HOME Investment Program is not available to the individual homebuyer, but is allocated to the Affordable Housing Trust with qualifications outside of the Consolidated Plan and concentrated in specific geographic areas without consideration for market need.

    Project 44 GRYD Summer Night Lights is money not well spent. The GRYD program lacks results, as per the Controllers report dated February 9, 2011. Again, there are not checks and balances for this program as the Mayor controls the program through his office and allocates funding for it.

    Programs that are pass-through like those awarded to LA Conservation Corps should be reviewed to see direct benefit under the conditions of the Consolidated Plan to those in qualified census tracts.

    Our current Governor Jerry Brown sees the need to eliminate the redevelopment agencies including the CRNLA which would have an effect on this plan.

    Overall, the Mayor and the City has missed the direction that others have started. The Southern California Leadership Council, former Governor Gray Davis, the late Lee Harrington and former California Governors Pete Wilson and George Deukmejian , have issued a report- "To Ensure the Region's Economic Vitality and Quality of Life.~ Here they see a future in the return of manufacturing and a research and development base not the construction jobs of affordable housing. They ask for a definition of Green Tech and see the need of the Alameda Corridor and the competition from China and the Panama Canal for business. Infrastructure plays a role that the Consolidated Plan does not even address.

    This plan lacks that foresight and application into the real world of unemployment and need for opportunity.

    Joyce Dillard P.O. Box 31377 Los Angeles, CA 90031

    Attachments: 01-0rdinance 181192 02-Banking District Motion 03- CRA Clean Tech Jan_20_2011 04-Controller 08-0465 02-09-2011

    1t:?.I'JI111 0·.10 AM

  • ORDINANCE NO. _'....=1::...:;8-=l-'-J_ 9_2 __ An ordinance repealing Chapters 37 and 84 of Division 5, and Chapter 23 of

    Division 8, of the Los Angeles Administrative Code, amending Section 5.530 of the Los Angeles Administrative Code, and creating Chapter 159 of Division 5 and Article 6 of Chapter 19 of Division 22, of the Los Angeles Administrative Code to create the Board of Community and Family Services Commissioners and a related Trust Fund and provide for the transfer to the Board of the powers, duties and functions of: (1) the Commission on Children, Youth and Their Families, and (2) the Citizens' Unit for Participation Board to the new Board; transfer oversight of the Vermont/Western Station Neighborhood Area Plan Child Care Trust Fund to the Department of Recreation and Parks; and amend Section 8.325.1 of the Los Angeles Administrative Code, and Section 12.22 of the Los Angeles Municipal Code, to provide uniformity of provisions.

    WHEREAS, the Mayor and City Council intend to provide, pursuant to Charter Section 514, for governmental efficiency through the orderly, phased transfer and consolidation of City governmental activities affecting the Commission on Children, Youth and Their Families and the Citizens' Unit for Participation Board into a single Board of Commissioners to alleviate poverty and promote the general well-being and quality of life for all residents of the City of Los Angeles.

    NOW THEREFORE,

    THE PEOPLE OF THE CITY OF LOS ANGELES DO ORDAIN AS FOLLOWS:

    Section 1. Chapter 23 of Division 8 of the Los Angeles Administrative Code is repealed in its entirety.

    Sec. 2. Article 6 of Chapter 19 of Division 22 of the Los Angeles Administrative Code is added to read:

    ARTICLE 6

    BOARD OF COMMUNITY AND FAMILY SERVICES COMMISSIONERS

    Sec. 22.476. The Board of Community and Family Services Commissioners.

    (a) Creation of Board. There is hereby created within the Community Development Department or a successor department a Commission to be known as the Board of Community and Family Services Commissioners ("Board") that shall serve as an advisory board to the Mayor, Council, and General Manager of the Community Development Department of the City of Los Angeles or a successor department ("General Manager").

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  • (b) Purpose, Powers and Duties. The Board shall act in an advisory capacity to the Mayor, Council, and General Manager on poverty and the needs, concerns, and interests of children, youth, and their families, and on the administration of the Housing and Community Development Consolidated Plan, including the fulfillment of all legal requirements for public participation related to the Housing and Community Development Consolidated Plan.

    In addition, the Board may:

    (1) Enhance and coordinate the City's efforts to serve children, youth, and their families, and advocate for these constituencies within both the City government and the greater community of the City; and

    (2) Promote the use of resources and the establishment of collaborations with the City, the County of Los Angeles, the Los Angeles Unified School District, other educational and governmental entities, national, state, and local associations and organizations, parents' groups, and community-based agencies concerned with poverty and the needs, concerns, and interests of children, youth, and their families; and

    (3) Develop a strategic plan and review and recommend policies or legislation that address issues of poverty and serve the needs of children, youth, and their families; and

    (4) Perform other duties required by federal, state, and local law for public participation in the administration and expenditure of grants awarded to the City under the Housing and Community Development Act; and

    (5) Participate in the development, planning, implementation, and evaluation of the Housing and Community Development Consolidated Plan to serve low-income communities; and

    (6) Perform such other duties relating to poverty and children, youth, and their families as may be requested by the Mayor, Council, and General Manager.

    (c) Membership. All members should have demonstrated knowledge and experience in areas relate

  • members to terms that end June 30, 2014. The initial term of each member of the Board shall be designated in the appointment.

    (e) Diversity Consideration. The Mayor, when submitting appointments to the Council for approval, shall state the specific area of expertise and the related qualifications and experience of the nominee. The Council shall review these qualifications as part of the confirmation process. The Mayor and Council shall also ensure that the membership of the. Board represents the City's diversity of race, ethnicity, culture, religion, national origin, gender, age, sexual orientation, and neighborhoods, in addition to other diverse communities of interest such as business and not-for-profit organizations.

    (f) Compensation. Members of the Board shall serve without compensation.

    (g) Officers. The Board shall, at the beginning of each fiscal year, elect from its members a President and Vice-President. The elected officers shall hold office for one year or until their successors are elected, unless their membership on the Board expires sooner. ·The Board may fill the unexpired terms of a vacancy occurring in office of the President or Vice-President.

    (h) Committees. The Board shall develop committees as it deems appropriate and necessary to carry out its work, including, but not limited to an Executive Committee; a Policy Committee to advise on family-related policies; and a Community Services Committee to advise on all Housing and Community Development Consolidated Plan-related matters. A member of the Board shall chair each committee. Committee chairs and members shall be selected in accordance with rules and regulations established by the Board.

    (i) Rules and Regulations. At its first meeting or as soon thereafter as possible, the Board shall adopt rules and regulations for the conduct of its business.

    0) Meetings. The Board shall designate the time and place for regular meetings, provided that it shall meet not less than one time within a calendar quarter.

    (k) Cooperation and Coordination with Other Agencies.

    (1) Whenever practical, the Board shall coordinate its programs with any other similar agency, Federal, State, or otherwise, to avoid duplication of effort and ensure an effective working relationship between the City and other private or public agencies.

    (2) All Boards, Offices, Departments, Agencies, and Bureaus of the City shall cooperate with the Board to the fullest extent practicable and in a manner that would not conflict with the lawful and necessary conduct of their duties as provided by law.

    3

  • (I) Solicitation of Funds.

    The Board may solicit and accept donations of funds which shall be placed in the Board of Community and Family Service Commissioners Trust Fund established under Los Angeles Administrative Code Section 5.564.

    Sec. 3. Chapter 37 of Division 5 of the Los Angeles Administrative Code is repealed in its entirety.

    Sec. 4. Chapter 84 of Division 5 of the Los Angeles Administrative Code is repealed in its entirety, and all remaining monies in the Commission for Children, Youth and Their Families Trust Fund are transferred to the Board of Community and Family Services Commissioners Trust Fund established at Chapter 159 of Division 5 of the Los Angeles Administrative Code.

    Sec. 5. Chapter 159 is added to Division 5 of the Los Angeles Administrative Code to read as follows:

    CHAPTER 159

    BOARD OF COMMUNITY AND FAMILY SERVICES.COMMISSIONERS TRUST FUND

    Sec. 5.564. Creation and Administration of the Fund.

    (a) There is hereby-created and established in the Treasury of the City of Los Angeles a special trust fund to be known as the "Board of Community and Family Services Commissioners Trust Fund," hereinafter referred to in this Chapter as the "Fund."

    (b) The Fund shall be used to create new programs and activities and to support or augment established programs and activities of the Board of Community and Family Services Commissioners, hereinafter referred to in this Chapter as the "Board," and may be used for the purchase of equipment, services, furnishings, or any lawful purpose in support of such programs and activities, subject to any special terms or conditions attached to individual gifts, contributions, or bequests to the City. The Fund rnay also be used by the Board to support or augment new or established programs of other City departments, other public agencies, or not-for-profit agencies that the Board determines will assist in combating poverty and in supporting children, youth and their families.

    (c) All monetary gifts, contributions or bequests to the City for the purposes set forth in this Chapter which exceed the sum of$ 10,000 shall be submitted to the City Council for acceptance or rejection. All such monetary gifts, contribution, or bequests which do not exceed the sum of$ 10,000 shall be submitted to the Board or its designee for acceptance or rejection. The Board's designee for purposes of this

    4

  • Chapter shall be a full-time employee serving in a duly authorized position on the staff of the Community Development Department or a successor department.

    (d) All monetary gifts, contributions, or bequests accepted by the City Council or the Board or its designee for the purposes set forth in this Chapter shall be placed in the Fund.

    (e) The Board or its designee shall inform the Controller of any special terms or conditions placed upon the use of all moneys accepted for deposit in the Fund. The Controller shall establish a separate account within the Fund for each specific use for all accepted monetary gifts, contributions or bequests which contain any special term or condition. No money shall be expended from the Fund except in compliance with each special term or condition under which the money was accepted. Any request by the Board or its designee for an expenditure of money from any separate account shall be accompanied by sufficient information for the Controller to determine that the proposed expenditure does not contravene the specific use for which the separate account was established.

    (f} All monetary gifts, contributions or bequests which are accepted without special terms or conditions upon their use shall be placed in a general account established in the Fund by the Controller.

    (g) All interest or other earnings attributable to money in the Fund shall be credited to the Fund and shall be devoted to the purposes set forth in this Chapter.

    (h} The Fund shall be administered and expenditures therefrom shall be authorized by the Board or its designee in accordance with established City practice, provided, however, no expenditure shall be made from the Fund for any purpose which is contrary to the budget policy of the Board as established by the Mayor and Council.

    (i) The Board shall report to the City Council regarding and indentifying all receipts into, and all expenditures out of, the Fund, as well as the purposes for which the expenditures were made. Each report shall cover the most recent six-month period of time which commenced on April 1 or October 1 and shall be submitted within 60 days after the close of the period.

    Sec. 5.565. Receipt and Registration of Personal Property.

    (a) Each offer of a gift or bequest of personal property to the City for the purposes set forth in this Chapter, the market value of which exceeds $10,000, shall be submitted to the City Council for acceptance or rejection. Each offer of a gift or bequest of personal property not exceeding $10,000 in market value shall be submitted to the Board or its designee for acceptance or rejection.

    (b) Title to any pi"Jrsonal property accepted by either the City Council or by the Board or its designee shall be vested in the City of Los Angeles.

    5

  • (c) The Board or its designee shall cause all personal property, whether acquired by gift or bequest or by purchase through the expenditure of money from the Fund, to be properly registered as required in the City's Equipment Inventory System.

    Sec. 6. Section 5.530 of the Los Angeles Administrative Code is amended to read:

    Sec. 5.530. Vermont/Western Station Neighborhood Area Plan Child Care Trust Fund.

    A. Creation and Administration of Fund. There is hereby created within the Treasury of the City of Los Angeles a special fund known as the Vermont/Western Station Neighborhood Area Plan Child Care Trust Fund, referred to in this Chapter as the Child Care Fund or Fund. The Department of Recreation and Parks (Department) with the concurrence of the President of the City Council shall administer, have overall management of and expend funds from the Child Care Fund in accordance with the provisions of this Chapter. The Department with the concurrence of the President of the City Council shall also administer the Fund in accordance with established City practice and in conformity with Government Code Section 66000, et seq. All interest or other earnings from money received into the Child Care Fund shall be credited to the Fund and devoted to the purposes listed in this Chapter.

    B. Purpose. The Child Care Fund shall be used for the deposit of money paid to the City of Los Angeles pursuant to the Vermont/Western Station Neighborhood Area Specific Plan and any other money appropriated or given to this Fund for the creation or development of Child Care programs or facilities in the Vermont/Western Station Neighborhood area.

    C. Expenditures. Except as set forth below, Child Care Funds collected pursuant to the Vermont/Western Station Neighborhood Area Specific Plan and any other monies placed in this Fund shall be expended only for the purpose of acquiring facilities, developing, improving, and operating Child Care programs physically located within the boundaries of the Vermont/Western Station Neighborhood Area Specific Plan area, and providing financial assistance with child care payments to qualifying parents in the area, as determined by the Department.

    The Department with the concurrence of the President of the City Council is authorized to make expenditures from this Child Care Fund in accordance with the Vermont/Western Station Neighborhood Area Plan and the Vermont/Western Station Neighborhood Area Plan Development Standards and Design Guidelines. Administration of the Fund and expenditures from the Fund shall also be in compliance with the requirements in Government Code Section 66000, et seq., including the following:

    1. The Department shall deposit all monies received pursuant to the Vermont/Western Station Neighborhood Area Specific Plan in the Fund and avoid any

    6

  • commingling of the monies with other City revenues and funds, except for temporary investments, and expend those monies solely for the purpose for which the Child Care payment was collected. Any interest income earned by monies in the Fund shall also be deposited in that Fund and shall be expended only for the purpose for which the Child Care payment was originally collected.

    2. The Department shall, within 180 days after the last day of each fiscal year, make available to the public all the information required by Government Code Section 66006 (a).

    3. The City Council shall review the information made available to the public pursuant to Paragraph 2 within the time required by Section 66006, and give notice of that meeting as required by that Section.

    4. When required to do so by Government Code Section 66001(e) and (f), the City Council shall authorize refunds of payments made to the Child Care Fund.

    D. Reporting. The Department shall report annually to the City Council and Mayor identifying and describing in detail receipts and expenditures of the Fund. The Department shall submit each annual report within 60 days after the close of the fiscal year covered in the report.

    Sec. 7. The second sentence of Section 8.325.1 of the Los Angeles Administrative Code is amended to read:

    The following shall be ex-officio, non-voting members of the Steering Committee: The City Engineer; the General Manager of the Department of Recreation and Parks; the General Manager of the Community Development Department or a successor department; the General Manager of the Department of Cultural Affairs; the General Manager of the Library Department; and a City Council staff person appointed by the President of the City Council.

    Sec. 8. The second sentence of Sub-subparagraph (x) of Subparagraph (1) of Paragraph (b) of Subdivision (3) of Subsection A of Section 12.22 of the Los Angeles Municipal Code is amended to read:

    This distance is to be measured along the shortest street route between the two lots as determined by the Department of Recreation and Parks.

    Sec. 9. The third sentence of Subdivision (2) of Subsection A of Section 12.22 of the Los Angeles Municipal Code is amended to read:

    The notice shall include verification provided by the Department of Recreation and Parks that the large family day care home is in compliance with the concentration and spacing condition set forth in Section 12.22 A.3.(b)(1 )(x) above.

    7

  • Sec. 10. Operative Date of Transfer of Powers, Duties and Functions.

    (a) Pursuant to Charter Section 514, the various powers, duties and functions of the Commission on Children, Youth and Their Families and the Citizens' Unit for Participation Board, except for those pertaining to oversight of the VermontANestern Station Neighborhood Area Plan Child Care Trust Fund, and as established by ordinance, are transferred to the Board of Community and Family Services Commissioners, an advisory board to the Mayor, Council and General Manager of the Community Development Department, and the transfers shall become operative on July 1, 2010. Personnel, funds and equipment to perform those powers, duties and functions will be provided in the Budget or any amendment thereto by appropriate action of the City Council and Mayor. The powers, duties and functions to administer the VermontANestern Station Neighborhood Area Plan Child Care Trust Fund are transferred to the Department of Recreation and Parks. It is the intention of the City Council to transfer to the Community Development Department or a successor department all positions which currently exist in the Commission on Children, Youth and Their Families and the Citizens' Unit for Participation Board and which the Council determines to be required by the Department for the performance of the transferred powers, duties and functions. It is also the intention of the City Council that all positions transferred to the Department be filled with personnel who occupy those positions at the time of the transfer.

    (b). Between the effective date of the transfer of the various powers, duties and functions of the Commission on Children, Youth and Their Families and the Citizens' Unit for Participation Board and the respective applicable effective date of each transfer of resources, the powers, duties and functions transferred shall be performed with existing personnel and resources by the Community Development Department or a successor department, except that duties and functions pertaining to oversight of the Vermont/Western Station Neighborhood Area Plan Child Care Trust Fund shall be performed with existing personnel and resources by the Department of Recreation and Parks.

    8

  • Sec. 10. The City Clerk shall certify to the passage of this ordinance and have it published in accordance with Council policy, either in a daily newspaper circulated in the City of Los Angeles or by posting for ten days in three public places in the City of Los Angeles: one copy on the bulletin board located at the Main Street entrance to the Los Angeles City Hall; one copy on the bulletin board located at the Main Street entrance to the Los Angeles City Hall East; and one copy on the bulletin board located at the Temple Street entrance to the Los Angeles County Hall of Records.

    I hereby certify that this ordinance was passed by the Council of the City of Los Angeles, at its meeting of .!UN Ill 2me

    JUN 11 Z0\0 Approved----------

    Approved as to Form and Legality

    CARMEN A. TRUTANICH, City Attorney

    Byrr~t_ fL1 JUDITH E. REEL"-· Deputy City Attorney

    Date (h e"f ..;{)? ) :::'Lo 1 o

    File No. /0- IJ1!J!t

    JUNE LAGMAY, City Clerk

    M:\General Counsel (GC}\JUD!TH REEL\ORDINANCE$\Finai_CUP.CCYF.Ordinance.doc

    9

    Mayor

  • DECLARATION OF POSTING ORDINANCE

    I, Julia Amanti, state as follows: I am, and was at all times hereinafter

    mentioned, a resident of the State of California, over the age of eighteen years,

    and a Deputy City Clerk of the City of Los Angeles, California.

    Ordinance No. 181192 -Repealing Chapters 37 and 84 of Division 5, and Chapter

    23 of Division 8 of the LAAC, amending Section 5. 530 of the LAAC, and creating

    Chapter 159 of Division 5 and Article 6 of Chapter 19 of Division 22, of the

    LAAC to created the Board of Community and Family Services Commissioners and

    a related Trust Fund - a copy of which is hereto attached, was finally adopted

    by the Los Angeles City Council on June 1, 2010, and under the direction of said

    City Council and the City Clerk, pursuant to Section 251 of the Charter of the

    City of Los Angeles and Ordinance No. 172959, on June 15, 2010 I posted a true

    copy of said ordinance at each of three public places located in the City of

    Los Angeles, California, as follows: 1) One copy on the bulletin board at the

    Main Street entrance to Los Angeles City Hall; 2) one copy on the bulletin board

    at the Main Street entrance to Los Angeles City Hall East; 3) one copy on the

    bulletin board at the Temple Street entrance to the Hall of Records of the County·

    of Los Angeles.

    Copies of said ordinance were posted conspicuously beginning on June 15,

    2010, and will be continuously posted for ten or more days.

    I declare under penalty of perjury that the foregoing is true and correct.

    Signed this 15th day of June, 2010 at Los Angeles, California.

    Clerk

    Ordinance Effective Date: July 27, 2010 Council File No. 10-0706

    (Rev. 8/05)

  • BUC MA

    ET & F! NANCE y 2 2 2iJ!t$

    MOTION HOUSING, COMM & ECON. DEVELOP. According to a recent analysis by the Pew Charitable Trusts, Los Angeles has nearly twice as

    many "alternative" financial service provider storefronts than banks and credit unions-with 944 check-cashing outlets and 312 payday lenders, respectively, compared to just 694 total bank and credit union branches.

    It is not surprising, therefore, that our city is home to one of the largest unbanked populations in the United States: An estimated 300,000 Los Angeles households do not have a checking or a savings account at all.

    These families must continually rely on expensive alternative financial service providers •• such as check cashers and payday lenders-- to carry out their financial needs. The Brookings Institution estimates that the average unbanked Los Angeles household pays over $700 each year to carry out simple financial necessities at these storefront providers, such as cashing checks and using money orders to pay for bills.

    Unfortunately, these are the same households that can least afford to lose $700 a year. The Mayor's office has estimated that this translates into a loss of more than $54 million in check cashing fees and $88 million in payday loan fees in Los Angeles every year-- out of the very homes and communities that need these dollars most.

    In the big picture, what's more alarming for these families is that those who do not have a checking or savings account miss out on a crucial step necessary to attain a decent life in the 21" century-- establishing a credit history. Without a credit history, it is difficult if not impossible to obtain reasonably priced mortgage or education loans and other forms of credit such as car loans, credit cards, and so on.

    I THEREFORE MOVE, that the CLA work with the Department of Finance, the Community Redevelopment Agency (CRA) and other necessary Departments to prepare a report within 30 days on the steps necessary to adopt a Banking Development District program in the City of Los Angeles, similar to the successful model used by the City and State of New York to promote new bank branches in underserved communities in Los Angeles.

    I FURTHER MOVE, that Los Angeles Banking Development Districts should include incentives for banks such as: a guaranteed percentage of municipal deposits and discretionary Council District deposits; real property tax breaks that decrease over time; and fast-track land use approval, as well as incentives for contractors that seek City business to bank with Banking Development District branches, such as "points added" on bids or proposals submitted in response to a City issued RFP or RFQ.

    I FURTHER MOVE, that the report describe eligibility criteria for Banking Development C) Districts, including local socioeconomic data and indications that the bank product and service needs ::D of a community are low or unmet; and that the City consider matching and overlapping Banking 52& ...., Development Districts with existing Empowerment and Enter · e Zones. G)

    PRESENTED Blf{._,.{i:c~~;t_f-.:rt::!:~~~~-RI ALARCON

    Councilmember, 71h District

    L;PZ,: ~·?-~

    F MM

    z > I

  • THE COMMUNITY REDEVELOPMENT AGENCY OF THE CITY OF LOS ANGELES, CALIFORNIA

    DATE:

    TO:

    FROM:

    MEMORANDUM

    JANUARY 20, 2011

    CRAILA BOARD OF COMMISSIONERS

    CHRISTINE ESSEL, CHIEF EXECUTIVE OFFICER

    2 Cl2160 100418

    STAFF: DAVID RICCITIELLO, REGIONAL ADMINISTRATOR

    SUBJECT:

    JOSH ROHMER, ASSISTANT PROJECT MANAGER ALEX PAXTON, SPECIAL ASSISTANT TO DEPUTY CHIEF OF OPERATIONS

    CLEANTECH BUSINESS INCUBATOR. Conditional Grant Contract for Services with Community Partners on behalf of CleanTech Business Incubator with initial funding of $1,000,000 to assist with implementation of Incubator Business Plan and provide planning and location services to start-up clean tech businesses, and various actions related to the receipt of up to $4,000,000 in CDBG funding for the Incubator in the Central Industrial Redevelopment Project Area DOWNTOWN REGION (CD 14)

    RECOMMENDATIONS

    That the CRAILA Board of Commissioners, subject to City Council approval, authorize the Chief Operating Officer (COO) or designee to: ·

    1. Enter into a grant contract with Community Partners, a 501(c)(3) non-profit public benefit corporation, on behalf of the Clean Tech Business Incubator ("Incubator"), in the amount of $1,000,000 of Central Industrial Tax Increment in Budget Line Item "Economic Developmenf' for implementation services to establish the Incubator in a temporary facility to provide planning and location assistance to cleantech businesses in the Central Industrial Redevelopment Project Area;

    2. Authorize the receipt of $2,000,000 in CDBG Funds (36'" Program Year) for the Incubator as authorized by City Council on March 5, 2010, and an additional $2,000,000 in CDBG Funds (37'" Program Year) if and when authorized;

    3. Authorize the Chief Operating Officer or designee to enter into agreements as needed with the Community Development Department ("CDD") regarding the receipt and use of CDBG funds; and

    4. Amend the FY11 Central Industrial Budget to recognize said funds into budgeted line item Economic Development (CI2160).

    SUMMARY

    Authorization is requested, subject to City Council review and approval, to enter into a grant contract with Community Partners ("CP") on behalf of the Clean Tech Business Incubator of the La Kretz Innovation Campus ("Incubator") to provide implementation services to establish the Incubator in a temporary facility while a permanent facility is being developed, and to provide planning and location services to start-up clean tech entrepreneurs in the Central Industrial Redevelopment Project Area.

  • CLEANTECH BUSINESS INCUBATOR PAGE2

    As recommended in the Incubator Business Plan, prepared by Business Cluster Development ("BCD") for CRA/LA, the Incubator will provide flexible, affordable office space as well as services and programs to assist start-up clean tech entrepreneurs in growing businesses that develop and commercialize ecologically sustainable technologies, products, and processes. The expectation is that as these businesses graduate from the Incubator, they will populate and stimulate the redevelopment of industrial spaces in the Central Industrial Project Area, which is part of the Clean Tech Corridor.

    This action will allow for the Incubator to open, and fund the first year of providing planning assistance to start-up clean tech entrepreneurs locating in the Central Industrial Redevelopment Project area. CP's implementation services will include hiring incubator staff, leasing and operating the temporary location, developing operational procedures, implementing a marketing and outreach program, and legal services related to the Advisory Board and the application for tax exempt status.

    The Incubator is presently advised by an Interim Advisory Board composed of the steering committee of CleanTech Los Angeles, a collaboration of public and private stakeholders working to advance Los Angeles as a center of clean technology. The Incubator has submitted an application to operate as a non-profit project under the umbrella of CP, a long-standing Los Angeles-based fiscal sponsor for non-profit organizations. While under CP, the Incubator will be governed by CP's Board of Directors with guidance from the Incubator's Advisory Board, which will transition to a Board of Directors when and if the Incubator obtains independent 501 (c)(3) status from the IRS.

    In March 2010 City Council authorized an allocation of $2,000,000 in Community Development Block Grant ("CDBG") funds from the 36th Program Year to pay for public and tenant improvements at the site of the permanent CleanTech Incubator facility. CRA/LA and the Mayor's Office are presently pursuing an additional allocation of up to $2,000,000 from 37'h Program Year CDBG funds. This action will recognize the receipt of allocated 36th Program Year CDBG funds as well as funds from the 37th Program Year if and when they are authorized.

    PREVIOUS ACTIONS

    April 1, 201 0 - CRA/LA Board authorized award of a contract to Business Cluster Development (BCD) not to exceed $100,000, negotiation of a Memorandum of Understanding with LADWP, and submission of a $3,000,000 EDA grant application for the development, funding, and programming of the proposed Los Angeles Clean Technology Business Incubator to be located in the Central Industrial Redevelopment Project Area and the Clean Tech Corridor. City Council subsequently approved the item on May 25, 2010. (CF# 1 0-0591)

    March 5, 2010 - City Council authorized expenditure of $2,000,000 in Community Development Block Grant Funds for construction related to the Clean Tech Business Incubator (CF# 09-2665).

    DISCUSSION & BACKGROUND

    Location

    Both the permanent and temporary locations of the Incubator will be in the Central Industrial Project Area ("CI"). Just east of the Downtown commercial center, Cl covers approximately 738 acres and is generally bounded by Third Street on the north, the Los Angeles River on the east, Washington Boulevard and the Santa Monica Freeway on the south, and San Pedro and Stanford Streets on the west. The Redevelopment Plan was adopted by the Los Angeles City Council on November 15, 2002.

  • CLEANTECH BUSINESS INCUBATOR PAGE3

    Cl is a predominantly industrial area with a commercial presence, with an emerging artist residential loft district, primarily in the northern end of the project area, and single roorn occupancy hotels serving residents of Skid Row. Many of the industrial properties are underutilized, obsolete, and/or deteriorated. In order to stimulate the redevelopment of these properties, higher-value uses need to be sought for the area.

    The permanent location for the Incubator will be at the La Kretz Clean Technology Center, on a 3-acre site bounded by Colyton, South Hewitt, Fifth, and Palmetto Streets, recently purchased by the Los Angeles Department of Water and Power (LADWP). CRAILA has entered into an MOU with LADWP to lease a portion of the site for the Incubator. Construction and tenant improvements to make this site usable for the Incubator will take several years. There is general consensus among the Incubator's stakeholders that it would be a serious challenge to the success of the Incubator to wait that long to open, given the immediate energy and interest generated by the business plan development process, and given the generally-acknowledged fact that cleantech technology development is at a decisive moment and will take hold wherever the resources are currently located.

    Contractor

    Community Partners ("CP") is a nonprofit organization that operates a fiscal sponsorship program, in which an existing nonprofit corporation extends their 501 (c)(3), tax-exempt status to a project so that the project may solicit tax-deductible contributions and grants and operate under the "umbrella" of that organization. CP provides its fiscal sponsorship projects with financial and administrative services, as well as programmatic support. Its financial and administrative services include accounting, general liability insurance, payroll and other human resources services, audits, and tax and lobbying filings. Programmatically, they provide project leaders with a CP staff liaison who provides one-on-one counsel on organizational development issues ranging from fundraising and resource development to strategic planning. CP also facilitates trainings and workshops, networking and peer learning opportunities, and "Meet the Grantmaker" sessions on an ongoing basis.

    Projects accepted for fiscal sponsorship by CP share costs by paying a 9% fee on all revenue raised from private sources (including grants, contracts, donations, special events, etc.) and 12% on revenues from government sources. CP also requires that project leaders maintain close communication with CP by updating their staff liaisons on current programs, grant proposals, activities and special events, fundraisers, board development and budget changes. In addition to regular verbal updates, a Periodic Project Report is also due semiannually. Lastly, they require that all our projects identify themselves as a project of CP on public materials such as websites and brochures.

    CP has been in operation since 1992, with a track record of supporting, training, and investing in more than 500 social innovators and entrepreneurs working in a variety of fields. In 2009 and 2010, CRAILA entered into two grant funding contracts with CP as the umbrella 501(c)(3) for LA Streetcar, Inc. (LAS!) while establishing the corporation under California law and obtaining its non-profit status letter from the United State Internal Revenue Service. As the legal parent organization to LAS!, CP worked with CRA/LA on the grant funding contract, monitored the expenditure activity of LAS!, received and processed charitable contributions.

    Selection Process

    CRAILA staff and business plan consultant BCD interviewed CP regarding the suitability of its fiscal sponsorship program for the Cleantech Business Incubator. Staff also interviewed organizations currently sponsored by CP and found that they were very satisfied with the

  • CLEANTECH BUSINESS INCUBATOR PAGE4

    services of CP. No other comparable fiscal sponsorships operate in the local area, and staff determined that it would be impractical to contract with a non-local fiscal sponsor.

    Acting as the Incubator's Interim Advisory Board, the CleanTech Los Angeles Steering Committee recommended at their January 13, 2011 meeting using the fiscal sponsorship capacity of CP to enable the Incubator to more quickly start operations.

    Description and Project Context

    Economic development and the creation of new employment opportunities are among CRAILA's top priorities and responsibilities. Spanning diverse industrial sectors such as renewable energy, recycling, and next-generation transportation, clean technology is considered a high-growth, high-value sector due to its rapid pace of innovation, attraction of private investment dollars, generation of well-paying green collar jobs, and responsiveness to advancing environmental regulations. As such, the City of Los Angeles and CRA/LA have launched a program to develop the cleantech sector in Los Angeles. The initial target of these efforts is to develop the Clean Tech Corridor, an area that straddles the Los Angeles River in and adjacent to Downtown Los Angeles, Lincoln Heights and Boyle Heights, and which includes the Central Industrial Project Area, as a haven for cleantech businesses. Building a business incubator dedicated to clean technology is one part of this effort. The Incubator will serve as a critical link between locally-generated intellectual capital and real economic and environmental impact for the City of Los Angeles. Too often, technological breakthroughs that are developed in Los Angeles become the basis for new business in another region or country because, in spite of the desire of the entrepreneurs to stay in Los Angeles, they simply cannot find the support it takes to launch a new business here. The Clean Tech Business Incubator is one step in addressing this serious loss of talent and technology to the Los Angeles economy, its workforce, and its efforts to achieve aggressive environmental standards.

    Importantly to CRAILA, a critical function of the CleanTech Business Incubator will be to grow new businesses to sustainability and then link them to resources which will help them find permanent locations within the Central Industrial Project Area and CleanTech Corridor, to support the redevelopment and revitalization of this valuable job-producing but deteriorated industrial area.

    Role of Incubators in Economic Development

    Business incubators nurture the development of entrepreneurial companies, helping them survive and grow during the start-up period, when they are most vulnerable. They provide their client companies with business support services and resources tailored to young firms. The most common goals of incubation programs are to create local jobs at a range of skill and educational levels, enhance a community's entrepreneurial climate, retain businesses locally, accelerate growth in a local industry, and diversify local economies.

    Research by the EDA and National Business Incubator Association (NBIA) finds that 87 percent of all firms that have graduated from NBIA member incubation programs are still in business after five years compared to 44 percent in the general business population. More importantly, about 84 percent of those graduate firms remain in the incubator's community. Further, the research shows that business incubators provide communities with significantly more and longer-lasting jobs at far less cost than do other public works infrastructure projects - including road and bridges, industrial parks, commercial buildings, and sewer and water projects. The jobs created by incubators are enduring, high-paying positions with benefits that contribute to the City's competitiveness. And for every $1 of estimated public operating subsidy provided, an incubator can generate approximately $30 in local tax revenue.

  • CLEANTECH BUSINESS INCUBATOR PAGES

    Project History

    This project was motivated by the realization that the City's base of job-producing industrial land was being eroded, with the eventual result of loss of local jobs. With input from local industrial landowners through the Central City East Association, CRA/LA staff began to work with other stakeholders in identifying industrial sectors that might be nurtured for this industrial area, including the emerging cleantech sector. As the City developed relationships with the local research universities and business leaders, staff determined that there were many resources located in Los Angeles that would support a strong cleantech sector. This led to the development of the concept of a "CieanTech Corridor'' as the home of a nascent cleantech industry cluster.

    The idea of launching a cleantech incubator was conceived concurrently, an incubator being one of the key catalysts and complements to industry cluster development. When LADWP purchased the La Kretz site and entered into an MOU with CRA/LA, that project began to move forward. Shortly thereafter, CRA/LA and LADWP hired BCD to create a business plan for the incubator, and in the six months during which they interviewed experts and stakeholders and put together the document, the vision became concrete. A grant contract with Community Partners is the next critical step to ensure that the Incubator can begin operations by this summer, and capitalize on all the opportunities identified in the business plan.

    ECONOMIC IMPACT

    The following table describes the economic impacts estimated to be created by this project. Estimates for construction jobs are based on a proposed development cost for the permanent Incubator facility of $6,000,000. Preliminary estimates for permanent jobs were prepared by BCD, based on experience from comparable incubator facilities.

    Estimated Construction Jobs Created 37

    Estimated Permanent Jobs Created (first 5 years) 250 to 500

    *The figures provided in the table about are for estimation purposes only; actual fiscal impact or job creation may be higher or lower than these estimates. Standardized formulas were used to generate these figures and are based on accepted econometric practices and basic tax calculations taken from research performed by a variety of sources, including the Los Angeles Economic Roundtable, California Redevelopment Association, US Department of Housing and Urban Development, CRA/LA, and the City and County of Los Angeles.

    The Incubator will also have qualitative economic impacts for the community. Much of the recent real estate development in the Artists District and this portion of the Central Industrial project area has been residential rehabilitation of outmoded industrial buildings dating from the first half of the Twentieth Century. While such residential conversions provide housing units that are much needed on a regional scale, they come at the expense of property that has been locally designated for uses that employ workers and contribute to the City's economy. The Incubator will help establish a jobs-producing anchor in this district, and will attract small firms that will be encouraged to expand into nearby facilities once they graduate from the Incubator. The Incubator hopes to strengthen the revitalize the community by creating jobs to complement the healthy activity that has occurred in the residential and commercial sectors.

  • CLEANTECH BUSINESS INCUBATOR

    SOURCE OF FUNDS

    Central industrial Redevelopment Project Area Tax Increment Funds.

    PROGRAM AND BUDGET IMPACT

    This action is consistent with the amended FY2011 Budget and Work Program.

    PAGE6

    Following approval of this contract, $4,096,900 of $5,270,900 will remain for the Economic Development Budget Category. Sufficient funds exist to make any legally-required State ERAF in FY2011.

    There is no impact on the City's General Fund as a result of this action.

    ENVIRONMENTAL REVIEW

    The proposed action, authorizing execution of a grant contract for funding of planning related activities, is statutorily exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15262 of the CRA/LA CEQA Guidelines. The proposed action, establishing the temporary Incubator facility in an existing building in the Central Industrial Project Area, is also categorically exempt from CEQA pursuant to Section 15301 of the CRA/LA CEQA Guidelines. If approval of a development project is contemplated, the appropriate CEQA document for that proposal will be prepared and brought to the lead agency at the time the approval is requested.

    SUPPORT FOR PROJECT

    The prompt development of the Clean Tech Business Incubator, including fiscal sponsorship by Community Partners, is strongly supported by the members of CleanTech Los Angeles (Office of Mayor Antonio Villaraigosa, Los Angeles Department of Water and Power, University of California Los Angeles, University of Southern California, California Institute of Technology, Jet Propulsion Laboratory, Los Angeles Economic Development Corporation, Greater Los Angeles Chamber of Commerce, Los Angeles Business Council, Central City Association) and by the Central City East Association.

    Calvin E. Hollis Chief Operating Officer

    By:

    Calvin E. Hollis Chief Operating Officer Real Estate and Economic Development

    There is no conflict of interest known to me which exists with regard to any CRA/LA officer or employee concerning this action, except that CRA/LA's Chief Executive Officer, Christine Esse!, has disqualified herself from any participation concerning this matter due to the fact that she is a

  • CLEANTECH BUSINESS INCUBATOR PAGE?

    board member of CleanTech Los Angeles, the current steering committee for the proposed Incubator.

    ATIACHMENTS

    Attachment A: Location Map Attachment B: Project Summary Report

  • . ' .~

    February 9, 2011

    Honorable Members of the Audits and Governmental Efficiency Committee c/o City Clerk Room 395, City Hall

    SUBJECT: ASSESSMENT OF GRYD'S ACTION PLAN AND URBAN INSTITUTE'S YEAR 1 PROGRAM EVALUATION REPORT

    At your August 10, 2010 meeting, the Audits and Government Efficiency (AGE) Committee requested my Office to report back with an analysis of the Gang Reduction and Youth Development (GRYD) Office's plans to address the issues noted in our July 27, 2010 audit report entitled, Semi-Annual Follow-up of the Blueprint for a Comprehensive Citywide Anti-gang Strategy (the second follow-up review). Additionally, your Committee requested that my Office assess the Urban Institute's (UI) Year 1 (Y1) program evaluation report, which was released after the audit was issued, and comment on whether Ul delivered what the City had expected to receive under the terms of their $900,000 contract.

    GRYO's Action Plan

    As part of our typical audit process, departments are requested to advise the Controller's Office on actions taken or planned to address the audit's recommendations. My auditors then review the department's action plan to ensure the audit issues have been adequately addressed, and target implementation dates appear reasonable.

    The GRYD Office submitted its action plan relative to the second follow-up audit on August 30, 2010. Based on the plan as presented, the actions already taken or planned by the GRYD Office, as well as the targeted implementation timelines, are acceptable. We noted that the GRYD Office has outlined efforts to strengthen service provider monitoring, better defined the roles of the GRYD Cabinet and Advisory Committees, and improved oversight of the comprehensive program evaluation.

    AN EQUAL EMPl~Ol'MENT OPPORTUNITY·· t\F'FIRMI\T1VF- A(:TIQN F.:MPLOY€-P

  • Honorable Members of Au,. _.;and Governmental Efficiency Cor •.• ittee February 9, 2011 Page 2 of7

    Urban Institute's Year 1 Program Evaluation Report

    The second follow-up audit noted that the formal evaluation of GRYD's prevention and intervention programs had been significantly delayed, and no results were anticipated for at least another year. Yet, GRYD had paid the contracted evaluator more than $500,000 for evaluation activities through June 30, 2010. (GRYD reports that Ul's billings over a fifteen month period total $868,705.)

    At the AGE meeting, GRYD management indicated that the contracted evaluator, Urban Institute, had recently submitted a report detailing its evaluation of the GRYD program. As requested by the AGE Committee, my auditors reviewed the Ul research report entitled "Evaluation of the Los Angeles Gang Reduction and Youth Development Program: Y1 Report" that was submitted to the GRYD Office in August 2010, to determine whether Ul's report met the contract deliverables.

    Our overall assessment of Ul's report found that it contains valuable information about the program that can be used by the GRYD Office, City leaders, and the public. However, the work performed and the deliverable provided by Ul does not meet the City's expectations as outlined in the contract. That is, Ul's report is not a comprehensive program evaluation of GRYD's program relative to outcomes achieved by the City's anti-gang strategy. In addition, our review of the payments made to Ul under the contract disclosed risks that GRYD must address through improved contractor oversight and expenditure tracking for appropriate allocation to eligible funding sources.

    Ul's report provides a very detailed description of the challenges encountered during their first year. These challenges were similarly described in our audit report, which led to our conclusion that real program results, i.e., the measured impact and outcome of the GRYD programs, were still unknown, and not anticipated for at least another year. Ul's report also provides an overview of street gangs in the U.S. and Los Angeles, describes the GRYD Program, as well as the challenges and successes of the program's development and implementation, lessons learned, the results of a risk factor pilot retest, and identifies evaluation design decisions for the future.

    Our conclusion is based on a comparison of the contract's description of services that were to be provided by Ul (and therefore expected by the City) to the information contained in Ul's Year 1 report. Per the contract, the City would pay Ul an amount not to exceed $900,000 for the complete and satisfactory performance of the Agreement terms. The contract stipulated that Ul would work with the GRYD Office "to evaluate the gang reduction and youth development strategy, including intervention and prevention services provided by contractors in the GRYD zones and in targeted areas of need outside of the GRYD zones." GRYD has since indicated that management agreed to revise Ul's scope of work based on operational challenges with program implementation. The contracted services are summarized below, with our assessment on whether they were fully met:

  • Honorable Members of Au, .; and Governmental Efficiency Cor. .ittee February 9, 2011 Page 3 of?

    1. Conducting separate evaluations for each of the 12 GRYD zones and then pooling the results to obtain a comprehensive GRYD assessment (Research and Evaluation);

    Auditors Assessment: Not Completed.

    Ul completed 12 "Zone Profiles" in addition to the Y1 Report. Though these reports were titled "Evaluation of the LA GRYD Program: Zone Profile", they discussed specific issues within each zone relative to the implementation of the anti-gang strategies funded through GRYD. While these reports present useful baseline and process information, including the successes and challenges to the program's implementation, neither the 12 zone profiles nor the overall Year 1 report concludes on the overall effectiveness of the GRYD program, or the City's revised anti-gang strategy. In fact, Ul's report acknowledged this, stating that "the evaluation was significantly handicapped during Y1 with respect to the outcome component". Accordingly, the reports prepared and issued by Ul in August 2010, titled "evaluations" fall short of what was expected by this effort per the original RFP, Ul's proposal, and the contract.

    2. Data collection and analysis on the implementation process to assess progress towards benchmarks and fidelity to program design including the development of a scorecard to gauge community perception of gang-related issues, pre-post analyses of individuals to determine the effect of the prevention and intervention programs on the participants, analyses of community level data of the outcome measures, cost benefit analysis to assess the costs of implementing GRYD's strategy in relation to the potential reductions in the levels of gang crime and other outcomes (Data Collection and Analysis);

    Auditors Assessment: Partially Completed.

    Ul's zone profiles and the Y1 Report describe providers' program implementation successes and challenges (fidelity to program design) and the Y1 Report also provides pilot results from a reassessment of a small sample of GRYD program youth (pre-post analyses). However, Ul acknowledged that the pilot retest is not an outcome assessment. Ul also acknowledged delays in obtaining gang and crime data at the GRYD zone level from the Los Angeles Police Department. As a result, Ul would not have been able to perform a cost benefit analysis on the costs of GRYD's strategy to reductions in gang crime and other outcomes.

    3. Creating a series of reports including quarterly progress reports to explain statistical models and analytical methods used to analyze monthly data

  • Honorable Members of Au, j and Governmental Efficiency Cor, .lttee February 9, 2011 Page4 of?

    collected from GRYD Zones, a process and outcome briefing and summary interim finding report and a final evaluation report (Reporting).

    Auditor's Assessment: Not Completed.

    Although U I technically submitted all the required reports, because they did not satisfactorily complete the Research and Evaluation and all of the Data Collection and Analysis tasks, the Year 1 report does not contain all of the information that was contractually expected.

    We recognize that challenges can be common when evaluating complex social service programs, however, in light of the setbacks encountered over the first year. Through the quarterly progress reports provided by Ul, it was evident that the consultant would not be able to conduct the full outcome evaluation. However, GRYD did not formally amend or renegotiate the Ul contract, nor communicate these challenges or revised expectations to policymakers and the public. Ultimately, the City did not get the product from Ul that was defined by the contract and expected by the public, though still paid close to the contracted amount.

    GRYD management believes the services provided by Ul in the first year were valuable and necessary to help refine GRYD's models and approaches. GRYD describes much of this as a process evaluation, that shifted Ul's work from collecting and analyzing data, to having to first train and counsel service providers, who had never taken part in a rigorous evaluation process and were initially reluctant or resistant to participate. Interim reports prepared by Ul discuss activities relative to establishing trust and an effective working relationship with the providers, as well as developing a data collection system, working with a newly established Evaluation Advisory Committee, and expanding the evaluation to include the Summer Night Lights program. However, because there was no formal contract modification or subsequent renegotiation as to contract amount related to the changes in scope, the value of these services, including amounts paid, cannot be determined as to reasonableness.

    Year 2 Planned Activities

    According to Ul's Year 1 Report, the GRYD Office has made progress to address the issues that hampered their ability to complete an evaluation during Year 1. For example, program implementation is stronger and more uniform now than when Ul began its work in 2009, and GRYD's information system, GRYDIS, is now being used by all prevention providers. Ul stated that "the prospect of reporting more solid program implementation and rigorous outcome results in the Y2 annual evaluation report appears to be quite strong."

    This is encouraging, but it remains imperative that the GRYD Office ensure that the evaluation progresses in a timely manner, and will include programmatic outcomes. If it becomes apparent that Ul is again facing setbacks, the GRYD Office must act quickly to

  • Honorable Members of Au, J and Governmental Efficiency Cor. .ittee February 9, 2011 Page 5 of 7

    postpone, cancel or revise the contracted scope of work. Otherwise, as stated in our audit, the GRYD Office risks spending hundreds of thousands of dollars while again encountering delays and challenges with no performance evaluation completed.

    The GRYD Office has recently contracted with a professor from California State University, Los Angeles to serve as an in-house evaluator who will oversee the program evaluation. Having this in-house expertise should help ensure that the evaluation progresses smoothly and in a timely manner.

    Additional Observations

    Our review of contract payments made to Ul noted additional areas of risk that must be addressed. These were discussed with GRYD management so that corrective actions could be implemented quickly.

    Tasks and Activities Paid for by the City

    In addition to comparing the Year 1 Report to the expected tasks outlined in the contract, we also reviewed Ul's monthly invoices as a means to determine the tasks and activities completed by Ul. Per the contract, Ul was required to submit a report detailing the tasks and activities completed each month. However, it does not appear that Ul supplied this ·information to the GRYD Office with each monthly invoice. We noted Ul's quarterly reports provided a description of the work performed. GRYD management maintains that Ul's work was both necessary and useful to the program in providing process evaluations, collecting pilot YSET re-test preliminary outcomes and setting the foundation for Y2 full outcomes. GRYD management stated that Ul's revised work efforts were directed through informal agreement, and agrees that changes in Ul's scope of work in response to "the programmatic realities on the ground" were not formally documented, as they should have been.

    As stipulated in the contract, Ul is paid on a cost reimbursement basis in accordance with an agreed-upon budget. This is an acceptable method for the City to pay contractors, but requires diligent oversight to ensure that invoices are adequately supported, including documentation of tasks and/or deliverables completed during the period. Oversight of the contractor's activities should also include assessing how consultants are expending their efforts on agreed-upon tasks, and determining if such efforts are commensurate with expected results, or whether any revisions to expected approach or the contract terms are appropriate. As previously stated, because there was no formal contract modification or subsequent negotiation to arrive at an amended contract amount related to the change in services provided, the amount paid for services performed cannot be evaluated as to reasonableness.

  • Honorable Members of Au, ; and Governmental Efficiency Cor, .ittee February 9, 2011 Page 6 of7

    Grant-Funded Payments to Ul

    As of October 2010, of the $767,026 that was paid to Ul, $162,351 was funded by two federal grants and one State grant. Grant funding was provided by the following:

    1. Dept. of Justice, Office of Justice Programs' Bureau of Justice Assistance FY 2007 Edward Byrne Memorial Discretionary Grant

    This grant was to support the 77th Street Gang Reduction Zone in reducing violent crime through a comprehensive, coordinated approach involving multiple community-based service providers offering prevention, intervention, reentry and suppression activities, as well as local and regional enforcement activities, such as the Los Angeles Police Department (LAPD), City Attorney, Los Angeles District Attorney, and Los Angeles County Probation Department. The grant award included $85,000 for a 77th Street Gang Reduction Zone Evaluation to be coordinated with eight existing gang zones to develop a formative/process evaluation and outcomes/performance evaluation.

    2. Bureau of Justice Assistance FY 2006 Congressional Mandated Award

    This grant was to reduce violence and gang-related crime in the Baldwin Village area through a coalition of multiple community-based organizations, law enforcement (LAPD, City Attorney, Los Angeles District Attorney and Los Angeles County Probation Department) schools and employment providers. The grant award was initially part of the Baldwin Village Safer Cities Initiative: S.T.O.P. (Suppression of Crime through Training and Education Outreach .to Services in Participation with the Community). In November 2007, Baldwin Village was declared a GRYD Zone. The grant award included $85,000 for an evaluation to provide measurements of program fidelity, processes, and operations and objective measurements of violent crime and qualitative observations for the Baldwin Village area.

    3. FY 08 California Gang Reduction, Intervention and Prevention Program grants

    This grant was to sustain the efforts of the comprehensive Gang Reduction Strategy in Boyle Heights. The grant award included $40,000 for an outside consultant to evaluate the Boyle Heights Gang Reduction Zone on an on-going basis. The evaluation consultant was expected to use baseline data from the close-out evaluation of the City's previous Gang Reduction Program in Boyle Heights as a starting point and then collect quantitative and qualitative data moving forward.

  • Honorable Members of Au~ 3 and Governmental Efficiency Con ..• ttee February 9, 201 1 Page 7 of7

    In our review of payments made to Ul, we observed potential issues related to the grant reimbursements. First, the grants were awarded to the GRYD Office with the expectation that the funds would be used for a program evaluation. As stated for the reasons noted above, the GRYD Office did not complete a comprehensive program evaluation in Year 1, yet the GRYD Office paid Ul with these grantfunds.

    Second, the grants were awarded to the GRYD Office for evaluations of specific GRYD zones; however, the GRYD Office paid the full amount invoiced by Ul for a month or months' work with those grant funds. For example, one grant was awarded to the GRYD Office for an evaluation of the Baldwin Village GRYD Zone. The GRYD Office charged Ul's entire May and June 2009 invoiced charges to this grant Though we cannot verify the specific activities performed by Ul due to the absence of the required monthly report, it seems unlikely that Ul spent the entire period on evaluation work related to only one GRYD zone.

    While the City's contract with Ul specified payment schedules, including grant funds to be used, the three grants referenced above appear to be intended to fund activities related to only those areas (GRYD zones). These issues appear to be in violation of the grant agreements and could put the City at risk to reimburse the funds.

    GRYD maintains that grantors were informed of the evaluation activities through required progress reports, and at no point did any grantor indicate that funds were being used out of compliance. However, GRYD's practice of charging entire months' of consultant services to specific grants with an area-specific limitation, coupled with the absence of data or an accounting of how the consultant's efforts and their related fees related to specific GRYD zones, could result in questioned costs. The GRYD Office should seek specific approval and clarification from the grantor agencies that the payments to Ul for overall activities, which included some zone-specific work, though possibly incurred during other periods from which they were charged, are allowable costs, as defined in the grant agreements.

    Going forward, we recommend stronger oversight of Ul during Year 2 to ensure that a comprehensive program evaluation can be completed, and that GRYD appropriately allocates evaluation expenditures to eligible funding sources.

    Sincerely,

    ({~~-/~ WEN GREUEL City ntroller

    cc; Guillermo Cespedes, GRYD Director

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    A. Monitoring Protocol Manual

    B. Additional Contract Language

    The GRYD office is expanding the scope of the existing written "monitoring protocols manual" beyond fiscal/administrative, and contract compliance protocols. In addition to these administrative areas, the new expanded written manual will include programmatic service delivery checklists that will monitor contractor's adherence to the GRYD prevention and intervention models of practice. This manual will incorporate both the administrative functions and the clinical functions of contractor's

    As the prevention, and intervention programs have evolved the GRYD Office has identified additional areas of responsibilities for contractors. Therefore in the 2010-2011 FY contracts, the GRYD office has expanded the contractual obligations of contractors to include: a) participation in a peer learning network for prevention contractors, b) participation in the compstat inspection for intervention contractors, c) adherence to the GRYD model of service delivery by prevention contractors, d) participation in all going

    September 2010 to December 2010

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  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    specific evaluation tasks including data collection, and tracking of non eligible youth for prevention providers, f) participation in Summer Night Lights planning and programming.

    C. Formation of Prevention Team The GRYD office will form a Prevention Team that will September 2010 to June be responsible for monitoring all prevention contracts. 2011 The prevention team will monitor: a) Concrete compliance administrative issues such as number of clients, consent forms, data collection and evaluation obligations b) Clinical compliance issues related to adherence to tne prevention model of practice that includes the family, individual, and peer domains of services. The Prevention Team will include staff with demonstrated experience in prevention models of practice. This team will report to the Research Director, and have monthly joint meetings with the GRYD Deputy Mayor/Director

    D) Sub Contractor Monitoring All providers will be formally monitored on a quarterly September-November 2010, basis (and as needed depending on performance). December 201 0-February Major Sub-contractors (as defined by the size of their 2011, March- June 2011, and contract and the breadth of services provided) will be as needed included in these site visits. GRYD staff will visit the facilities and review the documentation of both the primary provider and all major sub-contractors. Primary providers will also be responsible for monitoring all of their sub-contractors (major and minor) on a quarterly basis. Documentation of these monitoring visits will be reviewed during these visits by GRYD staff.

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    E. Intervention Monitoring In order to increase the level of practice accountability November 2010 and on going while at the same time providing intervention contractors with additional tools to track their work, the GRYD Office will establish a Compstat Inspection Process for Intervention Agencies. This process will consist of the following: a) The intervention teams in all12 GRYD zones will come together in the compstat room, b) One intervention team for a specific GRYD zone will be designated as the "presenter" for that meeting c) All gang related crime data for that GRYD zone will be outlined via maps, and charts, d) The presenter for that meeting will outline the specific strategies of that team in addressing the gang related crime data presented.

    The intervention compstat inspection will be attended by crisis intervention workers, and selected GRYD office staff. This contractually mandated inspection has been added to the practice obligations of intervention contractors, and will serve to increase effectiveness in tracking and following up on gang related incidents.

    Intervention agencies will also be monitored on a quarterly basis in order to review provision of case management services. Monitoring will include a review of client case management files which include intake, assessment, case notes, case plan, and trackinq mechanism for client referrals.

    F. GRYDIS Training The use of GRYDIS data collection system will be August 2010, and as needed expanded to include additional case management functions, family based work, and intervention services.

  • G. Cabinet

    MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    Training in the GRYDIS data collection system will be expanded to include all GRYD staff. This training will be implemented in the following manner: a) All GRYD administrative staff have been re-trained during the month of August, b) All GRYD program staff will be trained during the month of October, c) All GRYD providers will be provided additional training in the "model adherence" application of GRYDIS The GRYD Cabinet has been re-structured as a body that will implement specific collaborative projects. Conceptually the GRYD Cabinet will be guided by the family life cycle, meaning that all collaborations must leverage program development efforts that will address needs at all stages of family life.

    Three projects have been chosen for 2010-2011 with subcommittees for each project: 1) The co-location project that will bring City and County resources under one roof at the Family Resource Center site in Pacoima GRYD zone, 2) The Probation Youth Transition Project headed by the County in which GRYD contracted intervention workers will accept referrals, 3) A pilot project that will develop a conceptual framework and a model for intervening with multi-generational gang involved families. This pilot project will be carried out with three families in one GRYD zone.

    The attached chart shows the relationship of the GRYD Cabinet to the GRYD advisory groups, the County CEO Gang Violence Reduction Advisory

    August 2010- September 2011

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    A. Collaboration with County on SNL

    n Youth Community Transition Project

    The GRYD SNL Program has been collaborating with I July 2010- to Sept 2011 the County at the Normandale and Hubert Humphrey 2010 SNL sites. County representatives participate in the SNL planning process as well as link SNL participants to the following County Resources: District Attorney, LA County Dept of Social Services, LA County Child Support Services, Community and Senior Services, Office of Emergency Management, and Department of Public Health and Women's Health. In 2010-2011 The GRYD Office will: a) provide overall consultation to County in the development of the Parks After Darks Program which is modeled after the City's SNL Program, b) Collaborate with the County in the development of Parks After Dark at Ted Watkins

    The GRYD Office will: a) collaborate with the County I Sept 2010 to June-201 0 CEO Office by providing referral resources of intervention services in the Pacoima County demonstration site b) develop an MOU with County

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    C. Peer Learning Network Initial planning meetings have taken place to develop January 2010 City-County Collaboration in the GRYD Peer Learning Network. The GRYD Peer learning network will bring together prevention providers to accomplish the following: a) Contractors will receive training in the areas of family systems model of practice, individual models of practice, peer based models of practice, b) Contractors will present examples of their best practices as it relates to targeting specific risk factors for gang joining. In the context of the Peer Learning Network City and County would share training resources specific to familv svstems model of practice.

    D. Community Education Campaign The GRYD Office will complete a Community September 201 0-March 2011 Education Campaign (CEC) to each school in each GRYD zone, and those schools attended by youth in each GRYD zone. The first phase of the CEC campaign began in Spring of 2010, and the second phase will be completed by March 2011. All CEC training presentations are carried out by GRYD staff. The focus of the CEC is to provide school personnel and parent groups with information on the identified 9 risk factors for gang joining as well as on the process of making referrals to prevention agencies. An evaluation survey will be administered to the participants in the CEC campaign.

    E. Intervention Agreements A number of GRYD Intervention agencies have been September- November 20 l 0 able to establish agreements with local schools in order to provide services on the school campus, obtain referrals, and assist with monitoring hot spots surrounding the school. In order to facilitate services to all schools in GRYD zones, the GRYD Office will formalize~MOLJ_INi!h [_JI.l)SD that will enable GRYD

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    agencies, both Prevention and Intervention, to have access to school sites and increase collaborative efforts.

    F. Crisis Response Protocol GRYD and LAUSD had an informal protocol to December 2010- February 2011 address violence that impacts students in the GRYD zone schools. The Crisis Coordinator for LAUSD that GRYD worked with previously has retired and a new Coordinator has taken over this role as of August 2010. GRYD will establish a relationship with the new Crisis Coordinator and formalize an agreement that establishes a Protocol for Crisis Response in and around LAUSD GRYD zone schools to address gang related violence that may impact the school site.

    GRYD Cabinet facilitator and convener (Attorney Lois Thompson) will assist in developing and finalizing a MOU with LAUSD that will enable GRYD providers to gain access to schools, provide services on campus and establish protocols for crisis response, among other services.

    G. Collaboration between the GRYD The GRYD Office and HAC LA currently have an July 2010- July 2011 Office and HACLA in relation to SNL MOU that specifies the terms of the collaboration in

    relation to the SNL Program.

    This collaboration has yielded the following: a) SNL 2009 the GRYD Office leveraged infrastructure projects by creating a public private partnership between HACLA, Nike, and the LA84 Foundation and built permanent skate parks at Nickerson Gardens and Imperial Courts, and a futsal (mini soccer) field at Nickerson.

    This collaboration continues to be reinforced through

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    I

  • MAYOR'S OFFICE OF GANG REDUCTION AND YOUTH DEVELOPMENT (GRYD) ACTION PLAN IN RESPONSE TO CONTROLLER'S AUDIT

    zone adv1sorv group a

    The GRYD.·office·will·irnplementthe•following:

    A. YSET Re-Test All of the youth that have been each prevention contractor in each GRYD zone will be re-tested. This process will be facilitated by each prevention contractor in collaboration with the evaluation consultants

    The evaluation consultants will: a) interpret data and provide The GRYD Office with re~test resu