Exhibit_A_-_City_of_Wheat_Ridge_Statement_of_Work_6.12.26_V3.docx

Grant Agreement # Exhibit A - Statement of Work

Exhibit A - Statement of Work Grant Agreement # City of Wheat Ridge, Colorado

Section 1: Project Background and Description The following section provides an overview of the Local Implementation, Mitigation, and Policy Action Accelerator Program (Local IMPACT Accelerator or “Accelerator” hereafter) and the City of Wheat Ridge (“the Grantee” hereafter) specific policy and project work. It also includes key requirements from the U.S. Environmental Protection Agency (EPA) and the Colorado Energy Office (CEO).

The term “Grantee” refers to recipients of CEO CPRG funding and “Grant Agreement” refers to the Intergovernmental Agreement between Grantees and CEO. However, CEO will refer to Grantees as “Subrecipients” and Grant Agreements as “Subaward Agreements” for all other documentation, in order to align with EPA’s naming conventions.

Overview of EPA and CEO Compliance Requirements The Grantee shall comply with all Federal Award Terms and Conditions associated with CPRG, including EPA General Terms and Conditions, 2 CFR 200, 2 CFR 1500, 40 CFR 33, Clean Air Act Sec 137, and all Quality Assurance (QA) requirements as detailed in Task 2. In addition, the grantee shall comply with CEO specific requirements including those that serve to monitor risk and performance as noted in Section 8.

Overview of the Accelerator Program The Accelerator will provide a total of approximately $50 million in grants from the EPA Climate Pollution Reduction Grant (CPRG) program. These funds will support local governments in adopting policies that extend beyond state requirements in four categories (Buildings, Land Use, Transportation, Waste) in order to bolster local resilience, reduce emissions, and advance other state priorities, such as improved air quality.

Overview of the Grantee Policy and Project The City of Wheat Ridge will develop and adopt housing-supportive zoning code amendments to remove regulatory barriers related to (1) attached housing in residential areas and (2) multi-family and mixed-use development near transit and commercial corridors, to be approved by City Council. The policy work includes a zoning code audit, stakeholder engagement, and drafting of ordinance amendments aligned with adopted housing, sustainability, and comprehensive plans.

This effort is supported by project activities that implement fee rebate programs for ADUs and multi-family development and provide financial support for soft costs for affordable housing. The project will reduce development barriers and accelerate delivery of diverse and affordable housing options enabled by the policy.

By executing this Grant Agreement, the Grantee commits to pursuing the adoption of local policies that exceed minimum State and local standards, as committed to in the Grantee’s Accelerator application and required by the Accelerator Program Guidance.

Overview of Deliverables and Work Products Deliverables, which must be submitted to CEO for review and approval, are distinct from work products, which are materials developed by the Grantee or its vendors that do not need to be submitted to CEO. Deliverables for this Statement of Work include the monthly progress reports, the final report, Quality Assurance and Compliance documents, and the Task Continuation Work Request. For tasks where the Grantee is expected to complete work or create work products but is not required to submit a deliverable to CEO, the Grantee shall provide a detailed summary of work progress in monthly progress reports. This requirement is noted in both the Summary of Task Deliverables sections and Section 3: Project Schedule as “Detailed to CEO in monthly progress reports.”

Unless otherwise stated, CEO will not require the Grantee to submit work products for approval, but the Grantee is expected to save all work products and have them readily available for CEO for monitoring or risk assessment. Work product completion will be validated through monthly reports and in monthly meetings with the Program Manager.

Overview of Phased Funding Approach CEO has awarded the Grantee funding in a phased approach, where the Grantee may only begin certain tasks after the completion and approval of prior tasks.

The Grantee may only begin work and submit reimbursement requests for the available funding amounts associated with Task 1-3 in Table 1 below until a Task Continuation Work Request is approved, as described herein. Upon completion of Task 3 - Advance Milestones toward Policy Adoption, the Grantee must submit a Task Continuation Work Request to CEO. The Grantee is prohibited from working on any task following Task 3 until they have received CEO approval of their Task Continuation Work Request. See Task 3.3 Task Continuation Work Request for request submission details. See Table 1 below for funding availability by phase and task.

If the Grantee fails to submit a Task Continuation Work Request or if CEO does not approve the request, CEO's maximum liability to the Grantee will be limited to the funds approved for Tasks 1-3. In such an event, CEO reserves the right to de-obligate any remaining project funding.

Table 1

Section 2: Work Tasks, Deliverables, and Timeline

· The Grantee shall complete the following work tasks and provide the following deliverables to CEO, subject to CEO’s (or others’) final approval and discretion.

· Any work products and deliverables must comply with the State of Colorado technical standards related to technology accessibility and with Level A and AA of the most current version of the Web Content Accessibility Guidelines (WCAG), currently WCAG 2.1.

· The State may require compliance to the State’s accessibility standards for any work product be determined by a third-party selected by the State. Please refer to the Vendor Accessibility Guide for more information on the State's accessibility requirements.

· The Grantee and its vendors and contractors shall adhere to Addendum 1, Artificial Intelligence (AI) Disclosure and Use Requirements, which includes disclosing in writing whether and how AI is used, human oversight of AI-generated content, data protection and confidentiality, and quality and accuracy standards.

· In all cases, CEO will need time to review deliverables. Whether called out in specific tasks or not, the Grantee should allow at least one week for CEO review and one week for the Grantee to accept edits into their process. Building in at least two additional weeks (or more) for this full review process will help ensure deadlines are met with an appropriate buffer to ensure the end product is meeting all standards for quality, accessibility, and design.

Task 1 Project Communication and Administration Project communication and administration activities are expected to occur for the duration of the project and include the tasks below.

· Task 1.1 Kickoff Meeting The Grantee shall attend a 60-90 minute (virtual or in-person) kick-off meeting with CEO, ideally within one week but no more than 12 business days of Grant Agreement Effective Date unless otherwise allowed in writing (i.e., email) by CEO.

· Task 1.2 Monthly Meetings The Grantee shall attend monthly meetings (virtual or in-person) with CEO. If the CEO Program Manager (PM) determines that meetings should be held more or less frequently, CEO will communicate this in writing (i.e., email).

· Task 1.3 Monthly Report The Grantee shall submit a monthly report, using a CEO provided template, no later than the 15th day of the following month unless otherwise allowed by CEO in writing (i.e., email). If the 15th day falls on a weekend or holiday, the report is due the Monday or workday following the weekend or holiday. The report shall summarize work for the previous month, including but not limited to: A) project status, B) a description of the work products, deliverables and tasks completed during the reporting period, C) budget expended and remaining by cost category, D) project findings, E) unanticipated outcomes or roadblocks, and, F) next steps in the project. The Grantee shall also include a description of Quality Assurance and EIO activities completed including, but not limited to: status of QA deliverables, collection and/or use of primary or existing data, or any other QA or EIO related activity. If work is behind schedule, the Grantee should provide a summary of reasons for the delay and an action plan to get back on schedule. The Grantee shall submit the monthly report together with the monthly invoice (unless CEO has approved an exception) in order to show grant spend down and timely billing to CEO. Note that a monthly report is required whether or not an invoice is submitted.

· Task 1.4 Annual Report Each year by the 15th of September, unless otherwise allowed by CEO in writing (i.e., email) the Grantee will submit an annual report, using a CEO provided template, which will replace the monthly report for that month only and require additional details. These will include: A) Verification that the Grantee has reviewed their Supplemental Assurance Plan, (SAP) as required in Task 2, B) Submission of the Grantee’s updated SAP, as necessary, and C) Confirmation that the Grantee is advancing milestones toward policy adoption, that the policy adoption timeline is still accurate, and a list of any risk mitigation strategies being applied to ensure the policy adoption will be successful. Failure to provide the necessary details above including showing the jurisdiction is still working to advance the policy/policies it committed to passing may result in actions such as pausing grant funding until such time as those details can be adequately provided to CEO and the CEO PM accepts the annual report.

· Task 1.5 Final Project Report The final report should describe project outcomes against tasks/subtasks, summarize achievements, challenges, and lessons learned, and be no more than five (5) pages. CEO will provide the Grantee with a final report template. The final report shall be submitted with the final invoice, which should indicate completion of all project deliverables. Final reports are due within 45 days of the expiration of the Agreement. However, the Grantee will not be reimbursed for hours spent completing the final report if those hours occur after the expiration of the Agreement.

Summary of Task 1 Deliverables

· 1.1 Kickoff Meeting. Within 12 business days of the Grant Agreement Effective Date.

· 1.2 Monthly Meetings. Monthly after the kickoff meeting.

· 1.3 Monthly Reports. Due by the 15th calendar day of the following month.

· 1.4 Annual Report. Due annually on September 15.

· 1.5 Final Project Report. Due within 45 calendar days of the Grant Agreement expiration date.

Task 2 Quality Assurance EPA requires that all organizations performing Environmental Information Operations (EIO) must adhere to EPA’s Quality Assurance Policy and that all EIO shall be implemented in accordance with an approved Quality Assurance Project Plan (QAPP). As such, all grantees under the Accelerator program must adhere to EPA’s Quality Program, CEO’s QMP (Quality Management Plan), CEO’s QAPP or CEO’s Programmatic Quality Assurance Project Plan (PQAPP).

In order to simplify this process for Grantees, CEO is drafting a PQAPP for EPA approval. The PQAPP outlines how CEO will perform EIO relevant to Accelerator Grantee project scopes, such as the use of existing environmental data or the collection of limited primary environmental data. CEO will provide the Grantee with a list of EIO activities covered by CEO’s PQAPP.

As part of adhering to CEO’s PQAPP, the Grantee must complete and submit a Supplemental Assurance Plan (SAP) to provide CEO with all expected data sources and reports the Grantee intends to use. CEO will review the SAP and determine if CEO’s PQAPP will cover the Grantee’s EIO, or if the Grantee will need to draft their own QAPP for EPA approval. Grantees that do not need to draft their own QAPP must only complete Tasks 2.1-2.3 below. Grantees that need to draft their own QAPP, whether determined before the Agreement Effective Date or during the term of the Agreement, must still complete Tasks 2.1-2.3 but must also complete tasks 2.4-2.6 below.

CEO will provide $40,000 in funding to Grantees to support the Quality Assurance activities detailed below. If it is determined jointly by CEO and the Grantee that funding support for PQAPP/SAP/QAPP compliance is not needed and CEO agrees to exercise this option, CEO may reallocate the funding associated with this task. The Grantee or CEO may initiate this request and it must be confirmed in writing (i.e. email) by CEO. Allowable uses of reallocated funds include but are not limited to: A) compliance with other federal requirements in this Agreement, B) adding funding to augment another task within this SOW, C) funding an optional task (if one is listed in this SOW and CEO agrees to exercise the option in writing (i.e., email) to Grantee), or D) adding a task not in the current SOW. Option D will require an amendment to the Agreement before work can begin.

· Task 2.1 SAP Submission The Grantee must complete and submit a SAP to CEO for review and approval with all expected data sources and reports the Grantee intends to use. In some cases, EPA may review as well. The Grantee must receive CEO approval of the SAP prior to engaging in EIO. CEO will provide the Grantee with a SAP template.

· Task 2.2 Annual SAP Review The Grantee must conduct a formal annual review of their SAP to confirm the information is still accurate and submit the review to CEO for approval. CEO will provide guidance on how to perform and document an annual SAP review.

· Task 2.3 Ongoing SAP QA Monitoring In addition to the formal annual review, the Grantee must also regularly review their SAP and track minor changes as needed. This includes reporting on Quality Assurance during each monthly meeting and monthly progress report. If, at any point throughout the grant term, either the Grantee or CEO determines the Grantee is working on EIO-related activities that are outside of the scope of the Grantee’s SAP, the Grantee shall immediately stop work on EIO-related activities and consult with the CEO PM and CEO’s Quality Assurance Manager. The Grantee may not resume work on EIO-related activities until CEO identifies a remedy, which is likely the resubmission of a revised SAP for CEO approval. As evidenced to CEO in monthly progress reports as well as in the SAP if/when a change is needed.

· Task 2.4 QAPP and Crosswalk Submission (if a QAPP is required) If the Grantee’s scope of EIO exceeds that which is covered by CEO’s PQAPP, the Grantee must develop their own QAPP and associated QAPP Crosswalk for EPA approval. The QAPP Crosswalk is used to ensure each aspect of the QAPP has been completed and meets EPA requirements. The Grantee will submit these documents to CEO for review, and CEO will provide feedback for the Grantee to incorporate prior to EPA submission. CEO will then submit the Grantee’s final QAPP/QAPP Crosswalk to EPA. The Grantee is expected to incorporate all edits and revisions until EPA provides final approval.

· Task 2.5 Annual QAPP Review (if a QAPP is required) If the Grantee has developed their own QAPP, the Grantee must conduct a formal annual review of the QAPP using the EPA QAPP Crosswalk to confirm the information is still accurate or identify and describe any changes to the approved QAPP. QAPP Crosswalks and/or revised QAPPS must be submitted to EPA no later than 60 calendar days prior to the anniversary of the EPA QAPP approval date. In order to provide CEO time to evaluate the Grantee’s annual QAPP review, the Grantee must submit the QAPP Crosswalk and, if applicable, the revised QAPP to CEO at least 90 calendar days prior to the anniversary of the EPA QAPP approval date.

· Task 2.6 Ongoing QAPP QA Monitoring (if a QAPP is required) In addition to the formal annual review, the Grantee must also regularly review their QAPP and track minor changes as needed. This includes reporting on Quality Assurance during each monthly meeting and monthly progress report. If, at any point throughout the grant term, either the Grantee or CEO determines the Grantee is working on EIO-related activities that are outside of the scope of the Grantee’s QAPP, the Grantee shall immediately stop work on EIO-related activities and consult with the CEO PM and CEO’s Quality Assurance Manager. The Grantee may not resume work on EIO-related activities until CEO identifies a remedy, which is likely the resubmission of the QAPP for EPA approval.

Summary of Task 2 Deliverables

· 2.1 SAP Submission. Due within 30 calendar days of request by CEO PM.

· 2.2 Annual SAP Review. Due annually on September 15.

· 2.3 Ongoing SAP QA Monitoring. Ongoing. Detailed to CEO in monthly progress reports (or in a SAP update as needed).

· 2.4 QAPP and Crosswalk Submission (if a QAPP is required). Due date to be determined by CEO Quality Assurance Manager.

· 2.5 Annual QAPP Review (if a QAPP is required). Due annually to CEO at least 90 calendar days prior to the anniversary of the EPA QAPP approval date.

· 2.6 Ongoing QAPP QA Monitoring (if a QAPP is required). Ongoing. Detailed to CEO in monthly progress reports.

Task 3 Advance Milestones towards Policy Adoption The subtasks in Task 3 represent the work that the Grantee must complete to demonstrate a good faith effort in advancing policy. CEO will not reimburse Grantee for work performed on any tasks following Task 3 until Task 3 is completed (unless otherwise allowed in writing by CEO).

· Task 3.1 Hire a Zoning Code Consultant The Grantee is committed to advancing several key milestones to demonstrate good faith effort toward policy adoption and unlock project funding. These advanced milestones include competitively hiring a consultant, through a competitive bid process, to complete a zoning code analysis. The consultant will also provide technical support to city staff in drafting code amendments, and supporting the policy adoption process in later tasks.

· Task 3.2 Complete a Zoning Code Audit The Grantee is committed to advancing several key milestones to demonstrate good faith effort toward policy adoption and unlock project funding. These advanced milestones include performing a technical analysis to identify zoning, permitting, and design barriers affecting 1) attached housing in residential areas and 2) multi-family and mixed-use development near transit and commercial corridors. Key milestones include: A) conducting an internal code audit amount city staff to identify known barriers and opportunities aligned with adopted housing and sustainability goals, and B) collaborating with the consultant to draft initial recommendations, and C) targeted one-on-one interviews with stakeholders, including builders and developers, to identify barriers and inconsistencies with the zoning code.

· Task 3.3 Task Continuation Work Request The Grantee shall submit a Task Continuation Work Request using a template provided by CEO via email to the CEO PM. The Grantee should also submit any associated documentation and/or publicly available hyperlinks as requested by CEO indicating completion of deliverables outlined in Tasks 3.1 and 3.2 with the Task Continuation Work Request. If the Grantee is unable to complete Tasks 3.1 and 3.2 due to unforeseen complications, they may request an exemption on the Task Continuation Work Request template and CEO will evaluate the request. If an exemption is granted, a formal Grant Agreement amendment may be required.

Summary of Task 3 Deliverables

· 3.1 Hire a Zoning Code Consultant. Estimated to start at the beginning of September 2026 and end at the end of February 2027. Detailed to CEO in the Task Continuation Work Request.

· 3.2 Complete a Zoning Code Audit. Estimated to start the beginning of September 2026 and end at the end of February 2027. Detailed to CEO in the Task Continuation Work Request.

· 3.3 Task Continuation Work Request. Due to CEO within 30 calendar days after Task 3.1 and Task 3.2 are completed.

Task 4 Policy Adoption The Grantee shall continue a good faith effort in advancing policy adoption. The following subtasks are a continuation of Task 3 and deliverables.

· Task 4.1 Attached Housing Zoning Code Amendment The Grantee is committed to advancing milestones towards policy adoption. These milestones include A) Draft zoning code amendments to enable attached housing, including updates to use permissions, dimensional standards, and development criteria, as applicable; B) Inform the community, using existing community engagement platforms that changes are being made in accordance with adopted plans; C) Coordinate with Planning Commission, City Council, and stakeholders to refine code amendments, and D) Present amendments to Planning Commission and City Council and advance adoption.

· Task 4.2 Multi-Family and Mixed-Use Zoning Code Amendment The Grantee is committed to advancing milestones towards policy adoption. These milestones include: A) Draft zoning code amendments to enable multi-family and mixed-use development, including updates to zoning districts, use tables, and development standards; B) Conduct stakeholder engagement with the community using existing community engagement platforms; C) Coordinate with City staff, Planning Commission, and stakeholders to refine amendments and ensure alignment with planning goals, and C) Present amendments to Planning Commission and City Council and advance adoption.

Summary of Task 4 Deliverables

· 4.1 Attached Housing Zoning Code Amendment. Estimated to begin in February 2027 and be completed by the end of March 2028. Detailed to CEO in monthly progress reports.

· 4.2 Multi-Family and Mixed-Use Zoning Code Amendment. Estimated to begin in February 2027 and be completed by the end of March 2028. Detailed to CEO in monthly progress reports.

Task 5 Project Implementation Comment by Alex Cortez - CEO: @russ.sands1@state.co.us and @tori.shaw@state.co.us Comment by Alex Cortez - CEO: flagging that for the rebate programs below - we did not include any language that would require the City of Wheatridge to develop eligibility requirements, we have included similar language in a lot of other SOWs that have rebates Comment by Shannon Terrell: We did provide preliminary eligibility criteria in questions 26 and 27 of the application. It would be helpful to know what process you guys would like to do to review our rebate eligibility criteria.

The Grantee shall implement projects to support adoption and implementation of the zoning code amendments including the following..

· Task 5.1 ADU Fee Rebate Program Implement a rebate program to offset plan review, and permit fees, and use tax for ADU construction, reducing upfront costs and increasing feasibility for homeowners. Comment by Alex Cortez - CEO: Does the $5,000 rebate cover the cost of the plan review, the permit fee and the use tax? Comment by Shannon Terrell: Yes, good catch. See revisions.

· Task 5.2 Multi-Family and Mixed-Use Fee Rebate Program Implement a rebate program for multi-family and mixed-use development, including plan review, permit fees, and use tax support, to improve project feasibility and accelerate housing delivery.

· Task 5.3 Affordable Housing Soft Cost Support Comment by Alex Cortez - CEO: Can you confirm this is also a rebate program? Where the City plans to reimburse 25% of the project costs per house. Would the City require that the beneficiary pay for 100% of the soft cost up front and then the City would reimburse up to 25% of the incurred costs? Comment by Shannon Terrell: Yes, this is a rebate program. The beneficiary or developer will pay 100% of these soft costs and the city will only reimburse $7,700 per housing unit. For a 50 unit development, that would be a rebate of $385,000 total.

Provide financial assistance for soft costs such as design, engineering, and permitting for deed-restricted affordable housing projects, enabling development of income-restricted units and advancing affordable housing production.

Summary of Task 4 Deliverables

· 5.1 ADU Fee Rebate Program. Estimated to begin in February 2027 and be completed by the end of April 2029. Detailed to CEO in monthly progress reports.

· 5.2 Multi-Family and Mixed-Use Fee Rebate Program. Estimated to begin in February 2027 and be completed by the end of April 2029. Detailed to CEO in monthly progress reports.

· 5.3 Affordable Housing Soft Cost Support. Estimated to begin in February 2027 and be completed by the end of April 2029. Detailed to CEO in monthly progress reports.

Section 3: Project Schedule

Section 4: Acceptance Criteria The Grantee shall submit all final deliverables to CEO by the dates established in this Statement of Work to CEO’s Program Manager, who shall determine whether deliverables meet the Task requirements in this Statement of Work and approve them. If needed, deliverables will be returned to the Grantee for modification before they are considered complete and reimbursement is made. CEO anticipates that prior to submission, all deliverables shall go through an internal review process and as such, shall reflect the requirements of this Statement of Work.

If project circumstances require modifications of the timelines within this SOW (prior to grant agreement expiration), the CEO may modify the respective Task deadlines (except for the grant agreement effective date and grant agreement expiration date and fund expenditure end date) provided any such modifications are appropriately justified and mutually agreed upon in writing (i.e. email) by both the CEO and the Grantee.

Section 5: Compliance Reporting Requirements The Grantee is responsible for adhering to all Federal Terms and Conditions referenced in the Overview of EPA and CEO Compliance Requirements section on page 1. If the Grantee's project prompts federal requirements such as compliance with Davis-Bacon and Related Acts (DBRA), Build America, Buy America (BABA) as required by CEO, the Grantee will be required to provide related documentation to CEO to demonstrate compliance. Exhibit C - Compliance Reporting outlines a detailed breakdown of any applicable reporting requirements that must be met prior to reimbursement.

Section 6: Budget CEO has reviewed and approved the budget in Exhibit B - Budget Information for this Agreement. The maximum amount payable under this Agreement to the Grantee by CEO shall be $2,640,000 as determined by the State from available funds. To make any changes to the approved budget, the Grantee shall follow the below processes and detail any requested changes in the monthly report. Note that Grant Agreement amendments cannot increase the total maximum amount of the Agreement unless otherwise approved by CEO, and CEO reserves the right not to approve budget change requests.

Budget Changes Requiring CEO Approval The following actions require written approval (i.e. email) from CEO and may also require a formal Grant Agreement amendment:

· Reallocating more than 10% of the total award value between cost categories.

· Reallocating any dollar amount of funds from Participant Support Costs to any other Cost Category or between Construction and any other Cost Category.

· Any changes to indirect rates or total indirect amounts. Grantees must use an approved NICRA, and all calculations remain subject to CEO approval.

· Any modification to the quantity or specifications of equipment purchases. While items listed in Exhibit B - Budget Information are pre-approved by CEO, any changes require CEO written approval.

Budget Changes Requiring CEO Notification

· Reallocating less than 10% of the total award value between cost categories excluding Participant Support Costs, Construction, and Indirect Costs.

Table 2

Section 7: Payment Payments shall be made in accordance with the provisions set forth in the Grant Agreement. The State shall pay the Grantee the reasonable, allocable, and allowable costs for work performed based on satisfactory progress of the work defined in this Grant Agreement.

The Grantee shall be reimbursed based on time and materials as outlined in the tasks and deliverables stated above and in Exhibit B - Budget Information.

The Grantee must provide supporting documents for each reimbursement request prior to the disbursement of any funds. Acceptable supporting documents may include invoices, copies of contracts, Vendor quotes/receipts, time and effort reports, and other expenditure explanations that justify the reimbursement requests. CEO may request additional information from the Grantee to support the payment requests prior to release of funds, as deemed necessary.

The Grantee shall be compensated only for work and services performed by the Grantee and accepted by the CEO pursuant to the terms of this Agreement. Payment shall also be contingent upon CEO’s timely receipt and acceptance of required reports described above. The Grantee shall be reimbursed no more than once a month based on the submission of the Grantee’s invoice and progress report.

The monthly progress report will provide detail of the work performed on each task or deliverable. The progress report should include a narrative that substantiates the work described on the invoice for each task/deliverable. The Grantee shall invoice by task on a time and materials basis for Tasks according to Exhibit B - Budget Information.

Section 8: Risk and Performance Monitoring To comply with state and federal requirements, the CEO must monitor and mitigate risk through its Risk Program. The State reserves the right to change monitoring procedures and requirements at any time during the Agreement term, provided the process does not unduly interfere with the Grantee’s performance.

CEO may request, collect, and validate any work products and invoice backup documentation (i.e. timesheets, receipts, contractor documentation, etc.)—including physically visiting project sites or public meetings—for auditing, checking performance, and mitigating risks.

CEO will develop its monitoring program to assign Grantees a risk level (lower or higher) based on factors such as fiscal security, fraud mitigation, technical support, and cybersecurity. Higher-risk Grantees may be required to comply with additional steps, including attending extra meetings, submitting additional documentation, documenting risk mitigation measures, or attending training, as deemed appropriate by the CEO and EPA. CEO will monitor risk and provide technical assistance as needed to the Grantee in order to help mitigate risk.

Addendum 1: Artificial Intelligence (AI) Disclosure and Use Requirements AI Disclosure: Grantees and any contractor or vendor funded under this grant agreement shall disclose in writing, prior to delivery of any deliverable, whether and how artificial intelligence tools, including generative AI, machine learning, or automated analysis systems, were used in creating or contributing to the deliverable. Disclosure shall include the specific AI tools or systems used and the nature of their contribution (e.g., research, drafting, analysis, editing).

Human Oversight Requirement: All deliverables shall be reviewed, verified, and approved by qualified personnel with relevant subject matter expertise prior to submission. The Grantee and any vendor or contractor funded under this grant agreement shall ensure that AI-generated or AI-assisted content is fact-checked for accuracy, reviewed for bias or errors, and validated against primary sources where applicable. The Grantee remains fully responsible for the quality, accuracy, and completeness of all deliverables regardless of AI use including for any vendor or contractor funded under this grant agreement.

Data Protection and Confidentiality: Grantee and any vendor or contractor funded under this grant agreement shall not input confidential state data, personally identifiable information (PII), or non-public information into any public or consumer-grade AI system. Any AI tools used must have appropriate enterprise-level data protections. State data shall not be used to train, fine-tune, or improve any AI model without prior written approval from the State.

Quality and Accuracy Standards: Deliverables must meet the acceptance criteria specified in the Statement of Work. AI-generated content must be clearly distinguishable from original research and analysis where appropriate. Reports shall cite primary sources and shall not rely solely on AI-generated summaries or conclusions for factual claims.

Requirements for Pass Through: Grantees shall use the language above in any solicitations and contracts or purchase orders to ensure that all contractors and vendors abide by these requirements. Grantees may modify the language as long as the intent of the language is maintained.