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Environmental Review No CDBG funds maybe committed to an activity prior to the satisfactory completion of an Environmental Review. PDD staff will complete this review at no-cost to the Implementing Department. Projects involving demolition, new construction, historic properties or facilities located in the 100-year flood plain may require a longer and more extensive review process. The implementing department agrees not to enter into any contracts or initiate any site limiting actions prior to being notified by PDD staff of the ER completion date. Labor Standards The general requirements for CDBG-funded construction projects include: Davis-Bacon Related Act: Title I, of the HCD Act and regulations at 24 CFR Part 570.603 require laborers and mechanics employed by contractors or subcontractors that perform construction work financed in whole or in part with CDBG funds must be paid at rates no lower than those determined in accordance with the Davis-Bacon Act, as amended (40 U.S.C. sections 276(a) - 276(a)(5)). Contract Work Hours & Safety Standards Act (CWHSSA): The HCD Act further requires that contractors and subcontractors comply with overtime compensation requirements, and pay covered workers no less than one-and one half times the base rate for hours exceeding 40 in a 7-day week in accordance with CWHSSA. Copeland Act: The Act makes it a Federal crime to cause or incur `kickbacks' (i.e., give up or pay back) of any part of a laborer or mechanics wages. Where it is determined that CDBG funds trigger the application of these labor standards requirements, the Implementing Department will ensure that the labor standards provisions (HUD 4010) and the applicable wage determination are incorporated into the prime contract. The Implementing Department will provide written confirmation of the incorporation of these documents. The Implementing Department will monitor labor standards compliance for construction work on the Project according to the procedures outlined on the exhibit attached to this MOU. Section 3 If PDD has determined that contracting conditions apply to the construction work pursuant to HUD regulations under Section 3 of the Housing and Urban Development Act of 1968, then the Implementing Department will review the bid specifications and the general or prime contract for construction to see that it includes the language required by 24 CFR Part 135 as listed in the Exhibit to this MOU. The Implementing Department will monitor the Project for compliance with these provisions according to the procedures outlined on Exhibit B to this MOU. Procurement and Cost Reasonableness CDBG regulations (referencing OMB Circulars) require a fair. and equitable process for obtaining bids and quotes. All work must be cost reasonable. Implementing Department will maintain documentation to .support this.