HomeMy WebLinkAboutResolutions - 2013.03.06 - 20714MISCELLANEOUS RESOLUTION #13036 MARCH 6, 2013
13Y; GENERAL GOVERNMENT COMMITTEE, CHRISTINE LONG, CHAIRPERSON
IN RE: HEALTH AND HUMAN SERVICES — HOMELAND SECURITY DIVISION —
MEMORANDUM OF AGREEMENT WITH THE FEDERAL EMERGENCY
MANAGEMENT AGENCY INTEGRATED PUBLIC ALERT AND WARNING SYSTEM
(IPAWS) PROGRAM MANAGEMENT OFFICE
TO THE OAKLAND COUNTY BOARD OF COMMISSIONERS
Chairperson, Ladies and Gentlemen:
WHEREAS the Oakland County Homeland Security Division has taken several actions
to plan and prepare for an emergency; and
WHEREAS during an emergency or threat to Oakland County, the Homeland Security
Division will need to alert the public; and
WHEREAS this system would allow the County of Oakland to distribute emergency
messages to alert the public following the guidelines and protocols outlined in the agreement;
and
WHEREAS forming agreements prior to an emergency ensures timely and collaborative
response efforts; and
WHEREAS this Memorandum of Agreement (MOA) defines a working relationship
between the Federal Emergency Management Agency Integrated Public Alert and Warning
System (IPAWS) Program Management Office and the County of Oakland, Homeland Security
Division; and
WHEREAS the MOA has been reviewed and approved by Oakland County Corporation
Council (#2013-0004).
NOW THEREFORE BE IT RESOLVED that the Oakland County Board of
Commissioners approves the attached Memorandum of Agreement between the County of
Oakland and the Federal Emergency Management Agency.
BE IT FURTHER RESOLVED that the Chairperson of the Board of Commissioners or
his designee is authorized to sign the Memorandum of Agreement.
Chairperson, on behalf of the General Government Committee, I move the adoption of
the foregoing resolution.
GENERAL GOVERNMENT COMMITTEE
GENERAL GOVERNMENT COMMITTEE
Motion carried unanimously on a roll call vote.
Memorandum of Agreement
between the
County of Oakland
and the
Federal Emergency Management Agency
Integrated Public Alert and Warning System
(IPAWS) Program Management Office
Regarding the use of:
County of Oakland
Interoperable System(s)
and
IPAWS OPEN Platform for Emergency Networks
(IPAWS-OPEN)
Version 1.0
WARNING: This document is FOR OFFICIAL USE ONLY (FOUO). It contains information that may be exempt from
public release under the Freedom of Information Act (5 U.S.C. 552). It is to be controlled, stored, handled,
transmitted, distributed, and disposed of in accordance with DHS policy relating to FOUO information and is not to
be released to the public or other personnel who do not have a valid "need-to-know" without prior approval of the
FEMA Integrated Public and Warning System and the FEMA Disclosure Offices.
MEMORANDUM OF AGREEMENT
SUPERSEDES: None
INTRODUCTION
The purpose of this memorandum is to establish a management agreement between the County of
Oakland, by and through the Oakland County Homeland Security Division, hereinafter referred to as the
Collaborative Operating Group (COG), and the Federal Emergency Management Agency (FEMA) IPAWS
Division regarding the utilization and security of County of Oakland Interoperable System(s) (as shown in
Appendix A), which interoperate with the IPAWS Open Platform for Emergency Networks (IPAWS-
OPEN). The expected benefit is to enable information interoperability across emergency response
organizations and systems as intended by the IPAWS Initiative.
This agreement will govern the relationship between the Collaborative Operating Group and FEMA,
including designated managerial and technical staff and system users associated with the
aforementioned COG. As indicated within the terms of this agreement, both parties agree to allow system
interoperability through the use of SOAP over HTTPS via the public Internet. Under this agreement, no
direct or networked connection using VPN (or equivalent technology) between the systems named in
Appendix A and IPAWS-OPEN is allowed. In the event a direct connection is required, an Interconnection
Security Agreement must be executed.
AUTHORITY
The authority for this agreement is based on the Communications Act of 1934, as amended (47 U.S.0 §
606) and the implementation of regulation 47 C.F.R § 11 which establishes the statutory basis under
which the FEMA IPAWS Program operates emergency alerting systems. In addition, Executive Order
13407 of June 26, 2006, Public Alert and Warning System Executive Order states, "It is the policy of the
United States to have an effective, reliable, integrated, flexible, and comprehensive system to alert and
warn the American people.,. establish or adopt, as appropriate, common alerting and warning protocols,
standards, terminology, and operating procedures for the public alert and warning system to enable
interoperability and the secure delivery of coordinated messages to the American people". In response,
FEMA established the IPAWS Program Management Office (PMO) in April 2007.
BACKGROUND
It is the intent of both parties to this agreement to establish and utilize a standardized web based
application interface (as defined by the IPAWS-OPEN Web Service Interface Design Guidance) between
the information technology (IT) systems shown below to facilitate the exchange of emergency messages
within the production environment. The testing of the interoperability of these systems has been
performed through the use of FEMA's Test and Development environment to ensure the transference and
receipt of emergency messages using approved messaging standards. The interoperability between
these systems is supported by the use of SOAP over HTTPS via the public internet.
COMMUNICATIONS
Frequent formal communications are essential to ensure the successful management and operation of
system interoperability. Both parties agree to maintain open lines of communication between designated
staff (as indicated in Appendix B) at both the managerial and technical levels. All communications
described herein must be conducted in writing and may be disseminated by electronic means unless
otherwise noted.
The owners of the respective systems agree to designate and provide contact information for technical
leads for their respective systems, and to facilitate direct contacts between technical leads to support the
management and operation of system interoperability. To safeguard the confidentiality, integrity, and
availability of the systems and the data they store, process, and transmit, both parties agree to provide
notice of specific events within the timeframes indicated below:
• Security Incidents: Technical, administrative and/or help desk staff will immediately notify their
designated counterparts by telephone or e-mail when a security incident(s) is detected and/or a
violation of the Rules of Behavior (see Appendix C) has been identified. Both parties agree to make
the appropriate technical and administrative individuals available for all necessary inquiries and/or
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investigations. Containment and/or resolution procedures will be documented by the identifying party
and after action reports generated and submitted to the system owner and/or designated security
officials within five (5) business days after detection of the incident(s).
• Disasters and Other Contingencies: The FEMA IPAWS Program Office will notify the COG by
telephone, e-mail or other acceptable means in the event of a disaster or other contingency that
disrupts the normal operation of IPAWS-OPEN.
• System Interconnections: This MOA is intended for systems interoperating with IPAWS OPEN
using SOAP over HTTPS via the public Internet. If in the future, an interconnection (i.e. dedicated
system-to-system connection) is required to IPAWS-OPEN, this MOA must be updated and an
Interconnection Security Agreement (ISA) must be executed. If a change in status from interoperating
to interconnected system is required, the initiating party will notify the other party at least 3 months
before the planned interconnection is to be in place.
• Discontinuation of Use: In the event the use of IPAWS-OPEN is no longer required, the COG
agrees to immediately notify, in writing, the FEMA IPAWS Program Office at which time the COGID
and associated access credentials will be deactivated.
• Personnel Changes: Both parties agree to provide notification of changes to their respective system
owner or technical lead. In addition, both parties will provide notification of any changes in the point of
contact information provided in Appendix B. All relevant personnel changes and changes to contact
information must be provided within 5 business days of the change.
TYPE OF INTERCONNECTIVITY
Both parties agree that the COG will utilize only the assigned COGID, associated credentials and digital
certificates provided by the FEMA IPAWS Program Office to support interoperability between the
system(s) listed in Appendix A and IPAWS OPEN. In addition, all interoperable systems must be
configured to interface with IPAWS-OPEN over the public Internet using only approved web service
standards and associated requirements. A listing of approved web service standards and supporting
requirements can be obtained from the IPAWS-OPEN Web Service Interface Design Guidance
document.
In the event, a dedicated connection is required, both parties will agree to negotiate and execute an
Interconnection Security Agreement (ISA) as required per Department of Homeland Security (DHS) policy
which must be signed by all required parties before the interconnection is activated. Proposed changes to
either system that affect system interoperability will be reviewed and evaluated to determine the potential
impact. If the proposed changes impact the agreed upon terms, the MOA will be renegotiated and
executed before changes are implemented.
SECURITY
To ensure the joint security of the systems and the message data they store, process, and transmit, both
parties agree to adhere to and enforce the Rules of Behavior (as specified in Appendix C). In addition,
both parties agree to the following:
• Ensure authorized users izil;UUbb ing the interoperable system(s) receive, agree to abide by and sign
(electronically or in paper form) the IPAWS-OPEN Rules of Behavior as specified in Appendix C.
Each jurisdiction is responsible for keeping the signed Rules of Behavior on file or stored
electronically for each system user.
• Utilize FEMA approved PKI certificates to digitally sign messages as they are transported over the
public Internet.
• Certify that its respective system is designed, managed and operated in compliance with all relevant
federal laws, regulations, and policies.
• Document and maintain jurisdictional and/or system specific security policies and procedures and
produce such documentation in response to official inquiries and/or requests.
• Provide physical security and system environmental safeguards for devices supporting system
interoperability with IPAWS-OPEN.
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(FEMA CIO) (FEMA CISO)
• Ensure physical and logical access to the respective systems as well as knowledge of the COGID
and associated access criteria are only granted to properly vetted and approved entities or
individuals.
• Where applicable, ensure that only individuals who have successfully completed FEMA-required
training can utilize the interoperable systems to issue alerts and warnings intended for distribution to
the public.
• Where applicable, document and maintain records of successful completion of FEMA-required
training and produce such documentation in response to official inquiries and/or requests.
COST CONSIDERATIONS
This agreement does not authorize financial expenditures by the COG on behalf of FEMA. The FEMA —
IPAWS Division is responsible for the costs associated with developing, operating and maintaining the
availability of the IPAWS-OPEN system. The COG is responsible for all costs related to providing their
users with access to IPAWS-OPEN via the public Internet. These costs may include hardware, software,
monthly Internet charges, completion of security awareness training and other related jurisdictional costs.
PROPERTY OWNERSHIP
Each Party agrees and acknowledges that nothing in this Agreement shall be construed as giving a party
any proprietary rights in or to the intellectual property of the other party. Each Party further agrees that
nothing in this Agreement shall be construed as creating or granting to a party any implied or express
license in or to the intellectual property of the other party.
TIMELINE
This agreement will remain in effect based on the life of the Authority to Operate (ATO) for IPAWS-OPEN
or a maximum of three (3) years after the last date on either signature in the signature block below. Upon
expiration of the IPAWS-OPEN ATO or after three (3) years (whichever comes first), this agreement will
expire without further action and system access privileges will be revoked. If the parties wish to extend
this agreement, they may do so by reviewing, updating, and reauthorizing this agreement. This newly
signed agreement supersedes all earlier agreements, which should be referenced above by title and date.
If one or both of the parties wish to terminate this agreement prematurely, they may do so upon 30 days'
advanced notice or in the event of a security incident that necessitates an immediate response.
SIGNATORY AUTHORITY
! agree to the terms of this Memorandum of Agreement. Noncompliance on the part of either organization
or its users or contractors concerning the policies, standards, and procedures explained herein may result
in the immediate termination of this agreement.
County of Oakland Official
Name: Michael J. Gingen
Title: Chairman of the Board of Commissioners
X
(Signature
County of Oakland
1200 N Telegraph Road Bldg 47 West
Pontiac, MI, 48341-0410
Federal Emergency Management Agency
IPAWS OPEN System Owner
Name: Mark A. Lucero
Title: Chief, !PAWS Engineering
(Signature Date)
Attn: IPAWS-OPEN System Owner
Federal Emergency Management Agency, Rm
506
500 C Street SW
Washington, D.C. 20472-0001
Date)
(Signature Date) (Signature Date)
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Function:
Location:
Description of data,
including sensitivity or
classification level:
• WebE0C
Appendix A
Listing of Interoperable Systems
IPAWS recognizes that Emergency Management organizations may utilize multiple tools to facilitate the
emergency management process. As a result, jurisdictions may need to interoperate with I PAWS-OPEN
using more than one system. In order to comply with DHS policy, all systems interoperating with IPAWS-
OPEN must be documented and supported by a Memorandum of Agreement. As a result this appendix
must be completed to identify all systems associated with the COG and used for interoperating with
IPAWS-OPEN. This Appendix must be amended as applicable systems are added or removed from
operations.
• IPAWS-OPEN
I IPAWS-OPEN is the backbone system that structures the alert and distributes
the message from one interoperating and/or interconnected system (message Function:
sender) to another interoperating and/or interconnected system (message
recipient).
Location: , FEMA Emergency Operations Center
Description of data, Messaging data is considered Sensitive But Unclassified (SBU) information and does
including sensitivity or not contain Personally Identifiable Information (P11), Financial data, Law Enforcement
classification level: Sensitive Information or classified information. Each message that flows through
the IPAWS-OPEN system will be associated to a specifically assigned system
User ID and COGID as captured within the message elements. This
information will be retained in system logs. 1
The systems listed below are managed and operated by the COG and are subject to the terms defined
within the Memorandum of Agreement including the Rules of Behavior in Appendix C. Each interoperable
system will be assigned unique authentication credentials, which must be protected by the COG. In the
event these credentials are compromised, the COG is expected to immediately contact the IPAWS
Program Management Office. The systems listed below are only allowed to interoperate with IPAWS-
OPEN based on the criteria set forth within the IPAWS-OPEN Web Service Interface Design Guidance.
• EMNet
Used statewide throughout Michigan to send emergency messages to
Emergency Management Offices and LP1, LP2 and public media
Pontiac, MI
COTS
FOUO
Data is comprised of unclassified, non-sensitive CAP alerts
Function: WebE0C is an application used statewide by the State of Michigan to share
emergency information in a collaborative effort
Location: Lansing, MI
Description of data, COTS
including sensitivity or FOUO
classification level: Data is comprised of unclassified, non-sensitive CAP alerts
*Add additional tables as needed.
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Appendix B
COG Point of Contact Information
Designated COG Primary Point of Contact:
Name: Theodore Quisenberry
Title: Manager, Homeland Security Divisions
Business Email Address: quisenberryt@oakgov.corn
Primary Phone Number: 248-452-9578
Alternate Phone Number:
Organization: Oakland County Homeland Security Division
Mailing Address: 1200 N Telegraph Road Bldg 47 West, Pontiac, MI 48341-0410
Designated Alternate Point of Contact:
Name: Sara Stoddard
Title: Chief of Emergency Management
Business Email Address: stoddards@oakgov.com
Primary Phone Number: 248-858-5080
Alternate Phone Number:
Organization: Oakland County Homeland Security Division
Mailing Address: 1200 N Telegraph Road Bldg 47 West, Pontiac, MI 48341 -0410
Designated Technical Point of Contact:
Name: Guy Compton
Title: Chief Technical Services
Business Email Address: comptong@oakgov.corn
Primary Phone Number: 248-975-9677
Alternate Phone Number:
Organization: Oakland County Information Technology
Mailing Address: 1200 N Telegraph Road Bldg 49 West, Pontiac, MI 48341-0410
FEMA: Integrated Public Alert and Warning System
Open Platform for Emergency Networks (IPAWS-OPEN)
Contact Summary of System
Contact Name Number Email Address Responsibilities
Ken Murphy 425-487-4604 Kenneth.Murphyfema.dhs.dov Acting Chief Information Officer, FEMA
Lamonte Acting Chief Information
202-646-3541 Lamonte.Yarboroudhfema.dhs.bov Yarborough Security Officer
Mark Lucero 202-646-1386 Mark.Lucero@femagov System Owner
Kirby Rice 703-574-7904 Kirby.Rice@associates.dhs.gov FEMA PMO - IPAWS-OPEN
Gary Ham 703-899-6241 Gary.Ham .ssociates.dhs.gov FEMA PM0 - IPAWS-OPEN
Kelli Campbell 979-260-0030 Kelli.Campbell@associates.dhs.gov FEMA ISSO - IPAWS-OPEN
FEMA-EADIS IPAWS-OPEN Neil Bourgeois 703-732-6331 Neil.Bourgeois@associates.dhs.gov Tech Lead
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Appendix C
IPAWS-OPEN Rules of Behavior
1.0 INTRODUCTION
The following rules of behavior apply to all persons with application access to County of Oakland I nteropera ble
System(s) and/or who have been issued a COGID with associated credentials for IPAWS-OPEN. These individuals
shall be held accountable for their actions related to the information resources entrusted to them and must comply with
the following rules or risk losing their access privileges. The Rules of Behavior apply to users on official travel as well
as at their primary workplace (e.g., Emergency Operations Center — EOC) and at any alternative workplace (e.g.,
telecommuting from a remote or satellite site) using any electronic device including laptop computers and portable
electronic devices (PED's). PED's include personal digital assistants (FDA's) (e.g. Palm Pilots), cell phones, text
messaging systems (e.g., Blackberry), and plug-in and wireless peripherals that employ removable media (e.g. CDs,
DVDs, etc.). PEDs also encompass USB flash memory (thumb) drives, external drives, and diskettes. These Rules of
Behavior are consistent with existing DHS policies and DHS Information Technology (IT) Security directives and are
intended to enhance the awareness of each user's responsibilities regarding accessing, storing, receiving and/or
transmitting information using IPAVVS-OPEN.
2.0 APPLICATION RULES
2.1 Official Use
• IPAWS-OPEN is a Federal application to be used only in the performance of the user's official duties in
support of public safety as described in the National Incident Management System (NI MS).
• The use of the IPAWS-OPEN for unauthorized activities is prohibited and could result in verbal or written
warning, loss of access rights, and/or criminal or civil prosecution.
• By utilizing IPAWS-OPEN, the user of the interoperable system(s) consents to allow system monitoring to
ensure appropriate usage for public safety is being observed.
• EMA's will be held accountable for safeguarding all configuration items and information entrusted to them by
FEMA. EMA's are expected to manage the relationship with supporting vendors, consultants and any other
entities providing system support on their behalf. In addition, EMA's will be held accountable in the event of
a security breach or disclosure of sensitive configuration information such as digital certificates. Each EMA
understands that the use of digital signatures used on behalf of the EMA is binding for the EMA and EMA's
will be held accountable accordingly. In the event sensitive information is mishandled, utilization of 'PAWS-
OPEN may be immediately revoked.
If software interoperating with IPAWS-OPEN enables users to geo-target public alert messages by means of
geospatial polygons or circles, then the user shall restrict any such geospatial boundaries so as to remain
within the geographical limits of their public warning authority (or as near as possible), as determined by
applicable state and/or local laws and duly adopted operational plans.
2.2 Access Security
• All Email addresses provided in connection with interoperable system(s) user accounts must be associated
to an approved email account assigned by the user's emergency management organization. The use of
personal email accounts to support emergency messaging through IPAWS-OPEN is prohibited,
• Upon approval of the MOA by FEMA, a COG account with COGID and Digital Certificate will be created and
issued to the designated technical representative. All individuals with knowledge of these credentials must
not share or alter these authentication mechanisms without explicit approval from IPAWS.
• Every interoperable system user is responsible for remote access security as it relates to their use of
IPAWS-OPEN and shall abide by these Rules of Behavior.
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2.3 lnteroperable System User Accounts and Passwords
• All users must have a discrete user account ID which cannot be the user's social security number. To
protect against unauthorized access, passwords linked to the user ID are used to identify and authenticate
authorized users.
• Accounts and passwords shall not be transferred or shared. The sharing of both a user ID and associated
password with anyone (including administrators) is prohibited.
• Accounts and passwords shall be protected from disclosure and writing passwords down or electronically
storing them on a medium that is accessible by others is prohibited.
The selection of passwords must be complex and include:
o At least eight characters in length
O At least two (02) upper case and two (02) lower case letters
O At least two (02) numbers and one (01) special character.
• Passwords must not contain names, repetitive patterns, dictionary words, product names, personal
identifying information (e.g., binhdates, SSN, phone number), and must not be the same as the user ID,
• Users are required to change their passwords at least once every 90 days.
• Passwords must be promptly changed whenever a compromise of a password is known or suspected.
2.4 Integrity Controls & Data Protection
• All computer workstations accessing IPAWS-OPEN must be protected by up-to-date anti-virus software.
Virus scans must be performed on a periodic basis and when notified by the anti-virus software.
• Users accessing interoperable system(s) to utilize IPAWS-OPEN must:
o Physically protect computing devices such as laptops, PEDs, blackberry devices, smartphones,
etc;
O Protect sensitive data sent to or received from IPAWS-OPEN;
O Not use peer-to-peer (P2P) file sharing, which can provide a mechanism for the spreading of
viruses and put sensitive information at risk;
O Not program computing devices with automatic sign-on sequences, passwords or access
credentials when utilizing IPAWS-OPEN.
Users may not provide personal or official IPAWS-OPEN information solicited by e-mail. If e-mail messages are
received from any source requesting personal information or asking to verify accounts or other authentication
credentials, immediately report this and provide the questionable e-mail to the Local System Administrator and/or the
County of Oakland Help Desk.
• Only devices officially issued through or approved by DHS, FEMA and/or approved emergency management
organizations are authorized for use to interoperate with IPAWS-OPEN and use of personal devices to
access and/or store IPAWS-OPEN data and information is prohibited.
If a Blackberry, smartphone or other PED is used to access the interoperable system(s) to utilize IPAVVS-
OPEN, the device must be password protected and configured to timeout or lock after 10 minutes of
inactivity.
• If sensitive information is processed, stored, or transmitted on wireless devices, it must be encrypted using
approved encryption methods.
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2.5 System Access Agreement
• I understand that I am given access to the interoperable system(s) and IPAWS-OPEN to perform my official
duties.
• I will not attempt to access data, information or applications I am not authorized to access nor bypass
access control measures.
• I will not provide or knowingly allow other individuals to use my account credentials to access the
interoperable system(s) and IPAWS-OPEN.
To prevent and deter others from gaining unauthorized access to sensitive resources, I will log off or lock my
computer workstation or will use a password-protected screensaver whenever I step away from my work
area, even for a short time and I will log off when I leave for the day.
• To prevent others from obtaining my password via "shoulder surfing", I will shield my keyboard from view as
I enter my password.
• I will not engage in, encourage, or conceal any hacking or cracking, denial of service, unauthorized
tampering, or unauthorized attempted use of (or deliberate disruption of) any data or component within the
interoperable system(s) and IPAWS-OPEN.
• I agree to inform my Local System Administrator when access to the interoperable system(s) and/or IPAWS-
OPEN is no longer required.
I agree that I have completed Computer Security Awareness training prior to my initial access to the
interoperable system(s) and IPAWS-OPEN and that as long as I have continued access, I will complete
Computer Security Awareness training on an annual basis.
2.6 Accountability
• I understand that I have no expectation of privacy while using any services or programs interoperating with
IPAWS-OPEN.
• I understand that I will be held accountable for my actions while accessing and using interoperable
system(s) and IPAWS-OPEN, including any other connected systems and IT resources.
• I understand it is my responsibility to protect sensitive information from disclosure to unauthorized persons
or groups.
• I understand that I must comply with all software copyrights and licenses pertaining to the use of IPAWS-
OPEN.
2.7 Incident Reporting
• I will promptly report IT security incidents, or any incidents of suspected fraud, waste or misuse of systems
to the Local System Administrator and/or the County of Oakland Help Desk.
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3.0 IPAWS-OPEN Rules of Behavior Statement of Acknowledgement
I have read and agree to comply with the requirements of these Rules of Behavior. I understand that the terms of this
agreement are a condition of my initial and continued access to County of Oakland interoperable System(s) and
IPA ¼'S-OPEN and related services and that if I fail to abide by the terms of these Rules of Behavior, my access to
any and all IPAWS-OPEN information systems may be terminated and I may be subject to criminal or civil
prosecution. I have read and presently understand the above conditions and restrictions concerning my access.
Name (Print):
Signature: Date:
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Resolution #13036 March 6, 2013
Moved by Bosnic supported by Quarles the resolutions (with fiscal notes attached) on the Consent
Agenda be adopted (with accompanying reports being accepted).
AYES: Dwyer, Gershenson, Gosselin, Hatchett, Hoffman, Jackson, Long, Matis, McGillivray,
Middleton, Quarles, Scott, Spisz, Weipert, Woodward, Zack. (18)
NAYS: None. (0)
A sufficient majority having voted in favor, the resolutions (with fiscal notes attached) on the Consent
Agenda were adopted (with accompanying reports being accepted).
I HEREB! "1-,,DVE THIS RESOLUTION
CHIEF DE. UTY COUNTY EXECUTIVE
ACTING PURSUANT TO MCL 45,559A (7)
STATE OF MICHIGAN)
COUNTY OF OAKLAND)
I, Lisa Brown, Clerk of the County of Oakland, do hereby certify that the foregoing resolution is a true and
accurate copy of a resolution adopted by the Oakland County Board of Commissioners on March 6, 2013,
with the original record thereof now remaining in my office.
In Testimony Whereof, I have hereunto set my hand and affixed the seal of the County of Oakland at
Pontiac, Michigan this 6th day of March, 2013.
X-f-get/
Lisa Brown, Oakland County