2020 CA OPINION LETTER.PDF

Maricopa County — Formal (2020-06-24)

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222 NORTH CENTRAL AVENUE, SUITE 1100 
PHOENIX, AZ 85004 
WWW.MARICOPACOUNTYATTORNEY.ORG 
 
PH. 
(602) 506-8541
FAX 
(602) 506-8567
Maricopa County Attorney 
ALLISTER ADEL 
 
 
June XX, 2020 
 
 
 
U. S. Department of Housing and Urban Development 
San Francisco Regional Office 
1 Sansome Street #1200  
San Francisco, California 94104 
 
RE:  Maricopa County Cooperation Agreements – County Attorney Opinion Letter 
 
Dear Sir or Madam: 
 
I am a duly appointed Deputy County Attorney of Maricopa County, Arizona. 
 
I have reviewed: 1.) the 2011 Cooperation Agreements entered into by and among Maricopa County 
(“County”) and various municipalities, as amended in 2014, 2017, and June 2020; 2.) the 2017 
Cooperation Agreement entered into by and between the County and the Town of Fountain Hills, as 
amended in June 2020; and 3.) the 2020 Cooperation Agreement entered into between the County and 
the Town of Cave Creek (collectively, the “Agreements”), pursuant to the Housing and Community 
Development Act of 1974, the HOME Investment Partnership Act of the Cranston-Gonzalez National 
Affordable Housing Act of 1990, and the Homeless Emergency Assistance and Rapid Transition to 
Housing Act of 2009.   
 
Maricopa County and the cities and towns of Buckeye, Cave Creek, El Mirage, Fountain Hills, Gila 
Bend, Guadalupe, Litchfield Park, Tolleson, Wickenburg, and Youngtown have entered into the 
Agreements to participated in the Community Development Block Grant Program (CDBG), HOME 
Investment Partnerships Program (HOME), and Emergency Solutions Grants Program (ESG). The 
Agreements designate Maricopa County as an Urban County to submit a Consolidated Plan, Annual 
Action Plans, and Consolidated Annual Performance and Evaluation Reports (CAPERs) to the U.S. 
Department of Housing and Urban Development for the use of funds.  The Agreements also allow the 
cities and towns to join the County and undertake essential community development and housing 
assistance activities within the urban county’s units of general local government and unincorporated 
areas.  The Agreements, either new or as amended, cover the period July 1, 2021 to June 30, 2024. 
 
As the Urban County, Maricopa County is the governmental entity to execute any grant agreements 
and thereby is liable and responsible for the proper performance of the plan and program. Together, the 
County and participating municipalities will more comprehensively undertake and assist with essential 
community development and lower-income housing activities.

County Attorney Opinion Letter  
June XX, 2020 
Page 2 of 2 
 
 
I am of the opinion that the terms and provisions of the Agreements are fully authorized under state of 
Arizona and local law and provide full legal authority for the County to undertake, or assist in 
undertaking, essential community renewal and lower-income housing assistance activities. See Arizona 
Revised Statutes § 11-952.   
 
Sincerely, 
 
MARICOPA COUNTY ATTORNEY’S OFFICE 
CIVIL SERVICES DIVISION 
 
 
 
__________________________________ 
David W. Krula, Deputy County Attorney 
and not personally