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CDBG Citizen ParticipationFor Grant Administrators

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CDBG Citizen Participation

• Required by Section 104(a)(2) of the Housing and Community Development Act and by regulations at 24 CFR 570.486(a)(6)

• Vitally important to the success of CDBG-funded activities undertaken by local governments

• Compliance reduces the number of legal challenges and citizen complaints against the local government recipient

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Citizen Participation – Federal regulatory requirements

• Local governments must provide citizens with reasonable advance notice of and opportunity to comment on proposed activities in an application to the state

• For grants already made, the same opportunities must be provided for activities proposed to be added, deleted or substantially changed from the local government’s application to the state

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Citizen Participation Plan

• The primary goal is to provide citizens--especially low and moderate income citizens of the community where CDBG-funded activities will take place-- an opportunity to participate in an advisory role in the planning, implementation, and assessment of the programs and projects.

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Citizen Participation Plan - continued

• Items to be included:– Detail the public hearing requirements

– Identify the Citizen Participation Coordinator along with the duties and responsibilities

– Specify the date the plan was adopted

– Policy for providing technical assistance to the community so that they will become knowledgeable about the CDBG program and can contribute some ideas to solving some of the community’s needs

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Citizen Participation Plan - continued

– Policy for making available programmatic information to citizens during all phases of the CDBG project as well as records on past use of CDBG funds

– Policy for citizens providing comments on the Citizen Participation Plan and amendments

– Policy for providing citizens an opportunity to comment on performance reports for project activities

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Citizen Participation Plan - continued

– Policy for encouraging citizens to participate in an advisory role in the planning, implementation, and assessment of the project

– Procedures for comments, objections, and complaints

– Program income re-use plan

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Public Hearing Requirements

• When and Why

– Two public hearings are required by law

– Reasonable notice must be provided

– Must be held at two separate phases of the project

– Both must be held prior to application to the state

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Public Hearings - continued

– If a formal amendment to the project is to be submitted, another public hearing (with requisite notice) may be required

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Public Hearing Notification

• Notice must be published at least twice on different days in a newspaper of daily circulation

• The first notice must be published no less than two weeks prior to the date of the public hearing

• Applicants must make every effort to inform those who might not be reached through the newspaper

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Public Hearing Notificationcontinued

• Advertisements must state that accommodations for disabled or non-English speaking residents will be made available upon advance request

• Applicants must take appropriate affirmative actions to make the scheduling known to low and moderate-income residents

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Required Public Hearing Documentation

• Copies of the notices must be included as part of the application along with an Affidavit of Publication from the newspaper

• Local governments must document the notification and results of public hearings through the following:– Copy of advertisement/notice– Minutes of public hearing– List of attendees

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Public Hearing Content

• Information that should be made available at public hearings:– Goals and objectives of the CDBG program– The total amount of CDBG funds available – Community development and housing needs– Proposed activities for project and amount to be

requested for project – The proposed amount of funds to be used to

benefit low-and moderate-income people – Whether any persons will be displaced as a result

of the proposed activities

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Citizen Participation Planvs Public Hearings

• The two are not the same– Hearings are simply a component of the Plan– Hearings are the culmination of the Plan

• Doing one is not doing the other

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Citizen Participation Sample Documents

• Provide Sample Public Notices, Affidavits of Publication, Sample Program Income Plans and Citizen Participation Plans