CDBG Citizen Participation Requirements For Local Officials

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CDBG Citizen Participation RequirementsFor Local
Officials
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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 governments application to the state

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Citizen Participation Plan

• The primary goal is to provide citizens--especiall
  y 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 communitys 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