Citizen Participation Plan Requirements 2020-2024 CARES Act revisions

CITY OF DOVER CITIZEN PARTICIPATION PLAN The public participation events planned for the Consolidated Plan (2020-2024) represents the culmination of decades of experience in conducting similar events. In addition to the normal advertising of meetings in the local press and the internet, the staff notified stakeholders in writing by mail. The public was also notified of all meetings and hearings. The following section summarizes each of the Citizen Participation components of the Consolidated Plan. Citizen Participation Plan Purpose The City of Dover's Consolidated Plan Citizen Participation Plan (CPP) has been prepared by the City of Dover in accordance with the requirements contained in Part 9115 of Title 24 of the Code of Federal Regulations. The CPP outlines the various methods the City of Dover will use to inform its citizens of, and actively involve them in, developing the Consolidated Plan. The Consolidated Plan serves as the housing and community development planning document of the City and its application for funding under the current Community Planning and Development (CPD) formula grant program (CDBG). B Consolidated Plan Advisory Group (CPAG) In order to assure citizen participation and involvement in the Consolidated and Action Plan process, the Community Development Department established a Consolidated Plan Advisory Group (CPAG) which: 1. Is composed of representatives from units of local government, public and private agencies, and citizens in the community. 2. Provides the opportunity to review and comment upon all aspects of the Consolidated Plan process including: a. Providing input on housing and community development needs and priorities; b. Recommending funding activities Timely Access to Meetings and Information All citizens, particularly low and moderate income persons, shall be provided with reasonable and timely access to local meeting information and records relating to both the proposed use of funds and their actual use in the Consolidated Plan. Such information shall include but not be limited to:

1. Pertinent distribution relating to the Consolidated Plan; 2. Notice of and records of public hearings; 3. Key program documents, including prior applications, letters of approval, contracts, status reports, audit reports, and proposed applications; 4. Copies of program regulations; 5. Documents on other program requirements such as contracting procedures, environmental/historic preservation policies, fair housing and equal opportunity requirements, and acquisition and relocation provisions. D. Technical Assistance Technical assistance is provided to groups and representatives of persons of low and moderate income that request assistance in developing proposals for funding under any of the programs covered by the Consolidated Plan. The level and type of technical assistance to be provided will be determined by the City and will include those training activities necessary to increase the ability of low and moderate income persons to be involved effectively in the development, planning and design of the program proposals. E. Public Hearings Be held at times and locations convenient to potential and actual beneficiaries and with accommodations for persons with disabilities and Non-English speaking participants. To the maximum extent possible, all public hearings shall be held in the evening hours after 5:00 PM. All public hearing sites must be accessible to ramps or elevators and be convenient to parking or public transportation. Two public hearings are required. Adequate notice is given through advertisement in the City's local newspaper and the internet. Copies of the notices are sent to such service agencies and public housing administration offices who serve and advocate for the low and very low income persons and disability communities to encourage citizen’s participation input by the citizens and their advocates and meet the needs of citizens, particularly those who are beneficiaries of the programs covered in the Consolidated Plan. A minimum of two public hearings are held. The first public meeting will be held for the Consolidated Plan to determine the needs of the community, and the second public hearing will make available to citizens, public agencies and other interested parties, information that includes the amount of the Entitlement Grant and a list of subrecipient grant requests including the amount that will benefit persons of low and moderate income. The Draft Plan will be made available for thirty days in the City Hall Planning Department at 15 Loockerman Plaza, the Dover Public Library at 35 Loockerman Plaza and on the City's website at www.cityofdover.com. The Plan will also be accessible to persons with disabilities.

The City will consider any comments or views of citizens received in writing or orally at the public hearing. A summary of these comments or views and summary of any comments or views not accepted and the reasons therefore, shall be attached to the plan. Any amendments to the plan will be advertised in the local newspaper and sent to Social Service Agencies and Public Housing Officials. The City will provide a thirty-day period to receive comments on the substantial amendment before the amendment is implemented. The same procedure will be followed as explained above. Performance Reports The Citizen Plan will provide citizens with reasonable notice and an opportunity to comment on the Performance Report for the City in which the Department of Housing and Urban Development distributes annually. A fifteen-day period will be set aside for comments. The City will consider any comments or views of citizens received in writing or orally in preparing the Performance Report. A summary of these comments or views shall be attached to the Performance Report. F. Response to Comments The City will consider any comments or views of citizens or units of local government received in writing, or orally at public hearings, meetings, etc., in preparing the City's final Consolidated Plan and Performance Report. The City must provide a timely written response to written complaints and grievances within 15 working days. The written response must document the reasons for whatever action was taken. A summary of these comments and responses shall be attached to the final Consolidated Plan amendment of the plan or Performance Report. Criteria for Amendments to Consolidated Plan The City will publish the proposed amendment in the public notice section of a local newspaper. Comments will be requested for a thirty-day period, after which time, the City will consider any comments received and, if appropriate, modify the proposed actions. A summary of these comments shall be attached to the amendment submitted to HUD. Due to the COVID-19 crisis, substantial amendments to the Consolidated Plan, Action Plan and requirements to Public Hearings have been revised as follows:

Waivers will be submitted to HUD to waive certain regulatory requirements associated with the CDBG Program to prevent the spread of COVID-19 and to facilitate eligible households economically impacted by COVID-19. The 30-day minimum comment period required for public comment is waived for substantial amendments, provided that no less than 5 days are provided for public comments on each substantial amendment. Until the stay at home order has been lifted, all CDBG Public Hearings will be conducted by audio. Amendments to the Consolidated Plan The following criteria will be used in determining what actions will constitute a substantive change in the City's planned or actual activities under the Consolidated Plan, and which will require an amendment to the plan. Changes in Allocation Amounts: Any significant change in the allocation of funds under a specific program or activity defined under the Consolidated Plan shall require the City to prepare and pass an amendment to the Consolidated Plan. In the case of changes to specific allocations, significant change will be defined as any change in the allocation of funds under a specific program or activity which is greater than 20% of the total funds allocated to that program or activity. Any change that involves 10% or more of the total allocation (entitlement plus program income) in any given grant year, will also be considered a significant change. Changes in the Method of Distribution of Funds: Any significant change in an established method for the distribution of funds defined within the Consolidated Plan for a specific program or activity, will require that the City prepare and pass an amendment to the Consolidated Plan. Significant in this case will imply that a method(s) for the distribution of funds for the program or activity was defined within the Consolidated Plan, and the City subsequently changed this method of distribution (i.e. if the City decided to distribute funds for a program through a process of soliciting proposals through a Request for Proposals, and then decided instead to distribute the funds for the program or activity through a negotiated contract.) The second criteria, which must also be met for a change in method of distribution to be considered significant, will be when the funds in question are greater than 20% of the total CPS funding allocated to that program or activity. Using Consolidation Plan Funds for Activities not described in the Consolidated Plan: If the City proposes to use funds from any program covered by the Consolidated Plan (including program income) to carry out an activity not previously described in the Action Plan, the City will be required to prepare and request an amendment to the Consolidated Plan.

Changes in the Location of an Activity: If the City significantly changes the location of an activity, the City will be required to prepare and request an amendment to the Consolidated Plan. Changes in the location of an activity shall be considered significant if the City had specifically defined a location for an activity within the Consolidated Plan and subsequently decides to choose an alternative site for the location of that activity and thereby shifts the target benefit of that activity to a new area. Changes in the Beneficiaries of an Activity: If the City decides to significantly change the established beneficiaries of a specific activity (a defined "target group") defined in the Consolidated Plan, then the City will be required to prepare and pass an amendment to the Consolidated Plan. In the case of a change in beneficiaries of an activity, significant shall mean that the estimated number of individuals of the targeted group who will be benefited will change more than 10% of the total number of individuals in that you originally estimated. If an activity benefit is changed from one national objective to another, the City will not request an amendment unless other amendment thresholds are met. H. Consolidated Plan Adoption The Draft Consolidated Plan will be made available to the public per notice in the Delaware State News, the City's website and copies available at City Hall and the Library. Comments received will be considered prior to its adoption. The Consolidated Plan will be considered adopted once approved by City Council. Upon adoption, another notice will be placed on the city’s website that the Consolidated Plan has been adopted and can be reviewed on the City’s website and copies available at the City of Dover Planning and Inspections Office and the Public Library.