Citizen Participation Plan

Revision History

1. General Citizen Participation and Public Comment 

On January 16, 2025, the U.S. Department of Housing and Urban Development (HUD) allocated $1.428 billion of CDBG-DR funding to the State to address unmet recovery needs arising from Hurricane Helene which struck the western portion of the state in September 2024. To engage the citizens of North Carolina, the North Carolina Department of Commerce (NCDOC) Division of Community Revitalization (DCR) has developed this citizen participation plan to help inform the use of Community Development Block Grant Disaster Recovery (CDBG-DR) funding. HUD requires that all CDBG-DR grantees have a citizen participation plan and adhere to the specific citizen participation requirements as defined by the Common Application, Waivers, and Alternative Requirements for Community Development Block Grant Disaster Recovery Grantees: The Universal Notice in the Federal Register (90 FR 1754). In developing this plan, DCR has been guided by underlying statutory requirements, Federal Register Notices and applicable regulatory requirements. To any extent necessary, DCR will issue specific updates or alternate plans to comply with that guidance.

1.1 Overview and Encouragement of Citizen Participation 

DCR is the administrator of CDBG-DR funds provided to the State by HUD in response to damage caused by Helene, a presidentially declared disaster (FEMA designation DR-4827-NC). This funding is directed to DCR’s long-term disaster recovery programs to address unmet needs arising from Hurricane Helene as described in the related Action Plan for Disaster Recovery. With this funding, DCR and its partners will assist storm-impacted residents by providing services to restore housing and support communities damaged by Helene and to mitigate against damage due to future disasters. 

DCR is committed to ensuring that North Carolinians and communities impacted by Helene are aware of available resources, have an opportunity for input, and have equal access to information about the programs available to assist in recovery and mitigation efforts. Through in-person meetings, virtual meetings, outreach events, online and traditional media, DCR requests public comments on plans, publicizes existing programs and changes to existing plans and programs, and conducts outreach efforts throughout the storm-impacted areas. 

Overall, DCR seeks to encourage a community-driven process that engages the public as a key stakeholder in the planning and rebuilding process. In addition, Governor Josh Stein has established the Governor’s Advisory Committee on Western North Carolina Recovery to obtain formal and informal public input from a diverse array of affected people on strategies to address the needs of communities affected by Helene.

DCR values the input of impacted Western North Carolinians, other stakeholders, and decision makers that represent the vulnerable communities affected by Helene or at risk for future flooding and storm damage. DCR requests input from all western North Carolinians, including low- and moderate-income (LMI) persons, racial/ethnic minorities, persons with disabilities, and persons with Limited English Proficiency. To meet the public participation requirements applicable to the use of CDBG-DR grants, DCR commits to the processes described below for citizen participation, complaints, appeals, and the public notice period. 

1.2 Citizen Participation and Outreach for Action Plans 

For any CDBG-DR grant, HUD requires the creation and maintenance of an Action Plan that provides a strategy for the use of the disaster recovery funds. DCR invites and encourages citizen participation in the development of its Action Plans according to the regulatory requirements applicable to that allocation. Pursuant to HUD’s requirement, the Action Plan shall be provided for citizens, affected local governments, and other interested parties for comment for a period of not less than thirty (30) calendar days.

Further, citizen participation is also sought during the Substantial Amendment process that will periodically occur as DCR alters the Action Plan to address emerging needs and adjust the program consistent with implementation outcomes. Substantial Amendments are also subject to a thirty (30) calendar day period for public comment.

At a minimum, Substantial Amendments must follow the public comment period timelines indicated below. Substantial Amendment criteria include: 

• A change in program benefit or eligibility criteria.
• The addition or deletion of an activity.
• A change in program allocation in excess of $28.5 million (approximately 2% of the overall CDBG-DR Helene-related allocation from HUD).  

DCR will advertise opportunities for public comment on the draft Action Plan and, ultimately, Substantial Amendments, on its website and, if required, DCR will also hold public meetings or hearings in disaster-impacted areas or virtually if physical public meetings or hearings are not able to be held due to any reason.

1.3 Public Hearings, Public Notice, Comment Period, and Website 

Before submitting the Action Plan or any Substantial Amendment to HUD for review and approval, DCR must publish the proposed plan or amendment for public comment for thirty (30) calendar days. 

In accordance with CDBG-DR statutory and regulatory requirements, DCR has developed and will maintain a comprehensive website regarding all disaster recovery activities assisted with these funds. The website gives citizens an opportunity to read draft Action Plans and to submit comments. 

During the initial public comment period for the draft Action Plan, DCR will hold three public hearings as required by HUD given the size of the allocation to DCR for Helene recovery efforts. The public hearing may be virtually (alone, or in concert with an in-person hearing). All in-person hearings will be held in facilities that are physically accessible to persons with disabilities. For both virtual and in-person hearings, the times and locations of the hearings will be convenient to potential and actual beneficiaries, with accommodation for persons with disabilities and appropriate auxiliary aids and services to ensure effective communication.

Paper copies of the Action Plan and Substantial Amendments will be available in English upon request through email at Helene.recovery@commerce.nc.gov. Other accessibility needs, such as availability in a language other than English, are available upon request through email at Helene.recovery@commerce.nc.gov. 

After the conclusion of the required comment period, all comments are reviewed and DCR provides responses to comments in a revised version of the Action Plan or Substantial Amendment. DCR’s consideration of and response to all public comments can be reviewed in the Appendices of the Action Plan as posted on the DCR website after HUD approval of the Action Plan. 

DCR will take reasonable measures to increase coordination, communication, affirmative marketing targeted outreach, and engagement with underserved communities and individuals, including persons with disabilities and persons with limited English proficiency. In addition to Action Plans and all amendments, the DCR website includes the following information for public review: 

• The current approved CDBG-DR Action Plan (once approved by HUD).
• Citizen participation requirements.
• Procurement policies and procedures.
• Current procurements for goods and services.
• Performance reports, such as Quarterly Performance Reports (QPR).
• Current contract agreements.
• A summary of all procurements. 

1.4 Individuals with Limited English Proficiency (LEP) 

Based on an analysis of LEP data within the impacted areas, DCR will provide the Action Plans, Substantial Amendments, and other essential program materials in English. 

DCR can provide both oral interpretation and written translation services to people at no cost and these services are available upon request. Meaningful and equal access to federally funded programs and activities is required by Title VI of the Civil Rights Act of 1964.

1.5 Individuals with Disabilities 

DCR programs will be accessible to all people with disabilities and will operate in a manner that does not discriminate against or limit access to program services and benefits to persons with disabilities. To ensure that CDBG-DR funded programs are operating in compliance with Section 504 requirements of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA), DCR will: 

• Ensure that all facilities where clients will have face-to-face interaction with program staff are readily accessible and usable by people with disabilities.
• Assist program Intake Specialists/Case Managers in providing written and verbal communication to program applicants regardless of their disability or limited proficiency with the English language to include sign language, braille, interpreters, etc.
• Assist program Intake Specialists/Case Managers in completing home visits with applicants who are homebound or cannot access a recovery center as needed.
• Ensure that reasonable accommodation modifications to an applicant’s home are part of a program’s scope of work as applicable.
• Appropriately address any identified hearing, visibility, or mobility limitations of a program applicant and/or applicant’s household members as required by Section 504 and the Americans with Disabilities Act (ADA).
• Work with a disabled program applicant's designee who has power of attorney or any non-profit organization that is representing the applicant as needed. 

In addition, DCR complies with Section 508 requirements that require accessibility to electronic and information technology for individuals with disabilities. DCR’s program management vendor assists with ensuring that all public communications, including its website, meet Section 508 requirements. The online materials will also be accessible for the visually impaired. DCR will ensure that all print, verbal, or electronic communications with the public regarding distribution of CDBG-DR funding and actionable information are simultaneously communicated to persons with disabilities and others with access and functional needs via qualified channels (i.e. ASL interpreters, open captions, braille, large, high contrast print, formats accessible to screen readers, etc.) in an equitable, timely, and efficient manner. Information will be presented in an understandable manner, using plain language and identifying whom to contact for clarification or additional information. For more information on how people with disabilities can access and comment on the CDBG-DR program, email Helene.recovery@commerce.nc.gov. 

1.6 Response to Citizen Complaints 

Complaints are statements received from citizens related to situations concerning DCR’s disaster recovery programs, Action Plans, substantial amendments, quarterly performance reports, or related to the unsatisfactory or unacceptable behavior of a DCR representative carrying out a disaster recovery program. All subrecipients will be required to develop complaint procedures that align with the requirements set by DCR. 

Should any applicant or member of the public have complaints concerning the award or administration of CDBG-DR funds, complaints should be addressed using the following official channels:

• Online: The Complaint Submission Form can be found on DCR's Contact Us webpage.
• Phone: DCR Complaint Line at 919-707-1560
• Email: dcr.constituentservices@commerce.nc.gov
• Mail:
  • Division of Community Revitalization – Constituent Services 
    301 North Wilmington Street 
    4301 Mail Service Center 
    Raleigh, NC 27699-4301

The Constituent Services team will make every effort to provide a timely written response upon receipt of a citizen’s petition, within fifteen (15) business days, as expected by HUD, where practicable.

1.7 Response to Appeals 

DCR will implement a standardized appeals process for each of its CDBG-DR programs. Additional details on these processes will be found in each program’s policies and procedures document. Note that DCR does not have the authority to grant an appeal of a statutory or HUD-specified CDBG-DR requirement. 

1.8 Public Comments Contact Information 

Public comments may be submitted using DCR’s contact information as follows: 

• Email comments to: Helene.recovery@commerce.nc.gov  
  • Include “Action Plan,” “CDBG-DR,” or “Public Comment” in the subject line.
• Fax: (919) 715-0096
• Written comments may be mailed to: 
  North Carolina Department of Commerce (DCR)
  Attn: Division of Community Revitalization
  4301 Mail Service Center
  Raleigh, NC 27699-4346

1.9 Application Status  

DCR is committed to sharing timely and accurate updates on applications to the multiple programs that take applications directly from recovering individuals and families. For all direct applicant service programs, applicants will be able to learn more about the status of their application through a phone call or email with their case manager. 

Additional information on how applicants can learn more about the status of their application may be found in the program manual for the corresponding program directly serving applicants.

Some of DCR’s programs do not interface with individual applicants directly. For those programs, DCR will coordinate directly with the selected subrecipients, housing developers, public housing authorities, or other entities to review applications for funding and provide other updates to projects.  

1.10 Citizen Participation Requirements for Local Governments Participating in CDBG-DR Programs 

To further advance public participation in the CDBG-DR programs, the DCR is also setting out requirements for units of local government funded directly by DCR’s CDBG-DR programs.

§ 570.486 Local government requirements.

• Citizen participation requirements of a unit of general local government. Each unit of general local government shall meet the following requirements as required by the state at § 91.115(e) of this title.
  1. Provide for and encourage citizen participation, particularly by low- and moderate-income persons who reside in areas in which CDBG funds are proposed to be used;
  2. Ensure that residents will be given reasonable and timely access to local meetings, consistent with accessibility and reasonable accommodation requirements in accordance with section 504 of the Rehabilitation Act of 1973 and the regulations at 24 CFR part 8, and the Americans with Disabilities Act and the regulations at 28 CFR parts 35 and 36, as applicable, as well as information and records relating to the unit of local government's proposed and actual use of CDBG funds;
  3. Furnish citizens information, including but not limited to:
     • The amount of CDBG funds expected to be made available for the current fiscal year (including the grant and anticipated program income);
     • The range of activities that may be undertaken with the CDBG funds;
     • The estimated amount of the CDBG funds proposed to be used for activities that will meet the national objective of benefit to low and moderate income persons; and
     • The proposed CDBG activities likely to result in displacement and the unit of general local government's anti-displacement and relocation plans required under § 570.488.
  4. Provide technical assistance to groups that are representative of persons of low- and moderate-income that request assistance in developing proposals (including proposed strategies and actions to affirmatively further fair housing) in accordance with the procedures developed by the State. Such assistance need not include providing funds to such groups;
  5. Provide for a minimum of two public hearings, each at a different stage of the program, for the purpose of obtaining residents' views and responding to proposals and questions. Together the hearings must cover community development and housing needs (including affirmatively furthering fair housing), development of proposed activities, and a review of program performance. The public hearings to cover community development and housing needs must be held before submission of an application to the State. There must be reasonable notice of the hearings and they must be held at times and accessible locations convenient to potential or actual beneficiaries, with accommodations for persons with disabilities. Public hearings shall be conducted in a manner to meet the needs of non-English speaking residents where a significant number of non-English speaking residents can reasonably be expected to participate;
  6. Provide citizens with reasonable advance notice of, and opportunity to comment on, proposed activities in an application to the state and, for grants already made, activities which are proposed to be added, deleted or substantially changed from the unit of general local government's application to the state. Substantially changed means changes made in terms of purpose, scope, location or beneficiaries as defined by criteria established by the state.
  7. Provide citizens the address, phone number, and times for submitting complaints and grievances, and provide timely written answers to written complaints and grievances, within 15 working days where practicable.
• Activities serving beneficiaries outside the jurisdiction of the unit of general local government. Any activity carried out by a recipient of State CDBG program funds must significantly benefit residents of the jurisdiction of the grant recipient, and the unit of general local government must determine that the activity is meeting its needs in accordance with section 106(d)(2)(D) of the Act. For an activity to significantly benefit residents of the recipient jurisdiction, the CDBG funds expended by the unit of general local government must not be unreasonably disproportionate to the benefits to its residents.
• Activities located in Entitlement jurisdictions. Any activity carried out by a recipient of State CDBG program funds in entitlement jurisdictions must significantly benefit residents of the jurisdiction of the grant recipient, and the State CDBG recipient must determine that the activity is meeting its needs in accordance with section 106(d)(2)(D) of the Act. For an activity to significantly benefit residents of the recipient jurisdiction, the CDBG funds expended by the unit of general local government must not be unreasonably disproportionate to the benefits to its residents. In addition, the grant cannot be used to provide a significant benefit to the entitlement jurisdiction unless the entitlement grantee provides a meaningful contribution to the project. [57 FR 53397, Nov. 9, 1992, as amended at 61 FR 54922, Oct. 22, 1996; 77 FR 24143, Apr. 23, 2012; 80 FR 42367, July 16, 2015]

2. Technical Assistance 

DCR will host multiple in-person and virtual training sessions to inform potential applicants about the CDBG-DR requirements and program details. These trainings will be conducted by DCR in partnership with the League of Municipalities, the NC Association of County Commissioners, the University of North Carolina School of Government, and the five western regional Councils of Governments to ensure a diverse group of stakeholders is involved in CDBG-DR communications.

The training sessions will cover:

• The amount of CDBG-DR funds expected to be available, including the grant and anticipated program income.
• The range of activities that can be funded with CDBG funds.
• The estimated amount of CDBG funds planned to be used for activities that meet the national objective of benefiting low- and moderate-income people.
• Contracting and reporting requirements for CDBG funds.

DCR and its partners will also offer one-on-one consulting and technical assistance to groups representing low- and moderate-income persons that request help with developing proposals, including proposed strategies and actions to affirmatively further fair housing, following procedures set by DCR.

3. Fair Housing 

The Fair Housing Act requires all grantees, partners, subrecipients, and/or developers whose capital projects are wholly or partially funded with federal assistance to certify that no person was excluded from participation in, denied the benefit of, or subjected to discrimination in any housing program or activity because of their age, race, color, creed, religion, familial status, national origin, sexual orientation, military status, sex, disability or marital status. DCR and its contractors shall ensure that no applicant is treated in any way that does not comply with the federal Fair Housing Act, the Civil Rights requirements of Title I of the Housing and Community Development Act, and the North Carolina Fair Housing Act (Chapter 41A of the North Carolina General Statutes).

DCR has assigned staff who will ensure that: 

• DCR programs affirmatively further fair housing; 
• Fair housing complaints are directed to HUD or another appropriate agency;
• Programs are administered in accordance with DCR’s Fair Housing Plan.