City of Orange Draft Citizen Participation Plan
Updated September 2023
CITY OF ORANGE
CITIZEN PARTICIPATION PLAN
CDBG AND HOME PROGRAM FUNDS
I. PURPOSE
The United States Department of Housing and Urban Development (HUD) requires jurisdictions that receive funding under certain federal entitle ment programs to adopt and comply with a Citizen Participation Plan (CPP). The CPP sets forth the jurisdiction’s policies and procedures for citizen participation to ensure full compliance with federal regulations under Title 24 CFR Part 91. The City currently receives annual entitlement grants for the Community Development Block Grant (CDBG) Program and HOME Investment Partnerships Program through HUD. This CPP primarily addresses the citizen participation requirements for the CDBG and HOME Programs. If the City receives federal entitlement grants from other funding sources in the future, the guidelines set forth in this CPP will be followed unless separate citizen participation requirements are issued by HUD.
The CPP provides a strategy to ensure the participation of citizens and other interested parties in the development of the Five-Year Consolidated Plan (CP), the Annual Action Plan (AAP) and the Consolidated Annual Performance and Evaluation Report (CAPER) . The CP, which is prepared every five yea rs, iden tifies the City’s overall housing and community development needs and market conditions, establishes funding priorities, outlines a strategy to address these priorities, and provides the framework for the use of CDBG, HOME and other federal entitlement grant funds. The AAP is prepared annually and outlines eligible programs and projects that are to be funded with the annual allocation of federal grant funds received by the City to address the priorities of the CP. Last, the CAPER is prepared annua lly following th e end of the program year to report on annual accomplishments.
The City’s citizen participation process provides nonprofit agencies, City departments, the community, and other interested parties with the opportunity to work in partnership with the City to develop the CP, the AAP, any substantial amendments to the CP or the APP, and the CA PER. This process includes identifying needs and determining recommendations for the allocation of HUD funds and review and approval of performance evaluation reports.
In accordance with the regulations relating to citizen participation, the City will encourage all residents to participate in the development of the C P including Low- and Moderate -Income persons, and residents of predominantly Low- and Moder ate-Income neighborhoods. The City will also take appropriate actions to encourage the participation of minorities, non -English speaking persons, and persons with disabilities by extending accommodations for participation in the CPP process.
City of Orange Draft Citizen Participation Plan
Updated September 2023
II. CITIZEN PARTICIPATION STRATEGY
A. PROGRAM PLANNING PROCESS
The City of Orange recognizes that CDBG and HOME funds are to be used primarily to benefit Low- and Moderate -Income persons and neighborhoods . The following policy defines the City’s citizen participation strategy in accordance with federal regulations.
1. Citizen Involvement
In order to ensure that Orange residents and other interested persons/organizations have the opportunity to participate in the CP, AAP and CAPER process, public meetings and publi c hearings will be held to obtain community input, consider proposals, and provide technical guidance. The public meetings and hearings will address housing and community development needs including priority non-housing community development needs, develo pment of propose d activities, and r eview of program performance. The meetings and public hearings wil l be publicized through the following methods:
▪ Display ads will be published in a newspaper of general circulation within the jurisdiction of the City of Orange at least 10 days before the meeting and hearing dates.
▪ Notices of the meetings and public hearings will be posted at the public counters in the City Clerk's Office, Community Development Department, City of Orange Main Public Library, the public notice kiosk at Ci ty Hall, and the City of Orange Community Development Department website.
The following entities will participate in the process in the following manner.
Community Development Block Grant Program Committee:
The Community Development Blo ck Grant Program Committee (CDBG Committee) will be comprised of up to seven members from the community and will act as an advisory body to the City Council concerning planning, recommending, and implementing CDBG and HOME Program funding requests and allocations and changes to the CPP. This process will include the following tasks:
▪ Disseminating pertinent information during the CDBG application process, and other HUD application processes as applicable;
▪ Receiving presentations from nonprofit agencies and City Departments;
▪ Evaluating and rating applications for CDBG and HOME funding;
▪ Collecting citizen input concerning neighborhoods and community needs;
▪ Reviewing and providing feedback on draft funding recommendations for proposed projects for City Council's review and final approval; and
▪ Reviewing project/program progress and annual performance
City of Orange Draft Citizen Participation Plan
Updated September 2023
▪ Reviewing substantial amendment requests
Community Development Department:
The Community Development Department will be the lead agency in the coordination of the CPP, CP, AAP and CAPER develop ment and reporting process and w ill coordin ate all required activities and amendments. For the CP process, the Community Development Department will conduct a needs assessment survey every five years to identify community development needs. The survey will be sen t to various stakeholders including nonprofit agencie s, City Departments, State and local health agencies, and the Orange County Housing Authority and will notify them of the publ ic hearings before the CDBG Committee and City Council. The Communi ty Development Department will send written notice to various City Departments and nonprofit agencies each year notifying them of the Notice of Funding Availability process for CDBG program, and that applications are being accepted.
Citizen Participation Process:
The City of Orange will implemen t the following strategy to solicit meaningful community input during the preparation of the CP, AAP or CAPER. All public meetings and hearings will be conducted at City Ha ll located at 300 East Chapman Avenu e, or at key public facilities which are easily accessible to the general public including persons with disabilities. During public health emergencies, all public meetings and hearings wil l be conducted virtually or in-person and public comments will be received via emails, voice mails, e-comment features, or in-person.
Consolidated Plan Process:
At a minimum, this plan will ensure that all HUD requirements are met as follows:
▪ The City will hold at least two public hea rings during the CP process to obtain citizens’ views and to respond to proposals a nd questions. The first public hearing will be held during the development of the CP and will be held before the CDBG Committee; the second public hearing will be held before the City Council.
▪ Notices of the meeti ngs and public hearings will be posted at the public counters in the City Clerk's Office, Community Services Department, Community Development Department, City of Orange Main Public Library, the public notice kiosk at City Hall and the City of Community Development Department website.
▪ There will be a 30 -day review period for citizen s to review and comment on the CP prior to approving the CP by City Council and submitting the CP to HUD.
▪ Public comments will be given consideration. The plan will include a summary of comments received and, if applicable, reasons any comments/suggestions were not incorporated.
Annual Action Plan Process:
At a minimum, this plan will ensure that all HUD requirements are met as follows:
City of Orange Draft Citizen Participation Plan
Updated September 2023
▪ During the AAP process, at least one public meeting and two public hearings will be held. The first public hearing will be held by the CDBG Committee to receive application presentation s from City Departments and nonprofit agencies for CDBG and federal funding to obtain citizens’ views.
▪ The CDBG Committee will hold one public meeting during the developm ent of the plan to review, discuss and deliberate on the formulation of funding recommendations for the City Council.
▪ The City Council will hold on e public hearing to consider the funding recommendations and approve the AAP.
▪ The proposed AAP will be published. At a minimum, the City will publish a summary of the proposed plan in a newspaper of general circulation.
▪ Notices of the meetings and publi c hearings will be post ed at the public counters in the City Clerk's Office, Community Development Department, City of Orange Main Public Library, the public notice kiosk at City Hall , and the City of Orange Community Development Department website.
▪ There will be a 30 -day period for citizen review and comment prior to submitting t he AAP to the City Council for approval and submitting to HUD.
▪ Public comments will be given considerati on. The plan will incl ude a summary of comments received and, if applicable, reasons any comments/suggestions were not incorporated.
Consolidated Annual Performance and Evaluation Report (CAPER) Process:
At a minimum, this plan will ensure that all HUD requirements are met as follows:
▪ Notice of the availability of the CAPER for public review and comment will be published in a newspaper of general circulation within the jurisdiction of the City of Orange.
▪ Notices of the availability of the CAPER for public review and comment will be posted at the public counters in the City Clerk's Office, Community Development Department, City of Orange Main Public Librar y, the public notice kiosk at City Hall , and the City of Orange Community Development Department website.
▪ There will be a 15 -day period f or citizen review and comment prio r to submitting the CAPER to HUD.
Public comments will be given consideration. The plan will in clude a summary of comments received and, if applicable, reasons any comments/suggestions were not incorporated.
2. Public Health Emergency, Natural Disaster, or Other Emergency
During a public health emergency, natural disaster, or other emergency, th e City will follow an expedited planning process to address the acute needs of the Low- and Moderate-Income residents in a
City of Orange Draft Citizen Participation Plan
Updated September 2023
timely manner. The expedited process includes a five-day public review process and one City Council meeting (virtual or in -person) to review and approve the reprogramming of funds and substa ntial amendments to the CP or the AAP. Public comments will be received by email or voice mail during the five-day public review process and at the City Council hearing by using the e -comment feature to submit comments or through appearing at City Hall and providing in-person comments
B. ACCESS TO RECORDS
The City wil l ensure t imely and reasonable access to information and records related to the development of the CP, and the use of monies for pr ograms funded by CDBG and HOME funds for the past five yea rs. Infor mation to be made available will include budget and progra m performance information, meeting minutes, and comments received by the City during the development of the CP.
Certain records will remain confidential to protect the privacy rights of affected households.
Requests for information and records must be ma de to the City Clerk Department in writing by a Public Records Act request. Staff will respond to such requests within 10 days.
C. TECHNICAL ASSISTANCE
Upon request, staff will provide t echnical assistance to develop funding requests fo r CDBG-eligible activities. The following technical assistance will be provided:
▪ The annual project proposal submission and review cycle will include the distribution of information, instructions, forms and resources to interested citizens or representative groups so that they may have reasonable access to the funding consideration process.
▪ Self-explanatory project proposal forms and instruct ions will be provided to all persons who request them whet her by te lephone, letter, or email . The City's ap plication for funds is designed to be easily understood, whi le still covering all key items necessary to determine the merits of the request. Census and Block Group data and maps depicting the areas of the City will be furnished upon request.
▪ City staff will answer questions rece ived from citizens or representati ve groups asking for assistance with writing or submit ting eligible project proposals . Such assistance will not necessarily result in the provision of funds to said groups.
▪ Meetings will be conducted with groups or indiv iduals as requested, to assist in identifying specific needs and to provide guidance in preparing project proposal applications.
▪ Completed project proposal forms from citizens or local nonprofit agencies will be assembled and a list of these proposals will be made available for public review.
▪ A project eligibility analysis process will be conducted at an early stage to det ermine the eligibility of each project. In cases where onl y minor a djustments are needed to make proposals eligible or otherwise practical, City staff will allow the proponents to make necessary changes to the proposals within a reasonable time..
City of Orange Draft Citizen Participation Plan
Updated September 2023
D. COMMENTS AND COMPLAINTS
1. Comments
Citizens or adja cent loc alities, as well as agencies providing services to the community, wi ll be encouraged to state or submit their comments on the development of the CP or the AAP, suggest amendments to the CP or the AAP, or the CAPER . Written and verbal comments rec eived at public hearings or during the public review period will be consider ed, summarized, and included with the City’s response in the final CP, AAP and CAPER. Comments and responses will also be included in amendments to the C P, AAP and CAPER. Written comments can be emailed to the Community Development Department via [email protected] or addressed to: Administrative Analyst, City of Orange, Community Development Department, 300 East Chapman Avenue, Orange, CA 92866
A written response will be made to all written comments within 10 working days after receiving comments, acknowledging the letter and identifying a plan of action, if necessary. Ever y effort will be made to send a complete response within 10 working days to those who submit written proposals or comments.
Copies of the complete final CP, AAP, CAPER, and any amendments will be available to interested parties in the Community Development Department. The City will provide a summary of the CP , AAP or CAPER upon request.
2. Complaints
Complaints regarding the CP plann ing process, AAP planning process, CAPER or proposed amendments must be made within 30 days from the date the document is published for comment. A written response will be made to all written complaints within five working days, acknowledging the letter and identifying a plan of action, if necessary. Staff will provide complete written responses to citizen complaints within 10 working days from the date of their complaint when practicable.
The City will accept written complaints provided that they:
▪ Include the name, address, and telephone n umber of the complainant and the date of the complaint.
▪ Describe the objection and provide supporting facts and data.
E. BILINGUAL OPPORTUNITIES
Wherever a significant number of residents speak and read a primary l anguage other than English, translation services at all public hearings will be provided in such language if translation services are requested in advance.
F. AMENDMENTS TO THE ACTION PLA N, CITIZEN PARTICIPATIO N PLAN, OR
THE CONSOLIDATED PLAN
The City may transfer a portion of the allocations among approved, related activities (e.g., street rehabilitation projects) when necessary to offset budget sho rtfalls. CDBG -funded Public Facilities
City of Orange Draft Citizen Participation Plan
Updated September 2023
activities that require change orders to increase or reallocate the ir respective budgets will be subject to City Manager approval fo r changes involving $30,000 or less, or City Council approval for changes involving more than $30,000.
Pursuant to Title 2 4 CFR Part 92, t he City will perform a “substantial amendment” of its approved AAP, CPP, or CP whenever one of the following occurs:
▪ A change in goals and policies of the AAP or CP
▪ Allocation of CDBG and HOME funds, including program income , to a new activity not previously described in the AAP or CP
▪ Substantial change in the purpose, scope, location, or beneficiaries of an existing activity
▪ Reallocation of more than 20 percent of CDBG or HOME entitlement funds for the program year
▪ Updates to procedures, requirements, or other material changes to the Citizen Participation Plan
▪ Update to the CDBG eligibility map approved in the current Consolidated Plan
The process for a “substantial amendment” consists of the following during non-emergency scenarios.
1. Publishing a 30-day public notice of the date, time, and place of the pub lic hearing in a newspaper of g eneral circulation within the juris diction of the City of Orange as well as the City’s social media platforms. This notice also serv es as the notice for the 30 -day public review period.
2. Holding one public hearing before the City Council.
3. Noticing of the public hearing will be posted at the public counters in the City Clerk's Office , Community Development Department, City of Orange Main Public Library, the public notice kiosk at City Hall, and the City of Orange Community Development website.
In case of public health emergency, natural disasters, or other emergencies, the above proc ess follows an “expedited process” outlined under Section A.2.
G. APPEALS
Appeals concerning the Plan s or decisions, statements, or recommendations of the staff shou ld be made to the following parties in the order listed: Senior Administrative Analyst, Community Development Dep artment Director, City Manager, CDBG Program Committee, City Council , and finally, the Los Angeles Area HUD office.
H. ANTI-DISPLACEMENT/RELOCATION
In the event that any residential displacement and relocation must take place in o rder to carry out a program activity, the City of Orange ensures that it wil l collaborate with the applicant/developer to
City of Orange Draft Citizen Participation Plan
Updated September 2023
prepare and approve an Anti -displacement and Relocation Plan in connection with that project as required by federal regulations. In the event that any acquisition and relocation is required to carry out a prog ram activity, the City of Orange will also compl y with federal acquisition and relocation requirements pursuant to Uniform Relocation Assistance Policies Act of 1970 under Title 49 CFR Part
24. I. ASSURANCES
The Citizen Participation Plan outlines the n ecessary processes to engage the public when preparing or amending the CP, AAP or CAPER. Prior to City Council approval, citizens will be given a reasonable opportunity to comment on the CP, AAP or CAPER. The CP, AAP or CAPER will be made available to the public and reasonable efforts will be made to ma ke the se documents available in a format accessible to persons with disabilities, or in another language upon their request.
The City of Orange assures that the most diligent effort s will be made to comply w ith the process and procedures outlined in this Citizen Participation Plan.