ReBuild NC Citizen Participation Plan
North Carolina Office of Recovery and Resiliency (NCORR)September 18, 2020Citizen Participation PlanVersion 3.0State of North CarolinaFor CDBG-DR and CDBG-MIT Funds(Public Law 115-254, Public Law 116-20)Citizen Participation PlanCDBG-DR and CDBG-MIT
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North Carolina Office of Recovery and Resiliency (NCORR)Citizen Participation PlanCDBG-DR and CDBG-MITRevision HistoryVersionDateDescription2.0March 24, 2020Revises and replaces a defunct version of the Citizen Participation Plan andcombines the CDBG-DR and CDBG-MIT citizen participation plans into a singledocument.3.0September 18, 2020Clarified public comment and public hearing requirements for the CDBG-MIT ActionPlan. Simplified substantial Action Plan amendment criteria.ii
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North Carolina Office of Recovery and Resiliency (NCORR)Citizen Participation PlanCDBG-DR and CDBG-MITContents1.0 General Citizen Participation and Public Comment . 11.1 Overview and Encouragement of Citizen Participation . 11.2 Citizen Participation and Outreach for Action Plans. 21.3 Public Notice, Comment Period, and Website. 31.4 Individuals with Limited English Proficiency (LEP) . 41.5 Individuals with Disabilities . 41.6 Response to Citizen Complaints and Appeals . 51.7 Contact Information . 62.0 Mitigation Citizen Participation and Outreach Plan . 82.1 Outreach Activities and Public Hearings . 82.2 Outreach and Public Hearings Prior to Publishing Draft MIT Action Plan . 82.3 Publishing the Draft Mitigation Action Plan . 102.4 Outreach and Public Hearings after Publishing Draft MIT Action Plan . 102.5 Local Government and Stakeholder Input . 112.6 Limited English Proficiency (LEP). 122.7 Accessibility at the Public Hearings . 122.8 Complaint Policy . 123.0 Outreach and Citizen Participation after Publishing the Draft CDBG-MIT Action Plan . 143.1 Public Website . 143.2 Citizen Advisory Committee . 144.0 Mitigation Program Outreach . 164.1 Local Government and Public Participation for the Buyout Program . 164.2 Mitigation Program Outreach . 174.3 Program Access for LEP Participants. 174.4 Special Needs and Accessibility . 184.5 Fair Housing . 19Appendices – Public Notices . A-1iv
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North Carolina Office of Recovery and Resiliency (NCORR)Citizen Participation PlanCDBG-DR and CDBG-MIT1.0 General Citizen Participation and PublicCommentTo better engage recovering citizens of North Carolina, the North Carolina Office of Recoveryand Resiliency has developed an updated citizen participation plan. Specific citizen participationrequirements are generally prescribed in the Federal Register Notices that set forth the rulesand requirements for each source of funding. NCORR complies with these Federal RegisterNotices, and may issue specific updates or alternate plans to comply with that guidance.In the absence of alternate citizen participation plan guidance, this guide serves as aconsolidated CDBG-DR and CDBG-MIT guide. The CDBG-MIT specific section begins below atPart 2.0 below.1.1 Overview and Encouragement of Citizen ParticipationNCORR is the administrator of Community Development Block Grant – Disaster Recovery(CDBG-DR) and Community Development Block Grant – Mitigation (CDBG-MIT) funds providedto the State by the U.S. Department of Housing and Urban Development (HUD). These fundingsources support NCORR’s disaster recovery programs, known as “ReBuild NC”. Through ReBuildNC, NCORR and its partners are able to assist storm-impacted residents by providing services torestore housing and communities damaged by presidentially declared disasters or to takeaction to mitigate against future anticipated disasters.NCORR is committed to ensuring that all populations impacted by the presidentially declareddisaster of Hurricane Matthew and Hurricane Florence are aware of available resources, havean opportunity for input, and have equal access to information about the programs to assist inrecovery and mitigation efforts. Through in-person meetings, outreach events, online andtraditional media, NCORR requests public comments on plans, publicizes existing programs andchanges to existing plans and programs, and conducts outreach efforts throughout the stormimpacted areas. In addition, the Governor’s Office has engaged a grass-roots community drivenprocess that engages the public as a key stakeholder in the planning and rebuilding process.NCORR values the input of its many impacted citizens and the decision makers and stakeholdersthat represent the vulnerable communities affected by storms or at risk for future flooding andstorm damage. NCORR requests input from all citizens and will perform additional outreachefforts to low- and moderate-income (LMI) persons, racial/ethnic minorities, persons withdisabilities, and persons with Limited English Proficiency to obtain input. Each ReBuild NCprogram may have additional specific outreach and citizen participation responsibilitieshowever, each program will adhere to the citizen participation requirements outlined below. Tomeet the public participation requirements of the CDBG-DR and CDBG-MIT grants, NCORRcommits to the processes described below for citizen participation, complaints, appeals, andthe public notice period.1
North Carolina Office of Recovery and Resiliency (NCORR)Citizen Participation PlanCDBG-DR and CDBG-MIT1.2 Citizen Participation and Outreach for Action PlansFor each disaster recovery grant provided by HUD, HUD requires the creation and maintenanceof an Action Plan that provides a strategy for the use of the disaster recovery funds. NCORRinvites and encourages citizen participation in the development of its Action Plans according tothe regulatory requirements for each funding allocation. Citizen participation is also soughtduring the associated amendment processes that are done according to regulatoryrequirements (the amendment process is discussed more fully in each Action Plan). At aminimum, Substantial Action Plan Amendments must follow the public comment periodtimelines indicated in the table below. Substantial Action Plan Amendment criteria include: A change in program benefit or eligibility criteria. The addition or deletion of an activity. The addition of a “Covered Project” for Infrastructure (CDBG-MIT only).o See the definition of a Covered Project 0/pdf/2019-18607.pdf. A change in program allocation based on a threshold set in each Action Plan.Table 1 - Public Comment Period Lengths by Action PlanAction PlanPublic Comment PeriodHurricane Matthew – DR14 daysHurricane Matthew – MIT30 daysHurricane Florence – DR30 daysNCORR may elect to align the Hurricane Matthew – DR public comment period with theHurricane Florence – DR or CDBG-MIT public comment period of 30 days when the content ineach of those amendments is similar to simplify the receipt of public comment.NCORR will perform outreach through various state and local stakeholders, including theengagement of recovery partners such as the Recovery Support Function Groups, tribalcommunities, public housing authorities, church and faith-based organizations, professionalorganizations, other known constituency groups, and citizens who have requested notification.NCORR will advertise opportunities for citizen comment on the draft Action Plan on its ReBuildNC website and if required, NCORR will also hold public meetings or hearings in impactedcommunities. NCORR will advertise open comment period through: Neighborhood associations and groups, community-based organizations, agencies, andchurches providing services to or advocating for low- and moderate-income persons,racial/ethnic minorities, persons with disabilities, and persons with Limited EnglishProficiency; and2
North Carolina Office of Recovery and Resiliency (NCORR) Citizen Participation PlanCDBG-DR and CDBG-MITMedia sources that have direct contact with low- and moderate-income persons,culturally diverse persons, racial/ethnic minorities, persons with disabilities, and personswith Limited English Proficiency.During times of COVID-19 restrictions, NCORR’s outreach efforts have been modified to ensurepublic and staff safety. In-person public meetings have been suspended in accordance withstate requirements, and print and media outreach has taken precedence during the restrictions.1.3 Public Notice, Comment Period, and WebsiteA comment period for a minimum of the length of time indicated in Table 1, as required by HUD,shall be provided for citizens, affected local governments, and other interested parties tocomment on the initial draft and subsequent substantial amendments to Action Plans.In accordance with CDBG-DR and CDBG-MIT requirements, NCORR has developed and willmaintain a comprehensive website regarding all disaster recovery activities assisted with thesefunds. NCORR will post all Action Plans and amendments on the NCORR’s ReBuild NC website athttp://www.rebuild.nc.gov/action-plans. Specific information on the CDBG-MIT grant can befound at https://rebuild.nc.gov/mitigation.The website gives citizens an opportunity to read draft Action Plans and to submit comments.The website is featured prominently on, and is easily navigable from, NCORR’s homepage.Paper copies of Action Plan Amendments will be available in both English (including large, 18pttype) and Spanish as needed at ReBuild NC Centers as well as online. Other accessibility needs,such as availability in a language other than English, is available upon request as needed. Centerlocations are found at the ReBuild NC website at https://www.rebuild.nc.gov.After the conclusion of the required comment period, all comments are reviewed and NCORRprovides responses to comments in a revised draft of the Action Plan. NCORR’s consideration ofand response to all public comments can be reviewed in the Appendices of the final Action PlanAmendments which are posted on the ReBuild NC website after HUD approval of the actionplan draft.Upon approval of an initial Action Plan, HUD will provide an action plan approval letter, grantterms and conditions, and a grant agreement. Upon receipt of the grant agreement, the Statewill review and begin the process of executing the grant agreement with HUD. At grantagreement signing, NCORR makes available the final, approved Action Plans on the Action Planpage of the website.In addition to Action Plans and amendments, the ReBuild NC website includes the followinginformation for citizen review: The current approved Disaster Recovery Grant Reporting System (DRGR) Action Plans.Citizen participation requirements.Procurement policies and procedures.3
North Carolina Office of Recovery and Resiliency (NCORR) Citizen Participation PlanCDBG-DR and CDBG-MITCurrent procurements for goods and services.Performance reports, such as Quarterly Performance Reports (QPR).Current contract agreements.A summary of all procurements.Citizens interested in NCORR’s Mitigation Program plans, activities, Citizen Advisory Committeeand program expenditures may access the Mitigation webpage from the Rebuild NCcomprehensive website. The Mitigation webpage will be updated regularly and is available athttps://rebuild.nc.gov/mitigation.1.4 Individuals with Limited English Proficiency (LEP)Based on LEP data within the impacted areas collected by the State, Action Plans, Action Planamendments, and ReBuild NC program materials including manuals, forms and policies will beavailable in both English and Spanish. In addition, the instructions for commenting on andaccess to the Action Plan are also translated into Spanish.NCORR provides both oral interpretation and written translation services to persons at no costand these services are available upon request. Meaningful and equal access to federally fundedprograms and activities is required by Title VI of the Civil Rights Act of 1964.NCORR evaluates the LEP needs of each individual community using HUD’s final guidance onthe “four-factor analysis”, available here:https://www.hud.gov/program offices/fair housing equal opp/promotingfh/lep-faq#q7.To respond to efforts to communicate fully with LEP individuals, NCORR has developed aLanguage Access Plan that governs when and how communication in languages other thanEnglish is developed, disseminated, and provided by NCORR and its agents. Based on the fourfactor analysis, NCORR has concluded that critical program documents will be provided inSpanish. Other program materials will be provided in Spanish or other languages as neededwhen working in and coordinating with the public in those impacted communities based onthat analysis. A link to the Language Access Plan is available icy forms 1.5 Individuals with DisabilitiesThe ReBuild NC Program will be accessible to all persons with disabilities and will operate in amanner that does not discriminate or limit access to program services and benefits to personswith disabilities. To ensure that the Program is operating in compliance with Section 504requirements of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA),the ReBuild NC Program will:4
North Carolina Office of Recovery and Resiliency (NCORR)Citizen Participation PlanCDBG-DR and CDBG-MIT Ensure that all facilities where clients will have face-to-face interaction with programstaff are readily accessible and usable by persons with disabilities. Assist Intake Specialists/Case Managers in providing written and verbal communicationto program applicants regardless of their disability or limited proficiency with theEnglish language to include sign language, braille, interpreters, etc. Assist Intake Specialists/Case Managers in completing home visits with applicants whoare homebound or cannot access a ReBuild NC Center as needed. Ensure that reasonable accommodation modifications to the applicant’s home are partof a program scope of work as applicable. Appropriately address any identified hearing, visibility, or mobility limitations of theapplicant and/or applicant’s household members as required by Section 504 and theAmericans with Disabilities Act (ADA). Work with a disabled applicant's designee who has power of attorney or any non-profitorganization that is representing the applicant as needed.In addition, NCORR complies with Section 508 requirements that require accessibility toelectronic and information technology for individuals with disabilities. NCORR’s programmanagement vendor assists with ensuring that all public communications, including its ReBuildNC website, meet Section 508 requirements. The online materials will also be accessible for thevisually impaired. NCORR will ensure that all print, verbal, or electronic communications withthe public regarding distribution of CDBG-DR and CDBG-MIT funding and actionableinformation are simultaneously communicated to persons with disabilities and others withaccess and functional needs via qualified channels (i.e. ASL interpreters, open captions, Braille,large, high contrast print, formats accessible to screen readers, podcasts etc.) in an equitable,timely, and efficient manner. Information will be presented in an understandable manner, usingplain language and identifying whom to contact for clarification or additional information. Formore information on how people with disabilities can access and comment on the Action Plan,dial (833)–ASK–RBNC.1.6 Response to Citizen Complaints and AppealsNCORR shall provide a written response to every complaint relative to CDBG-DR or CDBG-MITwithin fifteen (15) working days of receipt. The state will execute its Appeals Process inresponse to appeals received and will require subrecipients to adopt a similar process. Theprocess will be tiered whereby applicants will be able to appeal a decision and receive furtherreview from another level.All subrecipients will be required to develop an appeals and complaint procedure that alignswith the requirements of NCORR’s Appeal Policy and complaints procedures. An appeal may befiled to handle complaints or appeals from individuals who have applied for or have an interestin CDBG-DR or CDBG-MIT funding. A written appeal may be filed when dissatisfied with5
North Carolina Office of Recovery and Resiliency (NCORR)Citizen Participation PlanCDBG-DR and CDBG-MITprogram policies, eligibility, level of service or other issue by including the individual facts andcircumstances as well as supporting documentation to justify the appeal.An appeal review committee will review the appeal. If the appeal is denied or the applicant isdissatisfied with the decision, an appeal can be made to NCORR directly.In programs that serve individual applicants, applicants may appeal their award determinationsor denials that are contingent on program policies. However, it should be noted that NCORRdoes not have the authority to grant an appeal of a statutory or HUD-specified CDBG-DR orCDBG-MIT requirement.1.7 Contact InformationComments and complaints may be submitted as follows: Email comments to publiccomments@rebuild.nc.gov.o Include the Action Plan or funding source of the comment in the subject line. Telephone: (984
however, each program will adhere to the citizen participation requirements outlined below. To meet the public participation requirements of the CDBG-DR and CDBG-MIT grants, NCORR commits to the processes described below for citizen participation, complaints, appeals, and the public notice period. 2.0 below
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Performance Report, Citizen Participation Plan as required by HUD. Objectives of the Citizen Participation Plan . The CPP includes the following objectives and describes how each will be met to ensure federal regulatory compliance. Encourage citizen participation by providing residents with adequate information concerning:
Encouraging Citizen Participation In order to facilitate citizen participation requirements and to maximize citizen interaction in the development of the Consolidated Plan, substantial amendments to the Consolidated Plan and/or the annual action plan (AAP) and the performance report (CAPER), the State will take actions necessary to
2. Self-Assessment and Planning Tool: assess past citizen participation and consultation activities and create citizen participation and consultation priorities and goals 3. Citizen Participation and Consultation Activities: potential methods or approaches grantees can use to support outreach to the public and stakeholders 4.
Sherry Arnstein – Ladder of Citizen Participation Sherry Arnstein’s ladder of citizen participation, published in 1969 in the Journal of the American Plan-ning Association, is considered one of the classic and most inluential participation theories. Arnstein rests her theory on the declaration that citizen par
of citizen participation. Together, these constitutional and legislative provisions avail various platforms for citizen participation in devolved governance. Citizen participation is one of the national values and is also one of the principles of public service as articulated in the Constitution in Articles 10 (2,a) and Article 232 (1).
"Bank's Summary Judgment Motion"). Rebuild agrees to these factual assertions. Response of the Defendants, Reo America Incorporated and Rebuild America, Inc., to· Huntington National Bank, N .A.'s Motion for Summary Judgment, served and flIed on or about April 12.2013 ("Rebuild's Response")) 11 a., at p. 1. 2.
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