HomeMy WebLinkAbout10 AMEND TO CDBG PROG 01-06-03AGENDA REPORT
NO. ~o
01-06-03
MEETING DATE:
TO:
FROM:
SUBJECT:
JANUARY 6, 2003
WILLIAM HUSTON, CITY MANAGER
COMMUNITY DEVELOPMENT DEPARTMENT
AMENDMENT TO THE CITIZEN PARTICIPATION PLAN FOR COMMUNITY
DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM
SUMMARY
The City's original Citizen Participation 'Plan (CP Plan) was adopted in November of
1995. The CP Plan sets forth the City of Tustin's policies and procedures for citizen
notification pertaining to all aspects of the development', amendment, and reporting related
to the Consolidated Plan for Community Development Block Grant (CDBG) program.
However, the existing CP plans does not provide a clear distinction between an
"amendment" and a "substantial amendment" to the Action Plan/Consolidated Plan. In
addition the CP Plan does not define the roles, responsibilities, and composition of the
Citizen Participation Committee. The proposed amendments would identify criteria for
an "amendment"' and a "substantial amendment" and define the roles, responsibilities,
and composition of the Citizen Participation Committee.
RECOMMENDATION
That the City Council adopt Resolution No. 03-05 amending the Citizen Participation
Plan for the Community Development Block Grant (CDBG) program.
FISCAL IMPACT
Programs and expenditures of CDBG eligible activities will be implemented with CDBG
funds. No impacts to the General Fund are anticipated.
PROPOSED AMENDMENTS
The City is required by Federal Law to have a detailed Citizen Participation Plan (CP
Plan). The purpose of the CP Plan is to detail an effective process which provides citizens
with an opportunity to participate in an advisory role in the planning, implementation,
amendment, and assessment of the City of Tustin's Consolidated Plan for Community
Planning and Development Programs such as the CDBG program.
The City's existing CP Plan was adopted in November of 1995. The CP Plan provides
Tustin's citizens with a process to participate in identifying needs, setting priorities,
allocating funds to eligible activities, and overseeing the overall program implementation
and performance. The existing CP Plan also provides notification and public hearing
City Council Meeting
January 6, 2003
Page 2
process in which the City would have to follow in developing, amending, and reporting
the performance of the Action Plan and/or Consolidated Plan. However, the existing CP
plans does not provide a clear distinction between an "amendment" and "substantial
amendment" to the Action Plan/Consolidated Plan. While Federal Law only requires the
City to notify HUD of any amendments to the Action Plan and/or Consolidated Plan, the
law also requires the City to provide its citizens with at least a 30 day notice before any
"substantial amendments" are implemented. Therefore, a clear distinction to the criteria
should be established.
In addition, CP Plan encourages citizens to participate in the development of the
Consolidated Plan, any substantial amendments to the Consolidated Plan, and the
performance report through the. Citizen Participation Committee. The existing CP Plan
does not define the roles, responsibilities, and composition of the Citizen Participation
Committee. Therefore the proposed amendment is necessary to define the roles,
responsibilities, and the composition of the Citizen Participation Committee.
The proposed amendments are as follows:
· Substantial Amendment.
Section 91.505 of the Final Rule requires the City to identify the criteria for determining
what changes in the planned or actual activities constitute a substantial amendment to
the City's Action Plan and/or Consolidated Plan. A substantial amendment is defined
as follows:
a) The deletion or addition of priorities established in the Consolidated Plan.
b)
An increase or decrease in funds of fifty (50) percent or more allocated to a
specific project or program.
c) Any new activity not previously described in the Action Plan and/or
Consolidated Plan.
· Citizen Participation Committee.
Citizen Participation Committee. The City will enc°urage citizens to participate in the
development, implementation, and evaluation of the Action Plan and/or Consolidated
Plan through the Citizen Participation Committee.
1. Citizen Participation Committee Membership
The Citizen Participation Committee is an Ad'Hoc Committee comprised of seven
(7) members. Committee members should be active community leaders who are
aware of the needs of the community and who will assist in obtaining citizen input
City Council Meeting
January 6, 2003
Page 3
concerning the Community Development Block Grant Program. The proposed
composition of the Citizen Participation Committee would be as follows:
· One representative from the Planning Commission
· One representative from the Parks and Recreation Commission
· One representative from the Cultural Resources Advisory Committee
· One representative from the Senior Advisory Board
· One representative from the Tustin Audit Committee
· Two at large representatives appointed by the City Council
2. The Citizen Participation Committee duties and responsibilities are as follows:
To provide citizen and community input in an advisory fashion on the
development, implementation, evaluation, and amendments to the Community
Development Block Grant Program.
To hold at least one public hearing during' the development of the Action Plan
and/or Consolidated Plan to obtain citizens views and to respond to citizen
proposals and requests, to assist in the determination of the community
development and housing needs and priorities, and to obtain comments on the
City's Community Development Block Grant program performance.
· To encourage broad citizen and community participation on the Community
Development Block Grant Program.
All aspects of the Citizen Participation meetings will be open to the public at all
times. All meetings are to be held at convenient times and locations and in
accordance with paragraph e for public hearing requirements.
In accordance with Federal Law, the City has published a notice in the local newspaper
with regard to the proposed amendments. Staff recommends that the City Council
support the amendments to the Citizen Participation Plan.
Associate Planner
~ab-eth A. Binsack-
Director of Community Development
Attachments:
1. Resolution No. 03-05
2. Citizen Participation Plan
S:\Cdd\CCREPOR'~Amendment to Citizen Participation Plan.doc
ATTACHMENT 1
Resolution No. 03-05
RESOLUTION NO. 03-05
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF TUSTIN, CALIFORNIA, APPROVING
AMENDMENTS TO THE CITY'S CITIZEN
PARTICIPATION PLAN FOR COMMUNITY
DEVELOPMENT BLOCK GRANT PROGRAM AND
AUTHORIZING SUBMISSION OF THE
AMENDMENTS TO THE FEDERAL DEPARTMENT
OF HOUSING AND URBAN DEVELOPMENT.
WHEREAS, under the Housing and Community Development Act of 1974, as
amended, Federal assistance may be provided for the support of Community
development activities which are directed toward certain specific objectives as set forth
in the Act as the Community Development Block Grant;
WHEREAS, the City is required by Section 91.105 of the Consolidated Plan Final
Rule to have a Citizen Participation Plan to encourage citizen participation for the
Community Development Block Grant Program;
WHEREAS, the existing Citizen Participation Plan does not have a clear
distinction between an "amendment" and a "substantial amendment" to the Action Plan
and/or Consolidated Plan and the proposed amendment would clarify the distinction
between an "amendment" and a "substantial amendment" to the Action Plan and/or
Consolidated Plan;
WHEREAS, the existing Citizen Participation Plan does not define the roles,
responsibilities, and composition of the Citizen Participation Committee and the
proposed amendment would define the roles, responsibilities, and composition of the
Citizen Participation Committee;
WHEREAS, citizens were notified of the proposed amendments to the City's
Citizen Participation Plan through a legal notice published in the local newspaper; and
WHEREAS, the City Council considered the amendments at the meeting on
January 6, 2003.
NOW THEREFORE BE IT RESOLVED, the City Council of the City of Tustin
resolves as follows:
Section 1: The amendments to the City of Tustin's Citizen Participation Plan
shall be as follows:
City Council Resolution 03-05
Page 2 of 5
'Section (a)(2)(iii) is added to read:
Citizen Participation Committee. The City will encourage citizens to
participate in the development, implementation, and evaluation of the Action
Plan and/or Consolidated Plan through the Citizen Participation Committee.
1. Citizen Participation Committee Membership
The Citizen Participation Committee is an Ad Hoc Committee comprised
of seven' (7) members. Committee members should be active
community leaders who are aware of the needs of the community and
who will assist in obtaining citizen input concerning the Community
Development Block Grant Program. The composition of the Citizen
Participation Committee is as follows:
· One representative from the Planning Commission
· One representative from the Parks and Recreation Commission
· One representative from the Cultural Resources Advisory Committee
· One representative from the Senior Advisory Board
· One representative from the Tustin Audit Committee
· Two at large representatives appointed by the City Council
2. The Citizen Participation Committee duties and responsibilities are as
follows:
To provide citizen and community input in an advisory fashion on the
development, implementation, evaluation, and amendments to the
Community Development Block Grant Program.
To hold at least one public hearing during the development .of the
Action Plan and/or Consolidated Plan to obtain citizens views and to
respond to citizen proposals and requests, to assist in the
determination of the community development and housing needs and
priorities, and to obtain comments on the City's Community
Development Block Grant program performance.
· To encourage broad citizen and community participation on the
Community Development Block Grant Program.
All aspects of the Citizen Participation meetings will be open to the public
at all times. All meetings are to be held at convenient times and
locations and in accordance with paragraph e for public hearing
requirements.
City Council Resolution 03-05
Page 3 of 5
Section 2: Section (c) is amended to read:
(c) Amendments.
Amendment to the Action Plan and/or Consolidated Plan. The City of
Tustin will amend the approved Action Plan and/or Consolidated Plan
whenever the City makes the following decisions, as found in
{}91.505 of the Final Rule of consolidated submission:
A decision to make a change in its allocation priorities or a
change in the method of distribution of funds;
A decision to carry out an activity, using funds from any
program covered by the Consolidated Plan (including program
income), not previously described in the Action Plan; or
A decision to change the purpose, scope, or location of
beneficiaries of an activity.
Upon completion, the City will make the amendment public and will
notify HUD of such amendment. The City reserves the right to make
non-substantial changes to the Action Plan and/or Consolidated Plan
without opening a public comment period.
(2)
Substantial Amendment. Section 91.505 of the Final Rule requires
the City to identify the criteria for determining what changes in the
planned or actual activities constitute a substantial amendment to the
City's Action Plan and/or Consolidated Plan. A substantial
amendment is defined as follows:
a) The deletion or addition of priorities established in the
Consolidated Plan.
b)
An increase or decrease in funds of fifty (50) percent or more
allocated to a specific project or program.
c)
Any new activity not previously described in the Action Plan
and/or Consolidated Plan.
The City of Tustin will provide citizens with reasonable notice and an
opportunity to comment on substantial amendments. Such substantial
amendments will be noticed in a local newspaPer of general circulation and
notices will be posted in public places, including the Tustin library and
various City Hall locations. Written comments will be accepted during
regular City business hours and by mail. A period, not less than 30 days, to
City Council Resolution 03-05
Page 4 of 5
receive comments on the substantial amendment before the amendment is
implemented will be provided. If determined appropriate or necessary by the
City of Tustin, a public hearing will also be held.
The City of Tustin shall consider any comments or views of citizens received
in writing, or orally.at public hearings, if any, in preparing the substantial
amendment of the Consolidated Plan. A summary of these comments or
views, and a summary of any comments or views not accepted and the
reasons therefore, shall be attached to the substantial amendment of the
Consolidated Plan.
Section 3: Staff is hereby directed to prepare and submit the amended Citizen
Participation to the Federal Department of Housing and Urban Development.
Section4: The City Manager of the City of Tustin or his designated
representative, such as the Director of Community Development, is authorized to
execute documents, certifications, contracts or other instruments as may be required to
carry out the City's Community Development Program.
Section 5: The City Clerk shall certify to the adoption of this Resolution and
shall file a copy of said application with the minutes of this City Council meeting.
PASSED AND ADOPTED at a regular meeting of the Tustin City Council, held on
the 6th day of January, 2003.
TRACY WILLS WORLEY
Mayor
Pamela Stoker
City Clerk
City Council Resolution 03-05
Page 5 of 5
STATE OF CALIFORNIA )
COUNTY OF ORANGE )
CITY OF TUSTIN )
SS
CERTIFICATION FOR RESOLUTION NO. 03-05
PAMELA STOKER, City Clerk and ex-officio Clerk of the City Council of the City of Tustin,
California, does hereby certify that the whole number of the members of the City Council of
the City of Tustin is five; that the above and foregoing Resolution No. 03-05 was duly passed
and adopted at a regular meeting of the Tustin City Council, held on the 6th day of January,
2003, by the following vote:
COUNCILMEMBER AYES:
COUNCILMEMBER NOES:
COUNCILMEMBER ABSTAINED:
COUNCILMEMBER ABSENT:
Pamela Stoker, City Clerk
ATTACHMENT 2
Citizen Participation Plan
CITY OF TUSTIN
CITIZEN PARTICIPATION PLAN
INTRODUCTION AND PURPOSE
The purpose of the Citizen Participation Plan (CP Plan) is to detail an effective process
which provides citizens with an opportunity to participate in an advisory role in the
planning, implementation, and assessment of the City of Tustin's Consolidated Plan
(Plan) for Community Planning and Development Programs, such as the Housing and
Community Development Block Grant (CDBG), HOME, Housing Opportunities for
Persons with Aids (HOPWA) and Emergency Shelter Grant (ESG) programs. However,
at this time, the CDBG program is the only one in which the City participates.
The CP Plan sets forth the City of Tustin's policies and procedures for citizen notification
pertaining to all aspects of the development, amendment and reporting related to the
Consolidated Plan.
The City of Tustin also pledges to follow its Citizen Participation Plan. The CP Plan will
be a working tool for City personnel, as well as citizens.
All questions related to the CP Plan may be addressed to The Community Development
Department of the City of Tustin during normal office hours by phone at (714) 573-3106
or by writing to 300 Centennial Way, Tustin, CA 92780. Copies of this CP Plan are
available upon request.
OBJECTIVES OF THE CITIZEN PARTICIPATION PLAN
The objectives of the Citizen Participation Plan are:
,
To encourage citizens, particularly residents with Iow- and moderate-incomes living
in areas eligible for the use of program funds and including minorities, non-English
speaking persons, and persons with mobility, visual, or hearing impairments, to
participate in the development of the Consolidated Plan.
,
To assure that citizens are furnished appropriate information about the
Consolidated Plan and its various component programs.
Citizen Participation Plan
The following Citizen Participation Plan has been prepared in accordance with §91.105 of
the Final Rule for Consolidated Submission for Community Planning and Development
Programs, dated January 5, 1995.
(a) Applicability and adoption of the Citizen Participation Plan.
The City of Tustin is required to adopt a Citizen Participation Plan that sets
forth policies and procedures for citizen participation in the preparation of a
Consolidated Plan for use of Community Development Block Grant (CDBG)
funds.
(2). Encouragement of citizen participation.
(i)
The Citizen Participation Plan provides for and encourages citizens
to participate in the development of the Consolidated Plan, any
substantial amendments to the Consolidated Plan, and the
Performance Report.
(ii)
The requirements are designed especially to encourage participation
by Iow- and moderate-income persons, particularly those living in
slum and blighted areas and in areas where CDBG funds are
proposed to be used, and by residents of predominantly Iow- and
moderate-income neighborhoods, as identified by the City of Tustin.
The City also is expected to take whatever actions are appropriate to
encourage the participation of all its citizens, including minorities and
non-English speaking persons, as well as persons with disabilities.
Citizen Participation Committee. The City will encourage citizens to
participate in the development, implementation, and evaluation of the
Action Plan and/or Consolidated Plan through the Citizen
Participation Committee.
1. Citizen Participation Committee Membership
The Citizen Participation Committee is an Ad Hoc Committee
comprised of seven (7) members. Committee members should
be active community leaders who are aware of the needs of the
community and who will assist in obtaining citizen input
concerning the Community Development Block Grant Program.
(iv)
The composition of the Citizen Participation Committee is as
follows:
· One representative from the Planning Commission
· One representative from the Parks and Recreation
Commission
· One representative from the Cultural Resources Advisory
Committee
· One representative from the Senior Advisory Board
· One representative from the Tustin Audit Committee
· Two at large representatives appointed by the City Council
2. The Citizen Participation Committee duties and responsibilities
are as follows:
To provide citizen and community input in an advisory fashion
on the development, implementation, evaluation, and
amendments to the Community Development Block Grant
Program.
To hold at least one public hearing during the development of
the Action Plan and/or Consolidated Plan to obtain citizens
views and to respond to citizen proposals and requests, to
aSsist in the determination of the community development and
housing needs and priorities, and to obtain comments on the
City's Community Development Block Grant program
performance.
· To encourage broad citizen and community participation on
the Community Development Block Grant Program.
All aspects of the Citizen Participation meetings will be open to
the public at all times. All meetings are to be held at convenient
times and locations and in accordance with paragraph e for
public hearing requirements.
The City of Tustin encourages, in conjunction with consultation with
public housing authorities (the Orange County Housing Authority),
the participation of residents of public and assisted housing
developments in the process of developing and implementing the
Consolidated Plan, along with other Iow-income residents of targeted
revitalization areas in which the developments are located. The City
shall make an effort to provide information to the housing agency
about Consolidated Plan activities so that the housing agency can
make this information available at the annual public hearing required
under the Comprehensive Grant program.
(3)
Citizen comment on the Citizen Participation Plan and amendments. The
City of Tustin will provide citizens with a reasonable opportunity to comment
on the original Citizen Participation Plan and on substantial amendments to
the Citizen Participation Plan, and will make the Citizen Participation Plan
public. The Citizen Participation Plan will be in a format accessible to
persons with disabilities, upon request. Prior to its adoption, notice of the
availability of the Citizen Participation Plan will be published in the local
newspaper and posted at various locations in City Hall. After a 30-day
period, during which comments on the Citizen Participation Plan will be
accepted by the Community Development Department, the Citizen
Participation Plan will be adopted.
(b)
Development of the Consolidated Plan. The Citizen Participation Plan includes the
following minimum requirements for the development of the Consolidated Plan.
(1)
Before the City of Tustin adopts a Consolidated Plan, the City will make
available to citizens, public agencies, and other interested parties
information that includes the amount of assistance the City expects to
receive (including grant funds and program income) and the range of
activities that may be undertaken, including the estimated amount that will
benefit persons of Iow- and moderate-income. The City of Tustin will make
this information available at a public meeting or hearing, noticed local
newspapers and posted at various City Hall locations. This meeting/hearing
will be held prior to "publication" of the Plan for comment.
Prior to the undertaking of any project resulting in the displacement of
person, the City will set forth plans to minimize that displacement, and to
assist any persons displaced, specifying the types and levels of assistance
the jurisdiction will make available (or require others to make available) to
persons displaced. The City of Tustin will make this information available in
direct mailings or by meeting with impacted residents.
(2)
The City of Tustin will publish the proposed Consolidated Plan in a manner
that affords citizens, public agencies, and other interested parties a
reasonable opportunity to examine its contents and to submit comments.
The requirement for publishing will be met by publishing a summary of the
proposed Consolidated Plan in one or more newspapers of general
circulation, and by making copies of the proposed Consolidated Plan
available at the Tustin Library and a City Hall location, including a notice
(c)
board. The summary will describe the contents and purpose of the
Consolidated Plan, and will include a list of the locations where copies of
the entire proposed Consolidated Plan may be examined. In addition, the
City of Tustin will provide free copies of the plan to citizens and groups that
request it.
(3)
The City of Tustin will provide for at least one public hearing during the
development of the Consolidated Plan after publication of the draft version.
See paragraph (e) of this section for public hearing requirements, generally.
(4)
The City will provide a period, not less than 30 days, to receive comments
from citizens on the Consolidated Plan.
(5)
The City of Tustin will consider any comments or views of citizens received
in writing, or orally at the public hearings, and in preparing the final
Consolidated Plan. A summary of these comments or views, and a
summary of any comments or views not accepted and the reasons
therefore, shall be attached to the final Consolidated Plan.
Amendments.
(1)
Amendment to the Action Plan and/or Consolidated Plan. The City of
Tustin will amend the approved Action Plan and/or Consolidated Plan
whenever the City makes the following decisions, as found in {}91.505 of
the Final Rule of consolidated submission:
A decision to make a change in its allocation priorities or a change in
the method of distribution of funds;
A decision to carry out an activity, using funds from any program
covered by the Consolidated Plan (including program income), not
previously described in the Action Plan; or
A decision to change the purpose, scope, or location of beneficiaries
of an activity.
Upon completion, the City will make the amendment public and will notify
HUD of such amendment. The City reserves the right to make non-
substantial changes to the Action Plan and/or Consolidated Plan without
opening a public comment period.
(2)
Substantial Amendment. Section 91.505 of the Final Rule requires the City
to identify the criteria for determining what changes in the planned or actual
activities constitute a substantial amendment to the City's Action Plan
and/or Consolidated Plan. A substantial amendment is defined as follows:
a)
The deletion or addition of priorities established in the Consolidated
Plan.
b)
An increase or decrease in funds of fifty (50) percent or more
allocated to a specific project or program.
c)
Any new activity not previously described in the Action Plan and/or
Consolidated Plan.
The City of Tustin will provide citizens with reasonable notice and an opportunity to
comment on substantial amendments. Such substantial amendments will be
noticed in a local newspaper of general circulation and notices will be posted in
public places, including the Tustin library and various City Hall locations. Written
comments will be accepted during regular City business hours and by mail. A
period, not less than 30 days, to receive comments on the substantial amendment
before the amendment is implemented will be provided. If determined appropriate
or necessary by the City of Tustin, a public hearing will also be held.
The City of Tustin shall consider any comments or views of citizens received in
writing, or orally at public hearings, if any, in preparing the substantial amendment
of the Consolidated Plan. A summary of these comments or views, and a
summary of any comments or views not accepted and the reasons therefore, shall
be attached to the substantial amendment of the Consolidated Plan.
(d) Performance reports.
The City of Tustin will provide citizens with reasonable notice and an
opportunity to comment on performance reports. The availability of
performance reports will be noticed in a local newspaper of general
circulation and notices will be posted in public places, including the Tustin
library and various City Hall locations. Written comments will be accepted
during regular City business hours and by mail. A period, not less than 15
days, will be provided to receive comments on the performance report that
is to be submitted to HUD, before its submission. If determined appropriate
or necessary by the City of Tustin, a public hearing will also be held.
(2)
The City of Tustin shall consider any comments or views of citizens
received in writing, or orally at public hearings, if any, in preparing the
performance report. A summary of these comments or views shall be
attached to the Annual Performance Report provided to HUD by the City.
(e)
(f)
(g)
Public hearings.
The City of Tustin will provide for at least two public hearings per year to
obtain citizens' views and to respond to proposals and questions, to be
conducted at a minimum of two different stages of the program year.
Together, the hearings will address housing and community development
needs, development of proposed activities, and review of program
performance. To obtain the views of citizens on housing and community
development needs, inclUding priority non-housing community development
needs, at least one of these hearings will be held before the proposed
Consolidated Plan is published for comment; the second public hearing will
be held after publication, during the 30-day comment period.
(2)
Advance notice of each hearing will be published in a local newspaper of
general circulation, a minimum of 10 days prior to the hearing date. Notices
will also be posted i'n public places, including the Tustin library and various
City Hall locations. Notices will include sufficient information published
about the subject of the hearing to permit informed comment. (Publishing
small print notices in the newspaper a few days before the hearing does not
constitute adequate notice.)
(3)
The City of Tustin will' hold public, hearings at times and locations
convenient to potential and actual beneficiaries, and with accommodation
for persons with disabilities. Generally, public hearings will be held during
evening hours at the Community Center at the City Hall Complex. If, based
on citizen input, the City of Tustin determines that a hearing held at another
time or location is warranted, the City will hold such a hearing. The time
and location will be determined and noticed per the method indicated
above.
(4)
In the case of public hearings where a significant number of non-English
speaking residents can be reasonably expected to participate, the needs of
those residents will be met, with reasonable advance notice.
Meetings. The City of Tustin will provide citizens with reasonable and timely
access to local meetings.
Availability to the public. The City of Tustin will provide that the Consolidated Plan,
as adopted, substantial amendments to the Plan, and the Annual Performance
Report will be available to the public, including the availability of materials in a form
accessible to persons with disabilities, upon request. Those documents will be
available to the public at City Hall, during regular business hours.
(h)
(i)
(J)
(k)
Access to records. The City of Tustin will provide citizens, public agencies, and
other interested parties with reasonable and timely access to information and
records relating to the City's Consolidated Plan and the City's use of Community
Development Block Grant assistance during the preceding five years.
Technical assistance. The City of Tustin will provide for technical assistance to
groups representative of persons of Iow- and moderate-income that request such
assistance in developing proposals for funding assistance under any of the
programs covered by the Consolidated Plan, with the level and type of assistance
determined by the City. The assistance need not include the provision of funds to
the groups.
Complaints. If citizen complaints related to the Consolidated Plan, amendments,
and performance reports are received, the City of Tustin will provide a timely,
substantive written response to every written citizen complaint, within 15 working
days, where practicable.
Use of Citizen Participation Plan. The City of Tustin will follow its Citizen
Participation Plan.
Jurisdiction responsibility. The requirements for citizen participation do not restrict
the responsibility or authority of the City of Tustin for the development and
execution of its Consolidated Plan.
S:\Cdd~JUSTINA\cdbg\Citizen Participation Plan Final.doc