Montgomery County is required to set forth the County’s policies and procedures for citizen participation in the process of developing and implementing the Consolidated Plan and all it’s integral components; such as annual action plans, annual performance evaluation reports and any amendments. In addition, citizens may participate in the development, implementation and evaluation on the specific activities described within the Consolidated Plan and funded through Federal programs such as the Community Development Block Grant (CDBG), HOME Investment Partnership (HOME), Emergency Shelter Grant (ESG), and other related programs.
Montgomery County encourages participation by low- and moderate-income persons, specifically those living in slum and blighted areas and in areas where Federal funds are proposed to be used, and by residents of predominately low- and moderate-income neighborhoods.
Montgomery County further encourages the participation of residents of public and assisted housing development in the process of developing and implementing the Consolidated Plan, along with other low-income residents of targeted revitalization areas in which housing developments are located. Montgomery County provides information to the Housing Authority about any activities related to the Authority’s housing developments and surrounding communities. The Housing Authority should make this information available to the annual public hearing it is required to hold under the Comprehensive Grant Program.
Montgomery County provides citizens with a "reasonable" opportunity to comment on this Citizen Participation Plan (including any substantial amendments to this Plan). The Citizen Participation Plan is a public document. It will be made accessible to those persons with disabilities and/or non-English speaking persons upon request.
A. Purpose
The Citizen Participation Plan is designed to serve the following specific purposes:
1) To present in a logical sequence the various components of the Consolidated Plan.
2) To identify the responsible departments or agencies of the County government who administer the various activities relating to the Consolidated Plan.
3) To clarify the opportunities which citizens, community organizations, and neighborhood groups, and others have to work with municipal and County officials in developing each component of the Consolidated Plan and the activities within.
4) To indicate the alternate courses of action which the Federal program(s) regulations make available to citizens, organizations and local government.
Any questions or comments on substantive issues or the adequacy of the Citizen Participation Plan should be referred to the Director, Housing & Community Development Department, Montgomery County Human Services Center, 1430 DeKalb Street, Norristown, PA 19404-0311; Phone (610) 278-3540; TDD (610) 631-1211.
DEVELOPMENT STAGE
B. Developmental Mechanisms
To develop the Consolidated Plan (once every five years) and each subsequent Annual Action Plan (one each year for five years), Montgomery County makes information available to and also collects information from:
Citizens, Citizen Organizations, Community Groups, Neighborhood Organizations
Local governments
Public Agencies
Other interested parties
Information will be compiled for reference and made available; including:
1) Amount of assistance Montgomery County expects to receive with regard to:
a. Grant funds
b. program income
2) Range of activities that may be undertaken
a. including estimated amount that will specifically benefit persons of low-and moderate-income
3) *Plans to minimize displacement of persons
4) *Plans to assist any persons displaced
a. Types of assistance
b. Levels of assistance
*Even if Montgomery County expects no displacement to occur
This information is presented by Montgomery County staff at various public hearings and informal meeting events or forums. Citizens may also review this information directly by appointment at the Housing & Community Development Department, Montgomery County Human Services Center, 1430 DeKalb Street, Norristown, PA 19404-0311; Phone (610) 278-3540.
Adequate advance notice is given to participants (including sufficient information about the event subject matter) in order to allow for informed comment, proposals or recommendations. An event is advertised through the minimum of one of the following method(s) (depending on event type) at least two weeks prior to event:
1) Non-legal section of those newspapers with general circulation within the County – a Notice of Hearing (for Public Hearings) 2) Local Access (television) 3) Letters to individual citizens, groups, etc. 4) Letters to those on the Housing Services Department mailing list 5) County Website 6) Other ways
All events are held at times and locations convenient to potential and actual beneficiaries. All public hearings will be held in various locations throughout the County. Hearings will be held in the evenings or on weekends in order to allow for greater participation.
Persons who are elderly or handicapped or who would otherwise be unable to attend may receive transportation to these hearings if such transportation can be arranged. Such persons should contact the Housing & Community Development Department, Montgomery County Human Services Center, 1430 DeKalb Street, Norristown, PA 19404-0311; Phone (610) 278-3540; TDD (610) 631-1211. The Housing Services Department will be responsible for arranging transportation and notifying individuals of the availability of thereof. Such request should be made at least two (2) working days prior to a public hearing date.
Persons, other than those addressed above, who have disabilities, will receive assistance to participate based on a case-by-case evaluation to insure the format provided is accessible to them.
When a "reasonable" amount of non-English speaking citizens are expected to participate, their needs are met by providing an appropriate translator if such an arrangement can be made.
Type of Event:
1) Initial Public Hearing (held prior to publishing proposed Consolidated Plan and/or Annual Action Plan) – to obtain the views of citizens on:
a. housing
b. community development needs
i. priority non-housing community development needs
2) Meetings
a. citizens have "reasonable" and timely access to local meetings
3) Forums
a. held for specific topics and audience (i.e., Housing Coalition)
Information gathered from the above events are considered and incorporated when the County prepares the Consolidated Plan and/or associated Annual Action Plan(s).
C. Availability Mechanisms
In order to receive further public participation, Montgomery County publishes the proposed Consolidated Plan and/or associated Annual Action Plan so that the following may have a "reasonable" opportunity to examine its contents and submit comments:
1. Citizens, Citizen Organizations, Community Groups, Neighborhood Organizations 2. Local governments 3. Public Agencies 4. Other interested parties
A summary of the proposed Consolidated Plan and/or associated Annual Action Plan and notice of a second public hearing is published in the non-legal section of newspapers with general circulation within the County. This will be completed at least two weeks prior to the public hearing.
The summary includes:
1. Content of Consolidated Plan (and/or Annual Action Plan)
2. Purpose of Consolidated Plan (and/or Annual Action Plan)
3. List of locations where entire proposed Consolidated Plan (and/or Annual Action Plan) is available
a) a "reasonable" amount of free copies will be made available
Copies of the entire proposed Consolidated Plan (and/or Annual Action Plan) are available at:
1. Local Public Libraries 2. County Commissioners Office 3. Housing Services Department 4. County Website (summary only) 5. Other designated locations
Citizens will have sufficient time to review documents in order to make informed comments. Citizens will have 30 days to make comments about the proposed Consolidated Plan and/or Annual Action Plan. Comments can be made by:
1. Attending 2nd Public Hearing
a. In writing
b. Orally
2. Contacting Housing Services staff
a. In writing
b. Orally
c. Responding to Website
All comments and views will be considered in preparing the final Consolidated Plan and/or Annual Action Plan. A summary of all comments will be made part of the final Consolidated Plan and/or Annual Action Plan. The final Plan will also include a summary of comments not accepted and reasons therefor.
IMPLEMENTATION STAGE
D. Amendment(s) to the Consolidated Plan
In the event the County elects:
1) Not to complete an activity contained in the Consolidated Plan; 2) To complete an activity other than those described in the Plan; 3) To make substantial changes in priorities or distribution of funds; or 4) To change the purpose, scope, location, or beneficiaries of an activity;
It will afford affected citizens the opportunity to comment on any substantial change. The following criteria will be used to determine what change in the County’s planned or actual activities constitute as a "substantial amendment":
1) A national goal changes (under which a project activity was proposed and approved); 2) The cost of a proposed activity increases by one half (50%) or more when activity is actually undertaken; 3) The physical location of an activity is changed;
a. When a specific location was defined and approved
b. When more than one half (50%) of the locations change under an activity with multiple locations 4) The class of beneficiaries change by more than one half (50%) 5) Changes in the use of CDBG funds from one eligible activity to another
Citizens will be provided with "reasonable" notice and opportunity to comment on proposed amendments. This will be accomplished through notification of a public hearing in the non-legal section of newspapers with general circulation within the County. These notices will be published at least two weeks prior to the hearing.
Citizens will have not less than 30 days to make comments about the amendments prior to any amendment implementation:
1) By attending the Public Hearing
a. In writing
b. Orally 2) Contacting Housing Services staff
a. In writing
b. Orally
A summary of these comments as well as a summary of any comments not accepted and reasons thereof shall be attached to the Consolidated Plan and Amendment(s). The amendment(s) will then be submitted to The U.S. Department of Housing and Urban Development (HUD).
Formal County approval of the all final plans and any amendments will occur during a regularly scheduled public Board of County Commissioners meeting. Notice of such meeting will be published at least two weeks prior to such meeting.
E. Consolidated Annual Performance and Evaluation Reporting (CAPER)
Montgomery County is required to make public annually the CAPER, a written summary and evaluation of accomplishments and performance based on the goals and activities described in the Consolidated Plan. This will be done through a public hearing, which will normally occur within the 90 days following the end of the fiscal year. Citizens will be provided with "reasonable" notice and opportunity to comment on the CAPER. "Reasonable" notice will be through advertisement of a hearing and availability of the CAPER in the non-legal section of newspapers of general circulation within the County. This notice will be published at least two weeks prior to the hearing.
Comments can be made by:
1) By attending the Public Hearing
a. In writing
b. Orally
2) Contacting Housing Services staff
a. In writing
b. Orally
There is a not less than 15 day period to receive comments on any CAPER prior to submission to HUD. A summary of these comments shall be attached to the final CAPER.
F. Availability of Documents
The following are available to the public upon completion:
1) Adopted, final Consolidated Plan, and all it’s components 2) Substantial Amendments, if any 3) Consolidated Annual Performance and Evaluation Report
These are available at:
1) Local Public Libraries 2) County Commissioners Office 3) Housing Services Department 4) Other designated locations
The materials may be available in a form accessible to persons with disabilities. Contact the Housing & Community Development Department staff at (610) 278-3540. In addition, the County makes available information and records relating to the development and implementation of this referenced Consolidated Plan and the County’s use of funds under the various programs covered by all previous Consolidated Plans.
G. Technical Assistance
The Housing & Community Development Department staff is available to provide technical assistance to any group, which represents persons of low- and moderate-income in developing proposals for funding assistance under any of the programs covered by the Consolidated Plan. Assistance does not guarantee funding approval.
In addition, staff is available to answer questions concerning the procedures for the development and implementation of the Consolidated Plan and all of its components.
Citizens or organizations requiring technical assistance should contact the Housing & Community Development Department, Montgomery County Human Services Center, 1430 DeKalb Street, Norristown, PA 19404-0311; Phone (610) 278-3540; TDD (610) 631-1211.
H. Complaints
The following procedures are followed when handling a complaint from a citizen or organization relating to the Consolidated Plan (and/or any Annual Action Plans, amendments, and CAPERs):
1) Timely, substantive written response to every written citizen complaint within 15 business days of its receipt, including:
a. County’s position on the matter
b. Any proposed action
2) Responses are prepared by the Board of Commissioners via the Housing Services Department
If the County’s response does not resolve the issue to the satisfaction of the complainant, he or she may request a meeting within two (2) weeks of receiving the response. This meeting shall be held within fifteen (15) business days of receipt of this meeting request. Following such meeting, the County shall notify the complainant of its proposed resolution within fifteen (15) business days of the date of the meeting. If the complainant is not satisfied with this response; he or she may follow the procedure described below:
Citizen or organizations who have followed the procedure described above to resolve complaints may choose to file an official objection with the U.S. Department of Housing and Urban Development (HUD), Philadelphia Area Office, The Wanamaker Building, 100 Penn Square East, Philadelphia, PA 19107-3390. Persons may choose to file a complaint directly to HUD and not follow a local complaint procedure. Following the local complaint procedure is not a prerequisite for filing an objection with HUD. However, citizens are encouraged to bring complaints first to the local level for resolution, since HUD procedures require that Montgomery County respond to any complaint filed. Therefore, the best opportunity for immediate resolution to the problems remains at the County level.
Complaints should be directed to the Housing & Community Development Department, Montgomery County Human Services Center, 1430 DeKalb Street, Norristown, PA 19404-0311. The complaint should contain the following information:
1) Name and signature of the complainant, or if an organization, the name and signature of the officer of the organization, responsible for the correspondence.
2) Address to which the County’s response should be mailed. 3) Telephone number where the complainant or an individual knowledgeable about the substance of the complaint may be reached during business hours. 4) Nature of the complaint, including any relevant information or documentation. 5) Recommendation concerning how the complainant desires to have the matter resolved.
I. Conclusion
Montgomery County will follow the above outlined Citizen Participation Plan. The requirements under this Citizen Participation Plan do not restrict the responsibility or authority of Montgomery County for the execution of the Consolidated Plan itself.
GLOSSARY
Affordable Housing:
Affordable Housing is generally defined as housing where the occupant is paying no more than 30 percent of his or her income for gross housing costs, including utilities.
Annual Action Plan:
Developed by local and state governments with the input from citizens and community groups; the Annual Action Plan serves as the vehicle which describes on an annual basis what activities will be funded under Federal, state and local programs within the current Consolidated Plan
Citizen Participation Plan:
Written policies and procedures for citizen participation in the process for developing and implementing the Consolidated Plan and all of its integral components.
Community Development Block Grant (CDBG):
A Federal program created under the Housing and Community Development Act of 1974. This program provides grant funds to local and State governments to be used to develop viable urban communities by providing decent housing with a suitable living environment and expanding economic opportunities to assist low- and moderate-income residents.
Consolidated Plan:
Developed by local and state governments with the input from citizens and community groups, the Consolidated Plan serves four functions:
1) it is a planning document for each state and community, built upon public participation and input;
2) it is the application for funds under HUD's formula grant programs (CDBG, HOME, ESG, and HOPWA);
3) it lays out local priorities; and
4) it lays out a 3-5 year strategy the jurisdiction will follow in implementing HUD programs.
Consolidated Annual Performance and Evaluation Report (CAPER):
Required by HUD on an annual basis by all jurisdictions receiving Federal funding, this document is a evaluation of the past year’s performance as outlined in the Annual Action Plan.
Emergency Shelter Grant (ESG):
A Federal grant program designed to help improve the quality of existing emergency shelters for the homeless, to make available additional shelters, to meet the costs of operating shelters, to provide essential social services to homeless individuals, and to help prevent homelessness.
Fiscal Year:
Any yearly accounting period, regardless of its relationship to a calendar year.
HOME Investment Partnership (HOME): A Federal grant program that provides funds to local governments and states for new construction, rehabilitation, acquisition of standard housing, assistance to homebuyers, and tenant-based rental assistance.
Housing Opportunities for Persons with AIDS (HOPWA):
HOPWA provides housing assistance and supportive services to prevent homelessness of low-income persons with HIV/AIDS and their families, and to devise long-term comprehensive strategies for meeting the housing needs of persons with AIDS and their families.
Low Income:
A household whose income does not exceed 80 percent of the median income for the area, as determined by HUD, with adjustments for smaller or larger families.
Public Housing Agency (PHA):
Organization created by local government, which administers HUD's Low-Income Public Housing Program and other HUD programs. (Housing Authority)
U.S. Department of Housing and Urban Development (HUD):
The Department of Housing and Urban Development is the Federal agency responsible for national policy and programs that address America's housing needs, that improve and develop the Nation's communities, and enforce fair housing laws. HUD's business is helping create a decent home and suitable living environment for all Americans.
