SECTION 3: Action Plan & Implementation

This section includes guidance on developing a CDBG-DR Action Plan in response to the Consolidated Notice, including steps to take when submitting the required pre-award submissions, the Implementation Plan, and the Public Action Plan. This section also moves into the Implementation phase of projects and activities, and includes relevant guidance on resilience planning and best practices when incorporating mitigation into long-term recovery.

Action Plan Development

Citizen Participation

Before the grantee submits the action plan or a substantial amendment to the action plan to HUD, the grantee must publish the proposed plan or amendment prominently on the grantee’s official disaster recovery website to afford citizens, affected local governments, and other interested parties a reasonable opportunity to review the plan or amendment. The grantee must provide a reasonable time frame (no less than 30 days) and method(s) (including electronic submission) for receiving comments on the action plan or substantial amendment. The grantee must consider all comments, received orally or in writing, on the action plan or any substantial amendment.

On March 17, 2016, HUD hosted a webinar covering the basics of a CDBG-DR action plan and the citizen participation process, including Limited English Proficiency (LEP) requirements. 

CDBG-DR Action Plan Webinar

This webinar can also be viewed on the HUD Exchange.

CDBG-DR grantees must convene at least one public hearing on the proposed action plan. The number of public hearings to be convened by a grantee shall be determined based upon the amount of the grantee’s CDBG-DR allocation: 

  1. CDBG-DR grantees with allocations under $500 million, are required to hold at least one public hearing in a HUD-identified MID area. The public hearing should occur before or during the initial public comment period; or

  2. CDBG-DR grantees with allocations that are $500 million or more shall convene at least two public hearings in the HUD-identified MID areas. At least one of these public hearings should occur before or during the initial public comment period, and all hearings are to be convened in different locations within the MID areas to ensure geographic balance and maximum accessibility.

Public hearings may be convened in-person or virtually through a number of unique and new formats. Each public hearing should consider the needs of those with disabilities and limited English proficiency.

  • If a grantee is conducting in-person hearings, the hearings must be held in facilities that are physically accessible to persons with disabilities. Existing federal requirements provide that where physical accessibility is not achievable, grantees must give priority to alternative methods of product or information delivery that offer programs and activities to qualified individuals with disabilities in the most integrated setting appropriate under HUD’s implementing regulations for Section 504 of the Rehabilitation Act (See 24 CFR part 8, subpart C).

  • If the grantee is conducting a virtual hearing the hearing must allow questions in real time, with answers coming directly from the elected representatives to all “attendees.” Grantees who hold virtual hearings must update their citizen participation plans to describe their procedures for virtual hearings, including how it shall take appropriate steps to ensure effective communication as required by 24 CFR 8.6 and provide meaningful access for individuals with limited English proficiency.

    For both virtual or in-person hearing, the grantee shall provide reasonable notification and access for citizens in accordance with the grantee’s certifications, timely responses to all citizen questions and issues, and public access to all questions and responses. Effective communication is especially important for individuals with disabilities. Effective communication is generally provided by use of auxiliary aids and services, such as interpreters, computer-assisted rea time transcription, captioned videos, and documents in alternative formats (e.g., Braille or large print).

Other examples include:
Telephone and video relay services to facilitate communication between people who are deaf, hard of hearing, or have speech impairments and people without hearing impairments. These services are provided free of charge under federal law and can be accessed by calling 711.

Providing sign language interpreters, computer-assisted real time transcription (CART), and assistive listening devices when requested by individuals who are deaf or hard of hearing and must provide all written materials in accessible formats for persons who are blind or have low vision at public hearings.

Creating accessible websites where text, images, buttons, and forms are accessible to blind persons who use screen readers, individuals with low vision who rely on screen magnifiers, and deaf persons who require text captions to access the audible content of videos and individuals who are blind or have low vision who require video description to access the visual content of videos.

The grantee must maintain a public website, as defined in section III.D.1.e. of the Consolidated Notice, that permits individuals and entities awaiting assistance and the general public to see how all grant funds are used and administered, including copies of all relevant procurement documents, grantee administrative contracts, details of ongoing procurement processes, and Action Plans and amendments.

To meet this requirement, each grantee must make the following items available on its website: 

  1. The Public Action Plan created using DRGR (including all amendments) and all vital documents;

  2. Each performance report (as created using the DRGR system);

  3. Citizen participation plan;

  4. Procurement policies and procedures;

  5. All executed contracts that will be paid with CDBG-DR funds as defined in 2 CFR 200.22 (including subrecipients’ contracts); and

  6. A summary including the description and status of services or goods currently being procured by the grantee or the subrecipient (e.g., phase of the procurement, requirements for proposals, etc.).

Contracts and procurement actions that do not exceed the micro-purchase threshold, as defined in 2 CFR 200.67, are not required to be posted to a grantee’s website.

The grantee must provide multiple methods of communication, such as websites, toll-free numbers, or other means to provide applicants for recovery assistance with timely information to determine the status of their application.

The grantee will provide a timely written response to every citizen complaint. The grantee response must be provided within 15 working days of the receipt of the complaint, or the grantee must document why additional time for the response was required. Complaints regarding fraud, waste, or abuse of government funds should be forwarded to the HUD OIG Fraud Hotline (phone: 1-800-347-3735 or email:

The primary goal of a Citizen Participation Plan in CDBG-DR is to provide all citizens with an opportunity to participate in the planning, implementation, and assessment of the CDBG-DR recovery program(s).  

Grantees should visit HUD’s recently published “Citizen Participation & Equitable Engagement (CPEE) Toolkit” that can be found here in English or here in Spanish. The CPEE Toolkit is a resource to aid CDBG-DR grantees in centering equity in disaster recovery programs throughout an enhanced citizen participation process. The primary objective of this new resource is to provide grantees with tools and strategies to assist residents—especially low- and moderate-income (LMI) persons, vulnerable populations, protected classes under fair housing and civil rights laws, and underserved communities impacted by a disaster—to actively participate in the planning, implementation, and assessment of CDBG-DR programs and projects.

Watch this message of welcome from Tennille Parker, Director of the Disaster Recovery and Special Issues Division, Office of Community Planning and Development, the United States Department of Housing and Urban Development (HUD).

Citizen Participation & Equitable Engagement Toolkit: Welcome by Tennille Parker

Watch on Youtube

Grantees should use the CPEE Toolkit when completing or updating a Citizen Participation Plan (CPP). The grantee should take time to develop policies and procedures for citizen participation throughout the lifecycle of the grant. The CPP facilitates citizen participation throughout the grantee’s initial development of the action plan, substantial amendment process, and any applicable annual performance reports. 
CPP regulations require grantees to demonstrate they are actively encouraging widespread citizen participation, with a particular emphasis on participation from LMI persons, residents of blighted areas, and predominately LMI areas, limited English speaking persons, persons with disabilities, and public housing residents and other low-income residents of targeted revitalization areas.

There are several resources available to support grantees in formulating, implementing, and maintaining an effective citizen participation plan. For example, soliciting input from all community members is a good place to begin to formulate the action plan. Soliciting feedback early in the process can increase citizen and stakeholder buy-in as well as ensure that the priorities of a community are understood.

To help facilitate feedback, grantees can use various outreach methods such as during community meetings and surveys, or through other means of electronic and in-person communication to request ideas from citizens and stakeholders. Effective outreach offers a chance to discuss meaningful issues and provide examples of past issues that have been successfully addressed. 

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Group of people taking notes at a meeting.

When the grantee is actively communicating with the stakeholders, more people in the community will be aware of the resources available for them and grantees should have higher rates of participation. Higher program participation can result in lower rates of citizen-complaints because the beneficiaries participating in the program should have a better understanding of how the grantee is attempting to meet their needs.

Grantees are also encouraged to establish a recovery task force with representative members of the private, public, and non-profit sector to advise the grantee on how its recovery activities can best contribute towards the goals of regional redevelopment plans.

Guidance on consultation with local stakeholders can be found in the National Disaster Recovery Framework and its discussion of pre- and post-disaster planning.

A Guide on How CDBG-DR Grantees Can Meet the Requirements of the Consolidated Notice