Citizen participation should be limited and controlled.
HUD CPD Document CDBG-DR-Fact-Sheet.pdf offers the question, "CAN CITIZENS DECIDE HOW CDBG-DR FUNDS ARE ALLOCATED AND USED?". States for years have understood this process is not in the best interest of the states using CDBG-DR programs.
HUD answers the question with: "Citizens participation is both encouraged and required throughout the CDBG-DR grant process."
To control the outside influence from citizens of the state your states executive order referencing the disaster and the use of HUD CDBG-DR funds should indicate that citizens can make public comment. The legal method to discard all comment is to not make it part of the executive order that any state agency, employee or appointed board member has to acknowledge or response to the comment in any forum that could lead to a debate or discussion. The state can acknowledge the public comment in writing within the pages of the action plan which are then final. This will reduce any obsicales your citizens may make public. Be sure to publish this information in the back end of your official website. Simply reference a link using the word "here" as in "Action Plan Comments can be viewed here."
HUD CPD Document: "Each grantee's Action Plan must include a Citizens Participation Plan which describes how the public will be informed and engaged throughout the grants' life cycle."
HUD allows states to waive comments on non-substantial action plan amendments. The state submits to HUD what it considers a Non-Substantial action plan using policy guidance from HUD.
Example: A change in a program that does not exceed $5 million can be non-substantial and not require public comment. You can submit several $5 million action plan amendments for the same program because HUD has no policy to creating new programs with multi-part funding from separate action plans. You can create a new program that may require $25 million and simply transfer $5 million over 5 months into the program using separate action plan amendments. At not time will you be required to allow citizens imput.
HUD states prior to approval of the states (grantee's) Action Plan for disaster recovery will be posted for public comment.
State's should publish all public comment in pages deep within the states website so not to provide easy access.
HUD states that all comments on the action plan or any action plan amendment will be considered.
You should answer comments that may slow down your approval so HUD will see you attempted to explain to the citizen your reasons for your action plan. You can dismiss comments simply by using your standard acknoledgement.
HUD will require states to link action plans, citizen participation requirements, performance reports, contracts, program availability, requirements and quarterly progress reports. You can place these links deep in your states website or create a domain location for each with a simply link in any news release.