The City of Middletown, New York has a public hearing scheduled for October 20, 2026 at 4:00 p.m. in the Common Council Chambers at 16 James Street. A 30-day comment period opens that same day and closes November 20, 2026. The subject is an amendment to the 2025–2029 Consolidated Plan and the 2025 Annual Action Plan for the Community Development Block Grant program. If you live in Middletown and you have something to say about how CDBG money gets spent, that window is the one that counts.
Most people find out about these notices after the fact. The hearing happened, the comment period closed, the Council approved the amendment, and the money moved. The point of this article is to give you a reading method that works before the notice appears, so that when it does appear you already know what you are looking at and what you can do about it.
Start with the citizen participation plan, not the Consolidated Plan
The Consolidated Plan is the big document. It runs dozens or hundreds of pages, it is full of census tables and needs assessments, and it is not the document that governs whether your comment counts. The document that governs your comment is the jurisdiction’s adopted citizen participation plan.
Under 24 CFR 91.105(a)(1), the jurisdiction is required to adopt a citizen participation plan that sets forth its policies and procedures for citizen participation. That plan is public. It is usually posted on the same city website where the Consolidated Plan lives, often as an appendix or a separate PDF. Find it first.
Why does it matter? Because the citizen participation plan is where the jurisdiction states, in its own words, how long its comment periods are, when its hearings happen, and what it considers a substantial amendment. The federal regulation sets floors. The plan sets the jurisdiction’s actual practice. When a notice appears, you compare the notice against the plan. If the notice gives you less than the plan promises, that gap is itself something you can comment on.
What 24 CFR 91.105 requires the plan to contain
The regulation is specific. Here is what the citizen participation plan must provide for plan development:
- The jurisdiction must publish the proposed Consolidated Plan in a way that gives residents a reasonable opportunity to examine it and submit comments. Publishing a summary in a newspaper of general circulation and posting the full document on the jurisdiction’s official website, at libraries, government offices, and public places satisfies this.
- At least one public hearing must be held during development of the Consolidated Plan.
- The plan must provide a period of not less than 30 calendar days to receive comments from residents on the Consolidated Plan.
- The jurisdiction must consider comments received in writing or orally at hearings. A summary of those comments, and a summary of any comments not accepted with the reasons why, must be attached to the final Consolidated Plan.
That last item is the one most people miss. If you submit a written comment and the jurisdiction does not adopt your suggestion, the jurisdiction has to say so in writing and explain why. That written response is attached to the final plan. It becomes part of the public record. A verbal remark at a hearing does not create the same trail.
Substantial amendments have their own rules
Most of the action in a given year is not the five-year plan. It is the amendment. The citizen participation plan must specify the criteria the jurisdiction will use to decide what counts as a substantial amendment. The regulation requires that those criteria include, at a minimum, changes in the use of CDBG funds from one eligible activity to another.
When a substantial amendment is proposed, the citizen participation plan must provide reasonable notice and an opportunity to comment. The comment period must be not less than 30 calendar days, and it must run before the amendment is submitted to HUD for review. The same written-response requirement applies: comments received must be considered, and a summary of comments not accepted, with reasons, must be attached to the amendment.
This is the track that Middletown is on right now. The October 20 hearing and the comment period running through November 20 are the amendment track, not the five-year plan track.
The performance report track is shorter
There is a third document in the cycle: the performance report, sometimes called the CAPER. The citizen participation plan must provide not less than 15 days to receive comments on the performance report before it is submitted to HUD. A summary of comments received must be attached. Fifteen days is short. If you want to comment on performance, you have to be watching for the notice.
Hearings: how many, when, and how much notice
The citizen participation plan must provide for at least two public hearings per year, conducted at a minimum of two different stages of the program year. Together, those hearings have to address housing and community development needs, proposed activities, strategies for affirmatively furthering fair housing, and a review of program performance.
At least one of those hearings must be held before the proposed Consolidated Plan is published for comment. That is the hearing where needs get discussed before the draft is locked. If you only show up to the hearing after the draft is out, you are commenting on a document that has already been written.
On notice: the regulation says the plan must state how and when adequate advance notice will be given, with enough information published about the subject to permit informed comment. HUD states in the regulation that publishing small print notices in the newspaper a few days before the hearing does not constitute adequate notice, and that HUD would consider two weeks adequate. Hearings must be held at times and locations convenient to potential and actual beneficiaries, with accommodation for persons with disabilities. The plan must also identify how the needs of non-English-speaking residents will be met where a significant number can reasonably be expected to participate.
Access to records and technical assistance
Two provisions are worth knowing because they give you standing to ask for things.
First, the citizen participation plan must require the jurisdiction to provide residents, public agencies, and other interested parties with reasonable and timely access to information and records relating to the Consolidated Plan and the use of assistance under the covered programs during the preceding five years. That is a five-year lookback. If you want to know how CDBG money was actually spent in your neighborhood, this is the provision that backs the request.
Second, the citizen participation plan must provide for technical assistance to groups representative of low- and moderate-income persons that request it. If your tenant union or neighborhood association wants help understanding the plan or preparing comments, the plan is supposed to describe how that assistance is provided.
How to read an amendment before the deadline closes
Here is a practical method. It assumes you have found the citizen participation plan and the amendment document.
- Mark the comment period length in the plan. Find the section on substantial amendments. Note the number of days. Note whether the plan says the period runs before submission to HUD.
- Mark the hearing schedule. Find the section on hearings. Note how many per year, at what stages, and what the plan says about advance notice.
- Read the notice against the plan. Does the notice give you at least the number of days the plan promises? Does it state where the full amendment document can be examined? Does it state how to submit comments?
- Read the amendment document itself. Look for the line items. What dollar amounts are moving? From which activity to which activity? What goals are being revised?
- Write a specific comment. Address a line item, a dollar figure, or a stated goal. Cite the page. Submit it in writing before the deadline.
The reason to focus on line items is that a reallocation amendment is often the most commentable document in the CDBG cycle. The tradeoff is explicit. You are not arguing about the plan’s general goals. You are arguing about whether a specific dollar amount should move from one use to another.
What the Middletown amendment actually says
The Middletown amendment document states that the City has decided to reallocate funds originally intended for Economic Development to two Public Facility Projects. The stated effect is a reduction in the original goal from approximately 10 businesses assisted and 50 jobs created or retained to approximately 8 businesses assisted and 40 jobs created or retained.
The two projects are itemized. The Warming Station project will utilize $55,000 in entitlement and program income funds, with $50,000 in Economic Development funds reallocated to it and $5,000 in un-allocated program income also used. The stated purpose is removal of an old fire alarm system and installation of a new one. The Wolslayer Field project will utilize $5,283.43 in un-allocated program income for installation of light poles.
Those are the kinds of numbers a comment can address directly. You can ask whether the job-creation reduction is acceptable, whether the fire alarm work is the highest priority use of $50,000 in Economic Development funds, or whether the light pole installation was reviewed against other public facility needs. You do not have to agree or disagree with the City’s priorities to make the comment useful. You have to be specific.
The amendment document also states that in the prior participation round there were no comments from the public. That is a factual statement in the record. It is also the reason the written-response requirement matters: if no one comments, there is nothing to respond to, and the plan moves forward without a documented public position on the tradeoff.
The part nobody says out loud
Reading a Consolidated Plan is tedious, and doing it after a long day of work, in a city where the same six people show up to everything, is demoralizing. That is real. The strategy response is to narrow the scope. You do not have to read the whole plan. You have to read the citizen participation plan, the notice, and the amendment document. Three documents. The rest can wait.
Frequently asked questions
Is the 30-day comment period a guarantee? The regulation sets 30 calendar days as the minimum for the Consolidated Plan and for substantial amendments. The jurisdiction’s own citizen participation plan must state its comment period. Read the plan to see what your jurisdiction has committed to.
What if the notice gives me fewer days than the plan says? The gap between the plan and the notice is itself a procedural point you can raise in a comment. The retrieved sources do not establish that any specific jurisdiction has done this, so treat it as a reading method, not an accusation.
Do verbal comments at a hearing count? The regulation requires the jurisdiction to consider comments received in writing or orally at hearings. But the written-response requirement attaches to the summary attached to the final plan or amendment. A written comment creates a clearer record.
Where do I find the citizen participation plan? It is usually posted on the jurisdiction’s website alongside the Consolidated Plan, often as an appendix. If you cannot find it, the plan must be made public, and the jurisdiction’s CDBG office can tell you where it is.
Can I get help preparing a comment? The citizen participation plan must provide for technical assistance to groups representative of low- and moderate-income persons that request it. Ask the CDBG office what that assistance looks like in your jurisdiction.
What is the difference between the Consolidated Plan, the Annual Action Plan, and the performance report? The Consolidated Plan is the multi-year strategy. The Annual Action Plan is the one-year spending plan. The performance report, sometimes called the CAPER, reports on what was actually done. Each has its own comment period: 30 days minimum for the plan, 30 days minimum for substantial amendments, and 15 days minimum for the performance report.
What to do this week
If you are in Middletown, the comment period closes November 20, 2026. Written comments go to the Office of Economic and Community Development, City Hall, 16 James Street, Middletown, NY 10940. The notice states that after the hearing and comment period, the amendments will be submitted to the City Council for approval.
If you are somewhere else, the method is the same. Find the citizen participation plan. Find the current notice. Compare the two. Read the amendment document for line items. Write a specific comment before the deadline. The money is committed when the Council votes, not when the notice appears. The window between those two moments is where public comment actually does something.