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Agenda 10.20.2025
NEW HANOVER COUNTY BOARD OF COMMISSIONERS 230 Government Center Drive, Suite 175, Wilmington, INC 28403 P: (910) 798-7149 1 F: (910) 798-7145 1 NHCgov.com Bill Rivenbark, Chair I LeAnn Pierce, Vice -Chair Dane Scalise, Commissioner I Stephanie A.C. Walker, Commissioner I Rob Zapple, Commissioner O CTO BE R 20, 2025 9:00 A M LOCATION (NHC Historic Courthouse, 24 North 3rd Street, Room 301) CALL TO ORDER (Chair Bill Rivenbark) I NVOCATI ON (Pastor Gayle Tabor, SALT Inclusive Methodist Community) PLEDGE OF ALLEGIANCE (Chair Bill Rivenbark) APPROVAL OF CONSENT AGENDA CONSENT AGENDA ITEMS OF BUSINESS 1. Approval of Minutes 2. Approval of the Order of Denial for Special Use Permit (S25-04) 3. Adoption of Budget Amendments 4. Resolution Delegating Real Estate Excise Tax Refund Authority ESTIMATED MINUTES REGULAR AGENDA ITEMS OF BUSINESS 10 5. Presentation of Service Awards and Introduction of New Employees 5 6. Recognition of Government Finance Officers Association Award 5 7. Consideration of Domestic Violence Awareness Month Proclamation 5 8. Consideration of Operation Green Light for Veterans Resolution 10 9. Consideration of Scotts Hill Water Main Extension CDBG-I Compliance Manual Resolution 15 10. Presentation of the NHC Destination 2050 Comprehensive Plan Update Final Goals and Future Land Use Map 11. Committee Appointments PUBLIC COMMENTS (limit three minutes) ESTI MATED MINUTES ADDITIONAL AGENDA ITEMS OF BUSINESS 12. Additional Items County Commissioners Board of Commissioners - October 20, 2025 County Manager Clerk to the Board County Attorney 13. ADJOURN Note: Minutes listed for each item are estimated, and if a preceding item takes less time, the Board will move forward until the agenda is completed. Mission New Hanover County is committed to providing equitable opportunities and exceptional public services through good governance to ensure a safe, healthy, secure and thriving community for all. Vision A vibrant, prosperous, diverse coastal community committed to building a sustainable future for generations to come. Shared Values Professionalism - Equity- Integrity- Innovation - Stewardship- Accountability Board of Commissioners - October 20, 2025 NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Consent DEPARTMENT: Governing Body PRESENTER(S): Kym Crowell, Clerk to the Board CONTACT(S): Kym Crowell SU BJ ECT: Approval of Minutes BRIEF SUMMARY: Approve minutes from the following meetings: Agenda Review held on October 2, 2025 Regular Meeting held on October 6, 2025 STRATEGIC PLAN ALIGNMENT: • Good Governance o Effective County Management ■ Increase transparency and awareness about county actions RECOMMENDED MOTION AND REQUESTED ACTIONS: Approve minutes. COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 1 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Consent DEPARTMENT: Planning PRESENTER(S): K. Jordan Smith, NHC County Attorney, Karen Richards, NHC Deputy County Attorney CONTACT(S): Jordan Smith and Karen Richards SU BJ ECT: Approval of the Order of Denial for Special Use Permit (S25-04) BRIEF SUMMARY: At the October 6, 2025 meeting, the Board conducted a quasi-judicial hearing and voted to deny Special Use Permit (S25-04). North Carolina General Statute 160D-406 requires that the Board's decision be reduced to writing and approved by the Board. The attached order has been prepared to comply with this statute and reflects the Board's decision to deny Special Use Permit (S25-04). STRATEGIC PLAN ALIGNMENT: Good Governance o Effective County Management ■ I ncrease transparency and awareness about county actions RECOMMENDED MOTION AND REQUESTED ACTIONS: Approve the order denying Special Use Permit (S25-04). ATTACHMENTS: S25-04 Order of Denial COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 2 This page intentionally left blank. COUNTY OF NEW HANOVER STATE OF NORTH CAROLINA ORDER TO DENY A SPECIAL USE PERMIT Additional Dwelling Allowance in a R-15, Residential Zoning District S25-04 — Additional Dwelling Allowance in a R-15 The County Commissioners for New Hanover County (hereinafter "County Commissioners"), having held an evidentiary hearing on the 6` day of October, 2025, to consider application number S25-04 submitted by Hoosier Daddy, LLC, applicant and agent, on behalf of James Yopp as property owner for a special use permit for an Additional Dwelling Allowance for additional density up to 6.54 dwelling units per acre in a R-15, Residential district on an approximately 43.10 acres parcel of land located at 5669, 5671, 5712, 5831 Carolina Beach Road and 1046, 1051, 1052 Rosa Parks Lane, and having heard all of the evidence and arguments presented at the hearing, the County Commissioners make the following FINDINGS OF FACT: 1. That New Hanover County Staff presented evidence via testimony and their staff report entered into evidence. 2. The applicant presented evidence through their attorney via testimony and their submitted documents. 3. The opposition presented evidence through their attorney via testimony. 4. That the applicant submitted the Ironwood Special Use Permit Application with Hoosier Daddy, LLC listed as the applicant/agent and James L. Yopp, III listed as the owner (page 1 of the application). 5. That James Yopp's initials appear on the Applicant Checklist as the applicant (page 6 of the application). 6. That Jack Carlisle's name appears on the Signature of Property Owner line and Print Name line for the Owner on the application (page 7 of the application). 7. That James Yopp's name appears on the Signature of Applicant/Agent line and Print Name line for the Applicant/Agent of the application (page 7 of the application). 8. That a duplicate page 7 of the application was submitted with the application where a James Yopp's name appears on the Signature of Property Owner signature line, as well as the Applicant/Agent signature and Print Name lines. The Signature of Property Owner Print Name line is listed as Hoosier Daddy, LLC. 9. That a May 11, 2023 authorization with Jack Carlisle's name was submitted with the Board of Commissioners - October 20, 2025 ITEM: 2 - 1 - 1 application. This authorization purports to give authority to James Yopp to act on behalf of Jack Carlisle, E85 Transport LLC, Hoosier Daddy LLC, and Rockhill Road Investments for Tarin Woods, Tarin Woods II, Sunset Reach, Nixon Connection, and Sunset Towns. 10. That James Yopp is not a managing member of Hoosier Daddy LLC. 11. That James Yopp is not a property owner of 5669, 5671, 5712, 5831 Carolina Beach Road and 1046, 1051, 1052 Rosa Parks Lane. 12. That this project is titled Ironwood Special Use Permit in the application and Traffic Impact Analysis. The revised WMPO approval dated August 27, 2025 is named Ironwood and places the Ironwood Residential development adjacent to Tarin Woods II. 13. That Jack Carlisle passed away prior to the September 4, 2025 Planning Board preliminary forum on the Ironwood application. 14. That after Jack Carlisle's passing and after the Planning Board meeting, the applicant amended the Ironwood application. 15. That the amendments made by the applicant included: a. The Owner name being changed from James Yopp, III to a blank space; b. The Applicant Initials on the Application Checklist were changed from James Yopp III to Michelle Carlisle and Lisa Carlisle Beaman; c. The Signature for the Property Owner changed from Jack Carlisle and James Yopp to Michelle Carlisle and Lisa Carlisle Beaman; d. The Print Name for the Property Owner changed from Jack Carlisle and James Yopp to the electronic signatures of Michelle Carlisle and Lisa Carlisle Beaman; e. The Signature of Applicant/Agent changed from James Yopp, III to a blank space; f. The second signature page was removed; g. The May 11, 2023 purported authorization was removed; and, h. A Written Consent of the Managers In Lieu of a Meeting document purporting to ratify and approve the application filed by James Yopp, III on behalf of Hoosier Daddy, LLC and executed by electronic signature of Michelle Carlisle and Lisa Carlisle Beaman was added. Board of Commissioners - October 20, 2025 ITEM: 2 - 1 - 2 16. That the actions taken by Hoosier Daddy, LLC, Michelle Carlisle, and Lisa Carlisle Beaman removed James Yopp entirely, despite him being the original applicant for this project. 17. That the initial application does not comply with New Hanover County Unified Development Ordinance (hereinafter "UDO") 10.2.4.A. 18. That the applicant provided testimony that the application was completed last minute to ensure the abilityto gain an additional dwelling allowance via a Special use Permit before the process to obtain an additional dwelling allowance became available only via a rezoning request. 19. That the applicant bears the burden of ensuring that an application contains sufficient information to demonstrate compliance with all applicable stands in the UDO. The applicant has provided information that James Yopp does not own the property and is not a member manager of Hoosier Daddy, LLC. 20. That the applicant has not provided information to attain clarity on the authorization and project name. The multiple amendments to the application provide further conflicting information about the authority by changing the property owner, the project name, and the authorizing member managers. 21. That the Annual Average Daily Trip (AADT) Planning Capacityfor Carolina Beach Road is 41,369 trips. 22. That the Annual Average Daily Trip (AADT) Latest Traffic Volume 2023 for Carolina Beach Road is 45,500 trips. 23. That the Latest WMPO Point -in -Time Count Daily Trips (DT), conducted July 1, 2024 is 47,645 trips. 24. That Carolina Beach Road is currently above capacity. 25. That the applicant's Ironwood Traffic Impact Analysis (TIA) traffic data collection was conducted between September 2, 2021 and December 9, 2021 during the height of COVID when schools and a significant amount of employers were still operating remotely. 26. That the Ironwood TIA was prepared June 30, 2022, approved July 27, 2022, and has a revised approval date of August 27, 2025. The revised approval with conditions Letter for the Traffic Impact Analysis (TIA) associated with the proposed Ironwood Residential development in New Hanover County, NC (adjacent to Tarin Woods II) sets out phases for the building of the road improvements. The is only phase left is a full build with build year of 2026. This revised approval level references Site Access Board of Commissioners - October 20, 2025 ITEM: 2 - 1 - 3 land Site Access 2 which are not enumerated on the application documents nor the staff packet. 27. That per the applicant's Ironwood Special Use Permit application, the current proposal would generate an additional 2167 trips daily. 28. That the applicant did not propose a timeline nor condition about the build out of the access road to Carolina Beach Road. Applicant acknowledged there is no current availability to access this property via Rosa Parks Lane. Until the right in, right out only access road has completed construction, the primary access point to the development is from Carolina Beach Road through the residential developments of Battle Park, Tarin Woods I, and Tarin Woods II (215 single family detached homes). 29. That current single access is functionally equivalent to a cul-de-sac which is discouraged under the 2016 Comprehensive Plan and therefore not in general conformity with the 2016 Comprehensive Plan. 30. This subject property is shown as General Residential in the 2016 Comprehensive Plan. 31. The 2016 Comprehensive Plan defines General Residential as: This place type focuses on lower -density housing and associated civic and commercial services. Housing for the area is typically single-family or duplexes... Access to areas outside these residential areas are provided by arterial roadways, but still allow for interconnection between other place types. Limiting cul- de-sacs is encouraged to promote better internal circulation and minimize high - volume traffic roads within the area. Types of uses include single-family residential, Low -density multi -family residential, light commercial, civic, and recreational ... The ideal density for multi- and single-family residential is low (ranging up to approximately eight units per acre). Densitywithin the General Residential place type may be limited by flood plain, wetlands, or other natural or manmade features and generally should be consistent with nearby communities. 32.That although the 2022 Ironwood TIA and 2025 revised approval letter directs improvements by the applicant to accommodate the future Ironwood traffic onto Carolina Beach Road, Carolina Beach Road is already over capacity. Additionally, there are other projects in the area that are nearing completion that will increase impacts on that capacity prior to this project being built out, one of those being the influx of traffic from the new Target north of the property. Adding the additional 2167 trips to an over capacity road after other projects have increased traffic and impacted the road capacity in the interim is a danger to the health and public safety. Board of Commissioners - October 20, 2025 ITEM: 2 - 1 - 4 33. That the area's elementary school (Bellamy) is over capacity at 104%, the middle school (Myrtle Grove) is under capacity at 80%, and the high school (Ashley) is near capacity at 99.7%. 34. That this subject property is currently zoned as R-15 with a maximum density of 108 single family homes. The surrounding residential areas are R-15 and B-2, none of which have an additional density allowance. 35. That the applicant seeks a density of 6.75 dwelling units per acre over 43.10 acres for a maximum 291 mix of attached and multi -family dwelling units. Without the additional dwelling allowance, the property is zoned for 2.5 dwelling units per acre. 36. That the project is not in harmony and not consistent with the 2016 Comprehensive Plan, because it is outside the Monkey Junction Growth Node of New Hanover County's 2016 Comprehensive Plan, and the proposed uses create a significant difference in density compared to the existing low -density development, and the subject property is not an appropriate transition area. 37. That the proposed density of the overall project of 6.75 dwelling units per acre is not "generally consistent with the nearby communities" as stated in the 2016 Comprehensive Plan. 38. That the proposed use of the overall project is substantially denser than the surrounding uses and is not in harmonywith the area. 39. That the proposed density of 6.75 dwelling units per acre is greater than the "ideal density" of approximately 2.5 dwelling units per acre as stated in the 2016 Comprehensive Plan. 40. That the proposed density of 6.75 dwelling units per acre is not "generally consistent with the nearby communities" as stated in the 2016 Comprehensive Plan. 41. That the proposed use is substantially denser than the surrounding uses and is not in harmony with the area. Based on the foregoing FINDINGS OF FACT, the County Commissioners make the following CONCLUSIONS OF LAW: 1. That the proposed use DOES NOT satisfy 10.3.5.D.1. which is the first general requirement listed in the New Hanover County Unified Development Ordinance (hereinafter "UDO"); namely the requirement that the use will not materially endanger the public health or safety if located where proposed and developed according to the plan as submitted and approved. Board of Commissioners - October 20, 2025 ITEM: 2 - 1 - 5 2. That the applicant has not met their burden under 10.2.4.B.that a complete initial application was submitted per the UDO and DOES NOT satisfy 10.2.4.A. Therefore, the proposed application DOES NOT satisfy 10.3.5.D.2; namely the second general requirement that the use meets all required conditions and specifications of this Ordinance. 3. That the UDO's inclusion of this special use as a possible use in this zoning district creates a rebuttable presumption that this use is in harmony with the surrounding area and in general conformity with the Comprehensive Land Use Plan for New Hanover County; and that opponents presented substantial, competent, and material evidence to rebut this presumption, and therefore the County Commissioners conclude that the proposed use DOES NOT satisfy 10.3.5.D.4 the fourth general requirement listed in the UDO; namely the requirement that the Location and character of the use if developed according to the plan as submitted and approved will be in harmony with the area in which it is to be located and in general conformitywith the Comprehensive Land Use Plan for New Hanover County. 4. That the inability to meet any of the four requirements under Section 10.3.5.D means the project must be denied. The County Commissioners, having made the FINDINGS OF FACT and CONCLUSIONS OF LAW, determine that the applicant's project does not satisfy all the required conditions and specifications of the UDO, and understanding that failing to meet two required conditions means the project is denied. WHEREFORE, all of the general and specific conditions precedent to the issuance of a special use permit HAVE NOT been satisfied, IT IS ORDERED that the application for the issuance of a special use permit be DENIED. Ordered the 6t" day of October, 2025. Signed and entered this the _ day of October, 2025. William E. Rivenbark, Chair Attest: Kymberleigh G. Crowell, Clerk to the Board Board of Commissioners - October 20, 2025 ITEM: 2 - 1 - 6 NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Consent DEPARTMENT: Budget PRESENTER(S): Eric Credle, NHC Chief Financial Officer CONTACT(S): Eric Credle and Amanda Kostusiak, NHC Budget Officer SU BJ ECT: Adoption of Budget Amendments BRIEF SUMMARY: The following budget amendments amend the annual budget ordinance for the fiscal year ending June 30, 2025. 26-015 - Project Grace Museum - Budgets $250,000 in grant funding from Institute of Museum and Library Services (IMLS). The grant will assist with costs associated with the Science Matters exhibit. Thus bringing the "Invest in Grace" campaign total to $1.1 million. $250,000 STRATEGIC PLAN ALIGNMENT: • Good Governance o Strong Financial Performance ■ Proactively manage the county budget RECOMMENDED MOTION AND REQUESTED ACTIONS: Adopt the ordinances for the budget amendments listed. ATTACHMENTS: BA - 26-015 COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 3 This page intentionally left blank. AGENDA: October 20, 2025 NEW HANOVER COUNTY BOARD OF COMMISSIONERS AN ORDINANCE AMENDING THE FISCAL YEAR 2026 BUDGET BE IT ORDAINED by the Board of County Commissioners of New Hanover County, North Carolina, that the following Budget Amendment(s) be made to the annual budget ordinance for the fiscal year ending June 30, 2026. Section 1: Details of Budget Amendment Strategic Focus Area: Workforce and Economic Development Strategic Objective(s): Plan forthe long-termneeds of business through timely, innovative programs & commxnity parr—^ Fund: Capital Improvement Projects Department: Museum Expenditure: Decrease Increase Total BA 26-015 Grant Expense $ - $ 250,000 I $ 250,000 Total $ - $ 250,000 $ 250,000 Revenue: Decrease I Increase 11 Total BA 26-015 Grant Revenue $ 1 $ 250,000 $ 250,000 Total $ 1 $ 250,000 $ 250,000 Prior to Actions Total if Actions Taken Today Departmental Budget $ 16,065,482 $ 16,315,482 Section 2: Explanation BA 26-015 Accepts a grant award and budget increase of $250,000 for the Project Grace Museum capital improvement project. The grant, from the Institute of Museum and Library Services (IMLS) administered through the Museums for America, aims to champion lifelong learning and advance shared knowledge and educational opportunities for all. This grant will be used to reimburse costs associated with the Science Matters exhibit, which promotes science, technology, engineering, and math (STEM) literacy through hands-on exploration. Section 3: Documentation of Adoption This ordinance shall be effective upon its adoption. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of New Hanover County, North Carolina, that the Ordinance for Budget Amendment(s) 26-015 amending the annual budget ordinance for the fiscal year ending June 30, 2026, is adopted. Adopted, this 20th day of October, 2025 (SEAL) William E. Rivenbark, Chairman ATTEST: Kymberleigh G. Crowell, Clerk to the Board Board of Commissioners - October 20, 2025 ITEM: 3 - 1 - 1 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Consent DEPARTMENT: County PRESENTER(S): Kemp Burpeau, N HC Senior Deputy County Attorney and Eric Credle, Attorney NHC Chief Financial Officer CONTACT(S): Kemp Burpeau and Eric Credle SU BJ ECT: Resolution Delegating Real Estate Excise Tax Refund Authority BRIEF SUMMARY: Article 8E of Chapter 105 of the North Carolina General Statutes imposes an excise tax (often referred to as "deed stamps" or "revenue stamps") to be paid on documents transferring real estate that are recorded with the Register of Deeds. On limited occasions there is an overpayment of the excise tax. N.C. Gen. Stat. 105-228.37 authorizes a refund of an overpayment, but the default position of that law only authorizes the Board of Commissioners to approve or deny the refund. For context, the Board last considered such refund requests on January 8, 2024, and September 2, 2025. In 2022, the law was amended to allow the Board of Commissioners to delegate decision -making authority for these refund requests to either or both the county manager and finance officer. To delegate that authority the Board of Commissioners must adopt a resolution. If this resolution, is adopted either the county manager or finance officer could approve or deny refund requests. In the event of a denial, the person seeking the refund could still request the refund be considered by the Board of Commissioners. The Register of Deeds is in full agreement with this resolution. STRATEGIC PLAN ALIGNMENT: • Good Governance o Effective County Management ■ Increase transparency and awareness about county actions RECOMMENDED MOTION AND REQUESTED ACTIONS: Adopt resolution. ATTACHMENTS: Resolution COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 4 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS RESOLUTION DELEGATING REFUND AUTHORITY FOR OVERPAYMENTS OF EXCISE TAX WHEREAS, all grantors of interests in real property are required to pay an excise tax to the register of deeds of the county in which the real estate is located before recording the instrument of conveyance unless otherwise exempted; and WHEREAS, on occasion excise taxes are overpaid due to such actions as recording a deed in the wrong county or mistakenly paying the tax when exempt; and WHEREAS, North Carolina General Statute (NCGS) §105-228.37 authorizes a board of county commissioners to conduct a hearing to determine whether a refund should be granted; and WHEREAS, NCGS §105-228.37 was amended by Session Law 2022-50 adding a new subsection authorizing a board of county commissioners to delegate, by resolution, to either or both the county manager or the county finance officer the discretion to grant a request for a refund for overpayments of excise tax paid in accordance with statute; and WHEREAS, this Board has determined that it is in the best interests of the citizens and residents of the County to delegate this task. NOW, THEREFORE, BE IT RESOLVED by the New Hanover County Board of Commissioners that the County Manager and County Finance Officer, or either of them, are hereby authorized to grant requests for refund of overpayments of excise taxes paid in accordance with NCGS §105-228.37, written notification will be provided to the Board after any refunds are approved, and that this resolution be effective upon its adoption. ADOPTED this 20th day of October, 2025. NEW HANOVER COUNTY William E. Rivenbark, Chair ATTEST: Kymberleigh G. Crowell, Clerk to the Board This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: Human Resources PRESENTER(S): Commissioners and Chris Coudriet, County Manager CONTACT(S): Bo Dean, NHC Human Resources Sr. Analyst and Cala Blondin, NHC Human Resources Specialist SU BJ ECT: Presentation of Service Awards and Introduction of New Employees BRIEF SUMMARY: Service awards will be presented to retirees and employees. New employees will be introduced. STRATEGIC PLAN ALIGNMENT: Good Governance o Internal business processes ■ Communicate what the county does and why RECOMMENDED MOTION AND REQUESTED ACTIONS: Present service awards and meet new employees. COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Present service awards and meet new employees. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 5 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: Finance PRESENTER(S): Eric Credle, NHC Chief Financial Officer CONTACT(S): Eric Credle SU BJ ECT: Recognition of Government Finance Officers Association Award BRIEF SUMMARY: County staff is pleased to inform the public and the Board of County Commissioners of an award received from the Government Finance Officers Association (GFOA). The GFOA has completed its review of New Hanover County's Annual Comprehensive Financial Report for the fiscal year ending June 30, 2024, and has awarded the County the Certificate of Achievement for Excellence, the highest form of recognition in governmental accounting and financial reporting. The County's report was judged by an impartial panel to meet the high standards of the program, which include demonstrating a constructive "spirit of full disclosure" that clearly communicates the County's financial story and encourages potential users and stakeholders to read the report. New Hanover County has now received this prestigious award for 44 consecutive years. STRATEGIC PLAN ALIGNMENT: • Good Governance o Internal business processes ■ Communicate what the county does and why RECOMMENDED MOTION AND REQUESTED ACTIONS: Recognize staff and take photo with representative(s). ATTACHMENTS: GFOA Award Certificate GFOA Press Release COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recognize staff. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 6 This page intentionally left blank. Government Finance Officers Association Certificate of Achievement for Excellence in Financial Reporting Presented to New Hanover County North Carolina For its Annual Comprehensive Financial Report For the Fiscal Year Ended June 30, 2024 Executive Director/CEO Board of Commissioners - October 20, 2025 ITEM: 6 - 1 - 1 GOVERNMENT FINANCE OFFICERS ASSOCIATION NEWS RELEASE FOR IMMEDIATE RELEASE 7/9/2025 For more information contact: Michele Mark Levine, Director/TSC Phone: (312) 977-9700 Fax: (312) 977-4806 Email: mlevine@gfoa.org (Chicago, Illinois) —Government Finance Officers Association of the United States and Canada (GFOA) has awarded the Certificate of Achievement for Excellence in Financial Reporting to New Hanover County for its annual comprehensive financial report for the fiscal year ended June 30, 2024. The report has been judged by an impartial panel to meet the high standards of the program, which includes demonstrating a constructive "spirit of full disclosure" to clearly communicate its financial story and motivate potential users and user groups to read the report. The Certificate of Achievement is'the highest form of recognition in the area of governmental accounting and financial reporting, and its attainment represents a significant accomplishment by a government and its management. Government Finance Officers Association (GFOA) advances excellence in governmentfinance byproviding best practices, professional development, resources, and practical research for more than 25,000 members and the communities they serve. 203 NORTH LASALLE �TMUC� ��sO 5 ��� ��l INOIS 60601-1210 ITEM: 6 - 2 - 1 NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: County PRESENTER(S): Hannah McCoy, Outreach Coordinator at Domestic Violence Shelter Manager and Services, Inc. CONTACT(S): Hannah McCoy SU BJ ECT: Consideration of Domestic Violence Awareness Month Proclamation BRIEF SUMMARY: Hannah McCoy, Outreach Coordinator with Domestic Violence Shelter and Services, Inc., has submitted the attached proclamation for the Board's consideration. This proclamation seeks to officially designate October 2025 as Domestic Violence Awareness Month in New Hanover County. Observing this month will shine a light on the realities of domestic violence, uplift and empower survivors, and strengthen our collective commitment to building a community where every person feels safe, respected, and free from harm. STRATEGIC PLAN ALIGNMENT: • Community Safety & Well-being o The community supports a life that mitigates health and safety risks ■ Effectively and efficiently respond to public health and safety demands. RECOMMENDED MOTION AND REQUESTED ACTIONS: Adopt the proclamation and take photo with representative(s). ATTACHMENTS: Domestic Violence Awareness Month Proclamation COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 7 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS DOMESTIC VIOLENCE AWARENESS MONTH PROCLAMATION WHEREAS, domestic violence transcends all ethnic, racial, gender, and socioeconomic boundaries, weakening the very core of our community; and WHEREAS, the effects of domestic violence are far-reaching and may have lifetime implications for families, the criminal justice system, and our community; and WHEREAS, Domestic Violence Shelter and Services, Inc. provides emergency crisis intervention, ongoing support, and services in New Hanover County for victims and survivors of domestic abuse; and WHEREAS, 1,295 adults and 99 children received direct services such as court accompaniment, advocacy, empowerment groups and counseling; including 137 adults and 89 children who received emergency shelter through Domestic Violence Shelter and Services, Inc. in the year 2024; and WHEREAS, on September 4, 2002, Gladys Bryant, an employee of New Hanover County for more than two decades, and on August 6, 2008, Tarica Pulliam, an employee of New Hanover County for two years, lost their lives in acts of domestic violence, reminding their coworkers and friends of the prevalence and devastating consequences of domestic violence; and WHEREAS, many other individuals throughout New Hanover County and the United States find themselves in abusive relationships and need a safe and empowering environment; and WHEREAS, this year's Domestic Violence Awareness Month serves as a call to action to citizens of New Hanover County to encourage, support and empower one another to live lives free from violence. NOW, THEREFORE, BE IT PROCLAIMED, that the New Hanover County Board of Commissioners is committed to addressing domestic violence in all its forms, creating a community that upholds strong values, fosters safe and loving homes for all families, and encourages citizens to work together to prevent and eliminate domestic violence. The Board further proclaims October 2025 as Domestic Violence Awareness Month in New Hanover County. ADOPTED this 20th day of October, 2025. NEW HANOVER COUNTY William E. Rivenbark, Chair ATTEST: Kymberleigh G. Crowell, Clerk to the Board Board of Commissioners - October 20, 2025 ITEM: 7 - 1 - 1 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: Veteran Services PRESENTER(S): Betsy Graham, New Hanover County Veteran Services Director CONTACT(S): Betsy Graham SUBJECT: Consideration of Operation Green Light for Veterans Resolution BRIEF SUMMARY: Operation Green Light is a national initiative spearheaded by National Association of Counties (NACo) and the National Association of County Veteran Services Organization (NACVSO) to recognize the service and sacrifice of all who served in the armed forces. Community members are encouraged to join in this tribute by using green lighting at their own home or business to show support November 4 -11, 2025. North Carolina is home to more than 600,000 veterans, with approximately 14,000 of those living in New Hanover County. Operation Green Light is an opportunity to shine a light on the county resources that are dedicated to assist and raise the awareness of resources available to veterans and their families. STRATEGIC PLAN ALIGNMENT: • Community Safety & Well-being o Residents feel supported and connected to their community ■ Build relationships and create opportunities that enhance engagement for a diverse community. • Good Governance o Effective County Management ■ Continuous focus on the customer experience RECOMMENDED MOTION AND REQUESTED ACTIONS: Adopt resolution and present to representatives. ATTACHMENTS: Consideration for Operation Green Light for Veterans Resolution COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 8 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS RESOLUTION SUPPORTING OPERATION GREEN LIGHT FOR VETERANS WHEREAS, the residents of New Hanover County have great respect, admiration, and the utmost gratitude for all the men and women who have selflessly served our country and this community in the Armed Forces; and WHEREAS, the contributions and sacrifices of those who served in the Armed Forces have been vital in maintaining the freedom and way of life enjoyed by our citizens; and WHEREAS, New Hanover County seeks to honor individuals who have made countless sacrifices for freedom by placing themselves in harm's way for the good of all; and WHEREAS, Veterans continue to serve our community in Veteran Service Organizations, religious groups, civil service, and with other local organizations to support fellow former service members; and WHEREAS, more than 14,000 veterans call New Hanover County home, and the County's Veteran Services Department provides comprehensive benefit counseling, claim development, and community outreach to assist an average of 2,000 veterans and eligible family members each year in obtaining and maintaining the benefits they have earned; and the Department of Veterans Affairs provided more than $230 million last year in compensation, medical care, pensions, education, and other services to veterans residing in New Hanover County; and WHEREAS, approximately 200,000 service members transition to civilian communities each year, and that number is expected to increase by an estimated 20 percent in the coming years; and WHEREAS, studies indicate that 44 to 72 percent of service members experience significant stress during the transition from military to civilian life; and WHEREAS, active military service members transitioning from military service are at a high risk for suicide during their first year after military service; and WHEREAS, New Hanover County appreciates the sacrifices of our United States military personnel and believes specific recognition should be granted. NOW, THEREFORE, BE IT RESOLVED, the New Hanover County Board of Commissioners hereby recognizes November 4 —11, 2025, as a time to salute and honor the service and sacrifices of those transitioning from active service and is proud to participate in Operation Green Light for Veterans by lighting the Government Center, Health and Human Services Building, and Senior Resource Center in green to let veterans know they are seen, appreciated, and supported. New Hanover County citizens are encouraged to recognize the importance of honoring all those who made immeasurable sacrifices to preserve freedom by displaying a green light in a window of their place of business or residence from November 4 —11, 2025. ADOPTED this 20th day of October, 2025. NEW HANOVER COUNTY William E. Rivenbark, Chair ATTEST: Kymberleigh G. Crowell, Clerk to the Board Board of Commissioners - October 20, 2025 ITEM: 8 - 1 - 1 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: Planning PRESENTER(S): Theo McClammy, NHC Planning& Land Use Program Manager CONTACT(S): Theo McClammy, Rebekah Roth, NHC Director, Planning & Land Use SU BJ ECT: Consideration of Scotts Hill Water Main Extension CDBG-I Compliance Manual Resolution BRIEF SUMMARY: Staff requests the Board's consideration of a resolution adopting the program compliance manual for the Scotts Hill Water Main Extension Project. The project received a $2,997,703 federal Community Development Block Grant — Infrastructure (CDBG-1) award (Grant No. 24-1-4204; HUD ALN 14.228). Adoption of the compliance manual is required by the funding agency. This manual brings together key County policies and practices related to citizen participation, language access, fair housing, employment, procurement, accessibility, and codes of conduct. It was developed collaboratively with input from Legal/Risk, Finance, Human Resources, Civic Engagement, and the Ardurra Group North Carolina (grant consultant). The manual will be reviewed and updated as necessary to maintain compliance with the North Carolina Department of Environmental Quality (NCDEQ), the U.S. Department of Housing and Urban Development (HUD), and other applicable oversight agencies, ensuring full alignment with all relevant federal and state regulations. On February 19, 2025, the State Water Infrastructure Authority (SWIA) approved the County's application for this water extension project. NCDEQ issued a Notice of Intent to Fund and grant contract on April 29, 2025. The Board approved related agreements with NCDEQ, CFPUA, and Ardurra Group NC on July 21, 2025. Since then, staff have provided project updates to Scotts Hill residents and convened a start-up meeting with partners in accordance with the ILA. CFPUA has selected Ardurra Group NC firm to deliver the environmental review and engineering report by October 28, 2025. Construction contract execution is anticipated by June 2027, with project completion in July 2028. The total estimated cost of the extension project is $4,748,792. Of this amount, 63.13% ($2,997,703) is secured through the CDBG-I grant, and 36.87% ($1,751,089) is allocated in the approved fiscal year 2025-2026 county budget. This project will provide public water service to residents in the Old Scotts Hill/Kirkland area, benefiting approximately 120 residents across 57 parcels. Compliance Manual Note: NC DEQ policies and guidelines are periodically updated. When a new version is released or when the CDBG-I program manual is revised, changes are shown in red for easy reference. STRATEGIC PLAN ALIGNMENT: • Community Safety & Well-being o The community supports a life that mitigates health and safety risks ■ Effectively and efficiently respond to public health and safety demands. RECOMMENDED MOTION AND REQUESTED ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 9 Staff recommends adopted of the attached resolution. ATTACHMENTS: Staff Presentaion CDBGI Compliance Manual Resolution CDBGI Compliance Manual COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend approval. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 9 NEW HANOVER COUNTY BOARD OF COMMISSIONERS A RESOLUTION AUTHORIZING THE ADOPTION OF THE SUPPLEMENTAL PROGRAM MANUAL FOR NEW HANOVER COUNTY DURING THE IMPLEMENTATION OF THE NORTH CAROLINA SMALL CITIES COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) INFRASTRUCTURE (CDBG-1) PROGRAM WHEREAS, the New Hanover County agreed to participate in the FY2024 Small Cities CDBG Program under the Housing and Community Development Act of 1974, as amended, and administrated by the North Carolina Department of Environmental Quality (NCDEQ), Division of Water Infrastructure (DWI); and WHEREAS, the CDBG program has many federal performance and program requirements; and WHEREAS, the following documents require supplemental policies and plans under this CDBG program: 1. Language Access Plan 2. Citizen Participation Plan 3. Equal Opportunity Plan and Policy 4. Equal Housing Opportunity Plan and Policy 5. Fair Housing Plan and Policy 6. Fair Housing Compliant Procedure 7. Procurement Plan and Policy 8. Section 3 Plan and Policy 9. Section 504 Non -Discrimination Policy 10. Section 504 Grievance Procedure 11. Residential Anti -Displacement and Relocation Assistance Plan 12. Code of Conduct Policy 13. Excessive Force Policy NOW, THEREFORE, BE IT RESOLVED: a. That the New Hanover County Board of Commissioners hereby authorizes and empowers the County Manager, Mr. Chris Coudriet, to execute all grant -related documents necessary to establish and maintain this CDBG-1 program compliance manual. b. That this program manual is hereby submitted and adopted and to be used throughout the implementation of the New Hanover County Scotts -Hill Water Main Extension FY2024 CDBG-I Program (FY2024 CDBG-I Program). c. Amendments will be made to this manual, whole or in parts, as required by the funding agency, their lead state agency, and/or the U.S. Department of Housing and Urban Development (HUD) to keep current with state and federal statutes and CDBG program regulations and requirements. d. That the compliance plans and policies in this Program Manual are hereby submitted and adopted and to be used throughout the implementation of the New Hanover County FY2024 CDBG-I Program. ADOPTED this the 20' day of October, 2025. NEW HANOVER COUNTY William E. Rivenbark, Chair ATTEST: Kymberleigh G. Crowell, Clerk to the Board Board of Commissioners - October 20, 2025 ITEM: 9 - 2 - 1 SDI a OMIK61110 I WWII 01 Uea gel:&Io1rM:1 Role] ME Small Cities Community Development Block Grant Infrastructure (CDBG-1) Program North Carolina Department of Environmental Quality, Division of Water Infrastructure, CDBG-I Unit FundingYea r (2024) CDBG-I Program Authorized Representative and Compliance Coordinator .......................... Language Access Plan & Policy......................................................................................... Providing Meaningful Communication with Persons with Limited English Proficiency (LEP) Four Factor Analysis.................................................................................................. Language Assistance Measures.................................................................................. Monitoring Language Need and Implementation.......................................................... Citizen participation Plan(CPP)......................................................................................... Scopeof Participation................................................................................................... ContactPerson............................................................................................................. TechnicalAssistance.................................................................................................... PublicHearings............................................................................................................ Public Hearing Accommodations and Accessibility..................................................... Programming Information.......................................................................................... Procedures for Comments, Objections, and Complaints ............................................. Amendments............................................................................................................ Authority................................................................................................................... Sample Public Hearing Notices...................................................................................... Sample Application Public Hearing Public Notice........................................................ Sample Performance Assessment (Close Out) Public Hearing Notice ........................... Sample Project Amendment Public Hearing Notice ..................................................... Modified Notice of Public Hearing —Application by City/Town/County for Funding......... Modified Sample Performance Assessment (Close Out) Public Hearing Notice ............. Modified sample Project AMENDMENT Public Hearing Notice ...................................... Public Hearing Discussion Checklists............................................................................ ApplicationPublic Hearing......................................................................................... Project Amendment Public Hearing............................................................................ Project Closeout Public Hearing................................................................................. EqualOpportunity Plan..................................................................................................... FairHousing..................................................................................................................... Equal Housing Opportunity Policy.................................................................................. Fair Housing Plan and Policy.......................................................................................... FairHousing Complaints............................................................................................... Fair Housing Complaint Procedure (for Newspaper).................................................... 1 2 2 3 4 2 3 4 4 4 5 .7 .9 10 11 12 12 12 13 13 14 15 16 17 17 18 18 19 20 21 21 23 25 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 2 Violence Against Women Act (VAWA) Certification ...................... VAWA Certification................................................................ Procurement Plan and Policy........................................................ Section 3 Action Policy and Plan .................................................... Section504.................................................................................. 24 CFR -8.51 Self -Evaluation Survey ........................................... Section 504 Non -Discrimination and Grievance Procedure Policy Residential Anti -Displacement and Relocation Assistance Plan ...... Codeof Conduct.......................................................................... Excessive Force Policy.................................................................. LaborStandards........................................................................... Acquisition Guidelines.................................................................. Build America, Buy America (BABA) ............................................... AppendixA................................................................................... AppendixB................................................................................... AppendixC.................................................................................. AppendixD.................................................................................. AppendixE................................................................................... AppendixF................................................................................... AppendixG.................................................................................. AppendixH.................................................................................. AppendixI.................................................................................... AppendixJ.................................................................................... AppendixK................................................................................... Appendix L Appendix M 26 26 27 29 30 31 31 33 35 36 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 3 The Authorized Representative for all FY2024 CDBG-I Program plans and policies is, and any successors to this position: Mr. Chris Coudriet, County Manager New Hanover County 230 Government Center Drive, Suite 110 Wilmington, North Carolina 28403 Phone: 910.798.7184 Email: coudriet@nhcgov.com The County Commission authorized the County Manager to approve/sign the following, but not limited to, grant -related documents: • All official correspondence and requests to NCDEQ/CDBG-I Unit (funding agency) • Quarterly Progress Reports, Annual Performance Reports, Final Grant Report, and other reports required or requested by funding agency • Compliance Plans and policies revisions, amendments, updates • Affirmatively Furthering Fair Housing plan updates, revisions, amendments • Closeout Package The main Compliance Coordinator for the plans and policies outlined in this FY2024 CDBG-I Program manual is: Theo McClammy, Program Manager New Hanover County Planning & Land Use Planning & Zoning 230 Government Center Drive, Suite 110 Wilmington, NC 28403 Phone: (910) 798-7180 Email: tmcclammy@nhc og v.com Additional county staff have been identified for specific plans/policies to assist with ensuring compliance with specific topics (citizen participation, language access, Section 504, etc.). Title VI Compliance Linda Thompson ADA Compliance Chief Civic Engagement Officer County Attorney's Office - Risk Management Thompson@nhcgov.com Franklin Juarez 910-798-7414 Safety Officer fjuarez@nhcgov.com 910-798-7037 New Hanover County CDBG-I Program Manual Page 1 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 4 This Language Access Plan is a supplemental policy to the 2024 New Hanover County Language Access Plan (see Appendix A), solely for New Hanover County's FY2024 CDBG-I Program. The 2024 New Hanover County Language Access Plan was approved by the county Board of Commissioners on February 7, 2024, and took effect on July 1st, 2024. The 2024 County LAP reflects the county's commitment to ensuring equitable access to county services for all residents, regardless of their primary language. The purpose the Plan is to ensure compliance with Title VI of the Civil Rights Act of 1964, Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency," and other applicable federal and state laws and their implementing regulations with respect to persons with limited English proficiency (LEP). Title VI of the Civil Rights Act of 1964, and clarified in Executive Order 13166, requires units of general local government (UGLG) to ensure individuals with limited English proficiency (LEP) have meaningful access to federally -funded programs and services. These individuals are protected from the national origin discrimination under Title VI. All recipients are federally -funded assistance and are expected to make reasonable efforts to provide this language assistance. Meaningful Opportunities. All CDBG recipients are required to take reasonable steps to ensure meaningful access to their programs and activities. The methodology recommended by HUD is properly prepare a Limited English Proficiency Plan is as follows: 1. Conduct a four factor analysis; 2. Develop a Language Access Plan (LAP); and 3. Provide appropriate language assistance. Definitions. Limited English Proficient (LEP) Individual. Any prospective, potential, or actual beneficiary of services from the local unit of government whose primary language is not English and who has a limited ability to speak, read, write, or understand English are entitled to language assistance with respect to a particular service, benefit, or encounter. May be citizens or non -citizens. Meaningful Access. The ability to access programs and participate in services or activities. Additional Information and Resources. Additional LEP resources can be found at these websites: • https://www.len•gov/ • http://portal.hud. ov/hudportal/HUD?src=/program offices/fair housing_ egual_opp/promoting /lep-faq PROVIDING MEANINGFUL COMMUNICATION WITH PERSONS WITH LIMITED ENGLISH PROFICIENCY (LEP) In order to comply with Title VI of the Civil Rights Act of 1964 and Executive Order 13166, the County will take reasonable steps to ensure that persons with Limited English Proficiency (LEP) have meaningful access and an equal opportunity to participate in benefits and services for which such persons qualify. This New Hanover County CDBG-I Program Manual Page 2 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 5 Policy defines the responsibilities the unit of general local government (UGLG) must ensure LEP individuals can communicate effectively. Four Factor Analysis CDBG subrecipients must first assess and evaluate four factors when determining how to best serve eligible LEP persons. These factors include: 1. The number or proportion of LEP persons eligible to be served/encountered in an eligible service population (town/city/or county level); 2. The frequency with which LEP individuals come in contact with the CDBG program; 3. The nature and importance of the program, activity, or service provided by the CDBG program to people's lives; and 4. The (financial and human) resources available to the grantee/recipient and costs of language service options. Factor 1. The number or proportion of LEP persons eligible to be served/encountered in an eligible service population. To determine the number of proportion of LEP persons served in County, use the most recent American Community Survey data (Table B16001) and complete the below table. Appendix A has the ACS 2015 5- year estimates, Table B 16001, "Language Spoken at Home by Ability to Speak English for the population 5-years and over." Grantee Population 5 years and older 201,810 per B 16001 for New Hanover Count LEP Population (speaking English "not well" or 7,011 per B 16001 for New Hanover County not well at all') of coup 3.47% Languages Spanish (5243), Vietnamese (353), Other Asian Languages (304), Chinese (217), French (165), Korean (142), Portuguese (129), Greek (91), Gujarati (67), German (49), Russian (44), Japanese (25), Hindi (23), Polish (14), Italian (11), Other Languages 134 1. More than 5% of the eligible population 0% of project area are LEP per application or beneficiaries and has more than 50 in number; or surveys 2. More than 5% of the eligible population 0% of project area are LEP per application or beneficiaries but has less than 50 or less in number; or surveys 3. More than 1,000 individuals in the 0% of project area are LEP per application eligible population in the market area or among current beneficiaries. surveys Factor 2. The freauencv with which LEP persons come into contact with the CDBG program. This frequency with which a program engages with the public can vary depending upon the type of assistance. For CDBG grants, grantees must engage with the public at these critical steps: • When notifying the public about a grant award application and its proposed activities. • When notifying the public about the grant award and its funded activities. • When seeking applicants to participate in the program (i.e., seeking new connections/ hookups for water/sewer services). New Hanover County CDBG-I Program Manual Page 3 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 6 • When seeking qualified contractors to bid on projects. • When working with homeowners selected for assistance. • When notifying the public on their civil rights and complaint procedures. • When notifying the public about the grant closeout and its accommodations. The proposed project includes providing a public water service to residents in an area of the county. Residents will have considerable direct contact with the program and county staff. However, all citizen participation activities are open to the public. Factor 3. The nature and importance of programs, activities, or services to people's lives. The more important the activity, information, service, or program, or greater the possible consequences of the contact to the LEP persons, the more likely the need for language services. The obligations to communicate rights to a person who is being evicted differ, for example, from those to provide recreational programming. A CDBG recipient needs to determine whether denial or delay of access to services or information could have serious or even life -threatening implications for the LEP individual. The proposed project will provide direct assistance to project area beneficiaries with the extending of public water mains and private service connections to dwelling. While the CDBG project benefit depends on the targeted low -moderate -income population, the nature of the activity or service is of significant importance to the entire project area residents. All citizen participation activities are open to the public. Factor 4. Resources available to jzrantee/recipient and costs. New Hanover County will take all reasonable steps to ensure meaningful access for LEP persons to CDBG programs and activities. The availability of resources, however, may limit the provision of language assistance services in some instances. "Reasonable steps" may cease to be reasonable when the costs imposed substantially exceed the benefits. County's LAP balances the needs of the LEP community with the funding resources available. If resources limit the provision of services already laid out in this document, New Hanover County will keep record of both the service requested and financial reasoning for the limitation. Language assistance measures that County might provide to LEP persons are outlined in this plan. Language Assistance Measures The type of language assistance necessary to provide meaningful access will vary depending on the type of communication County staff is having with the LEP person (i.e., phone, in -person, or written communication) and in some circumstances more than one method will work. Regardless of how the language assistance is provided, County recognizes the importance of providing such services in a timely manner and in an appropriate place. Failure to do so may effectively delay or deny LEP residents access to CDBG programs and services. County staff understands that the extent of the County obligation is to provide both oral and written translations is dependent on the four -factor analysis conducted by the community. "I Speak" Cards. Language -specific cards should inform the reader of the use of the card on one side, while instructing staff (on the other side and in their vernacular language) which procedures to follow to assist the card holder. The "I Speak" card in Spanish, for example, would read in Spanish as follows: "The language I speak is Spanish. Please find someone who is fluent so that I may communicate effectively. Thank you. " New Hanover County CDBG-I Program Manual Page 4 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 7 The County will promptly identify the language and communication needs of the LEP person. Staff will use a language identification card (or "I speak cards," http://www.lep.gov/resources) and LEP posters to determine the language. In addition, when records are kept of past interactions with individuals or family members, the language used to communicate with the LEP person will be included as part of the record. Obtaining A Qualified Interpreter. List the current name, office telephone number, office address and email address of the local Title V[ compliance officer(s): Per the 2024 LAP for New Hanover County: "Individuals with limited English proficiency may request interpretation for public meetings, small group meetings, or one-on-one interactions with county staff. Such requests should be made at least 48 hours in advance to ensure adequate time to arrange for interpreter services and can be submitted by staff to the Office of Civic Engagement for confirmation. Family members, friends, or minors should not be used as interpreters if the LEP individual declines services offered by New Hanover County as the use of such a person would compromise the effectiveness of services or violate the LEP individual's confidentiality. Bilingual/Multilingual Staff Currently, on -site bilingual/multilingual staff are available at the New Hanover County Government Center, Sheriff's Office, and Health and Human Services facility. Approved county bilingual/multilingual staff must demonstrate an ability to: • Fluently and effectively communicate in both English and the primary language of the LEP individual • Have a basic knowledge of specialized terms and concepts used frequently in the provision of county services • Understand the obligation to maintain confidentiality • Understand the roles of interpreters and the ethics associated with being an interpreter New Hanover County has a bilingual/multilingual hiring preference for positions that provide direct, critical services to individuals with limited English proficiency and these positions are advertised to attract bilingual/multilingual candidates. Prior to becoming a New Hanover County employee, a bilingual/multilingual candidate shall be tested to ensure that they are competent in each identified language. Bilingual/multilingual employees may receive additional remuneration if interpreter duties fall outside of their everyday responsibilities. Compensation for interpretation services performed by qualified employees is determined by Human Resources. " Check all methods that will be used. ❑ Maintaining an accurate and current list showing the language, phone number and hours of availability of bilingual staff (provide the list): ® Contacting the appropriate bilingual staff member to interpret, in the event that an interpreter is needed, if an employee who speaks the needed language is available and is qualified to interpret: New Hanover County contracts with Language Line Solutions to provide LEP Interpretation Services. New Hanover County CDBG-I Program Manual Page 5 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 8 ❑ Obtaining an outside interpreter if a bilingual staff or staff interpreter is not available or does not speak the needed language. Identify the organization (s) name(s) with whom you have contracted or made arrangements. ❑ Have/has agreed to provide qualified interpreter services. The organization's (or organizations') telephone number(s) is/are insert number here and the hours of availability are insert hours here. ❑ Other (describe): Unit of General Local Government (UGLG) Staff. All county staff are aware of the existing 2024 New Hanover County LAP and staff who may have direct contact with any LEP individuals on this FY2024 CDBG-I program will understand the resources and procedures on effective communication techniques, including the effective use of an interpreter. Family Member or Friend as an Interpreter. Some LEP persons may prefer or request to use a family member or friend as an interpreter. However, family members or friends of the LEP person will not be used as interpreters unless specifically requested by that individual and after the LEP person has understood that an offer of an interpreter at no charge to the person has been made by the facility. Such an offer and the response will be documented in the person's file. If the LEP person chooses to use a family member or friend as an interpreter, issues of competency of interpretation, confidentiality, privacy, and conflict of interest should be considered. If the family member or friend is not competent or appropriate for any of these reasons, competent interpreter services will be provided to the LEP person. Children and other residents will not be used to interpret, in order to ensure confidentiality of information and accurate communication. Written Translations. The County has chosen to follow the Safe Harbor rule, contained in HUD's final guidance, to assist in determining when to provide translations of vital documents. The Safe Harbor rule for written translation of vital documents is based on the number and percentages of the market area -eligible population or current beneficiaries and applicants that are LEP. According to the Safe Harbor Rule: HUD would expect translation of vital documents to be provided when the eligible LEP population in the market area or current beneficiaries exceeds 1, 000 persons or if it exceeds 5% of the eligible population or beneficiaries along with more than 50 people. In cases where more than 5% of the eligible population speaks a specific language, but fewer than 50 persons are affected, there should be a translated written notice of the person's right to an oral interpretation. As such, the County`s eligible LEP population or current beneficiaries is: ❑ Exceeds 1,000 persons. Therefore, vital documents will be translated. New Hanover County CDBG-I Program Manual Page 6 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 9 ❑ More than 5% of the eligible LEP population or current beneficiaries and more than 50 in number. Therefore, vital documents will be translated. ❑ More than 5% of the eligible population or current beneficiaries and 50 or less in number. Therefore, there will be a translated written notice of the person's right to an oral interpretation of vital documents. ❑X 5% or less of the eligible population or current beneficiaries and less than 1,000 in number. Therefore, vital documents will not be translated at this time but, rather, a translated written notice of the person's right to an oral interpretation will be provided. When translation of vital documents is needed, the County will submit documents for translation into frequently encountered languages. Ensure records are kept of those documents that apply to your local unit of government. The County will provide translation of other written materials, if needed, as well as written notice of the availability of translation, free of charge, for LEP individuals. Vital FY2024 CDBG-I Program Documents. The County has chosen to follow the Safe Harbor rule, contained in HUD's final guidance, in determining vital documents. The County has identified those vital documents for each federally funded program that directly faces LEP individuals and for which a delay in service provision might significantly negatively impact the wellness of any individual that program serves. The County has prioritized those documents for which either the following statements are true, according to direct program contacts: 1) Without this document, an individual could not access the program; 2) This document allows access to a major activity within the program. These vital documents include: • Public Notices — public meetings and public hearings; • Notices of Intent to Request the Release of Funds; • Findings of No Significant Impact; • Bid Documents and Notices; Notice to LEP Persons. • Fair Housing Information; • Civil Rights Notices; • Applications for Assistance; • Income Surveys; and • Complaint Procedures. The County will inform LEP persons of the availability of language assistance, free of charge, by providing written notice in languages LEP persons will understand. For example, the notification will include, in the primary language of the applicant/recipient, the following language: "Important: If you need help reading this, ask the county for an interpreter for assistance. An interpreter is available free of charge. " Minimum Required Phases. The County shall include at minimum the following phrases in English and Spanish in any document requesting public comments, or notifying the community of any modifications/amendments to the FY2024 CDBG program during the life of the grant, including but not limited to, public hearing notifications, citizen New Hanover County CDBG-I Program Manual Page 7 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 10 participation documents, fair housing notices and documentation, Environmental Review notifications, among other documents: This information is available in Spanish or any other language upon request. Please contact Linda Thompson, Chief Civic Engagement Officer at 910-798-7414 or at lthompsonknhc,gov.com for accommodations for this request. Esta informacion esta disponible en espafiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con Linda Thompson, Chief Civic Engagement Officer al 910-798-7414 o en lthompsonknhc og v.com de alojamiento para esta solicitud. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the person being served, and individuals and their families will be informed of the availability of such assistance free of charge. Minimum Required Notices and Signs. At a minimum, notices and signs will be posted and provided in intake areas and other points of entry, including but not limited, to the main lobbies, waiting areas of the New Hanover County Government Center. Notification will also be provided through one or more of the following: outreach documents, telephone voice mail menus, local newspapers, radio and television stations, and/or community -based organizations. Monitoring Language Need and Implementation During the performance period of the FY2024 CDBG-I program, the county will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, the County will regularly assess the efficacy of these procedures, including but not limited to mechanisms for securing interpreter services, complaints filed by LEP persons, feedback from residents and community organizations, etc. Compliance Procedures, Reporting and Monitoring. Reporting: The County will complete an annual compliance report and send this report to DWI. The form can be found at on the Division of Water Infrastructure website under CDBG-I Reports. 2. Monitoring: The County complete a self -monitoring report on a semi-annual basis, using a standardized reporting system proposed by the local government. These reports will be maintained and stored by the Title VI Compliance Officer and will be provided to the Division of Water Infrastructure upon request. The County will cooperate, when requested, with special reviews by the Division of Water Infrastructure. Applicant/Recipient Complaints of Discriminatory Treatment. 1. Complaints: The County will provide assistance to LEP individuals who do not speak or write in English if they indicate that they would like to file a complaint. New Hanover County CDBG-I Program Manual Page 2 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 11 a. A complaint will be filed in writing, contain the name and address of the person filing it or his/her designee and briefly describe the alleged violation of this policy. b. The form can be found on the Division of Water Infrastructure website under CDBG-I Compliance and Reporting Information. c. The County will maintain records of any complaints filed, the date of filing, actions taken and resolution. d. The County will notify the appropriate section within the Division of Water Infrastructure of complaints filed, the date of filing, actions taken and resolution. This information will be provided within 30 days of resolution. 2. Resolution of Matter: If the matter cannot be resolved by informal means, then the individual will be informed of his or her right to appeal further to the Department of Justice (DOJ). This notice will be provided in the primary language of the individual with Limited English Proficiency. If not resolved by Division of Water Infrastructure, then complaint will be forwarded to U.S. Department of Justice (DOJ) and U.S. Department of Housing and Urban Development (HUD) Field Office. The County has designed this community -wide Citizen Participation Plan (CPP) to provide for and encourage citizen participation in the Community Development Block Grant (CDBG) program. This Plan is an essential element of the County's present and future community development process and has been developed to comply with the regulations and requirements of the CDBG program as administered by the North Carolina Department of Environmental Quality — Division of Water Infrastructure (NCDEQ- DWI) and the Department of Housing and Urban Development (HUD). The Citizen Participation Plan is required by Section 104(a)(2) of the Housing and Community Development Act and by regulations at 24 CFR 570.486(a)(6). The primary goal of this CPP is to provide all citizens of the community with an adequate opportunity to participate in an advisory role in the planning, implementation, and assessment of the County's CDBG program(s) and project(s). The CPP sets forth policies and procedures for citizen participation, which are designed to maximize the opportunity for citizen participation in the community development process. Special emphasis has been placed on encouraging participation by persons of low and moderate incomes, residents of blighted neighborhoods, and residents of areas where community development funds are utilized. The plan is vitally important to the success of CDBG-funded activities undertaken by local units of general government. Compliance with the plan reduces the number of legal challenges and citizen complaints against the local government recipient. Local units of general government must provide citizens with reasonable advance notice of and opportunity to comment on proposed activities in an application to the state; and for grants already made, the same opportunities must be provided for activities proposed to be added, deleted, or substantially changed from New Hanover County CDBG-I Program Manual Page 3 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 12 the original application to the state. Substantially changes include, but not limited to, purpose, scope, location or beneficiaries. Citizens are encouraged to participate in all phases of the CDBG program(s) and will be provided full access to program information. However, the final responsibility and authority for the development and implementation of CDBG program(s) will lie with the County. SCOPE OF PARTICIPATION The County will make reasonable efforts to provide for citizen participation during the community development process and throughout the planning, implementation and assessment of all CDBG program(s) undertaken by the County. Local officials will make every effort to involve citizens in all phases of the development, implementation and assessment of community development programs including, but not limited to, the following phases: a. Identification and assessment of housing and community development needs; determination of CDBG project(s) and documentation; and the development of CDBG application(s); b. Changes and/or amendments to approved CDBG projects; and, C. Assessment of CDBG program performance. All phases of the community development process will be conducted by local officials in an open manner. Citizens of the County are encouraged to participate at all levels and will be given access to program information during each phase of any CDBG program as outlined herein. CONTACT PERSON The Compliance Coordinator has been designated Citizen Participation Coordinator and will serve as the contact person for all matters concerning citizen participation activities. This person shall be responsible for overseeing citizen participation throughout the community development process and the implementation of all citizen participation activities and functions, except those which may be specifically delegated to other parties by this Plan. The specific duties and responsibilities of the Citizen Participation Coordinator shall include, but not necessarily be limited to: disseminating information concerning proposed projects and the status of current project activities; coordinating various groups which may be participating in the community development process; receiving written comments; serving as a vehicle by which ideas, comments, and proposals from local residents may be transmitted to local officials and/or program staff, and, monitoring the citizen participation process and proposing such amendments to the Citizen Participation Plan as may be necessary. The Citizen Participation Coordinator may be contacted during regular business hours. All questions concerning citizen participation in the community development process should be addressed to the Citizen Participation Coordinator. TECHNICAL ASSISTANCE County staff shall provide technical assistance to individual citizens and citizen groups, especially those groups representative of persons of low or moderate income, as may be required to adequately provide for citizen participation in the planning, implementation and assessment of CDBG program(s). New Hanover County CDBG-I Program Manual Page 4 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 13 Such technical assistance is intended to increase citizen participation in the community development decision making process and to ensure that such participation is meaningful. Technical assistance shall also be utilized to foster public understanding of CDBG program requirements. Technical assistance shall be provided on request and may include, but not necessarily be limited to: interpreting the CDBG program and its rules, regulations, procedures and/or requirements; providing information and/or materials concerning the CDBG program; and, assisting low and moderate income citizens, and residents of blighted neighborhoods to develop statements of views, identify their needs, and to develop activities and proposals for projects which, when implemented, will resolve those needs. Technical assistance may be obtained by contacting the Compliance Coordinator. PUBLIC HEARINGS Citizen participation in the community development process will be conducted on a community -wide basis and will actively involve the views and proposals of all citizens, especially low- and moderate -income persons and residents of areas where CDBG activities are proposed or on -going. Public hearings will be held during all phases of the community development process, as outlined herein, to allow citizens to voice opinions and offer proposals concerning the development and performance of CDBG programs. Local officials will respond to questions and proposals from citizens at each public hearing. Any questions that citizens may have concerning a program will be answered and their comments, suggestions, and/or proposals will be received. Citizens may also express comments and views concerning the community development process or any specific CDBG project to the governing body at any regularly scheduled meeting. Public Hearing Times and Locations. All public hearings will be held at times and locations which will be accessible to all citizens, especially persons of low and moderate incomes, and residents of blighted neighborhoods and CDBG project areas. Public hearings will be scheduled for convenient times as determined by the County. Public hearings may be held at any site which, in the opinion of the County provides adequate access for citizen participation. Hearings will normally be held at the New Hanover County Government Center. This site is centrally located and generally accessible to all citizens. This building is also accessible to persons with disabilities. Hearings may, however, at the option of the County, be held at an alternate location to be specified in the public hearing notice(s). Application Public Hearing. One public hearing shall be held during any CDBG program fiscal year prior to the submission of an application to the NCDEQ-DWI for CDBG assistance. The primary purposes of the public hearing shall be to assess community needs and problems to determine the most critical needs to be addressed by the CDBG program; and, to present for public comment and review the program activities which have been selected by the County to resolve the identified needs. An application public hearing will be held during the initial stage of program development to discuss items regarding community development and housing needs, the CDBG program, and the application process. The objective of citizen participation at this stage is to provide meaningful, community -wide citizen input into the decision -making process during the assessment of community needs and the consideration of priorities and options associated with the development and submission of a CDBG application. Local officials will also entertain proposals and comments from citizens concerning community development activities at this hearing. New Hanover County CDBG-I Program Manual Page 5 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 14 This hearing will normally serve to discuss and review the information appropriate for all applications submitted by the County during any fiscal year. Additional changes in community development or housing needs in the community as determined by local officials can be addressed by a community meeting where citizens can share their comments prior to the submission of other CDBG applications late in the fiscal year. Citizens will be provided with information concerning the CDBG program at this public hearing. Such information shall include, but not necessarily be limited to: the goals and objectives of the CDBG program; the total amount of CDBG funds available for the fiscal year and for the funding round; the role of citizens in program planning, implementation, and assessment; the range of activities which may be undertaken; the process to be followed in developing a CDBG application; a statement that 100 percent of the CDBG funds will be used to benefit low -to -moderate income people; the schedule of meetings and hearings; location where the application can be reviewed; activities previously funded in the New Hanover County through the CDBG program; and, an identification of projects which could result in the relocation of area residences or businesses; and the actions that would be undertaken if such relocation were necessary; provide citizens with contact information such as address, telephone number, and dates for submitting complaints or grievances. Furthermore, the effectiveness of the Citizen Participation Plan in allowing citizen participation in the community development process and potential changes and/or amendments to the Plan shall also be discussed at this meeting. The County may, at the option of local officials, review multiple CDBG project applications at one hearing when more than one application is to be submitted during the same fiscal year. Each such hearing shall be held prior to, and in preparation for, the application's approval by the County. A second objective of citizen participation during this stage is to inform citizens of the proposed project activities to be included in a CDBG application(s) and to solicit comments from citizens concerning these activities. Citizens attending this hearing will be provided with information concerning the CDBG project(s) proposed including, but not necessarily limited to: the project application(s) to be submitted and the applicable CDBG fund; specific project activities to be included; the location of the project activities; the approximate cost estimate for the proposed activities; the estimate of local match required; the impact of the project on low and moderate income persons; and, the approximate application submittal date. Project Amendment Public Hearings. The County will ensure the opportunity for citizen participation during the implementation of any CDBG program(s) when changes to the project are under consideration by the County. Citizen participation shall be obtained and considered in any amendments to a CDBG program which involves changes in the dollar amount spent on any activity, changes in program beneficiaries, changes in the location of approved activities, addition to or deletion of project activities, and major budget shifts between approved activities. To ensure adequate opportunity for citizen participation during CDBG programs, the County shall hold a public hearing on all formal amendments which require the NCDEQ-DWI approval. For "local" amendments and changes for which the NCDEQ-DWI approval is not required, input from citizens concerning changes or amendments will be received at regularly scheduled County meetings where such changes or amendments are considered. Assessment of Performance (Close -Out) Public Hearings. This public hearing must be held after all third -party contracts' payments have been submitted. New Hanover County CDBG-I Program Manual Page 6 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 15 Citizens of the County will be provided with the opportunity to comment on the performance of local officials, the County staff, consultants, engineers, and contractors, and the actual use of CDBG funds during the implementation of a CDBG program. Citizens will also be requested to assess the performance of the County in resolving identified community development and housing needs, and in achieving its community development goals and objectives. On -going community assessment of the effectiveness of the community development process is considered essential to the success of the CDBG program. At the conclusion of each CDBG project, a public hearing will be held to review program activities and to assess program performance. This hearing shall be held prior to the submission of the Performance Assessment Report and any other required closeout documents to the NCDEQ-DWI for a CDBG project. This hearing will be used to ensure community -wide participation in the evaluation of the CDBG program. Additional Hearings. Other public hearings may be held as deemed necessary by the County to inform citizens of community development project(s) and activities, and to solicit citizen opinions and comments. All additional hearings shall comply with the requirements set forth in this Plan. Public Hearing Accommodations and Accessibility Hybrid Hearings. CDBG-I staff highly recommend local governments leverage online resources to hold hybrid public hearings. Hybrid public hearings provide for the ability of the public and interested parties to attend and participate in meetings without having to physically attend. This increases the access of the hearings to additional citizens who would be otherwise unable to attend. Local governments may use online platforms to hold hybrid hearings that facilitate public access to all questions and responses and provide timely responses from local officials. o Hybrid hearing methods could include but are not limited to, Google Hangouts, Adobe Connect, Facebook Live, a video streaming service (WebEx, Zoom, youtube, etc.), local community television stations, live streaming on county/city website, or other virtual platforms can help accommodate these meetings. A call -in option that does not require internet connection is strongly recommended. All hybrid hearings held shall provide reasonable notification and access for citizens, timely responses from local officials to all citizen questions and issues, and public access to all questions and responses. • Local governments must take appropriate actions to encourage the participation of all residents, including the elderly, minorities, persons with limited English proficiency, as well as persons with disabilities. Therefore, a hybrid hearing method or platform that is selected must provide appropriate accommodation made for those individuals that may not be able to physically attend the meeting. • Whether hearings are in -person or hybrid, local governments must take appropriate steps to ensure effective communication with persons with disabilities consistent with the requirements of accessibility laws, such as Section 504 of the Rehabilitation Act and the Americans with Disabilities Act. New Hanover County CDBG-I Program Manual Page 7 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 16 o Thus, local governments must provide appropriate auxiliary aids and services where necessary to afford individuals with hearing and/or vision impairment an equal opportunity to access and participate in such hearings. ■ These may include effective methods that make verbally delivered information available to individuals who are deaf or hard of hearing, and visually delivered materials available to individuals who are blind or have low vision. ■ The type of auxiliary aid or service necessary to ensure effective communication will vary in accordance with the method of communication used by the individual; the nature, length, and complexity of the communication involved; and the context in which the communication is taking place. ■ In determining what types of auxiliary aids and services are necessary, a local government shall give primary consideration to the requests of individuals with disabilities. In order to be effective, auxiliary aids and services should be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual with a disability. ■ For hybrid hearings, such steps should include ensuring that information is provided on an accessible website, that a -mails and other digital notifications are accessible, and that the application or platform used to host the hearing is also accessible. Additional services such as audio description or captioning may also be needed to provide effective communication in a digital context. ■ There are some helpful guidelines for ensuring the accessibility of web -based and digital materials are available through the World Wide Web Consortium's Web Accessibility Initiative at https://www.w3.org/WAI/. Examples of auxiliary aids and services that may be necessary when conducting hearings online can be found at 28 CFR 35.104. • Local governments are highly encouraged to use various forms of social media, and we will accept public comments in written form (i.e. emailed comments, mailed, comments collected via social media, and other communication types made possible by web -based platforms or digital materials). • Local governments must document their efforts and the reason for them and update their citizen participation plans as soon as possible to add the use of virtual hearings if the plan doesn't already mention them. • Local governments should consult with their attorney before undertaking such meetings to ensure conformance with the NC Senate Bill 704. Additional legal resources are: o School of Government's summary of Session Law 2020-3: https://canons. sog.unc. edu/new-rules-for-meetings-of-public-bodies-during-state- level-declared-emergencies/ Limited English Proficiency Residents. The County has followed the guidance provided in the Language Access Plan (LAP) to determine the need to undertake reasonable actions to facilitate the participation of persons with Limited English Proficiency. Local officials will undertake all reasonable actions necessary to allow such persons to participate in the community development process. Such actions may include the provision of an interpreter and/or the provision of materials in the appropriate language or format for persons with Limited English Proficiency. New Hanover County CDBG-I Program Manual Page 8 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 17 Public Hearing Notice. Notice of public hearings must be published in a local newspaper of general circulation, in a non -legal section of the paper at least ten (10) days prior to the hearing date, but no more than 25 days prior to the meeting date. Each notice of a hearing shall include the time, date, place, and topics and procedures to be discussed. Accessibility to Low- and Moderate -Income Persons. The public hearing procedures outlined herein are designed to promote participation by low- and moderate - income citizens, as well as residents of blighted neighborhoods and CDBG project areas in any public hearing(s). Local officials may take additional steps to further promote participation by such groups, or to target program information to these persons should officials feel that such persons may otherwise be excluded or should additional action be deemed necessary. Activities to promote additional participation may include: posting of notices in blighted neighborhoods and in places frequented by low and moderate income persons, and holding public hearings in low- and moderate -income neighborhoods or areas of existing or proposed CDBG project activities. Accessibility to Persons with Disabilities. The location of all public hearings as described herein shall be made accessible to persons with disabilities. o The County shall provide a sign language interpreter whenever the Citizen Participation Coordinator is notified in advance that one or more deaf people will be in attendance. o The County shall provide a qualified reader whenever the Citizen Participation Coordinator is notified in advance that one or more visually impaired persons will be in attendance. o Additionally, the County shall provide reasonable accommodation whenever the Citizen Participation Coordinator is notified in advance that one or more people with mobility or developmental disabilities will be in attendance. Programming Information Citizens will be provided with full access to CDBG program information during all phases of a CDBG project. Local officials of the County shall make reasonable effort to assure that CDBG program information is available to all citizens, especially those of low and moderate incomes and those residing in blighted or Limited English Proficiency neighborhoods and/or CDBG project areas. To facilitate citizen access to CDBG program information, the Citizen Participation Coordinator will keep all documents related to a CDBG program on file in Grant Files in the New Hanover County Planning Department. Information from the project files shall be made available for examination and duplication, on request, during regular business hours. CDBG program information and materials, concerning specific CDBG projects will be available and distributed to the public at the regularly scheduled public hearings as outlined in this Plan. Furthermore, information concerning any CDBG project will be available at regularly scheduled council meetings where the program is discussed. New Hanover County CDBG-I Program Manual Page 9 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 18 Materials to be made available shall include, but are not necessarily limited to: the Citizen Participation Plan; records of public hearing; mailings and promotional materials; prior CDBG program applications; letters of approval; grant agreements; the environmental review record; financial and procurement records; project design and construction specifications; labor standards materials; performance and evaluation reports; other reports required by the NCDEQ-DWI and/or HUD; proposed and approved CDBG program application(s) for the current year or project; written comments or complaints received concerning the community development program, and written responses from the County; and, copies of the applicable Federal and State rules, regulations, policies, requirements and procedures governing the CDBG program. In no case shall the County disclose any information concerning the financial status of any program participants which may be required to document program eligibility or benefit. Furthermore, the County shall not disclose any information which may be deemed of a confidential nature. Procedures for Comments, Objections, and Complaints The public hearings scheduled, as described in this Citizen Participation Plan, are designed to facilitate public participation in all phases of the community development process. Citizens are encouraged to submit their views and proposals on all aspects of a community development program at the public hearings. However, to ensure that citizens are given the opportunity to assess and comment on all aspects of the community development program on a continuous basis, citizens may, at any time, submit written comments or complaints to the County. Any citizen or citizen's group desiring to comment or object to any phase of the planning, development or approval of the application for CDBG funds, or to the implementation of any CDBG program, should submit such comments or objections in writing to the Compliance Coordinator. Should, after a reasonable period, a party believe that his/her comment or complaint has not been properly addressed or considered by the County Manager, then the aggrieved may appeal his/her case to the County. Local officials shall make every effort to provide written responses to citizen proposals or complaints within fifteen (15) working days of the receipt of such comments or complaints where practicable. Should the County be unable to sufficiently resolve an objection or complaint, it may be forwarded by the aggrieved party to the NCDEQ-DWI. Citizens may, at any time, contact the NCDEQ-DWI and/or HUD directly to register comments, objections or complaints concerning the County CDBG application(s) and/or program(s). Citizens are encouraged, however, to attempt to resolve any complaints at the local level as outlined above prior to contacting the NCDEQ-DWI or HUD. All comments or complaints submitted to the NCDEQ-DWI or the HUD shall be addressed in writing to: New Hanover County CDBG-I Program Manual Page 10 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 19 NC Department of Environmental Quality Division of Water Infrastructure / CDBG-I Unit 1633 Mail Service Center Raleigh, North Carolina 27699-1633 Or: U.S. Department of Housing and Urban Development Community Planning and Development Division Greensboro Field Office 1500 Pinecroft Road Greensboro, North Carolina 27407 Records of all comments, objections and/or complaints by citizens concerning the County CDBG program and subsequent action taken in response to those comments shall be maintained on file at County and shall be made available for public inspection upon request. Amendments The County may, from time to time, modify the provisions outlined herein through an amendment to this Citizen Participation Plan. It shall be the policy of the County to periodically review and discuss the effectiveness of this Citizen Participation Plan in allowing citizen participation in the community development process and in helping to meet the community development needs and goals identified by the citizens of the County. To this end, the effectiveness of the Plan will be discussed at public hearings held in conjunction with the community development program as discussed herein, and potential amendments to the Plan will be reviewed at this time. Amendments to the Plan will be made as necessary. All amendments shall be approved by resolution of the County and shall be incorporated into this Plan. New Hanover County CDBG-I Program Manual Page 11 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 20 Authority No portion of this Citizen Participation Plan shall be construed to restrict the responsibility and authority of the elected officials of the County in the development, implementation, and execution of any Community Development Block Grant program. Sample Public Hearing Notices Sample Application Public Hearing Public Notice Notice is hereby given that the City/Town/County will conduct a public hearing on [DATE] at [TIME] AM/PM, or as soon thereafter as the agenda will allow, at the [LOCATION] relative to the intention of the City/Town/Co untX to apply for FY20XX CDBG funding under Title I of the Housing and Community Development Act. City/Town/Co untX intends to submit an application for a grant of approximately $000 in CDBG Infrastructure funds to [project description -must match grant pplication and include all streets with proposed improvements and any alternative streets if time and budget allows]. The following is a tentative list of proposed activities and an estimated budget. The final application will be reviewed at the public hearing. Infrastructure Improvements and Grant Administration Estimated Budget The proposed project will provide benefits to % of whom are low- and moderate -income individuals based on [surveys or statistics] performed by (use if surveyed). No individuals will be displaced nor will any require temporary relocation assistance as a result of the proposed project (this phrase may or may not be true for your particular project). Citizens will be given the opportunity to provide oral and written comment on the City/Town/County's past and proposed use of CDBG funds at the public hearing. All interested citizens are encouraged to attend. If additional information is needed, please contact the [Name & Title] at [Phone #]. Formal written complaints or comments concerning the application process that are submitted to the City/Town/CoIM prior to or following the public hearing will be responded to with fifteen (15) working days by [Date]. A copy of the completed project application will be available for public review after rDatel, at the Location . Persons with disabilities or who otherwise need assistance should contact , at or (email address) (TDD # or Relay North Carolina ) by . Accommodations will be made for all who request assistance with participating in the public hearing. This information is available in Spanish or any other language upon request. Please contact [Name & Title], at [phone number], or at the location] for accommodations for this request. Esta information esta disponible en espafiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con [Name & Title], al [phone number] o en location], de alojamiento para esta solicitud. New Hanover County CDBG-I Program Manual Page 12 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 21 12Y EQUAL HOUSINO OPPORTUNITY logo or tag line "Equal Housing Opportunity" is required Sample Performance Assessment (Close Out) Public Hearing Notice The City/Town/County will hold a public hearing on (date,) at (location) to discuss the locality's Community Development Block Grant project, CDBG project number (project number) performance and closeout of this project. The above mentioned CDBG project awarded $0.000 to the (locality) on (date). The (locality) used the funds to (project scope) which benefited % of low -moderate income citizens. The purpose of this public hearing is to review the performance, expenditures and activities that have been accomplished through the CDBG project. All activities are complete and the locali is in the process of closing the grant with the State of North Carolina. The City/Town/County is interested in obtaining all citizens' input on the performance of local officials, the City/Town/County) staff, consultants and administrators, engineers, and contractors, and the actual use of CDBG funds during the implementation of a CDBG program. Citizens will also be requested to assess the performance of the City/Town/County in resolving identified community development and housing needs, and in achieving its community development goals and objectives. All citizens, including those in the targeted area, are encouraged to attend to comment on the proposed activities. Formal written complaints or comments concerning the project performance that are submitted to the City/Town/County prior to or following the public hearing will be responded to with fifteen (15) working days by [Date]. Persons with disabilities or whom otherwise need assistance should contact (Insert Name) at (Insert Phone Number) or Relay North Carolina #711 by (late . Accommodations will be make for all whom request assistance with participating in the public hearing. This information is available in Spanish or any other language upon request. Please contact (Insert Name) at (Insert Phone Number) or at (Insert physical location) for accommodations for this request." Esta informacion esta disponible en espafiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con (Insert Name) al (Insert Phone Number) o en (Insert physical location) de alojamiento para esta solicitud. it &WAW logo or tag line "Equal Housing Opportunity" is required Sample Project Amendment Public Hearing Notice The (locality) will hold a public hearing on (date,) at (location) to discuss the proposed project amendment the locality's Community Development Block Grant project, CDBG project number (project number). The New Hanover County CDBG-I Program Manual Page 13 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 22 locality submitted and received the CDBG funds in the amount of $0.00 to conduct (scope of work). The proposed amendment will include (scope of work in amendment). The project and the amendment will still benefit the same % of LMI residents. The locality is interested in obtaining all citizens' input on the proposed project amendment. Citizens will also be requested to assess the performance of the original grant of the (Town/City/County) in resolving identified community development and housing needs, and in achieving its community development goals and objectives. All citizens, including those in the targeted area, are encouraged to attend in order to comment on the accomplished activities. Formal written complaints or comments concerning the project amendment that are submitted to the City/Town/County prior to or following the public hearing will be responded to with fifteen (15) working days by [Date]. Persons with disabilities or whom otherwise need assistance should contact (Insert Name) at (Insert Phone Number) or Relay North Carolina #711 by (late . Accommodations will be make for all whom request assistance with participating in the public hearing. This information is available in Spanish or any other language upon request. Please contact (Insert Name) at (Insert Phone Number) or at (Insert physical location)'for accommodations for this request. Esta informacion esta disponible en espaiiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con (Insert Name) al (Insert Phone Number) o en (Insert physical location) de alojamiento para esta solicitud. 19 logo or tag line "Equal Housing Opportunity" is required Modified Notice of Public Hearing — Application by City/Town/County for Funding Notice is hereby given that the local government conduct an in -person and/or virtual public hearing on at AM/PM, or as soon thereafter as the agenda will allow, at the LOCATION OF IN - PERSON HEARING relative to the intention of the to apply for FY CDBG funding under Title I of the Housing and Community Development Act. The public hearing will be virtual through xxxx and conference call. The live hearing can be accessed at xxxx and the Conference Call -In number is xxxxx and the conference code is xxxxx. The local government intends to submit an application for a grant of approximately $xxxx in CDBG Infrastructure funds to xxxx (project description -must match grant application and include all streets with proposed improvements and any alternative streets if time and budget allows). The following is a tentative list of proposed activities and an estimated budget. The final application will be reviewed at the public hearing. Infrastructure Improvements Activities and Grant Administration Estimated Budget The proposed project will provide benefits to xxx, xxxx% of whom are low and moderate income individuals based on (surveys or statistics) performed by xxx use if surveyed). No individuals will be displaced nor will any require temporary relocation assistance as a result of the proposed project (this phrase may or may not be true for your particular project). Due to public health and safety concerns amid the Executive Order XXX restricting the number of persons allowed to gather in public places the meeting will be CLOSED to the public. New Hanover County CDBG-I Program Manual Page 14 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 23 However, citizens are asked and encouraged to submit written comments on past and proposed use of CDBG funds. All interested citizens are encouraged to participate in the following ways: 1. Present your comments at the public hearing. 2. Send written comments to NAME at LOCATION or at xxxkjzemail. All comments received 24 hours (or less) prior to the hearing will be read into the record. All citizens are encouraged to view and listen to the hearing online via live video at xxxxx; in addition, following the hearing, the recording of the public hearing will be made available. If additional information is needed, please contact the NAME at CONTACT INFORMATION. Formal written complaints or comments concerning the application process that are submitted to the NAME AFTER THE ABOVE WRITTEN COMMENT prior to or following the public hearing will be responded to within fifteen (15) working days by NAME. A copy of the completed project application will be available for public review after xxxx, at the LOCATION (if public building is closed to public, make other accommodations — website, etc.). Persons with disabilities or who otherwise need assistance should contact XXXX, at XXXX or EMAIL ADDRESS, (TDD # XXX or Relay North Carolina XXX) by XXXX Accommodations will be made for all who request assistance with participating in the public hearing. This information is available in Spanish or any other language upon request. Please contact NAME at XXX, or at the XXX for accommodations for this request. Esta informacibn esta disponible en espafiol o en cualquier otro idioma bajo petici6n. Por favor, p6ngase en contacto con NAME, al phone number o en Location, de alojamiento para esta solicitud. Q1 OPPORTUNITY logo or tag line "Equal Housing Opportunity" is required Modified Sample Performance Assessment (Close Out) Public Hearing Notice The City/Town/County will hold an in -person and/or virtual public hearing on (date,) at (location) to discuss the locality's Community Development Block Grant project, CDBG project number (project number) performance and closeout of this project. The public hearing will be virtual through xxxx and conference call. The live hearing can be accessed at xxxx and the Conference Call -In number is xxxxx and the conference code is xxxxx. The above mentioned CDBG project awarded $0.000 to the (locality) on date). The (locality) used the funds to (project scope) which benefited % of low -moderate income citizens. The purpose of this public hearing is to review the performance, expenditures and activities that have been accomplished through the CDBG project. All activities are complete and the locali is in the process of closing the grant with the State of North Carolina. The City/Town/County is interested in obtaining all citizens' input on the performance of local officials, the City/Town/County) staff, consultants and administrators, engineers, and contractors, and the actual use of CDBG funds during the implementation of a CDBG program. Citizens will also be requested to assess the performance of the City/Town/County in resolving identified community development and housing needs, and in achieving its community development goals and objectives. All citizens, including those in the targeted area, are encouraged to participate in order to comment on the accomplished activities. New Hanover County CDBG-I Program Manual Page 15 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 24 Due to public health and safety concerns amid the Executive Order XXX restricting the number of persons allowed to gather in public places the meeting will be CLOSED to the public or attendance will be reduced. However, citizens are asked and encouraged to submit written comments on past and proposed use of CDBG funds. All interested citizens are encouraged to participate in the following ways: 1. Present your comments at the public hearing. 2. Send written comments to NAME at LOCATION or at xxx@gemail. All comments received 24 hours (or less) prior to the hearing will be read into the record. All citizens are encouraged to view and listen to the hearing online via live video at xxxxx; in addition, following the hearing, the recording of the public hearing will be made available. Persons with disabilities or whom otherwise need assistance should contact (Insert Name) at (Insert Phone Number) or Relay North Carolina #711 by date . Accommodations will be make for all whom request assistance with participating in the public hearing. This information is available in Spanish or any other language upon request. Please contact (Insert Name) at (Insert Phone Number) or at (Insert physical location) for accommodations for this request." Esta informacion esta disponible en espafiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con (Insert Name) al (Insert Phone Number) o en (Insert physical location) de alojamiento para esta solicitud. 19 logo or tag line "Equal Housing Opportunity" is required Modified sample Project AMENDMENT Public Hearing Notice The (locality) will hold an in -person and/or virtual public hearing on (date,) at (location) to discuss the proposed project amendment the locality Community Development Block Grant project, CDBG project number (project number). The public hearing will be virtual through xxxx and conference call. The live hearing can be accessed at xxxx and the Conference Call -In number is xxxxx and the conference code is xxxxx. The locality submitted and received the CDBG funds in the amount of $0.00 to conduct (scope of work). The proposed amendment will include (scope of work in amendment). The project and the amendment will still benefit the same % of LMI residents. The locality is interested in obtaining all citizens' input on the proposed project amendment. Citizens will also be requested to assess the performance of the original grant of the (Town/City/CountX) in resolving identified community development and housing needs, and in achieving its community development goals and objectives. All citizens, including those in the targeted area, are encouraged to attend in order to comment on the proposed activities. Due to public health and safety concerns amid the Executive Order XXX restricting the number of persons allowed to gather in public places the meeting will be CLOSED to the public or attendance will be reduced. However, citizens are asked and encouraged to submit written comments on past and proposed use of CDBG funds. All interested citizens are encouraged to participate in the following ways: 1. Present your comments at the public hearing. New Hanover County CDBG-I Program Manual Page 16 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 25 2. Send written comments to NAME at LOCATION or at xxx@gov.com. All comments received 24 hours (or less) prior to the hearing will be read into the record. All citizens are encouraged to view and listen to the hearing online via live video at xxxxx; in addition, following the hearing, the recording of the public hearing will be made available. Persons with disabilities or whom otherwise need assistance should contact (Insert Name) at (Insert Phone Number) or Relay North Carolina #711 by date . Accommodations will be make for all whom request assistance with participating in the public hearing. This information is available in Spanish or any other language upon request. Please contact (Insert Name) at (Insert Phone Number) or at (Insert physical location)'for accommodations for this request. Esta informacion esta disponible en espaiiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con (Insert Name) al (Insert Phone Number) o en (Insert physical location) de alojamiento para esta solicitud. I& logo or tag line "Equal Housing Opportunity" is required Public Hearing Discussion Checklists Application Public Hearing Citizens will be provided with information concerning the CDBG program at this public hearing. Such information shall include, but not necessarily be limited to: ❑ The goals and objectives of the CDBG program ❑ The total amount of CDBG funds available for the fiscal year and for the funding round ❑ The location of the project activities ❑ The range of activities which may be undertaken (Specific project activities to be included) ❑ The approximate cost estimate for the proposed activities ❑ Process to be followed in developing a CDBG application ❑ A statement that 100 percent of the CDBG funds will be used to benefit low -to -moderate income people ❑ The schedule of meetings and hearings ❑ The role of citizens in program planning, implementation, and assessment ❑ Location where the application can be reviewed ❑ Activities previously funded in the (Town/City/County) through the CDBG program New Hanover County CDBG-I Program Manual Page 17 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 26 ❑ An identification of projects which could result in the relocation of area residences or businesses, and the actions that would be undertaken if such relocation were necessary ❑ Provide citizens with contact information such as address, telephone number, and dates for submitting complaints or grievances. ❑ The project application(s) to be submitted and the applicable CDBG fund ❑ The impact of the project on low and moderate income persons ❑ The approximate application submittal date Project Amendment Public Hearing Citizens will be provided with information concerning the CDBG program at this public hearing. Such information shall include, but not necessarily be limited to: ❑ Initial project scope and budget ❑ Reason for amendment ❑ The location of the project activities ❑ The range of activities which may be undertaken (Specific project activities to be included) ❑ The approximate cost estimate for the proposed activities ❑ Process to be followed after public hearing ❑ LMI statement ❑ The role of citizens in program planning, implementation, and assessment ❑ Activities previously, or newly proposed, funded in the (Town/City/County) through the CDBG program ❑ Provide citizens with contact information such as address, telephone number, and dates for submitting complaints or grievances. ❑ The impact of the project on low- and moderate -income persons ❑ The approximate amendment submission date Project Closeout Public Hearing Citizens will be provided with information concerning the CDBG program at this public hearing. Such information shall include, but not necessarily be limited to: ❑ Initial project scope and budget ❑ Any project amendments and change orders New Hanover County CDBG-I Program Manual Page 18 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 27 ❑ Final project financials (CDBG received/expended; deobligated amount, if any; local funds, if any) ❑ Final project accomplishments and performance (description of LF, connections, improvements, etc. and where) ❑ The benefits of the project on low and moderate income persons (LMI statement) This Equal Opportunity Plan is a supplemental policy to the New Hanover County Personnel Policies and Procedures, Article 4 Employment (see Appendix C), solely for New Hanover County's FY2024 CDBG - I Program. Section 109 of Title 1 of the Housing and Community Development Act of 1974; Title VII of Civil Rights Act of 1964, as amended; Section 504 of the Rehabilitation Act of 1973; the Americans with Disabilities Act of 1990; the Age Discrimination Act of 1975; the Equal Employment Opportunity Act; the Immigration Reform and Control Act of 1986; the Vietnam Era Veterans' Readjustment Act of 1974, amended to Jobs for Veterans Act in 2002; Federal Executive Orders 11246, 11625, 12432, and 12138 as amended; Section 3 of the Housing and Urban Development Act of 1968; N.C.G.S. 126-16 (Equal Employment Opportunity); N.C.G.S 143-422.2 (Equal Employment Practice Act); N.C.G.S 168A-5-11 (Handicapped Persons Protection Act); N.C.G.S. 75B 1-7 (Discrimination in Business); N.C.G.S. 95-151(OSHA); N.C.G.S. 95- 28.1; N.C.G.S. 12713-10-15 (Discrimination Against Military Personnel); N.C.G.S. 130A-148(i); N.C.G.S. 126-16; N.C.G.S. 143-48 and 143-128; and all applicable federal and other state regulations. The New Hanover County, as the recipient of federal funding through the Community Development Block Grant (CDBG program, maintains the policy of providing equal employment opportunities for all persons regardless of race, color, creed, religion, sex, national origin, physical or mental disability, age, genetic information, political affiliation, or any other non -merit factor, except where religion, sex, national origin, or age are bona fide occupational qualifications for employment. In furtherance of this policy, the New Hanover County prohibits any retaliatory action of any kind taken by any employee of the locality against any other employee or applicant for employment because that person made a charge, testified, assisted or participated in any manner in a hearing, proceeding or investigation of employment discrimination. New Hanover County shall strive for greater utilization of all persons by identifying previously underutilized groups in the workforce, such as minorities, women, and the handicapped, and making special efforts toward their recruitment, selection, development and upward mobility and any other term, condition, or privilege of employment. Responsibility for implementing equal opportunities and affirmative action measures is hereby assigned to the County Manager to assist in the implementation of this policy statement. The Compliance Coordinator shall develop a self -evaluation mechanism to provide periodic examination and evaluation. Every two years the results of the self -evaluation reporting on the progress of Equal Employment Opportunity and Affirmative Action will be presented, in a format and setting determined by the County, to the Chief Elected Official. Records presented shall be maintained in the files and will be provided to NCDEQ/Division of Water Infrastructure as needed. New Hanover County CDBG-I Program Manual Page 19 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 28 is committed to this policy and is aware that with its implementation, the community will receive positive benefits through the greater utilization and development of all its human resources. The County shall include the Equal Employment Opportunity logo and / or the phrase affirming Equal Employment Opportunity on all the CDBG documents intended to be shared with the staff and the public. The County shall obtain commitment from contractors that they will not discriminate against any employee or applicant for employment because of race, color, religion, sex, national origin, physical or mental disability, age, political affiliation, or any other non -merit factor, except where religion, sex, national origin, or age are bona fide occupation qualifications for employment. Contractors will take affirmative action to ensure that applicants are employed, and that employees are treated during employment without regard to their race, color, religion, sex, national origin, physical or mental disability, age, political affiliation, or any other non -merit factor, except where religion, sex, national origin, or age are bona fide occupation qualifications for employment. Such action shall include, but not be limited to the following: Employment, upgrading, demotion, or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay or other forms of compensation; and selection for training, including apprenticeship. The County shall obtain commitment from Contractors that will, in all solicitations or advertisements for employees placed by or on behalf of the contractor, state that all qualified applicants will receive considerations for employment without regard to race, color, religion, sex, national origin, physical or mental disability, age, political affiliation, or any other non -merit factor, except where religion, sex, national origin, or age are bona fide occupation qualifications for employment. Pursuant to Section 808(e)(5) of the Fair Housing Act, 42 USC §3608(e)(5), requires that HUD programs and activities be administered in an affirmative manner to further the policies of the Fair Housing Act. The Fair Housing Act provides for the protection of the following federally protected classes: 1) Race, 2) Disability, 3) Color, 4) Familial status, 5) Religion, 6) National origin, and 7) Sex. Executive Order 13672 was rescinded on January 21, 2025. However, these protected classes remain codified in 41 CFR and will stay in this manual until such time that the federal regulations are officially repealed or amended. In addition, on March 3, 2025, the Housing and Urban Development Department (HUD) published an interim final rule (effective April 2, 2025) revising HUD's regulation governing the Fair Housing Act's mandate that the Secretary administer HUD's program and activities in a manner that affirmatively furthers fair housing. This interim final rule returns to the original understanding of what the statutory AFFH certification was prior to 1994—a general commitment that grant recipients will take active steps to promote fair housing. Grant recipients AFFH certifications will be deemed sufficient provided they took any action during the relevant period rationally related to promoting fair housing, such as helping eliminate housing discrimination. This interim final rule does not, however, reinstate the obligation to conduct an Analysis of Impediments or mandate any specific fair housing planning mechanism; program participants must continue to affirmatively further fair housing as and to the extent required by the Fair Housing Act. As a subrecipient of CDBG funds, New Hanover County must adopt and publicize an Equal Housing Opportunity Policy and adopt a Fair Housing Policy by ordinance or resolution based on the requirements of the Fair Housing Act to affirmatively further fair housing choices for all seven protected classes. New Hanover County CDBG-I Program Manual Page 20 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 29 Equal Housing Opportunity Policy New Hanover County, as the recipient of federal funding through the Community Development Block Grant (CDBG) Grant program; the Civil Rights Act of 1964 prohibits all racial discrimination in the sale or rental of property; The Fair Housing Act (Act) declares a national policy of fair housing throughout the United States, making illegal any discrimination in the sale, rental and financing of housing, or making dwellings, and in other housing -related transactions, because of race, color, religion, sex, familial status, national origin or disability. In addition, the North Carolina State Fair Housing Act prohibits unlawful discriminatory housing practices for any person in real estate transactions, because of race, color, religion, sex, national origin, handicapping condition, or familial status; unlawful discriminatory housing practice to discriminate in land -use decisions or in the permitting of development based on race, color, religion, sex, national origin, handicapping condition, familial status, or, except as otherwise provided by law, the fact that a development or proposed development contains affordable housing units for families or individuals with incomes below eighty percent (80%) of area median income. New Hanover County hereby endorses a Fair Housing and Affirmatively Furthering Fair Housing Plan and Policy that ensures equal opportunity and fair housing for all persons to rent, purchase, obtain financing and enjoy all other housing attributes, that is affordable, safe, decent, free of unlawful discrimination and accessible as required on a non-discriminatory basis as providedby state and federal statutes and regulations. Furthermore, the County will take meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially or ethically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with the civil rights and fair housing laws. Fair Housing Plan and Policy In accordance with Fair Housing Act, New Hanover County hereby adopts the following policy with respect to the affirmatively furthering fair housing: 1. New Hanover County agrees to affirmatively further fair housing choice for all seven protected classes (race, color, religion, sex, disability, familial status, and national origin). 2. New Hanover County agrees to conduct quarterly activities during the grant contract performance period to affirmatively further fair housing. 3. New Hanover County shall include the Equal Housing Opportunity logo and/or the phrase (tag line) Equal Housing Opportunity on all the CDBG documents intended to be shared with the public. Affirmatively Furthering Fair Housing. The County will undertake quarterly, over the grant contract performance period (grant contract execution to grant closeout date), the following actions to affirmatively further fair housing in their community. The New Hanover County shall amend and revise this plan of quarterly activities to keep current with state and federal fair housing and equal fairing opportunity statutes and regulations, and local actions and activities to further the purposes of this plan. New Hanover County CDBG-I Program Manual Page 21 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 30 This is the County's first time affirmatively furthering fair housing. These activities were identified to inform all county residents of fair housing laws and their rights. Quarterly Fair Housing Actions Steps / Activities Fill in this table with identified quarterly action steps/activities. These activities must be tied to the identified local fair housing needs/interests and attributes based on local means. May delete this row for final plan. Additional rows can be added to the table. Quarterly Fair Housing Action Step / Activity Months Year Estimated Actual Cost Cost Adopt and publicize New Hanover County's Fair Housing 4th Quarter Complaint Procedure in the local newspaper and on / Oct.— 2025 $700 county's website. Dec. Post/display Fair Housing and Equal Housing Opportunity ls` Quarter posters provided by HUD in prominent locations / Jan.- 2026 $150 throughout county. March 2nd Designate April as Fair Housing Month by Proclamation or Quarter / 2026 $0 Resolution. April -June Yd Quarter Place HUD Fair Housing Brochures and NC Fair Housing / July — 2026 $125 Brochures in prominent locations throughout county Sept. 4th Quarter Post Fair Housing information on county's social media / Oct 2026 $0 platforms Dec. Place Fair Housing message on landing page of County's 1st Quarter website / Jan.- 2027 $0 March 2nd County representatives will attend a fair housing training Quarter / 2027 $500 and/or conference (either in person or virtual) April -June New Hanover County CDBG-1 Program Manual Page 22 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 31 Ensure local colleges/universities and schools have 3rd Quarter county's fair housing complaint procedure information for / July — 2027 $100 students. Sept. Ensure / Post/display Fair Housing and Equal Housing 4th Quarter Opportunity posters provided by HUD in prominent / Oct — 2027 $150 locations throughout county. Dec. Place Fair Housing message on landing page of county's 1 s` Quarter website / Jan.- 2028 $0 March 2nd Designate April as Fair Housing Month by Proclamation or Quarter / 2028 $0 Resolution. April -June Post Fair Housing and Complaint Procedure messages are 3rd Quarter shown on county's social media platforms. / July — 2028 $0 Sept. Ensure local colleges/universities and schools have 4th Quarter county's fair housing complaint procedure information for / Oct — 2028 $0 students. Dec. 12Y oWPORTIJNITY logo or tag line "Equal Housing Opportunity" is required New Hanover County will inform and refer New Hanover County residents to submit a discrimination complaint to the state and federal agencies that complete investigations and enforce anti -discrimination laws in North Carolina, such as: • North Carolina Human Relations Commission (NCHRC) • Legal Aid of North Carolina • US Department of Housing and Urban Development (HUD) • US Equal Employment Opportunity Commission (EEOC) • US Department of Justice The New Hanover County has on their website the HUD Housing Discrimination Complaint form. New Hanover County CDBG-I Program Manual Page 23 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 32 Fair Housing Officer (FHO). In accordance with Title VIII, Civil Rights Act of 1968, as amended, New Hanover County is responsible for referring all housing complaints to appropriate state and federal agencies / organizations responsible for handling said housing complaints as well as implementation of the AFFH Plan activities and actions. The New Hanover County and their Compliance Coordinator will refer residents to the county website to complete a housing complaint form (see Appendix D for example) and to submit said complaints to the appropriate federal and state agencies / organizations (HUD, North Carolina Housing Discrimination Section of the Civil Rights Division of NC Office of Administrative Hearings / NC Human Relations Commission). While not expected to be an "expert" in Fair Housing Laws, at a minimum, the County will be familiar with the complaint process and federal and state laws, which address Fair Housing. If the County receives any fair housing discrimination complaints, they will forward those complaints in a timely manner to the appropriate state and federal agencies and record them in the program file. Records will show the date/time received and forwarded and nature of complaint. A separate file will maintain a record of all housing discrimination complaints and any known follow-up actions or decisions on complaints. All referrals should be noted in the fair housing file. Housing Complaint Process. Any person or persons wishing to file a fair housing discrimination complaint in the County may do so by obtaining a complaint form from the county. All complaints are confidential. a. Complaint forms maybe found on the county's website by searching for housing complaint form in the search field or copies of the form can be obtained at the County Government Center. 2. If the County receives or becomes aware of a fair housing complaint is filed with the North Carolina Human Relations Commission (Commission) by county resident, the County will inform the Division of Water Infrastructure about the complaint and forward the received complaint form to the North Carolina Office of Administrative Hearings — Civil Rights Division, Human Relations Commission. 3. The Housing Discrimination Section of the Civil Rights Division will investigate and reconcile all housing discrimination complaints based on events occurring in the County. 4. The County will publicize in the local newspaper with the TDD# and full contact information for the Commission, who will handle fair housing discrimination complaints. A summary of actions which may constitute housing discrimination, and instructions for completing and filing housing discrimination complaints will be made available to citizens at New Hanover County Government Center, 230 Government Center Drive, Room 137, Wilmington, NC 28403. 12y oYPORTUNITY logo or tag line "Equal Housing Opportunity" is required New Hanover County CDBG-I Program Manual Page 24 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 33 Fair Housing Complaint Procedure (for Newspaper) Housing discrimination is prohibited by Title VIII of the Civil Rights Act of 1968 (Fair Housing Act) and the North Carolina Fair Housing Act. To promote fair housing and ensure that the rights of housing discrimination victims are protected, New Hanover County has adopted the following procedures for receiving housing discrimination complaints: 1. Any person or persons wishing to file a fair housing discrimination complaint in the County may do so by obtaining a complaint form from the county. All complaints are confidential. 2. Complaint forms may be found on the county's website by searching for a fair housing complaint form in the search field and / or copies of the form can be obtained at the County Government Center. 3. If the County becomes aware of or receives a fair housing complaint that will be or has been filed with the North Carolina Human Relations Commission (Commission) by a county resident, the County will inform the Division of Water Infrastructure within fifteen (15) working days about the complaint; and forward any received forms within fifteen (15) working days to the NC Office of Administrative Hearings — Civil Rights Division, Human Relations Commission. 4. The Housing Discrimination Section of the Civil Rights Division will investigate and reconcile all housing discrimination complaints based on events occurring in the County. 5. The County will publicize in the local newspaper with the TDD# and full contact information for the Commission, who will handle housing discrimination complaints. It is the policy of New Hanover County to implement the CDBG program to ensure equal opportunity in housing for all persons regardless of religion, race, color, national origin, sex, familial status, or disability. If you have any questions about the process or would like to file a fair housing discrimination complaint please contact the NC Office of Administrative Hearings - Housing Discrimination Section of the Civil Rights Division, 1318 Mail Service Center, Raleigh NC, 27699, Telephone 984-236-1919, Houisng Complaints: HRC.Complaintskoah.nc.gov, or for the hearing impaired, TDD assistance is available at NC Relay 711 and providing the facts and circumstances of alleged discriminatory act or practice. This information is available in Spanish or any other language upon request. Please contact Linda Thompson, Chief Civic Engagement Officer at 910-798-7414 or at lthompsonknhcgov.com for accommodations for this request. Esta informaci6n esta disponible en espahol o en cualquier otro idioma bajo petici6n. Por favor, p6ngase en contacto con Linda Thompson, Chief Civic Engagement Officer al 910-798-7414 o en lthompsonknhcgov.com de alojamiento para esta solicitud. 12Y oYPORTIJNITY logo or tag line "Equal Housing Opportunity" is required New Hanover County CDBG-I Program Manual Page 25 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 34 Violence Against Women Act (VAWA) Certification Pursuant to the Violence Against Women Act (VAWA) Reauthorization Act of 2022, which became effective October 1, 2022, requires CDBG recipients to certify local policies do not interference with residents' Right to Report Crime and Emergencies from One's Home. The certification will confirm that no ordinances, local regulations, or policies adopted by the local government and currently in effect contain any financial or regulatory penalty imposed on property owners or residents as a result of any use of emergency services, or that the local government is actively addressing such local regulations. CDBG-I grants awarded on or after the effective date will be required to: 1) "Report any of their laws or policies, or, as applicable, the laws or policies adopted by subgrantees, that impose penalties on landlords, homeowners, tenants, residents, occupants, guests, or housing applicants based on requests for law enforcement or emergency assistance or based on criminal activity that occurred at a property; and 2) Certify that they are in compliance..." with the VAWA requirements. Therefore, the County shall complete and sign off on the following VAWA Certification form. VAWA Certification As the Compliance Coordinator, it is certified that New Hanover County is in compliance with the Violence Against Women Reauthorization Act of 2022. The Grantee has reviewed its ordinances, local regulations, and policies (collectively referred to as "policies") adopted by the local government and currently in effect, with the following results: ❑N No policies were identified that contain any financial or regulatory penalty imposed on property owners or residents as a result of any use of emergency services. OR The following policies were identified that may contain financial or regulatory penalties imposed on property owners or residents as a result of any use of emergency services. Policy Purpose of Policy Financial or Regulatory Penalty or Potential Penalty) N/A N/A N/A The County commits to re-evaluating and addressing any policies identified above as follows: N/A The County understands that any policies identified above must be re-evaluated and addressed within the grant agreement period. • A summary of efforts to evaluate alternative policies that do not impede the Right to Report Crime and Emergencies from One's Home and a timeline for action on one or more alternatives must be submitted prior to the release of grant funds for construction. • The timeline for implementation of alternative policies is subject to CDBG-I review and approval; grant funds will be placed on hold if the County fails to comply with the requirements of this VAWA certification. Name of Compliance Coordinator Date Policy Review Completed Signature of Compliance Coordinator Date of Certification New Hanover County CDBG-I Program Manual Page 26 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 35 The County will comply with the terms and conditions of federal funding that is awarded and accepted, including, but not limited to, the terms and conditions of the Grant Contract, and the most recent version of the Procurement Policy of the North Carolina Department of Environmental Quality's Water Infrastructure Division, Community Development Block Grant -Infrastructure Program (CDBG-I Program Procurement Policy), attached in Appendix E. As States were advised by Housing and Urban Development (HUD) to develop their own procurement policies, and the CDBG-Infrastructure Program has developed and adopted the attached policy (CDBG-I Program Procurement Policy) as reference for its grantee communities, using portions of 2 CFR Part 200 "Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards," supplemented with NC General Statutes 143-64.31, 143-129, and 143-131; and 24 C.F.R. § 570.489(g), which explicitly prohibit cost plus a percentage of cost and percentage of construction cost methods of contracting. In addition, all purchase orders and contracts shall include any clauses required by Federal Statutes, executive orders, and implementing regulations including the Section 3 clause, per 2 C.F.R. 200.327 (Appendix 11 of Part 200), 24 C.F.R. 570.489 (g), and 24 C.F.R. 570.607. The County, as the subrecipient of Federal CDBG funds, acknowledges its responsibility to and will adhere to the aforesaid CDBG-I Program Procurement Policy of the North Carolina Department of Environmental Quality's Division of Water Infrastructure, will to the extent applicable, follow methods of procurement, procure by contracting with small, minority firms, women's business enterprises, and labor surplus area firms, when those entities offer the best level of knowledge, skills and abilities for professional services, and when those entities offer the knowledge, skills and abilities and are the lowest cost responsive, responsible bidders in building trade and related services. The County will demonstrate contract cost and price awareness and adhere to awarding agency contract provisions (2 CFR Part 200, Appendix II, except for items F and J, which were not adopted by the CDBG- Infrastructure Program, as allowed under 2 CFR Part 200.101(e)(1)). All procurement of goods and services by the County with CDBG grant funds shall be accomplished in accordance with the requirements of the CDBG-I Program Procurement Policy, and HUD implementing regulations at 24 CFR Part 570.489 (g) and (h), which prohibits cost plus a percentage of construction cost method of contracting for services. In addition, all purchase orders and contracts shall include any clauses required by Federal Statutes, Executive Orders, and implementing regulations including the Section 3 clause, per 2 C.F.R. 200.327 (Appendix II of Part 200), 24 CFR 570.489(g), 24 C.F.R. 570.607, or the North Carolina General Statutes Chapter 143 applying to procurement in general by North Carolina municipalities and counties. When Federal and State regulations are different, the more restrictive regulation shall apply to the procurement in question, as outlined in the CDBG-I Program Procurement Policy. The County will adhere to the following guidelines during procurement of goods and services using the Federal CDBG funds: A. In all cases where goods or services are procured based on one bid or proposal received, the County will follow established principles to verify the reasonable cost of the procurement and shall contact the State Agency supervising the grant program before making any contract award New Hanover County CDBG-I Program Manual Page 27 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 36 based on non-competitive negotiation. The County shall follow all noticing and advertising requirements prior to accepting the single source respondent. Written permission from the CDBG-I Program shall be obtained prior to entering into a single source contract. B. Section 3 certified businesses, and historically underutilized businesses, including women -owned and minority -owned enterprises shall be included on bidders' or professional services' lists maintained by the County. Firms shall be solicited for all competitive negotiations, small purchases, and informal and formal bids when such firms are potential competitive sources for goods and services. C. As applicable, appropriate and to the extent consistent with law, the County shall, to the greatest extent practicable under a federal award, provide preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States, Buy American preferences set forth in 2 C.F.R. part 184, for their infrastructure project. The County will adhere to the following guidelines during procurement of professional service contracts for their CDBG-I program/project: A. Professional services shall be procured through the use of Request for Proposals (administrative services) or Request for Qualifications (engineering services). Respondents offering administrative services shall be selected on the basis of the best qualified respondent for the price. Respondents offering engineering services shall be selected on the basis of the best qualified respondent, without regard for price. A written selection procedure shall be used to evaluate respondents, and those records maintained in the procurement files. B. The County shall develop a written scope of work for each service to be awarded on the basis of competitive negotiation, which shall include descriptions of tasks to be completed, project timetables, and an outline of fee proposal requirements. The selected engineering services respondent and the County shall then enter into competitive negotiations to arrive at a mutually agreeable price for engineering services. All contracts awarded through competitive negotiations shall be awarded strictly on the basis of the written selection procedure. The County will adhere to the following guidelines during procurement of construction contacts for their CDBG-I program/project: A. Construction service contracts shall be competitively bid using sealed bids, with the award going to the lowest responsive, responsible bidder. A minimum of three bids shall be received prior to opening the sealed bids. Additionally, the County will adhere to the following guidelines during all procurement involved with their CDBG-I program/project: A. Prior to any contract award, the County shall verify the consultant and/or contractor's eligibility to participate in a federally assisted program. B. No consultant or bidder shall assist in the development of the Request for Proposals, in the Request for Qualifications, nor the construction bid posting in which the consultant or bidder has a direct or indirect interest. C. No consultant or bidder shall assist in the evaluation of proposals or bid packages for contracts in which that consultant or bidder has a direct or indirect interest. The County shall adhere to all applicable Federal and State conflict of interest regulations in making contract awards. New Hanover County CDBG-I Program Manual Page 28 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 37 D. The County shall request references or check references of contractors or firms who are awarded contracts with Federal grant funds and will request a written warranty for all goods and services provided through the small purchase procedure. E. The County shall not award any contract for federally -assisted projects on a contingency or cost- plus -percentage of construction basis. F. The County shall hold a pre -bid meeting and a pre -construction meeting for each construction project bid competitively using CDBG-Infrastructure funds. Evaluation criteria for the bids may add points for attending the pre -bid meeting of contractors, but it is not a prerequisite. New Hanover County was awarded a CDBG-Infrastructure (CDBG-1) grant from the North Carolina Department of Environment Quality (NCDEQ), Division of Water Infrastructure, by virtue of this awarded, New Hanover County is required by the North Carolina Department of Environmental Quality and Section 3 of the Housing and Urban Development Act of 1968 to adopt a Section 3 Action Plan. The Section 3 Action Plan is intended to ensure, to the greatest extent feasible, will provide job training, employment and contracting opportunities generated by the U.S. Department of Housing and Urban Development projects be given to low-income workers of the Section 3 project area, and that contracts for work in connection with this project be awarded to qualified Section 3 Business Concerns. It is the intention of the County to implement its FY2024 CDBG-I Program in accordance with all program regulations including the said Section 3 requirements (Section 3 Action Plan). New Hanover County Section 3 Action Plan. In accordance with 12 U.S.C. 1701u, New Hanover County agrees to implement the following steps, which, to the greatest extent feasible, will provide job training, employment and contracting opportunities for Section 3 workers and Section 3 businesses of the area in which the project is being carried out. A. Pass a resolution adopting this plan as a policy to strive to attain goals for compliance to Section 3 regulations by increasing opportunities for employment and contracting for Section 3 workers and businesses. B. Assign duties related to implementation of this plan to a designated Section 3 Coordinator (Compliance Coordinator). C. Identify projected employment, training, and contracting opportunities as the subrecipient of federal funds and facilitate the training and employment of Targeted Section 3 workers, Section 3 workers and contracting with Section 3 businesses. D. Notify and recruit Section 3 workers and business concerns of potential new employment and contracting opportunities as they are triggered by CDBG grant awards through the use of. public hearings and related advertisements; public notices; bidding advertisements and bid documents; notification to local business organizations such as the Chamber(s) of Commerce, NC Works; local advertising media including public signage; project area committees and citizen advisory boards and meetings; local HUD offices; regional planning agencies; public and private institutions operating within or serving the project area; and all other appropriate referral sources. New Hanover County CDBG-I Program Manual Page 29 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 38 E. Include Section 3 information in procurement solicitations, incorporate Section 3 clauses in contractual documents, and review Section 3 information at the pre -bid meeting and preconstruction conference and then monitor contractor compliance. F. Maintain a list of those eligible Section 3 business concerns for utilization in CDBG funded procurements, notify those businesses of pending contractual opportunities, and make this list available for general grant recipient procurement needs. G. Maintain a list of those persons who have identified themselves as Section 3 workers and contact those persons when hiring/training opportunities are available through either the grant recipient or contractors. H. Require all bidders, and their subcontractors, to submit a written Section 3 Affirmative Action Plan with their bids. In addition, require submission of and monitor all prime contractors and subcontractors' forms and reports to document actual accomplishments and compliance. I. Submit reports as required by HUD or NCDEQ regarding compliance with Section 3 Maintain records, including copies of correspondence, memoranda, reports, contracts, etc., which document that the above action steps have been taken, and any barriers encountered. And submit reports and qualitative information on accomplishments as required. K. To the extent feasible, additional affirmative steps and qualitative efforts will be taken to encourage and utilize Section 3 workers and businesses and to reach employment, training, and contracting numerical benchmarks. Per the Grant Contract, New Hanover County must comply with the provision of Section 504 of the Rehabilitation Act of 1973, as amended and HUD implementing regulations at 24 C.F.R. Parts 8 and 9. The County must complete the Section 504 Self -Evaluation Survey and adopt a Grievance Procedure, as well as complete a Transition Plan, if applicable. These documents cover policies, practices, and physical accessibility and notify affected people that it does not discriminate on the basis of the handicap. Compliance with the plan must be documented, including the information made public and the means used to make it public. The 504 Self -Evaluation Survey is designed to serve as a working guidance tool to help recipients focus on key issues that could affect the accessibility of their programs and practices. In developing answers to the questions, a recipient will be preparing most of the information that Section 504 requires. Use of the checklist should also assist a recipient in pinpointing areas where action is likely to be required to achieve compliance with Section 504. It should be emphasized; however, that this checklist is for reference purposes, and is not intended as a substitute for individual judgment or analysis of the pertinent regulations issued pursuant to Section 504. Any information in this checklist cannot be used as a sole basis for determining compliance with Section 504. New Hanover County CDBG-I Program Manual Page 30 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 39 24 CFR -8.51 Self -Evaluation Survey - Each CDBG subrecipient shall, within one year of July 11, 1988, and after consultation with interested persons, including individuals with handicaps or organizations representing individuals with handicaps: (1) Evaluate its current policies and practices to determine whether, in who!e or in part, they do not or may not meet the requirements of this part; (2) Modify any policies and practices that do not meet the requirements of this part; and (3) Take appropriate corrective steps to remedy the discrimination revealed by the self - evaluation. A CDBG subrecipient that employs fifteen or more persons shall, for at least three years following completion of the evaluation required under paragraph (al(1) of this section, maintain on file, make available for public inspection, and provide to the responsible civil rights official/ upon request: (1) A list of the interested persons consulted; (2) a description of areas examined and any problems identified; and (3) a description of any modifications made and of any remedial steps taken. New Hanover County's Section 504 Self -Evaluation Survey is in Appendix G. Section 504 Non -Discrimination and Grievance Procedure Policy In accordance with 24 CFR Section 8, Discrimination based on Handicap in federally assisted programs and activities oft eh Department of Housing and Urban Development, Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794), and Section 109 of the Housing and Community Development Act of 1974, as amended (42 U.S.C. 5309), New Hanover County hereby adopts the following policy and grievance procedures: Discrimination prohibited. No otherwise qualified individual with handicaps in the United States shall, solely by reason of his or her handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance from the Department of Housing and Urban Development (HUD). 2. New Hanover County does not discriminate on the basis of handicap in admission or access to, or treatment or employment in, its federally assisted programs and activities. New Hanover County's recruitment materials or publications shall include a statement of this policy in 1. above. 4. New Hanover County shall take continuing steps to notify participants, beneficiaries, applicants and employees, including those with impaired vision or hearing, and unions or professional organizations holding collective bargaining or professional agreements with the recipients that it does not discriminate on the basis of handicap in violation of 24 CFR Part 8. 5. For hearing and visually impaired individuals eligible to be served or likely to be affected by the FY2024 CDBG-I program, New Hanover County shall ensure that they are provided with the information necessary to understand and participate in the CDBG-I program. 6. Grievances and Complaints a. Any person who believes she or he has been subjected to discrimination on the basis of disability may file a grievance under this procedure. It is against the law for New Hanover New Hanover County CDBG-I Program Manual Page 31 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 40 County to retaliate against anyone who files a grievance or cooperates in the investigation of a grievance. b. Complaints should be addressed to: Risk Management, Safety Officer / ADA Compliance, 230 Government Center Drive, Suite 125, Wilmington, North Carolina 28404, who has been designated to coordinate Section 504 compliance efforts. C. A complaint should be filed in writing or verbally (alternate methods of communication such as personal interview, tape recording, Braille, etc. are acceptable), contain the name and address of the person filing it, and briefly describe the alleged violation of the regulations, and should include all relevant details including dates, locations, and description of the alleged violation. d. A complaint should be filed within thirty (30) working days after the complainant becomes aware of the alleged violation. e. An investigation, as may be appropriate, shall follow the filing of a complaint. The investigation will be conducted by Safety Officer/ADA Compliance for Risk Management. Informal but thorough investigations will afford all interested persons and their representatives, if any, an opportunity to submit evidence relevant to a complaint. f. A written determination as to the validity of the complaint and description of resolution, if any, shall be issued by Safety Officer/ADA Compliance and a copy forwarded to the complainant with fifteen (15) working days after the filing of the complaint where practicable. g. The Section 504 coordinator shall maintain the files and records of the New Hanover County relating to the complaints files. h. The complainant can request a reconsideration of the case in instances where he or she is dissatisfied with the determination/resolution as described in item f. above. The request for reconsideration should be made to the New Hanover County within ten (10) working days after the receipt of the written determination/resolution. The right of a person to a prompt and equitable resolution of the complaint filed hereunder shall not be impaired by the person's pursuit of other remedies such as the filing of a Section 504 complaint with the U.S. Department of Housing and Urban Development. Utilization of this grievance procedure is not a prerequisite to the pursuit of other remedies. They may also write to the North Carolina Department of Environmental Quality (DEQ), Division of Water Infrastructure (DWI), 1633 Mail Service Center, Raleigh, North Carolina, 27699-1633, Phone: (919) 707-9057, TDD: (800) 735-2962. DEQ will respond only to written comments within ten (10) calendar days of the receipt of the comments. Can also send complaint to the U.S. Department of Justice, Civil Rights Division, 950 Pennsylvania Avenue, NW, Washington, DC, 20530. Telephone 800-514-0301 (voice) or 1-833-610-1264 (TTY). These procedures shall be construed to protect the substantive rights of interested persons, to meet appropriate due process standards and ensure that the New Hanover County complies with Section 504 and HUD regulations. New Hanover County CDBG-I Program Manual Page 32 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 41 This information is available in Spanish or any other language upon request. Please contact Linda Thompson, Chief Civic Engagement Officer at 910-798-7414 or at lthompsongtilicgov.com for accommodations for this request. Esta informacion esta disponible en espaiiol o en cualquier otro idioma bajo peticion. Por favor, pongase en contacto con Linda Thompson, Chief Civic Engagement Officer al 910-798-7414 o en lthompsonktilic og v.com de alojamiento para esta solicitud. This Residential Anti -Displacement and Relocation Assistance Plan is prepared by the County in accordance with the Housing and Community Development Act of 1974, as amended; and HUD regulations at 24 CFR 42.325 and is applicable to the FY2024 CDBG-I Program. Minimize Displacement. Consistent with the goals and objectives of activities assisted under the Act, the County will take the following steps to minimize the direct and indirect displacement of persons from their homes: (The steps provided below are examples only. each jurisdiction must determine the actions it will take based on local needs and prioritiesselect one or multiple steps or describe others steps below) ❑ Coordinate code enforcement with rehabilitation and housing assistance programs. ❑ Evaluate housing codes and rehabilitation standards in reinvestment areas to prevent undue financial burden on established owners and tenants. ❑ Stage rehabilitation of apartment units to allow tenants to remain in the building/complex during and after the rehabilitation, working with empty units first. ❑ Arrange for facilities for persons who must be relocated temporarily during rehabilitation. ❑ Adopt policies to identify and mitigate displacement resulting from intensive public investment in neighborhoods. ❑ Adopt policies which provide reasonable protections for tenants faced with conversion to a condominium or cooperative. ❑ Adopt tax assessment policies, such as deferred tax payment plans, to reduce impact of increasing property tax assessments on lower income owner -occupants or tenants in revitalizing areas. ❑ Establish counseling centers to provide homeowners and tenants with information on assistance available to help them remain in their neighborhood in the face of revitalization pressures. ❑ Where feasible, give priority to rehabilitation of housing, as opposed to demolition, to avoid displacement. ❑ If feasible, demolish or convert only dwelling units that are not occupied or vacant occupiable dwelling units (especially those units which are "lower -income dwelling units" (as defined in 24 CFR 42.305). ❑x Target only those properties deemed essential to the need or success of the project. M Other: (Describe) The County's FY2024 CDBG-I Program is to extend water and connect homes to public service. Frequent communication and outreach will occur throughout the program to ensure there is little to no displacement during the construction phase. Relocation Assistance to Displaced Persons. The County will provide relocation assistance for lower -income tenants who, in connection with an activity assisted under the CDBG Program[s], move permanently or move personal property from real property as New Hanover County CDBG-I Program Manual Page 33 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 42 a direct result of the demolition of any dwelling unit or the conversion of a lower -income dwelling unit in accordance with the requirements of 24 CFR 42.350. A displaced person who is not a lower -income tenant, will be provided relocation assistance in accordance with the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended, and implementing regulations at 49 CFR Part 24. One -for -One Replacement of Lower -Income Dwelling Units. The County will replace all occupied and vacant occupiable lower -income dwelling units demolished or converted to a use other than lower -income housing in connection with a project assisted with funds provided under the CDBG Program[s] in accordance with 24 CFR 42.375. Before entering into a contract committing County to provide funds for a project that will directly result in demolition or conversion of lower -income dwelling units, the County will make public by a block display ad published in the local newspaper and submit to State CDBG Program(s) North Carolina Department of Environmental Quality (NC DEQ) the following information in writing: 1. A description of the proposed assisted project; 2. The address, number of bedrooms, and location on a map of lower -income dwelling units that will be demolished or converted to a use other than as lower- income dwelling units as a result of an assisted project; 3. A time schedule for the commencement and completion of the demolition or conversion; 4. To the extent known, the address, number of lower -income dwelling units by size (number of bedrooms) and location on a map of the replacement lower -income housing that has been or will be provided. [See also 24 CFR 42.375(d)1. 5. The source of funding and a time schedule for the provision of the replacement dwelling units; 6. The basis for concluding that each replacement dwelling unit will remain a lower -income dwelling unit for at least 10 years from the date of initial occupancy; and 7. Information demonstrating that any proposed replacement of lower -income dwelling units with smaller dwelling units (e.g., a 2-bedroom unit with two 1-bedroom units), or any proposed replacement of efficiency or single -room occupancy (SRO) units with units of a different size, is appropriate and consistent with the housing needs and priorities identified in the HUD -approved Consolidated Plan and 24 CFR 42.375(b). To the extent that the specific location of the replacement dwelling units and other data in items 4 through 7 are not available at the time of the general submission, the County will identify the general location of such dwelling units on a map and complete the disclosure and submission requirements as soon as the specific data is available. All occupied and vacant occupiable low/moderate-income dwelling units demolished or converted to a use other than as IOw/moderate-income dwelling units as a direct result of activities assisted under the CDBG program must be replaced with low/moderate-income dwelling units. Substandard but economically repairable units that have been demolished or converted must be replaced under this provision, but more seriously deteriorated units need not be replaced. For purposes of this plan, the fallowing definitions shall apply: • "Vacant Occupiable" or "Suitable for Rehabilitation" means a unit which is no worse than moderate according to the needs gradient scale published in the Application Guidelines, may be brought up to N.C. Small Cities CDBG Housing Rehabilitation Standards for an expenditure of less than $4,000 in rehabilitation costs, and will have an expected useful life of at least 10 years with routine maintenance upon completion of the rehabilitation. In addition, a vacant unit may be classified as New Hanover County CDBG-I Program Manual Page 34 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 43 "not occupiable" if it has been condemned, is condemnable or otherwise unsuitable for human habitation under the local government's housing code or redevelopment plan. "Low- and Moderate -Income Dwelling Units" (Occupied Unitsl means a unit that either is occupied by a low- or moderate -income family or rents for an amount that would be affordable to a low- or moderate -income family (i.e., rent and utilities would not exceed 24% of the median Income for a family that would occupy the unit without overcrowding). "Low- and Moderate -Income Dwelling Units" (Vacant Units) means a unit whose fair market rent would make it affordable to a low- or moderate -income family, as calculated above. If assisted rehabilitation raises the rent of a low/moderate-income unit above the affordable rent level, the unit must be replaced. Replacement low/moderate-income dwelling units must be provided within three years of commencement of the demolition, or the rehabilitation related to the conversation, and must be: • Located within the same jurisdiction • Sufficient in number and size to house at least the number of occupants that could have been housed in the units demolished or converted, as determined in accordance with applicable housing occupancy codes. • Provided in standard condition (a substandard unit raised to standard condition will count). • Designed to remain low/moderate-income dwelling units for at least ten years from the date of initial occupancy of the units (replacement dwellings units may include public housing and existing housing receiving Section 8 project -based assistance). Replacement not Required Based on Unit Availability. Under 24 CFR 42.375(d), the County may submit a request to the State (NC DEQ) for a determination that the one -for -one replacement requirement does not apply based on objective data that there is an adequate supply of vacant lower -income dwelling units in standard condition available on a non-discriminatory basis within the area. Contacts. The Compliance Coordinator is responsible for tracking the replacement of lower income dwelling units and ensuring that they are provided within the required period. The Compliance Coordinator is responsible for providing relocation payments and other relocation assistance to any lower -income person displaced by the demolition of any dwelling unit or the conversion of lower -income dwelling units to another use. This Code of Conduct is a supplemental policy to the 2023 Resolution Adopting a Code of Ethics (see Appendix I), solely for New Hanover County's FY2024 CDBG-I Program. The conflict -of -interest provisions, including but not limited to those found at N.C. General Statutes § 14- 234, 2 C.F.R. § 200.317-318, 320-321, 323-326, 24 C.F.R. § 570.489 (g) and (h), and 24 C.F.R. § 570.611 must be carried out. The conflict of interest provisions of this policy apply to any person who is an employee, agent, consultant, officer, or elected official or appointed official of the recipient, or of any designated public agencies, or subrecipients that are receiving funds. No persons described in this policy who exercise or have exercised any functions or responsibilities with respect to CDBG activities assisted under this part, or who are in a position to participate in a decision - New Hanover County CDBG-I Program Manual Page 35 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 44 making process or gain inside information with regard to such activities, may obtain a financial interest or benefit from a CDBG-assisted activity, or have a financial interest in any contract, subcontract, or agreement with respect to a CDBG-assisted activity, or with respect to the proceeds of the CDBG-assisted activity, either for themselves or those with whom they have business or immediate family ties, during their tenure or for one year thereafter. No employee, officer or agent of the County shall participate in the selection, or in the award or administration of a contract supported by Federal funds if a conflict of interest, real or apparent, would be involved. Such a conflict arises when the employee, official or agent or any member of his/her immediate family, his/ her partner or an organization that employs or is about to employ the above -mentioned, has a financial interest in the firm selected for an award. In addition, the County's officers, employees, or agents will neither solicit nor accept gratuities, favors or anything of monetary value from contractors, potential contractors, or parties to sub agreements except as provided for in N.C.G.S. 133-32. Certain limited exceptions to the conflict of interest rules listed in 24 C.F.R. § 570.489(h) may be granted in writing by Housing and Urban Development (HUD) and/or the State funding agency upon written request and the provision of information specified in 24 C.F.R. § 570.489(h)(4 and (5). The failure to adhere and enforce this policy may cause the New Hanover County to lose its grant or eligibility for future federal grants. This Excessive Force Policy is a supplemental policy to the updated 2024 Excessive Force Provision Standard Operating Policy for the Office of the Sherrif (see Appendix J), for New Hanover County's FY2024 CDBG Program. New Hanover County, as the subrecipient of federal funding through the Community Development Block Grant (CDBG) Grant program, hereby adopts an Excessive Force Policy for this FY2024 CDBG-I Program that is in accordance with Title 1 of the Housing and Community Development Act (HCDA) of 1974, Section 519 of Public Law 101-144, and 1990 HUD Appropriations Act. It is the policy of the County and the Sheriff's Office that excessive force by local law enforcement agencies shall not be used against individuals engaged in lawful and non-violent civil rights demonstrations within their boundaries. The County and the Sherriff's Office will enforce applicable federal, state and local laws against the physical barring of an entrance to or exit from a facility or location which is the subject of nonviolent civil rights demonstrations within its jurisdiction. In addition, the County Sheriff Department will coordinate with the local law enforcement agency(ies) to implement this policy. The failure to enforce such policy may cause the County to lose its grant or eligibility for future federal grants. New Hanover County will follow all applicable laws, rules and regulations concerning the payment of wages, contract work hours, safety, health standards, and equal opportunity for CDBG programs, including but not limited to the rules set forth in 24 CFR § 570.603 and the following (as may be applicable to CDBG- I projects): A. Davis -Bacon Act (40 U.S.C.A. 276a). Among other provisions, this act requires that prevailing local wage levels be paid to laborers and mechanics employed on certain construction work assisted with CDBG funds. New Hanover County CDBG-I Program Manual Page 36 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 45 B. Contract Work Hours and Safety Standards Act (40 U.S.C.A. 327 through 333). Under this act, among other provisions, laborers and mechanics employed by contractors and subcontractors on construction work assisted with CDBG funds must receive overtime compensation at a rate not less than one and one-half the basic rate of pay for all hours worked in excess of forty hours in any workweek. Violators shall be liable for the unpaid wages and in addition for liquidated damages computed in respect to each laborer or mechanic employed in violation of the act. C. Fair Labor Standards Act (29 U.S.C. 201 et seq.), requiring among other things that covered employees be paid at least the minimum prescribed wage, and also that they be paid one and one- half times their basic wage rate for all hours worked in excess of the prescribed workweek. D. Federal anti -kickback laws (18 U.S.C. 874 and 40 U.S.C. 276), which, among other things, outlaws and prescribes criminal penalties for "kickbacks" of wages in federally financed or assisted construction activities. Weekly statements of compliance and weekly payrolls must be provided by all contractors and subcontractors. The Labor Standards Officer will be the Compliance Coordinator with assistance from the Grant Administrator. As a recipient of CDBG federal funds, New Hanover County must adhere to the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA or Uniform Act) and other HUD requirements such as section 104(d) of the Housing and Community Development (HCD) Act provide important protections and assistance for people and businesses affected by a federally funded projecting involving acquisition, rehabilitation, or demolition of real property. The URA was enacted by Congress to ensure fair, uniform, and equitable treatment and just compensation for, and assistance in moving from, the property they own or occupy. The URA establishes minimum federal requirements for real property acquisition and relocation assistance for federally funded projects. The implementation regulations include 24 CFR 570.488, 49 CFR 24.101(b)(1)-(5) and must comply with the full subpart B requirements of 49 CFR part 24, as may be amended The County must: 1. Provide uniform, fair and equitable treatment of persons whose real property is acquired or who are displaced in connection with federally funded projects. 2. Ensure relocation assistance is provided to displaced persons to lessen the emotional and financial impact of displacement. 3. Ensure no individual or family is displaced unless decent, safe, and sanitary housing is available within the displaced person's financial means. 4. Help improve the housing conditions of displaced persons living in substandard housing. 5. Encourage and expedite acquisition by agreement and without coercion. Resources: HUD Real Estate Acquisition and Relocation New Hanover County CDBG-I Program Manual Page 37 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 46 New Hanover County will comply with the requirements of the Build America, Buy America (BABA) Act, 41 USC 8301 note, and all applicable rules and notices, as may be amended, if applicable to the Subrecipient's infrastructure project. Pursuant to HUD's Notice, "Public Interest Phased Implementation Waiver for FY 2022 and 2023 of Build America, Buy America Provisions as Applied to Recipients of HUD Federal Financial Assistance" (88 FR 17001), any funds obligated by HUD on or after the applicable listed effective dates, are subject to BABA requirements, unless excepted by a waiver. The County will ensure all relevant parties comply with the NCDEQ CDBG-I Build America, Buy America guidance document (Appendix M). New Hanover County CDBG-I Program Manual Page 38 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 47 ACS 5-Year Estimates December 2023 New Hanover County LAP New Hanover County CDBG-I Program Manual Page 39 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 48 Table: ACSDT5Y2015.1316001 LANGUAGE SPOKEN AT HOME BY ABILITY TO SPEAK ENGLISH FOR THE POPULATION 5 YEARS AND OVER United States - Census Bureau Note: The table shown may have been modified by user selections. Some information may be missing. DATA NOTES TABLE ID: B16001 SURVEY/PROGRAM: American Community Survey VINTAGE: 2015 DATASET: ACSDT5Y2015 PRODUCT: ACS 5-Year Estimates Detailed Tables UNIVERSE: Po ulation 5 years and over MLA: U.S. Census Bureau. "LANGUAGE SPOKEN AT HOME BY ABILITY TO SPEAK ENGLISH FOR THE POPULATION 5 YEARS AND OVER." American Community Survey, ACS 5-Year Estimates Detailed Tables, Table B16001, https://data.census.gov/table/ACSDTSY2015.B16001?q=new+hanover+county,+nc+B16O01. Accessed on 14 Sep 2025. FTP URL: https://www2.census.gov/programs-surveys/acs/summary_file/2015/data/ API URL: https:Hapi.census.gov/data/2015/acs/acs5 USER SELECTIONS GEOS New Hanover County, North Carolina TABLES B16001 EXCLUDED COLUMNS INone APPLIED FILTERS INone APPLIED SORTS INone PIVOT & GROUPING PIVOT COLUMNS None PIVOT MODE Off ROW GROUPS None VALUE COLUMNS None data.census.gov I Measuring America'sBwmb,cpra siggq � A�r 20, 2025 Table: ACSDT5Y2015.1316001 WEB ADDRESS https://data.census.gov/table/ACSDT5Y2015.B16001?q=new+hanover+county,+nc+B16001 TABLE NOTES Supporting documentation on code lists, subject definitions, data accuracy, and statistical testing can be found on the American Community Survey website in the Data and Documentation section. Sample size and data quality measures (including coverage rates, allocation rates, and response rates) can be found on the American Community Survey website in the Methodology section. Tell us what you think. Provide feedback to help make American Community Survey data more useful for you. Although the American Community Survey (ACS) produces population, demographic and housing unit estimates, it is the Census Bureau"s Population Estimates Program that produces and disseminates the official estimates of the population for the nation, states, counties, cities and towns and estimates of housing units for states and counties. data.census.gov I Measuring America'sB��mb,clPra _i 0 20, 2025 Table: ACSDT5Y2015.B16001 Explanation of Symbols: * An "**" entry in the margin of error column indicates that either no sample observations or too few sample observations were available to compute a standard error and thus the margin of error. A statistical test is not appropriate. * An "-" entry in the estimate column indicates that either no sample observations or too few sample observations were available to compute an estimate, or a ratio of medians cannot be calculated because one or both of the median estimates falls in the lowest interval or upper interval of an open-ended distribution. * An "-" following a median estimate means the median falls in the lowest interval of an open-ended distribution. * An "+" following a median estimate means the median falls in the upper interval of an open-ended distribution. * An "***" entry in the margin of error column indicates that the median falls in the lowest interval or upper interval of an open-ended distribution. A statistical test is not appropriate. * An "*****" entry in the margin of error column indicates that the estimate is controlled. A statistical test for sampling variability is not appropriate. * An "N" entry in the estimate and margin of error columns indicates that data for this geographic area cannot be displayed because the number of sample cases is too small. * An "(X)" means that the estimate is not applicable or not available. Estimates of urban and rural population, housing units, and characteristics reflect boundaries of urban areas defined based on Census 2010 data. As a result, data for urban and rural areas from the ACS do not necessarily reflect the results of While the 2011-2015 American Community Survey (ACS) data generally reflect the February 2013 Office of Management and Budget (OMB) definitions of metropolitan and micropolitan statistical areas; in certain instances the names, codes, and boundaries of the principal cities shown in ACS tables may differ from the OMB definitions due to differences in the effective Methodological changes to data collection in 2013 may have affected language data for 2013. Users should be aware of these changes when using multi -year data containing data from 2013. For more information, see: Language User Note. data.census.gov I Measuring America'Pp�r�1ljCpfflpr��r 20, 2025 Table: ACSDT5Y2015.B16001 Data are based on a sample and are subject to sampling variability. The degree of uncertainty for an estimate arising from sampling variability is represented through the use of a margin of error. The value shown here is the 90 percent margin of error. The margin of error can be interpreted roughly as providing a 90 percent probability that the interval defined by the estimate minus the margin of error and the estimate plus the margin of error (the lower and upper confidence bounds) contains the true value. In addition to sampling variability, the ACS estimates are subject to nonsampling error (for a discussion of nonsampling variability, see Accuracy of the Data). The effect of nonsampling error is not represented in these Source: U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates COLUMN NOTES None data.census.gov I Measuring America'Pp r pfipfopr � A�r 20, 2025 Table: ACSDT5Y2015.B16001 New Hanover County, North Carolina Label Estimate Margin of Error Total: 201,810 ±106 Speak only English 186,479 ±1,137 Spanish or Spanish Creole: 9,990 ±780 Speak English "very well" 4,747 ±554 Speak English less than "very well" 5,243 ±688 Vietnamese: 468 ±284 Speak English "very well" 115 ±103 Speak English less than "very well" 353 ±245 Other Asian languages: 716 ±453 Speak English "very well" 412 ±300 Speak English less than "very well" 304 ±352 Chinese: 497 ±266 Speak English "very well" 280 ±142 Speak English less than "very well" 217 ±211 French (incl. Patois, Cajun): 535 ±172 Speak English "very well" 370 ±124 Speak English less than "very well" 165 ±124 Korean: 230 ±136 Speak English "very well" 88 ±57 Speak English less than "very well" 142 ±97 Portuguese or Portuguese Creole: 305 ±179 Speak English "very well" 176 ±96 data.census.gov I Measuring America'sB��mb,clPra � �r 20, 2025 Table: ACSDT5Y2015.1316001 New Hanover County, North Carolina Label Estimate Margin of Error Speak English less than "very well" 129 ±136 Greek: 352 ±192 Speak English "very well" 261 ±148 Speak English less than "very well" 91 ±80 Gujarati: 139 ±154 Speak English "very well" 72 ±93 Speak English less than "very well" 67 ±71 German: 484 ±184 Speak English "very well" 435 ±177 Speak English less than "very well" 49 ±44 Russian: 217 ±142 Speak English "very well" 173 ±125 Speak English less than "very well" 44 ±39 Japanese: 37 ±39 Speak English "very well" 12 ±15 Speak English less than "very well" 25 ±30 Hindi: 43 ±45 Speak English "very well" 20 ±33 Speak English less than "very well" 23 ±33 Polish: 28 ±32 Speak English "very well" 14 ±23 data.census.gov I Measuring America's0wmb,clPra sigbq c6 Ai r 20, 2025 Table: ACSDT5Y2015.B16001 New Hanover County, North Carolina Label Estimate Margin of Error Speak English less than "very well" 14 ±22 Italian: 98 ±75 Speak English "very well" 87 ±69 Speak English less than "very well" 11 ±13 Other West Germanic languages: 72 ±76 Speak English "very well" 64 ±76 Speak English less than "very well" 8 ±13 Scandinavian languages: 33 ±33 Speak English "very well" 24 ±28 Speak English less than "very well" 9 ±13 Persian: 49 ±43 Speak English "very well" 45 ±38 Speak English less than "very well" 4 ±8 Other Indic languages: 49 ±59 Speak English "very well" 33 ±47 Speak English less than "very well" 16 ±27 Other Indo-European languages: 54 ±45 Speak English "very well" 34 ±34 Speak English less than "very well" 20 ±28 Tagalog: 385 ±248 data.census.gov I Measuring America'sBwmb,clPra sigbq � A�r 20, 2025 Table: ACSDT5Y2015.B16001 New Hanover County, North Carolina Label Estimate Margin of Error Speak English "very well" 353 ±243 Speak English less than "very well" 32 ±28 Other Pacific Island languages: 44 ±45 Speak English "very well" 31 ±39 Speak English less than "very well" 13 ±20 Arabic: 129 ±112 Speak English "very well" 107 ±92 Speak English less than "very well" 22 ±24 Hebrew: 74 ±64 Speak English "very well" 64 ±63 Speak English less than "very well" 10 ±16 data.census.gov I Measuring America'Pp�r�1ljCpfflpr��r 20, 2025 O o o I K 1, ---Ml �' i i ("A i, IT, 84 `— s irsi�stiitn NEW HANOVER COUNTY EL CONDADO DE NEW HANOVER DECEMBER 2023 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 57 Why Language Access? "Language access" means providing individuals with limited English proficiency (LEP) meaningful access to the same services as English-speaking individuals. A language access plan (LAP) for New Hanover County is a critical tool to ensure residents with limited English proficiency can connect with and have access to vital community services and information. An efficient and effective language access plan will also guide county staff and internal stakeholders on best practices for assisting residents with limited English proficiency and serve as a model for inclusive customer service across the organization. New Hanover County's mission is to provide equitable opportunities and exceptional public services through good governance to ensure a safe, healthy, secure, and thriving community for all. To achieve this, county services and resources must be equitable and accessible to all. The creation of a language access plan will not only increase access to county resources but will bring the community together through better understanding, engagement, and empowerment. A language access plan also ensures compliance with federal, state, and local laws and regulations. These laws, such as Title VI of the Civil Rights Act of 1964, Section 1557 of the Affordable Care Act, require government entities that receive federal funds to provide language assistance services to individuals with limited English proficiency to avoid national origin discrimination and to provide meaningful access to county resources, essential services, and vital information. Introduction and Purpose In 2023, New Hanover County was selected to participate in the 2023 Local Government Language Access Collaborative by UNC-Chapel Hill's Institute for the Study of the Americas, an initiative that brings together local governments and community -based organizations to build inclusive practices and policies related to language access. Relationship -building between residents, local governments, and community partners through the Language Access Collaborative sets an example and encourages language access service expansion throughout the county. Cape Fear Latinos is New Hanover County's community partner, a grassroots non-profit organization that works with the Hispanic/Latino community in and around New Hanover County. This collaboration will help build trust in communities that often feel overlooked and connect individuals and families to resources that will help build sustainable and successful futures. A language access plan put into action will ensure that residents have the right resources and information at the right time to make informed decisions that impact their health, safety, and well-being. This plan will address and outline our efforts to empower individuals with limited English proficiency and enable them to fully engage with and access services throughout the county. Through consistent monitoring and updating of this LAP, the county will better serve and understand the needs of residents and improve the accessibility of services and resources. Further, New Hanover County will ensure it moves towards policies and procedures supporting the right of all residents to communicate within the language they prefer and provide resources to county staff to meet residents' diverse needs. Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 58 Organization(s) / Individuals Affected This policy applies to all New Hanover County departments and agencies. Training for language access will include training in language services, cultural sensitivity, and customer service to help staff deliver effective and efficient language access services to individuals with limited English proficiency. The training will be delivered via a blended approach, using a variety of tools, such as new employee orientation as well as in -person, classroom -style training, and online webinars designed to enhance skills, including the language skills of our employees. Definitions • Bilingual/multilingual staff: Bilingual staff refers to individuals who are proficient in speaking two languages. Multilingual staff refers to individuals who are fluent in more than two languages. Both bilingual and multilingual staff play a crucial role in language access initiatives. • Interpretation: Is the act of facilitating communication between individuals or groups who speak or sign in different languages. It involves the oral rendering of spoken words of one language into another language in real-time, allowing for effective communication. • Language Access: Language Access refers to the provision of language services and resources to ensure effective communication between individuals with limited English proficiency (LEP) and those who speak English fluently. It involves implementing measures to overcome language barriers and to ensure that language is not a barrier to accessing important information and services. • Language Access Plan (LAP): A set of policies and procedures established to provide the most effective services for those with limited English proficiency. • Limited English Proficiency (LEP): LEP refers to individuals who have a limited ability to understand, speak, read, or write in the English language. These individuals may have a primary language other than English or have a limited command of English due to factors such as immigration, language barriers, or educational background. • Meaningful Access: Refers to the concept of ensuring that individuals can fully and effectively engage in a certain activity or process. It entails removing barriers and implementing practices that allow individuals to understand and engage in the process without limitations or discrimination. • Preferred Language: This is the language that an individual chooses to use for communication purposes. It is the language in which they feel most comfortable, proficient, and able to convey their thoughts, ideas, and needs effectively. • Qualified interpreter or translator: A qualified interpreter or translator is an individual who possesses the necessary skills, proficiency, and expertise to convey information accurately and effectively from one language to another. In both cases, qualifications can be demonstrated through education, certification, training, experience, and ongoing professional development. • Translation: The process of converting written communication from one language into another, while maintaining the meaning, tone, style, and intent of the original text or speech. It involves a skilled translator who possesses a deep understanding of both the source language (the language of original content) and the target language (the language the content is being translated into). • Title VI of the 1964 Civil Rights Act: Prohibits discrimination based on race, color, or national origin by entities that receive federal financial assistance. As explained in Executive Order 13166, a person may not be discriminated against because they are not proficient in the English language due to their national origin. Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 59 Vital Document: Refers to a document that holds crucial information and requires translation or interpretation services to ensure effective communication between individuals who speak different languages. These documents are often related to legal, medical, emergency, or government matters where accurate and clear communication is essential to protect the rights, safety, and well-being of individuals with limited English proficiency or non-native speakers. Assessment New Hanover County will identify strategic languages to be addressed by this plan using collected data and assessments, the four -factor analysis, and the safe harbor parameters as listed below. Four -factor Analysis' • Number of individuals with limited English proficiency (LEP) served or encountered in the eligible service populations • The frequency with which individuals with limited English proficiency come in contact with the recipient's program, activity, or service • The nature and importance of the recipient's program, activity, or service • The resources available to the recipient and costs Safe Harbor Parameters • 5% (or 1,000 residents, whichever is less) of the population eligible to be served or likely to be affected or encountered • If there are fewer than 50 people in a language group that reaches the 5% trigger above, the recipient can request oral interpretation of vital documents, free of cost. These factors create a picture of the needs of the community and priority areas that the county needs to address first. The greater the number of individuals with limited English proficiency, the greater the frequency of contact with county services, and the greater the importance of the service, the more likely language services will be needed. The guidance provided helps to create an indicator and a formal threshold by which language access policy and procedure can be formed. Through regular data and trend assessment, language access demands can be monitored and improved based on changing community demographics. In developing the Language Access Plan (LAP), New Hanover County staff completed a departmental needs assessment, gathered information from stakeholder groups, and reviewed language assistance services. Details and findings from these assessments are outlined below. Departmental Assessment The Offices of Diversity & Equity and Communications & Outreach submitted an internal survey to all departments about language access and resources. Sample survey questions and key findings are listed below: Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 60 What are the most frequently encountered non-English languages by your department and how often do these encounters occur? (Please select one: Frequently, Often, Occasionally, Rarely or Never) NON-ENGLISH LANGUAGE IDENTIFIED* FREQUENCY OF REQUESTS Spanish Frequently ASL Often Chinese Occasionally Mandarin Occasionally Portuguese Occasionally Russian Occasionally Japanese Occasionally Vietnamese Occasionally Arabic Occasionally Korean Occasionally *More languages were identified by departments in the survey responses, but all fell within the "Rarely" or "Never" category rankings. How does your department interact with the public and individuals who prefer languages other than English? TOP COMMUNICATION METHODS (ranked in descending order) Telephonic interpreter (Language Line) Bilingual staff (not certified as an interpreter) Translated written documents or signage (e.g., notices/tools on how to identify language service needs, notices of eligibility translated into languages other than English) Electronic communications in languages other than English (can include social media, website, and other digital promotions) Events and services are promoted through non -English-speaking media (can include social media, website, outreach to local organizations, and other digital promotions) Staff interpreter (verbal communication) Staff translator (written communication) Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 61 In -person contract interpreter/translator and/or Language Service organization Video interpreter Most county departments identified a resource or process for meeting the needs of individuals with limited English proficiency, with the Language Line reported as the most used tool. Many departments use bilingual staff for assistance, but only a few have embedded qualified interpreters or translators on staff. Translation of vital documents is available to all county departments, either through county staff, a contracted, professional service, or pre-existing materials from state or federal partners, but more work can be done to improve the number of documents accessible to individuals with limited English proficiency. Stakeholder Engagement The collaboration between New Hanover County and Cape Fear Latinos in the Language Access Collaborative aims to enhance communication and accessibility services for the community. As a part of this collaboration, Cape Fear Latinos conducted a survey aimed at capturing language proficiency data in the Hispanic/Latino community and gauging the community's sentiments regarding the services and communication provided by New Hanover County. This information helps New Hanover County understand the language needs of our community and implement inclusive language access policies. Throughout this collaboration with Cape Fear Latinos and internal initiatives, issues have been identified that will be addressed in part by this plan. Resolving these issues will improve language access and support for the LEP population. Key findings from Cape Fear Latinos are highlighted below. Cape Fear Latinos has identified a gap in the availability of interpreters which can hinder effective and timely communication between service providers and individuals with limited English proficiency. This highlights the importance of recruiting and providing trained interpreters to bridge the language gap and ensure accurate understanding and effective services. It was noted by Cape Fear Latinos that many individuals with limited English proficiency have had issues with the Language Line, causing more confusion than assistance. This highlights the need for further evaluation and improvement of language access technologies and services. Clear guidelines, training, and user-friendly systems can help minimize confusion and ensure smooth communication. • It has also been identified that documents and forms are not always available in Spanish or other strategic languages. This creates an additional barrier for individuals with limited English proficiency who may have difficulty understanding information provided in English. Addressing this gap involves ensuring that essential documents, such as forms, notices, and instructions, are provided in strategic languages to facilitate access to vital information and services. These identified barriers highlight the ongoing challenges that the LEP population faces in accessing services. It is crucial to continue collaborating between Cape Fear Latinos, New Hanover County, and any other community stakeholders to implement necessary measures that address these gaps. The collaboration between New Hanover County and Cape Fear Latinos in creating a language access plan exemplifies a shared commitment to inclusivity, effective communication, and community engagement. Through this partnership, New Hanover County is actively working to bridge language barriers, improve accessibility to services, and create a supportive environment for all individuals in the community. Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 62 Language Data Collection Data is collected from a variety of sources to capture the full picture of individuals with limited English proficiency and the need for language access in New Hanover County. Sources used to inform this plan include data from the U.S. Census Bureau's American Community Surveys and 2020 Census, New Hanover County 911 Communications, New Hanover County internal surveys and customer service records of Language Line usage, New Hanover County Schools, University of North Carolina Wilmington, Novant Health, Cape Fear Latinos, and other community -based organizations and partners. There are more than 51 languages spoken in New Hanover County. Based on internal and external data sources, the most common non-English languages spoken in New Hanover County are Spanish, Chinese, Mandarin, Portuguese, Vietnamese, Arabic, Japanese, Korean, and Russian. New Hanover County also includes American Sign Language (ASL) as an identified language need based on population data from these sources. AMERICAN COMMUNITY SURVEY, 2021 (Five -Year Data) Limited English Proficiency Households in New Hanover County PRIMARY LANGUAGE SPOKEN IN HOUSEHOLD TOTAL RESIDENTS PERCENTAGE OF TOTAL POPULATION Spanish 3,884 4% Other Indo-European languages 2,057 2.10% Asian and Pacific Island languages 908 0.90% Other languages 321 0.30% LANGUAGE LINE USAGE, 2020-2023 Languages Requested by Residents within New Hanover County Government LANGUAGE REQUESTED BY RESIDENT PERCENTAGE OF TOTAL REQUESTS Spanish 71.08% Arabic 8.3% Portuguese 7.18% Vietnamese 3.29% Swahili 1.86% Burmese 1.69% Pashto 1.51% Russian, Kinyarwanda, Korean, Mandarin, Karen, Hindi, Portuguese Brazilian, Haitian Creole, Cantonese, French, Urdu Less than 1% Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 63 Strategic Languages New Hanover County's primary language spoken in LEP households is Spanish, based on data collected from the above sources and ongoing monitoring of community needs. American Sign Language (ASL) interpretation is also identified as a communication need to be addressed in this plan. Language Access Policy New Hanover County will ensure individuals with limited English proficiency have meaningful access to benefits, programs, and services provided by the county, aligning with the county's mission to provide equitable opportunities and exceptional public service. County departments and staff will let individuals with limited English proficiency know they have the right to language services at no cost to the resident requesting assistance. Notices of this right will include information about available language services and will be provided in a variety of ways, including, but not limited to the county's website, NHCty public television channel, social media, local community organizations and agencies, public statements, brochures, signage, and posters within county facilities. Language Access Resources To facilitate this policy, New Hanover County has several resources readily available for employees to assist residents with additional communication needs. Language Line The Language Line is available at all customer -facing facilities to provide access to live interpreters in 240 languages. Once connected through a phone line, an interpreter will interpret for the customer and the employee throughout the encounter. Employees serving customers who are deaf or hard of hearing will have access to sign language video interpretation through an app, facilitated by trained staff at the following locations: SIGN LANGUAGE VIDEO INTERPRETATION SERVICES, New Hanover County Government Access Locations COUNTY FACILITY DEVICE LOCATION Government Center 230 Government Center Drive Wilmington, NC 28403 Health and Human Services 1650 Greenfield Street Wilmington, NC 28401 Sheriff's Office 3950 Juvenile Center Road Castle Hayne, NC 28429 Downtown Register of Deeds 320 Chestnut Street Wilmington, NC 28401 Customer Service Counter, first floor First floor, front desk reception Detention Division, front desk Register of Deeds' office Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 64 Northeast Library 1241 Military Cutoff Road Reference desk Wilmington, NC 28405 Downtown Library 201 Chestnut Street Reference desk Wilmington, NC 28401 Pine Valley Library 3802 College Road Reference desk Wilmington, NC 28412 Pleasure Island Library 1401 N. Lake Boulevard, #72 Reference desk Carolina Beach, NC 28428 Cape Fear Museum 814 Market Street Front desk/lobby area Wilmington, NC 28401 Senior Resource Center 2222 South College Road Front desk/lobby area Wilmington. NC 28403 In -person Interpretation New Hanover County will make its best effort to ensure timely access to in -person, professional interpretation services at county facilities and public meetings. On -site multilingual staff are available at the New Hanover County Government Center, Sheriff's Office, and Health and Human Services facility. Individuals with limited English proficiency may request interpretation for public meetings, small group meetings, or one-on-one interactions with county staff. Such requests should be made at least 48 hours in advance to ensure adequate time to arrange for interpreter services and can be submitted by staff to the Language Access Coordinator for confirmation. Family members, friends, or minors should not be used as interpreters if the LEP individual declines services offered by New Hanover County as the use of such a person would compromise the effectiveness of services or violate the LEP individual's confidentiality. Bilingual/Multilingual Staff Currently, on -site bilingual/multilingual staff are available at the New Hanover County Government Center, Sheriff's Office, and Health and Human Services facility. Approved county bilingual/multilingual staff must demonstrate an ability to: • Fluently and effectively communicate in both English and the primary language of the LEP individual • Have a basic knowledge of specialized terms and concepts used frequently in the provision of county services • Understand the obligation to maintain confidentiality • Understand the roles of interpreters and the ethics associated with being an interpreter New Hanover County has a bilingual/multilingual hiring preference for positions that provide direct, critical services to individuals with limited English proficiency and these positions are advertised to attract Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 65 bilingual/multilingual candidates. Prior to becoming a New Hanover County employee, a bilingual/multilingual candidate shall be tested to ensure that are competent in each identified language. Bilingual/multilingual employees may receive additional remuneration if interpreter duties fall outside of their everyday responsibilities. Compensation for interpretation services performed by qualified employees is determined by Human Resources. Translation New Hanover County will ensure the proactive translation of vital written documents into identified strategic languages or frequently encountered languages of LEP groups served or likely to be affected by the benefit, program, or service. The determination of what documents are considered "vital" is left to the discretion of individual departments, which are in the best position to evaluate their circumstances and services within their language access planning materials. Documents that may be considered "vital" may include, but are not limited to: • Claim or application forms, release, administrative complaints, or waiver forms • Public outreach or educational materials (including web -based material) • Emergency preparedness information for the public • Letters or notices pertaining to policy changes • Written notices of rights, denial, loss, or decreases in benefits or services, or hearings • Forms or written material related to individual rights • Notices of community meetings or other community outreach • Notices regarding the availability of language assistance services provided by the component at no cost to individuals with limited English proficiency Official translation requests should be submitted to the Language Access Coordinator for assessment and routing to internal or professional services. Departments will incur any additional costs for translation requests that are routed to professional services. Language Access Coordinator The Language Access Coordinator will help bridge language barriers and ensure effective communication across various departments and agencies within New Hanover County. The coordinator oversees and implements the language access plans and policies. They also assess the current language needs of New Hanover County and develop strategies to effectively communicate with individuals with limited English proficiency, including but not limited to: • Coordination of interpreter services for language -dependent interactions between agency staff and individuals with limited English proficiency • Ensure compliance across the agency with Title VI LEP standards and other federal, state, and local regulations • Oversee the translation of key documents, forms, and informational materials into multiple languages to ensure accessibility for individuals with limited English proficiency • Coordinate and implement community outreach and communication efforts to inform the public of language access resources • Serve as the main point of contact for language -related inquiries and concerns within the agency Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 66 Overall, the Language Access Coordinator is responsible for facilitating effective communication, identifying, and addressing language barriers, and improving access to government services for individuals with limited English proficiency. Their work contributes to creating a more equitable experience for diverse members of the community in their interactions with government agencies. Resolving Complaints New Hanover County will make all reasonable modifications to policies and programs to ensure that individuals with limited English proficiency have an equal opportunity to enjoy all county programs, services, and activities. Any person who believes they have been mistreated by an unlawful discriminatory practice has a right to file a formal complaint with New Hanover County. Complaints may be sent by email, mail, or dropped off in person to the Office of Diversity and Equity. Complaints must be filed within 180 days following the alleged discrimination occurrence. New Hanover County will follow the established complaint procedures and will document actions taken to resolve each complaint promptly. Title VI Compliance Office of Diversity & Equity Linda Thompson, Chief Diversity & Equity Officer Ihompson@nhcgov.com 3t11sA: -*aKA§[! ADA Compliance County Attorney's Office - Risk Management Franklin Juarez, Safety Officer fivarez@nhcgov.com 910-798-7037 Language Access Coordinator Office of Diversity & Equity (pending) Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 67 References • Title VI of the Civil Rights Act of 1964 https://www.justice.gov/crt/fcs/TitleV[ • Section 1557 of the Patient Protection and Affordable Care Act, Health and Human Services https://www.hhs.gov/civil-rights/for-individuals/section-1557/index.html • Executive Order 13166 https://www.0ustice.gov/crt/executive-order-13166 • Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, Department of Justice https://www.iustice.gov/media/1052766/dl?inline • Frequently Asked Questions on the Final LEP Guidance, Housing and Urban Development https://www.hud.gov/program offices/fair housing equal opp/promotingfh/lep-fag • Stafford Act, Federal Emergency Management Agency https://www.fema.gov/sites/default/files/documents/fema Stafford act 2021 voll.pd f • Americans with Disabilities Act https://www.ada.gov/law-and-regs/title-ii-2010- regulations/ • Section 504, Rehabilitation Act of 1973 https://www.dol.gov/agencies/oasam/centers- offices/civil- rights-center/statutes/section-504-reha b i I itation-act-of-1973 • U.S. Department of Justice, "Guidance to Federal Financial Assistance Recipients regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons," The Federal Register, June 6, 2022, https://www.federalregister.gov/documents/2002/06/18/02- 15207/guidance-to-federal-financial- assistance-recipients-regarding-title-vi-prohibition-against- national. • Language Access Assessment and Planning Tool for Federally Conducted and Federally Assisted Programs. U.S. Department of Justice. https://www.lep.gov/resources/2011 Language Access Assessment and Planning Tool.pdf • Building Integrated Communities 2023, UNC-Chapel Hill's Institute for the Study of the Americas. https://migration.unc.edu/ Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 68 Intentionally left blank New Hanover County CDBG-I Program Manual Page 40 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 69 EEO Plan and Policy for New Hanover County New Hanover County CDBG-I Program Manual Page 41 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 70 NEW HANOVER COUNTY PERSONNEL POLICIES & PROCEDURES ARTICLE 4: EMPLOYMENT 4.0 Purpose and Applicability In establishing and following employment policies, the County strives to attract, select and employ the most qualified and best suited candidates for position vacancies, all the while fostering and promoting equal employment opportunity. These policies apply to all applicants and employees applying for the position. 4.1 Policy It is the policy of the County to employ according to merit and fitness. To that end, it will be the practice of the County to use all available means to attract qualified candidates for employment, and to make such investigations and examinations as are deemed appropriate to fairly assess the aptitude, education and experience, knowledge and skills, abilities, character and other standards required for positions in the service of the County. 4.2 Equal Employment Opportunity Policy New Hanover County is committed to maintaining a work environment that is free of discrimination. In accordance with employment discrimination law, the County prohibits any supervisor, employee, agent or customer of the County from discriminating against any individual on the basis of race, sex (including gender identity and sexual orientation), color, religion, national origin, age, pregnancy or disability. Personnel decisions (including decisions affecting hiring, promotion, work assignments, disciplinary actions, receipt of benefits, or participation in organization -sponsored programs) shall not be based on an individual's protected status. Any applicant for employment or any employee who believes a personnel decision was based on their protected status may contact Human Resources. All complaints of unlawful workplace harassment, including sexual harassment, will be investigated promptly and where necessary, immediate appropriate action will be taken to stop and remedy any such conduct. Any supervisor, agent or employee found in violation of this policy is subject to disciplinary action, including dismissal. 4.3 Recruitment Procedures As a position becomes vacant, the hiring department will submit a requisition to fill the vacancy to the Human Resources Department for review and approval by the Chief Human Resources Officer. The Chief Human Resources Officer may approve filling casual part-time or temporary position vacancies, after determining the hiring department has sufficient funds in its budget to support the position. Upon approval to fill position vacancies, the Human Resources Department will publicize employment opportunities by posting position vacancies on the County website and through other recruitment sources to reach as wide a geographic area as is necessary to attract a Established: May 1977 Article 4 - Employment Page 1 Last Revised: November 16, 2020 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 71 NEW HANOVER COUNTY PERSONNEL POLICIES & PROCEDURES good pool of well -qualified applicants from both the general population of potential applicants and protected group minority applicants. A hiring department may request that a recruitment opportunity be open only to departmental employees (intra-departmental recruitment announcement) or to County employees (interdepartmental recruitment announcement). If approved by the Chief Human Resources Officer, the position vacancy will be advertised in the appropriate department(s) and those County employees who may apply must submit a completed County application form in a timely manner. Applications will be processed by the Human Resources Department and appointments will be made in the same manner as outlined in the above sections. Recruitment announcements will include a description of the available position(s), the minimum qualifications required and preferred, salary information, and application instructions. Also, they will contain assurances of equal employment opportunity with the County. 4.4 Employment Applications All persons expressing interest in employment with the County will be given the opportunity to file an application for any position for which applications are being advertised and received at that time. An application must be filed for each advertised position vacancy for which an individual wants to be considered. The County does not maintain general applications or resumes for use with future advertised position vacancies, with the exception of specified positions for which the County continuously advertises and accepts applications. 4.5 Employment Selection Procedures Human Resources Department staff will receive applications for advertised vacancies, process the applications, and screen the applications for qualifications. They may conduct preliminary screening interviews with selected applicants. They may also make appropriate records and other suitability checks. They will select and refer a manageable number of the most suitably qualified applicants to the hiring department for interview and further selection activities. The hiring department will conduct interviews and reference checks and consult with Human Resources prior to making a job offer to the selected candidate(s). It will update the applicant tracking system indicating the reasons for selection or rejection of each of the candidates. The hiring department will make the offer of employment contingent upon a successful pre- employment drug screening. 4.6 Introductory Period of Employment An employee appointed to a full-time or part-time regular (benefits -eligible) position will serve an introductory period of no less than six (6) months and no more than twelve (12) months. During the introductory period, an employee may be dismissed at any time the hiring authority feels the employee is not satisfactorily performing the assigned duties. Before completion of an Established: May 1977 Article 4 - Employment Page 2 Last Revised: November 16, 2020 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 72 NEW HANOVER COUNTY PERSONNEL POLICIES & PROCEDURES employee's introductory period, the employee's supervisor or department head will evaluate the employee's performance and follow the following procedures: a. Discuss the employee's performance evaluation and progress with the employee; b. Determine and document whether the employee's performance meets expectations held for an employee at that point in employment; c. Complete a personnel action to retain the employee in the position and move the employee from the introductory period status; extend the introductory period for a designated time, documenting expectations for successful completion; or demote, transfer or dismiss the employee. 4.7 Casual Part-time or Temporary to Regular Status No service credit shall be given for time and service while in a casual part-time or temporary position; nor shall service credit be given for such time upon transferring into a regular (benefits -eligible) position. Established: May 1977 Article 4 - Employment Last Revised: November 16, 2020 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 73 Page 3 Housing Discrimination Complaint Form New Hanover County CDBG-I Program Manual Page 42 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 74 "\ l�i�rel! W. Victim FM Lo Discrimination? Fair Housing is Your Right! P�MENi OF ZG IIIIIIII F�2 Q 9egN DE"EVO If you have been denied your housing rights ... you may have experienced unlawful discrimina- tion. U.S. Department of Housing and Urban Development Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 75 WHERE TO MAIL YOUR FORM OR INQUIRE ABOUT YOUR CLAIM For Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont: NEW ENGLAND OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development Thomas P. O'Neill, Jr. Federal Building 10 Causeway Street, Room 321 Boston, MA 02222-1092 Telephone (617) 994-8320 or1-800-827-5005 Fax (617)565-7313•TTY (617)565-5453 E-mail: Complaints_office_01@hud.gov For New Jersey and New York: NEW YORK/NEW JERSEY OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development 26 Federal Plaza, Room 3532 New York, NY 10278-0068 Telephone (212) 264-1290 or1-800-496-4294 Fax (212) 264-9829 • TTY (212) 264-0927 E-mail: Complaints_office_02@hud.gov For Delaware, District of Columbia, Maryland, Pennsylvania, Virginia, and West Virginia: MID -ATLANTIC OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development The Wanamaker Building 100 Penn Square East Philadelphia, PA 19107 Telephone (215) 656-0663 or1-888-799-2085 Fax (215) 656-3419 • TTY (215) 656-3450 E-mail: Complaints_office_03@hud.gov For Alabama, the Caribbean, Florida, Georgia, Kentucky, Missis- sippi, North Carolina, South Carolina, and Tennessee: SOUTH EAST/CARI BBEAN OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development Five Points Plaza 40 Marietta Street, 16th Floor Atlanta, GA 30303-2808 Telephone (404) 331-5140 or 1-800-440-8091 Fax (404) 331-1021 •TTY (404) 730-2654 E-mail: Complaints_office_04@hud.gov For Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin: MIDWEST OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development Ralph H. Metcalfe Federal Building 77 West Jackson Boulevard, Room 2101 Chicago, IL 60604-3507 Telephone (312) 353-7776 or1-800-765-9372 Fax (312) 886-2837 • TTY (312) 353-7143 E-mail: Complaints_office_05@hud.gov For Arkansas, Louisiana, New Mexico, Oklahoma, and Texas: SOUTHWEST OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development 801 North Cherry, 27th Floor FortWorth,TX 76102 Telephone (817) 978-5900 or1-888-560-8913 Fax (817) 978-5876 or 5851 • TTY (817) 978-5595 E-mail: Complaints_office_06@hud.gov For Iowa, Kansas, Missouri and Nebraska: GREAT PLAINS OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development Gateway Tower II 400 State Avenue, Room 200, 4th Floor Kansas City, KS 66101-2406 Telephone (913) 551-6958 or 1-800-743-5323 Fax (913) 551-6856 -TTY (913) 551-6972 E-mail: Complaints_office_07@hud.gov For Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming: ROCKY MOUNTAINS OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development 1670 Broadway Denver, CO 80202-4801 Telephone (303) 672-5437 or 1-800-877-7353 Fax (303)672-5026•TTY (303)672-5248 E-mail: Complaints_office_08@hud.gov For Arizona, California, Hawaii, and Nevada: PACIFIC/HAWAH OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development 600 Harrison Street, Third Floor San Francisco, CA 94107-1300 Telephone (415) 489-6524 or1-800-347-3739 Fax (415) 489-6558 - TTY (415) 436-6594 E-mail: Complaints_office_09@hud.gov For Alaska, Idaho, Oregon, and Washington: NORTHWEST/ALASKA OFFICE Fair Housing Hub U.S. Dept. of Housing and Urban Development Seattle Federal Office Building 909 First Avenue, Room 205 Seattle, WA 98104-1000 Telephone (206) 220-5170 or1-800-877-0246 Fax (206) 220-5447 - TTY (206) 220-5185 E-mail: Complaints_office_10@hud.gov If after contacting the local office nearest you, you still have ques- tions — you may contact HUD further at: U.S. Dept. of Housing and Urban Development Office of Fair Housing and Equal Opportunity 451 7th Street, S.W., Room 5204 Washington, DC 20410-2000 Telephone (202) 708-0836 or1-800-669-9777 Fax (202)708-1425•TTY 1-800-927-9275 To file electronically, visit: www.hud.gov Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 76 PLACE POSTAGE HERE MAIL TO: Public Reporting Burden for this collection of information is estimated to average 20 minutes per response, including thetimefor reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The Department of Housing and Urban Development is authorized to collect this information by Title VIII of the Civil Rights Act of 1968, as amended by the Fair Housing Amendments Act of 1988, (P.L. 100-430); Title VI of the Civil Rights Act of 1964, (P.L. 88-352); Section 504 of the Reha- bilitation Act of 1973, as amended, (P.L. 93-112); Section 109 of Title I- Housing and Community Development Act of 1974,asamended, (P.L. 97-35); Americans with Disabilities Act of 1990, (P.L.101-336);and bythe Age Discrimination Act of 1975, as amended, (42 U.S.C. 6103). The information will be used to investigate and to process hous- ing discrimination complaints. The information may be disclosed to the United States Department of Justice for its use in the filing of pattern and prac- tice suits of housing discrimination or the prosecution of the person(s) who committed that discrimination where violence is involved; and to State or local fair housing agencies that administer substantially equivalent fair housing laws for com- plaint processing. Failure to provide some or all of the requested information will result in delay or denial of HUD assistance. Disclosure of this information is voluntary. P.1 N T ply 11 � j�e* EQUAL HOUSING 2a IIIIIIII OPPORTUNITY � Q� 9egN EV E10 Board of Commissioners - Octoer 20, 2025 ITEM: 9 - 3 - 77 Instructions: (Please type or print) Read this form carefully. Try to answer all questions. If you do not know the answer or a question does not apply to you, leave the space blank. You have one year from the date of the alleged discrimination to file a complaint. Your form should be signed and dated. Your Name Your Address City State Zip Code Best time to call Your Daytime Phone No Evening Phone No Who else can we call if we cannot reach you? Contact's Name BestTimeto call Daytime Phone No Evening Phone No Contact's Name BestTimeto call Daytime Phone No Evening Phone No What happened to you? How were you discriminated against? jor example: were you refused an opportunity to rent or buy housing? Denied a loan? Told that housing was not avail- able when in fact it was? Treated differently from others seeking housing? State briefly what happened. Form HUD-903.1 (1/02) OMB Approval No.2529-0011 (exp. 1/31/2011) Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 78 Why do you think you are a victim of housing discrimination? it because of your: race • color • religion • sex • national origin -familial status (families with children under 18) • disability? For example: were you denied housing because of your race? Were you denied a mortgage loan because of your religion? Or turned down for an apartment because you have children? Briefly explain why you think your housing rights were denied and circle the factor(s) listed above that you believe apply. Who do you believe discriminated against you? jl�r example: was it a landlord, owner, bank, real estate agent, broker, company, or organization? ventify who you believe discriminated against you. Name Address Where did the alleged act of discrimination occur? Or example: Was it at a rental unit? Single family home? Public or Assisted Housing? A Mobile Home? Ed it occur at a bank or other lending institution? Provide the address. Address City State When did the last act of discrimination occur? ■iter the date Is the alleged discrimination continuing or ongoing? Signature Zip Code Yes No� Date Send this form to HUD orto the fair housing agency nearest you. If you are unable to complete this form, you may call that office directly. See address and telephone listings on back page. Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 79 7 oe� It is Unlawful to Discriminate in Housing Based on These Factors... • Race • Color v Q • National origin 0 • Religion a • Sex M • Familial status (families with children under the age of 18, Q) or who are expecting a child) 0, s • Handicap (if you or someone close to you has a disability) .§ v 0 If You Believe Your Rights Have Been Violated... • HUD or a State or local fair housing agency is ready to help you o file a complaint. v v: s: s: • After your information is received, HUD or a State or local fair housing agency will contact you to discuss the concerns you raise. o Keep this information for your records. Date you mailed your information to HUD: Address to which you sent the information: Street City State Zip Code If you have not heard from HUD or a State or local fair housing agency within three weeks from the date you mailed this form, you may call to inquire about the status of your complaint. See address and tele- phone listings on back page. Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 80 "The American Dream of having a safe and decent place to call'home' reflects our shared belief that in this nation, opportunity and success are within everyone's reach. Under our Fair Housing laws, every citizen is assured the opportunity to build a better life in the home or apartment of their choice — regardless of their race, color, religion, sex, national origin, family status or disability.' Alphonso Jackson Secretary Under the Fair Housing Act, it is Against the Law to: • Refuse to rent to you or sell you housing • Tell you housing is unavailable when in fact it is available • Show you apartments or homes only in certain neighborhoods • Set different terms, conditions, or privileges for sale or rental of a dwelling • Provide different housing services or facilities • Advertise housing to preferred groups of people only • Refuse to provide you with information regarding mortgage loans, deny you a mortgage loan, or impose different terms or conditions on a mortgage loan • Deny you property insurance • Conduct property appraisals in a discriminatory manner • Refuse to make reasonable accomodations for persons with a disability if the accommodation may be necessary to afford such person a reasonable and equal opportunity to use and enjoy a dwelling. • Fail to design and construct housing in an accessible manner • Harass, coerce, intimidate, or interfere with anyone exercising or assisting someone else with his/her fair housing rights Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 81 CDBG-I Program Procurement Policy New Hanover County CDBG-1 Program Manual Page 43 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 82 Compliance Manual Note: NC DEQ policies and guidelines are periodically updated. When a new version is released or when the CDBG-1 program manual is revised, changes are shown in red for easy reference. NC DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER INFRASTRUCTURE (DIVISION) COMMUNITY DEVELOPMENT BLOCK GRANT -INFRASTRUCTURE UNIT Policy Title: CDBG-I Program Procurement Policy Revised: November 5, 2024 Version: 7 Effective Date: November 6, 2024 This policy remains effective until it is amended, superseded, or rescinded. CONTENTS: PURPOSEAND SCOPE..................................................................................................................1 Maximum Full and Open Competition....................................................................................2 Conflictof Interest and Ethics.................................................................................................3 BUILD AMERICA, BUY AMERICA (BABA), "BUY AMERICA PREFERENCE" ...............................4 REASONABLECOSTS...................................................................................................................4 PriceAnalysis.........................................................................................................................6 CostAnalysis..........................................................................................................................6 PROCUREMENT METHODS..........................................................................................................8 Micro-Purchases.....................................................................................................................8 SimplifiedAcquisitions..........................................................................................................9 SealedBids...........................................................................................................................10 Competitive Proposals for Professional Services. (Request for Proposals /RFPs).................14 Competitive (Proposals) Qualifications for Professional Architectural and Engineering (A/E) Services. (Request for Qualifications/RFQs)......................................................................16 Non -Competitive Procurement..............................................................................................18 CONTRACTMODIFICATIONS....................................................................................................19 ChangeOrders......................................................................................................................19 OtherContract Amendments.................................................................................................20 PURPOSE AND SCOPE Goods and services must be procured in an effective manner and in compliance with Federal, State, and local laws. These laws exist to ensure that funds are awarded through fair and open competition and are spent on eligible and reasonably priced goods and services. Per 24 CFR 570.489(g), when procuring property or services to be paid for in whole or in part with CDBG funds, the State shall follow its procurement policies and procedures and shall establish requirements for procurement policies and procedures for units of general local CDBG-I Program Procurement Policy v.7 Page 1121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 83 Type text here government (grantees), based on full and open competition where cost reasonableness has been determined in advance of contract bidding, per 2 CFR 200.324 Contract Cost and Price. Methods of procurement (e.g., simplified acquisitions, sealed bids/formal advertising, competitive proposals, and noncompetitive proposals) and their applicability shall be specified by the State. Cost plus a percentage of cost and percentage of construction costs methods of contracting shall not be used [L200.324(011. The policies and procedures shall also include standards of conduct governing grantees' employees engaged in the awarding and/or administration of contracts. Other conflicts of interest are covered by § 570.489(h). The State shall ensure that all purchase orders and contracts include any clauses required by Federal statutes, Executive orders and implementing regulations. The State shall make subrecipients and contractor determinations in accordance with the standards in 2 CFR 200.330-.332. This policy is for the use of Community Development Block Grant -Infrastructure (CDBG-I) Program grantees (units of general local government). As authorized by 24 CFR 570.489(g), this policy was developed to replace the Uniform Administrative Requirements of Subpart D of 2 Part 200, Sections 200.317-327 Procurement Standards, which does not apply to the CDBG State programs, per 2 CFR 200.101(e). This policy takes the most restrictive of Federal and State procurement regulations and applies them to grantee's procurement of services and goods for the CDBG-I program. Maximum Full and Open Competition This policy provides for full and open competitions among prospective vendors and bidders. Competition should ensure that the pricing is fair, and the grantees are getting a reasonable price for the goods or services procured. In addition, full and open competition should reduce the potential for conflicts of interest and collusion on bids between potential bidders and the units of general local government. Maximum full and open competition: • Prevents fraud, waste, and abuse. • Increases visibility and transparency. • Receive reasonable prices from qualified contractors. • Provides opportunities for all responsible contractors. Maximizing competition to ensure that procurements are conducted, and contracts are awarded in a way that obtains the most competition that will serve the grantee well. This policy strives to avoid the following procurement issues: • Unjustified sole -source contracts, • Insufficient price or rate quotes from qualified sources, • Lack of independent cost estimates or cost analyses, • A failure to rotate vendors on lower priced purchases, The use of unreasonably narrow or specific qualification criteria or bid specifications, Short timeframes for responding to offers, An insufficient number of responsive bidders, CDBG-I Program Procurement Policy v.7 Page 2121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 84 • Overuse of change orders, • Collusive bidding or price fixing, • Cost mischarging, • Source selection fraud, • Fictitious vendor fraud, • Failure to check government debarment lists, Conflict of Interest and Ethics Overuse of small purchase contracts, Lack of outreach to minority and women business enterprises, and An excessive number of small purchases contracts close to the small purchase dollar limit. Grantees as part of their procurement processes, must adhere to the conflict -of -interest regulations, including but not limited to those found at N.C. General Statutes § 14-234(a)(1), 2 CFR 200. 318(c), 24 CFR 570.489 (g) and (h), and 24 CFR 570.611 must be carried out. It is the unit of general local government obligation to not only avoid conflicts of interest, but also to be alert and question real or apparent conflicts by any others, including procured consultants and contractors. Grantees must maintain procurement integrity through strong documentation and financial controls to avoid fraudulence, misuse, and abuse of federal funds. • Separation of Duties. 0 One method for minimizing the potential for fraud and abuse in the procurement process is to have different individuals handling different parts of the process. For example, where one individual award the contract or orders the goods or services, a separate individual will review the goods or services for performance and/or delivery. An easy guide for compliance is that employees who handle the money, the mail or the goods purchased should be different from employees managing the bookkeeping and financial accounts. This practice can be difficult in small cities, small departments, or organizations with few employees, but a method of oversight must be established to avoid fraud and unnecessary purchases. The rule of thumb should be that if an employee touches the money, mail, or goods purchased, he or she should not touch the books. • Documentation. o Each step in the procurement process should be documented, from the initial decision to purchase through to final inspection of goods and services and final payment. The records should include, but are not limited to, files on the rationale for selecting the methods of procurement used, selection of contract type, the contractor selection/rejection process, and the basis for the cost or price of a contract. The records should also include a justification for lack of competition when competitive bids or offers are not obtained, and the basis for the award cost or price. Documentation does not end at contract signing but should continue through the delivery of goods and services to record payments, inspection, change orders and cost/price analysis of the change order. Monitoring the performance of the vendor should be documented through inspections and review of performance and delivery. CDBG-I Program Procurement Policy v.7 Page 3121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 85 BUILD AMERICA, BUY AMERICA (BABA, "BUY AMERICA PREFERENCE" The Build America, Buy America Act (BABA) requires that all iron and steel, construction materials, and manufactured products used in federally -funded infrastructure projects are produced in the United States (2 CFR 200.322 Domestic Preferences for Procurement). This requirement, known as the 'Buy America Preference" (BAP), is detailed in the Infrastructure Investment and Jobs Act, Pub. L. 117-58 and 2 CFR 184. Grantees of CDBG-I awards made with FY2023 and newer federal CDBG funds must comply with BABA requirements and the HUD's phased implementation of BAP. For additional information on meeting BAP, grantee's should review the CDBG-I Program BABA Guidance found on the Division's website at https://www.deq.nc.Rov/about/divisions/water- infrastructure/i-have-fundin /g cdbg i-compliance-and-reporting-information#Tab-Procurement- 1831. REASONABLE COSTS Per §200.324(a), grantees must perform a cost or price analysis for every procurement transaction, including contract modifications, greater than the simplified acquisition threshold. The method and degree of analysis conducted depend on the facts surrounding the procurement transaction. However, as a starting point, the recipient or subrecipient must make independent estimates before receiving bids or proposals. An independent cost estimate serves as a yardstick for evaluating the reasonableness of the contractor's proposed costs or prices. An independent cost analysis consists of evaluating the separate elements (for example, labor, materials, etc.) that make up a contractor's total cost proposal to determine whether they are allowable, directly related to the requirement, and reasonable. • Price Analysis. Price analysis is essentially price comparison. It is the evaluation of a proposed price (i.e., total sum) without analyzing any of the separate cost elements. Cost Analysis. Cost analysis is the evaluation of the separate elements (e.g., labor, materials, profit, etc.) that make up a contractor's total cost proposal or price to determine if they are allowable, directly related to the requirements and ultimately, reasonable. Cost analysis should apply to both new contracts and contract modifications or change orders. The basic document in the grantee's efforts to evaluate cost and price is an "independent analysis" based on the procedures described below. The "independent analysis" can be done by grantee staff, by third party consultants, or by examination of existing price lists and product catalogs, but it is not based on bids received. The analysis is done prior to receipt of bids or review of proposals. This is the area where most findings have occurred historically because the analysis was not independent, or it was not documented prior to receipt of bids or proposals. While the procurement method and degree of analysis depends on the facts surrounding the procurement, the following illustrates some of the cost and price analyses that may be performed in certain procurement situations. CDBG-I Program Procurement Policy v.7 Page 4121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 86 • Micro Purchases. Require simple price analysis prior to receiving bids or proposals. They do not require a cost analysis. • Simplified Acquisitions. Grantees should review the proposed prices, from offerors to prices paid for the same or similar services. Catalog or market prices of products sold to the public can suffice for cost estimates for equipment and supply purchases. • Sealed Bid. Grantees should always prepare their own cost estimate and compare it to the low competitive bid received. If they are significantly different, the grantee will need to evaluate its initial estimate, compare it to the bids received, and identify the appropriate price. • Competitive Proposals. To determine the reasonableness of proposed costs, the grantee will need to obtain cost breakdowns showing all the elements of the scope of work and perform a cost analysis using the appropriate set of principles. Grantees should obtain a breakdown of proposed costs and perform a cost analysis of those costs. The following are special circumstances involving contracts and cost analysis requirements: • Cost Reimbursement Contracts. A cost analysis using cost principles must be performed on a cost reimbursement contract. • Architecture and Engineering Contracts. Cost analysis is required in determining if the cost portion of an A/E contract is fair and reasonable. • Construction Contracts. Construction contracts awarded using sealed bids do not require cost analysis. However, an estimate of market costs should be made prior to awarding the contract. Construction contracts awarded using any other method of procurement require cost analysis. Some grantees will contract out cost analysis to independent architect or engineering firms. In addition, changes to the contract will require cost analysis in the following situations: • Contract Modifications. If a grantee is negotiating a modification or change order to a contract that changes the scope and/or impacts the price or estimated cost, the grantee should perform further cost analysis. The only exception to this is if the modification is based on pricing already established in the contract. A contract where the scope is reduced, and the contract price remains the same will still require further cost analysis to determine that the change is fair and reasonable. • Contract Terminations. If a grantee terminates a contract for convenience, the grantee must use cost analysis and the appropriate cost principles to negotiate the final amount of termination settlement. If the grantee is terminating a cost re-imbursement contract for cause, the grantee should use cost analysis and the appropriate cost principles to negotiate the final amount of termination settlement. o In addition, contracts must include termination language when they are over $10,000, as described in 2 CFR Appendix-II-to-Part-200(B). CDBG-I Program Procurement Policy v.7 Page 5121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 87 Price Analysis Both micro purchase and simplified acquisitions procurement methods require price analysis when selecting vendors and suppliers. There are a variety of ways of analyzing price, some of which are illustrated below, but the method and degree of analysis grantees used is dependent on the facts surrounding the procurement situation. Price analysis should be documented in the procurement file. • Compare competitive prices received in response to the solicitation to each other. • Compare proposed prices to prices on existing contracts or contracts proposed in the recent past. Be sure to factor in any changing conditions, including market, inflation, material price changes. • Apply rough approximations and review significant inconsistencies, which may require a deeper look at prices to determine if the items are truly comparable. The types of approximations might include price per pound, per square foot, per hour or other typical unit pricing mechanisms. • Review price lists, catalogs, or market prices of similar products to determine the market prices generally available to the public. Cost Analysis Cost analysis includes the review and evaluation of the separate cost elements, including labor, supplies, equipment, profit, overhead and general conditions. Grantees should prepare an independent cost analysis before receiving bids, proposals, and contract modifications. The method and degree of analysis is dependent on the facts surrounding the procurement situation. An independent estimate must be made before receiving bids or proposals if one of the following applies: • When evaluating competitive proposals. • When there is a sole source or non-competitive proposal. • When only one bid is received after soliciting bids, the grantee does not have enough data to establish cost reasonableness and the grantee is considering awarding the contract to the single bidder. • When negotiating modifications to contracts that impact on the price or estimated cost. • When terminating a contract and the contractor is entitled to payment of reasonable costs incurred. • When awarding a cost -reimbursement contract. The major categories of costs include both direct costs (direct labor, equipment, supplies, travel and per diem, subcontractors, and other direct costs) and indirect costs (overhead, general and administrative expenses, and profit). In the process of analyzing costs, profit should be analyzed separately, based on complexity of the work, risk to the contractor, investment required, amount of subcontracting involved, and typical profit in the industry. The process for completing a cost analysis includes verifying cost data and evaluating the elements of the project as described below. Costs that can be charged against the award are the allowable direct costs and the CDBG-I Program Procurement Policy v.7 Page 6121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 88 allocable indirect costs, less any applicable credits. • Allowable (Allowability) Costs. (2 CFR 200.403 and 24 CFR 570.207, §570.502 and §570.610) A cost is allowable under criteria to be allowable under the CDBG program if the expenditure is: o Be necessary, reasonable, and directly related to the grant program. o Authorized by the State -administered CDBG program. o Not prohibited under federal, state, or local laws or regulations. o Consistently treated. o Allocable to the CDBG program. o Be adequately documented. o Cost must be incurred during the approved budget period. • Reasonable Costs. (2 CFR 200.404) For the cost to be allowable, it must also be reasonable. This term is generally defined as what a prudent business would pay in a competitive marketplace. In determining the reasonableness of a given cost, pay attention to the following: o Is the cost generally recognized as ordinary and necessary for the operation of your organization or the performance of the award? o Are the restrictions or requirements imposed by generally accepted sound business practices, arms -length bargaining, Federal and state laws and regulations, and terms and conditions of the award? o Are the prices or cost comparable to market prices for goods or services for the geographic area? o Are the individuals performing their duties with good judgment under the circumstances, considering their responsibilities to the organization, its members, employees, clients, the public -at -large, and the government? o Have there been significant changes from the established practices of the organization that have unreasonably increased costs? • Allocable Costs. (2 CFR 200.405) The costs should be related to or required for the performance of the contract. Many costs may be allowable but not related to the work required under the contract, and therefore not allocable. o Is the cost incurred specifically for the CDBG grant? o Does the cost incurred benefit both the CDBG project and other projects, and can the cost be allocated pro-rata across the relevant funding sources? o Has an indirect cost plan been approved to allocate indirect costs? The process for applying cost and price analysis should include the following due diligence review. • Check the accuracy of the cost and pricing information submitted, and evaluate: o The necessity for proposed cost items. A cost may be allowable under the cost principles and even allocable to the type of work to be performed, but still not be necessary for the specific contract. o The application of audited or pre -negotiated indirect cost rates, labor and fringe benefit rates, or other factors. CDBG-I Program Procurement Policy v.7 Page 7121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 89 o The effect of the vendor's bid approach on potential future costs. Does the vendor have a track record of containing costs (completing contracts at or "under cost")? Do they frequently have cost overruns? o The projection of the vendor's cost trends. Is there any indication that the vendor's costs are likely to increase or decrease over the life of the contract? • Compare costs proposed by the vendor with: o Actual costs previously incurred by the same contractor for the same or similar work. Apply any appropriate inflation factors for past work. o Actual costs of the same or similar work performed by other contractors. o Previous cost estimates from the vendor or others for the same or similar items. o The methods proposed by the vendor with the requirements of the solicitation (i.e., do the costs reflect the technical approach proposed and the work required?). o The grantee's independent cost estimate, either created by grantee staff or for the grantee by an independent architect, engineer, appraiser, etc. • Verify that the vendor's cost submissions comply with the appropriate set of cost principles. PROCUREMENT METHODS Grantees must select from one of the following procurement methods based on the type of goods and/or services being procured and their cost. Micro -Purchases This method can be used for contracts without soliciting pricing or bids if the price of the goods or services is fair and reasonable. To the extent practicable, must distribute micro -purchases among qualified suppliers. Applies to all purchases of goods and services, including construction, up to the micro -purchase threshold of $10,000. Process: 1. Must distribute micro -purchases equitably among qualified suppliers to the extent practicable. 2. When possible, the grantee should ensure that small businesses, minority businesses, women's business enterprises, veteran -owned businesses, and labor surplus area firms (See U.S. Department of Labor's list), and Section 3 business concerns are considered as set forth in 2 CFR 200.321(b). (2 CFR 200.321, 24 CFR 570.607 and 24 CFR part 75). 3. Cannot divide contract to lower cost below micro -purchase threshold to avoid competitive bidding requirements. 4. If using this method for services, check for eligibility at SAM.gov and at the NC Department of Administration Debarred Vendors listing prior to finalizing the service contract (24 CFR 570.509, 24 CFR part 5). CDBG-I Program Procurement Policy v.7 Page 8121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 90 5. Can award contract without competition if price is fair and reasonable. 6. Must document decision process for the purchase. o Requires needs and rationale documentation. o Requires cost reasonableness documentation. o Requires documentation of best efforts to use M/WBE firms when possible. [Cite 2 CFR 200 and 24 CFR 570. There is no comparable method in State law; therefore, all purchases and service contracts that meet the above threshold must comply with this federal method.] Simplified Acquisitions This method as the informal bidding process for goods and services. Grantees cannot divide the contract for the purpose of evading competitive (formal) bidding requirements or to get costs under the threshold. Applies to all purchases of goods and services, including construction that fall between the thresholds stated below. • $10,001 up to the Simplified Acquisition Threshold (now $250,000) or the equivalent local/state threshold if more restrictive (it is for purchase of goods). Threshold includes contract modifications that increase total cost. o Construction: Cost up to $250,000 o Goods: Cost up to $89,999 • Fixed price, unit price, or not -to -exceed contract types. Process: 1. Cost or price analysis (updated cost estimate provided by the project engineer) is not required prior to soliciting bids for goods but is required for construction. 2. Obtain price or rate quotes from at least three (3) sources. 3. Take consideration means [2 CFR 200.321(b)] to directly solicit bids must include qualified HUB, M/WBEs, small businesses, veteran -owned, labor surplus area firms (See U.S. Department of Labor's list) and Section 3 business concerns in the area. (2 CFR 200.321, 24 CFR 5 70.60 7 and 24 CFR part 75). 4. If using this method for services, check for eligibility at SAM.gov and at the NC Department of Administration Debarred Vendors listing prior to finalizing the service contract (24 CFR 570.509, 2 CFR 200.214, CFR part 5). 5. Standard of award. • Award contract to the lowest responsive, responsible bidder. 6. Documentation for Files. • Requires everything required by micro -purchase. CDBG-I Program Procurement Policy v.7 Page 9121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 91 • Requires documented informal solicitation of bids/prices solicitation information should be consistent for all vendors. • Requires cost reasonable documentation. • Requires applicable federal contracting language and provisions in the written contract. [Cite 2 CFR 200 and 24 CFR 570); PDAT Supplement at H-6, V-8; NCGS 143-131; NCGS 143-131(b)) Purchases and service contracts less than $30, 000 are not subject to state competitive bidding requirements. Per NCGS 143-128.2, local governments must establish good faith efforts prior to bid solicitation.] Sealed Bids. This formal bidding process for construction. Grantees cannot divide the contract for the purpose of evading competitive bidding requirements. Applies to purchase and service contracts costing more than the Simplified Acquisition Threshold (>$250,000) or the equivalent local/state threshold if more restrictive. • For the CDBG-I Program, the thresholds are: o Construction: $250,001 and over. o Goods: $90,000 and over. • Preferred method for construction contracts above the simplified acquisition threshold. Requires an independent cost estimate or price analysis (updated cost estimate provided by the project engineer) is required prior to soliciting bids for all types. Bid Alternates. The CDBG-I program allows specific bid alternates. Bid alternates should only be used as an option to get more work done if the base bid is low enough that acceptance of an alternate(s) stays within the budget, or to receive prices for different materials, or an alternative construction method for the project. 1. An Additive bid is a body of work that the grantee may award with the base bid if there is sufficient funding after the bids are received. 2. A Deductive bid is a body of work that the owner may delete from the base bid if there is insufficient funding to award the full base bid. o The purpose of both Additive and Deductive bids is to build flexibility into the bidding process so that the grantee can award the maximum amount of the project possible dependent on funding available. 3. An Alternate bid is a bid in which the grantee asks for prices for an alternate method of constructing something in the base bid or using alternate materials. The alternate price would be the differential between the price included in the base bid and the price for the alternate method or material. In developing the bid form, it's important to make sure that it's clear that the alternate bid amount should be the differential price. o Alternates that specify a different material to stay within the budget or get more value for the dollars spent (e.g., base bid has DIP specified and associated unit CDBG-I Program Procurement Policy v.7 Page 10121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 92 price. Alternate would propose using PVC in lieu of DIP. The difference in price of the material may or may not make a difference to the owner). Alternates should stand alone and not dependent on another alternate being accepted or rejected at the time of award. If it becomes apparent there are sufficient funds to add scope to the project, the owner must re -procure / re -bid the additional scope of work. Adding a bid alternate (i.e., increasing the scope) that was previously rejected via change order violates this procurement policy. Alternates may not be used to help "choose the bidder" the grantees want to work with. The base bid and alternates should be evaluated in the same manner for all bidders. Alternates should be used sparingly. Too many alternates may confuse bidders or make the project look so complicated that contractors don't bid at all. They should be limited to a reasonable number. Process: The following process may begin once Grantees receive bid and design package approval from the Division. 1. Coordinate Dates. • Contact the CDBG-I Unit Grant Representative assigned to your project to coordinate pre -bid meeting dates prior to finalizing the bid notice. • A pre -bid meeting must be held involving all interested contractors and invested parties (CDBG-I Program Staff, Project Engineer, Grant Administrator, and local government representatives). The meeting must be scheduled to give contractors sufficient time to factor in the additional work required to comply with Davis -Bacon and Section 3 regulations. 2. Bid Notice. • A complete, adequate, and realistic set of plans/specifications or purchase description is available to bidders. • All required federal and state language must be in the bid notice. A sample bid notice can be found on the Division of Water Infrastructure website. • A digital copy of the final bid notice must be received by the NCDEQ at the time it goes out for solicitation. • Public advertisement of at least thirty (30) days prior to bid opening. 3. Solicitation of Bids. • Solicit bids from an adequate number of known suppliers. • At least three (3) direct solicitations, in addition to the public advertisement, and publication on both the state NC eVP system and HUB websites (this is the responsibility of the local governments not NCDEQ nor their consultants). CDBG-I Program Procurement Policy v.7 Page 11121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 93 • Take consideration means [2 CFR 200.321(b)] to directly solicit bids must include qualified HUB, M/WBEs, small businesses, veteran -owned, labor surplus area firms (See U.S. Department of Labor's list) and Section 3 business concerns in the area. (2 CFR 200.321, 24 CFR 5 70.60 7 and 24 CFR part 75). • Section 3 business concerns must meet the requirements of 24 CFR Part 75. 4. Minimum Number of Bids Needed. • Public bid opening at date and time advertised. • For construction, a 5% bid bond is required for all bidders; performance and payment bonds of 100% of the contract price is required of the winning bidder. • At least two (2) bidders for the purchase of goods and services, or if the contract is a construction repair contract. • At least three (3) bidders minimum are required for bid opening on the first attempt for construction. o If three (3) bidders DO NOT bid on the project, the bids MAY NOT be opened. ■ The grantee must then publicly advertise in a newspaper with a larger distribution for at least seven days (NCGS 143-129). o If two (2) or more bids are received, then bids may be opened. o If one (1) bid is received, then a price analysis must be conducted, and a letter sent to DEQ Division of Water Infrastructure requesting permission to move forward with sole source procurement. 5. Standard of Contract Award: Award to the lowest, responsive, responsible bidder. The local governing board approval is required unless the governing board has delegated award authority to an individual official or employee. o Determination of lowest price must include factors such as discounts, transportation costs, and lifecycle costs. o Determination of responsive and responsible, see the NC School of Government's "Awarding Competitively Bid Contracts, Lowest Responsive Responsible Bidder Flowchart." • Can reject any and all bids for "sound documented reasons" — must be stated in the bid notice. CDBG-I Program Procurement Policy v.7 Page 12121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 94 Check for eligibility to receive federal funds at SAM.gov and at the NC Department of Administration Debarred Vendors listing prior to finalizing the construction contract. Contract awarded on a firm -fixed -price basis in writing with all applicable contract provisions. 6. Process after Multiple Failed Attempts If a local government has attempted, and failed, to secure a sealed bid after two attempts, the local government must: • Reassess and repackage (i.e., construction timeframe, scope of work, etc.) the project to fit the CDBG-I funds awarded without compromising the LMI. • Take into consideration the plan holders' comments within your control to simplify the bids. If applicable, limit bid alternates no more than three (3). Once this is completed, approved by the NCDEQ CDBG-I Unit, the project can go out for sealed bids under this method from the beginning. 7. Overbids and Bid Negotiations If the bids received exceed the designated budget, the grantee has the following options: • Reject all bids and re -bid the project; or • Accept the deductive alternates in the bid packet (if applicable); or • Delete bid items before contract award if all bidders agree in writing to changes; or • Accept the low bid and provide additional local funds. Per N.C.G.S. 143-129(b), units of general local government cannot negotiate with bidders on projects in the formal bidding range unless the bid submitted by the apparent lowest responsive, responsible bidder exceeds funds available for the project. In this case, the grantee may negotiate with that bidder and make "reasonable" changes in specifications and plans to bring the contract price to within funds available, and then it may award the contract to that bidder. If negotiations are unsuccessful, the project must be re -bid. Any redesign of the procurement project triggers the grantee to reject all bidders and start the procurement process from the beginning to ensure integrity of the process. 8. Documentation: Must have a well -documented transparent and formal procurement process, including all steps and decisions on procurement (e.g., required cost reasonable and independent cost estimate, pre -bid meeting minutes, advertisement(s) with an affidavit(s) of publication, copy of each solicitation, copy of the NC eVP system and HUB postings, certified bid tabs, written construction agreement with all required applicable federal contracting language and provisions, documentation of lowest price determination, bid negotiation if applicable). CDBG-I Program Procurement Policy v.7 Page 13121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 95 [Cite 2 CFR §200; NCGS 143-129; NCGS 143-128.2(e). Per NCGS 143-128.2, local governments must establish good faith efforts prior to bid solicitation.] Competitive Proposals for Professional Services. (Request for Proposals /RFPs). This method for specific professional services where price is one of the rating criteria. Applies to the procurement of grant administrators, lawyers, planners, accountants, etc. for the project, regardless of the size of the contract. • A contract costs more than the simplified acquisition threshold (now $250,000). • Situations where conditions are not appropriate for the use of sealed bids. The following process may begin once Grantees have received an award letter from the Division. Grantees may begin this process prior to applying to the Division for funding, if the request for proposals have specific language in it in case the funding application is not awarded. Process. 1. Appoint a Local Selection Review Committee and/or Person. Each local government needs to appoint a local selection review committee and /or person responsible for developing the RFP, receiving the submitted RFPs, reviewing, and evaluating the submissions, and recommending a firm/business to the local governing body. Must have written method for conducting technical evaluations of proposals and contractor selection. 2. Development of Request for Proposals (RFP). • Must clearly and accurately state the technical requirements and scope of work for goods and/or services required. • Evaluation criteria and relative importance is identified in the RFP. • If local government is giving a preference to Section 3 businesses, this must be stated in the RFP. • The author of the RFP may not respond to the same RFP. They are ineligible for consideration due to conflict of interest. • RFP templates are available on the Division of Water Infrastructure website to assist with RFP development. 3. Solicitation for Proposals. The Request for Proposals (RFP) must be publicly advertised in a newspaper of general circulation. There must be an adequate number of days (at least fifteen (15) business days starting on the date of publication) from the time of advertised notice and submission deadline to allow time for respondents to receive a detailed RFP (if applicable), prepare and submit their proposal. CDBG-I Program Procurement Policy v.7 Page 14121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 96 o There is a short -form RFP local governments may use in a newspaper as a cost saving measure. However, a more detailed RFP must be done. • In addition, the detailed RFP must be published on the NC eVP system and HUB website (all this is the responsibility of the local governments not NCDEQ). The detailed RFP must be directly solicited from at least three sources (responsibility of each local government not NCDEQ). o Direct solicitations must include qualified HUB, M/WBEs, small businesses, veteran -owned, and Section 3 businesses in the area to comply with direct solicitation requirements. o Section 3 businesses must meet the requirements of 24 CFR Part 75. 4. Minimum Number of Proposals Needed. • Must have a minimum of two (2) respondents to move forward with a contract. o If there is only one (1) respondent, the RFP must be republished in a newspaper of wider distribution for fifteen business days: in addition to, an expanded direct solicitation effort. o If only one firm responds again, request permission in writing from the DEQ CDBG-I Supervisor to use sole source procurement. 5. Review and Rate Received Proposals. • Any responses to the publicized RFP must be considered to the maximum extent practical. • Evaluations of each proposal must be in writing and dated. Those evaluations must be maintained in the project files. 6. Standard of Award. • Responsible firm with the most advantageous proposal, considering price and other factors identified in the RFP. Check for eligibility to receive federal funds at SAM.gov and at the NC Department of Administration Debarred Vendors listing PRIOR to finalizing the services contract (e.g., grant administrative services, accounting, planning, legal services, etc.). Either a fixed price (a specified price to be paid when the items or services are delivered and accepted) or a cost -reimbursement / "not -to -exceed" (price is usually reimbursed as costs are incurred) contract. ■ The service contract should contain four parts: • Part I — Agreement with Effective Dates • Part II — Scope of Work and Milestones • Part III — Payment Schedule • Part IV — Terms and Conditions (includes federal provisions and clauses) CDBG-I Program Procurement Policy v.7 Page 15121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 97 7. Documentation. o Must have a well -documented transparent procurement process including, but not limited to advertisement(s) of RFP, affidavit of publication(s) of RFP, NC eVP system and HUB postings, direct solicitation documentation, evaluation criteria, evaluations of every candidate, responses to proposal received, reason for final selection, council/commission meeting minutes of award. [Cite 2 CFR §200, No similar procedure in state statute that generally applies to procurement] Competitive (Proposals) Qualifications for Professional Architectural and Engineering (A/E) Services. (Request for Qualifications /RFQs). This method for any qualification -based solicitation and selection, where price cannot be a factor in the evaluation. Applies to procurement of architectural, engineering, construction management at -risk services and surveying services for the project, regardless of the size of the contract. This process may not be used for procurement of grant administrators. The following process may begin once Grantees have received an award letter from the Division. Grantees may begin this process prior to applying to the Division for funding, if the request for proposals have specific language in it in case the funding application is not awarded. Requires cost reasonableness and independent cost estimate. Process: 1. Appoint a Local Selection Review Committee and/or Person. • Each local government needs to appoint a local selection review committee and /or person responsible for developing the RFQ, receiving the submitted RFQs, reviewing and evaluating the submissions, and recommending a firm/business to the local governing body. • Must have written method for conducting technical evaluations of qualifications and contractor selection. 2. Development of Request for Proposals (RFQ). • Must clearly and accurately state the technical requirements and scope of work for goods and/or services required. • Evaluation criteria and relative importance must be identified in the RFQ; however, price is not a factor in the initial selection of the most qualified firm. If local government is giving a preference to Section 3 businesses, this must be stated in the RFQ. • May use local geographic preferences for the procurement of these specific services, provided that this leaves an appropriate number of qualified firms (three) CDBG-I Program Procurement Policy v.7 Page 16121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 98 given the nature and size of the project, to compete for the contract. • The author of the RFP may not respond to the same RFQ. They are ineligible for consideration due to conflict of interest. • RFQ templates are available on the Division of Water Infrastructure website to assist with RFQ development. 3. Solicitation for Proposals/Qualifications. The Request for Qualifications (RFQ) must be publicly advertised in a newspaper of general circulation. There must be an adequate number of days (at least fifteen (15) business days starting on the date of publication) from the time of advertised notice and submission deadline to allow time for respondents to receive a detailed RFP (if applicable), prepare and submit their proposal. o There is a short -form RFQ units of local governments may use in a newspaper as a cost saving measure. However, a more detailed RFP must be done. • The detailed RFQ must be published on the NC eVP system and HUB website (all this is the responsibility of the local governments not NCDEQ). • The detailed RFQ must be directly solicited from at least three sources (responsibility of each local government not NCDEQ). o Direct solicitations must include qualified HUB, M/WBEs, small businesses, veteran -owned, and Section 3 businesses in the area to comply with direct solicitation requirements. o Section 3 businesses must meet the requirements of 24 CFR Part 75. 4. Minimum Number of Proposals Needed. • Must have a minimum of two (2) respondents to move forward with a contract. o If there is only one (1) respondent, the RFQ must be republished in a newspaper of wider distribution for at least 15 business days; in addition to an expanded direct solicitation effort. o If only one (1) firm responds the second time, request permission in writing from the DEQ CDBG-I Supervisor to use sole source procurement. 5. Review and Rate Received Proposals. • Any responses to the publicized RFQ must be considered to the maximum extent practical. • Qualifications of respondents are evaluated to select the most qualified firm. • Evaluations of each proposal must be in writing and dated. Those evaluations must be maintained in the project files. CDBG-I Program Procurement Policy v.7 Page 17121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 99 6. Standard of Award. • The most qualified firm, where price is not an evaluation factor in the RFQ. • Once the most qualified firm is selected, fair and reasonable compensation can then be negotiated. • Check for eligibility to receive federal funds at www.SAM.gov and at the NC Department of Administration Debarred Vendors listing PRIOR to finalizing the engineering services contract (e.g., engineering services). • State licensure requirements apply. • Either a fixed price (a specified price to be paid when the items or services are delivered and accepted) or a cost -reimbursement / "not -to -exceed" (price is usually reimbursed as costs are incurred) contract. The service contract should contain four parts: ■ Part I — Agreement with Effective Dates ■ Part II — Scope of Work and Milestones ■ Part III — Payment Schedule ■ Part IV — Terms and Conditions (includes federal provisions and clauses) 9. Documentation. Must have a well -documented transparent procurement process including, but not limited to cost reasonableness and independent cost estimate, advertisement of RFQ, affidavit of publication of RFQ, NC eVP system and HUB postings, direct solicitation documentation, evaluation criteria, evaluations of every candidate, responses to the request for qualifications received, reason for final selection, council/commission meeting minutes of award, written contract with all required applicable federal contracting language and provisions. [Cite 2 CFR §§200; 200.320(d)(5); NCGS 143-64.31] Non -Competitive Procurement. Grantees may request the use of this method. Must be thoroughly documented with written approval from the NCDEQ CDBG-I Unit. Applies to noncompetitive procurement can only be awarded if one or more of the following circumstances apply. This method of procurement applies when one of the following is met and documented. • The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro -purchase threshold; or • The item is available from only one source: or CDBG-I Program Procurement Policy v.7 Page 18121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 100 • The public exigency or emergency for the requirement will not permit a delay that would result from publicizing a competitive solicitation; or • After solicitation of a number of sources, competition is determined inadequate; or • Award agency expressly authorizes noncompetitive procurement in response to a written request. The CDBG-I Program will approve the use of the non-competitive proposal procedure on a case -by -case basis only. Process: Perform independent cost estimate or price analysis if procurement is above the simplified acquisition threshold (now $250,000) or the equivalent local/state threshold if more restrictive. 2. If after the initial solicitation of proposals/qualifications only one response was received, the unit of local government is required to broaden their initial publication and direct solicitation by republishing in a larger circulation newspaper and expanding direct solicitation efforts. If after the second attempt only one response is received: • Submit procurement documentation to the NCDEQ CDBG-I Unit to use sole -source procurement. • Negotiate profit as a separate element of the contract price. 3. Check for the firm's eligibility to receive federal funds at SAM.gov and at the NC Department of Administration Debarred Vendors listing prior to finalizing the contract. 4. Documentation. o All required documentation as listed above, plus a copy of the letter to the DEQ CDBG-I Supervisor requesting permission to use sole source procurement and the response from the DEQ. Also, a copy of the price analysis performed. [Cite 2 CFR §200); NCGS 143-129(e)(2)J CONTRACT MODIFICATIONS To maintain maximum full and open competition with procurement, this policy addresses what type of contract modifications are allowed and not allowed. Change Orders Grantees can address an unforeseen problem during the progress of a construction project that was originally bid formally (sealed bids) or informally (simplified acquisitions) through change orders instead of using a procurement method. In other words, if a grantee bids out a construction or repair project, and then, during the project, discovers an unanticipated problem that will require additional work (and increased cost), the local government does not have to bid out that additional work. CDBG-I Program Procurement Policy v.7 Page 19121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 101 Though, to maintain the integrity of the bidding process, the change order exception must only be used when (1) the change order work fits within the scope of the original project and (2) the reason for the change is something that was unanticipated or unforeseen at the time the original contract was awarded. Thus, allowable change orders include: 1. Change orders to account for cost for unforeseen conditions, such as rock or undercut. 2. Change orders may be used for a minor redesign of a project if the redesign is required because of an unforeseeable problem with the original design. 3. Change order to adjust bid quantities to match those installed. Also known as a final adjusting change order. 4. Change order to account for a change of material, such as changing from DIP to PVC. 5. Change order to add minor scopes of work to the project if they are under the threshold for micro purchases. The following will not be allowed: • Change orders to add scope of work to a project more than a micro purchase. • Change orders that exceed 15% of the total construction cost. Change orders should account for no more than 15% of the total project cost unless they represent items 1 and 3 under the above allowable change orders. • Change orders that appear to circumvent procurement rules for fair and open bidding, etc. (e.g., trying to change order in a bid alternate that was not accepted by the grantee at the time they awarded the contract). • Change orders whose purpose is to spend excess funds from the grant (i.e., doing additional paving just because "we have extra money"). • Change orders that are under the scope of the general contractor but require materials or a subcontractor not procured during the bidding process. • Change orders cannot be used to take advantage of a good deal on a construction project. • Change orders cannot be used for fundamental redesign of a project and cannot be used to "fix" problems in the project specifications if the unit of local general government was aware of the problems before awarding the contract. Other Contract Amendments CDBG-I Program Procurement Policy v.7 Page 20121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 102 As necessary, Grantees may conduct contract amendments on professional service contracts due to unanticipated circumstances. Any contract amendments that include an increase in costs will not be paid for with CDBG-I grant funds; therefore Grantees must be ready to pay local funds for said contract amendments. POLICY HISTORY Version / Date: Name / Changes V.0 / 9/12/2017 Procurement Policy V.1 / 4/30/2019 Procurement Policy for the CDBG-I Program V.2 / 7/10/2019 Procurement Policy for the CDBG-I Program / Change in Simplified Thresholds V.3 / 2/l/2021 Procurement Policy for the CDBG-I Program / Expanded on processes and steps V.4 / 6/9/ 2021 Procurement Policy for the CDBG-I Program / Clarification on solicitation of HUB, M/WBE and Section 3 V.5 / 4/28/2023 CDBG-I Program Procurement Policy / Reformate, clarification Updated for new NC digital system for procurement, what needs to V.6 / 12/20/2023 happen after multiple failed seal bidding attempts, clarification on cost reasonable requirements, clarification on change orders and contract amendments, and bid negotiations. V.7 / 11/5/2024 Updated to reflect changes made to 2 CFR 200 that were effective 10/1/2024 and added a table of contents. CDBG-I Program Procurement Policy v.7 Page 21121 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 103 Intentionally left blank New Hanover County CDBG-I Program Manual Page 44 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 104 New Hanover County Section 504 Self -Evaluation Survey New Hanover County CDBG-I Program Manual Page 45 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 105 NEW HANOVER COUNTY FY2024 CDBG-I PROGRAM SECTION 504 SELF — EVALUATION INFORMATION 24 CFR PART 8 INTRODUCTION The following is a checklist of general requirements that recipients should consider in their self- evaluation efforts under Section 504 of the Rehabilitation Act of 1973, as amended. It should be used in conjunction with the United States Department of Housing and Urban Development (HUD)'s regulations at 24 CFR Part 8. This checklist is designed to serve as a working guidance tool to help recipients focus on key issues that could affect the accessibility of their programs and practices. In developing answers to the questions, a recipient will be preparing most of the information that Section 504 requires. Use of the checklist should also assist a recipient in pinpointing areas where action is likely to be required to achieve compliance with Section 504. It should be emphasized, however, that this checklist is for reference purposes, and is not intended as a substitute for individual judgment or analysis of the pertinent regulations issued pursuant to Section 504. Any information in this checklist cannot be used as a sole basis for determining compliance with Section 504. Government wide regulations do not prescribe a specific form. This self -evaluation was compiled from material by the Thompson Publishing Group Section 504 Compliance Handbook, the Department of Justice Civil Rights Division Technical Assistance Guide (TAG), report on Section 504 Self -Evaluation of U.S Department of Housing and Urban Development conducted programs and activities, and other HUD Region IV state checklists. REQUIREMENTS: CDBG-I Grant Contract: Per the CDBG-I Grant Contract, recipients must comply with the provision of Section 504 of the Rehabilitation Act of 1973, as amended, and HUD implementing regulations at 24 C.F.R., Parts 8 and 9. Recipients must complete the Section 504 Survey and adopt a Grievance Procedure, as well as complete a Transition Plan, if applicable. The Grant contract requires recipients to complete the Section 504 Survey and Transition Plan (if applicable), covering policies, practices, and physical accessibility and notify affected persons that it does not discriminate on the basis of the handicap. Compliance with the plan must be documented, including the information made public and the means used to make it public. 24 CFR 8.51: (a) Each recipient shall, within one year of July 11, 1988, and after consultation with interested persons, including individuals with handicaps or organizations representing individuals with handicaps: (1) Evaluate its current policies and practices to determine whether, in whole or in part, they do not or may not meet the requirements of this part; (2) Modify any policies and practices that do not meet the requirements of this part; and (3) Take appropriate corrective steps to remedy the discrimination revealed by the self -evaluation. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 1 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 106 (b) A recipient that employs fifteen or more persons shall, for at least three years following completion of the evaluation required under paragraph (a)(1) of this section, maintain on file, make available for public inspection, and provide to the responsible civil rights official, upon request: (1) a list of the interested persons consulted; (2) a description of areas examined and any problems identified; and (3) a description of any modifications made and of any remedial steps taken. ADDITIONAL INFORMATION HUD Portal on Section 504 can be found here: http://portal.hud. ov/hudportal/HUD?src=/profzram_offices/fair housing equal_opp/disabilities/sect504fa q INSTRUCTIONS COMPLETING THE EVALUATION The questions in the evaluation are a guide to ensure Section 504 compliance. Answer each question with Yes, No, N/A, a description, list, or explanation. If a question does not apply to your local government, then write "N/A" next to the question and explain. Some questions require identification of modification to policies and practices will be undertaken or what corrective action will be taken to remedy any discrimination found. In some cases, questions will require that additional information be supplied to complete the evaluation process. Please be sure to attach the local government grievance procedure and current nondiscrimination policy (e.a. excerpts from Human Resources personnel policies). The survey itself does not need to be adopted, but the grievance procedure and nondiscrimination policy do. SUBMITTING DOCUMENTS TO THE STATE It is recommended not to have the survey as grant number or program specific so it can be used for multiple grants for the local government. If a survey is indicated as grant number or program specific, it is only applicable for that specific grant. Should a local government have multiple grants, one (1) hardcopy of the survey needs to be submitted to the Division of Water Infrastructure (DWI) for each grant file. It is recommended to re-evaluate the survey every few years (such as 3 three years). TECHNICAL ASSISTANCE CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 2 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 107 There is no prior approval of the complete survey by Compliance Specialist. Should the local government need technical assistance it is recommended to email Emily Bacon at Emily.bacon&deq.nc.gov or 919- 707-9242 with questions or contact your Grant Representative. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 3 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 108 SECTION 504 SELF - EVALUATION FORM 24 CFR PART 8 I. RECIPIENT INFORMATION CDBG-I Recipient/Grantee Name: NEW HANOVER COUNTY CDBG-I Recipient/Grantee Mailing Address: 230 GOVERNMENT CENTER, SUITE 110 WILMINGTON, NC 28403 CDBG-I Recipient/Grantee Physical Address Click or tap here to enter text. (if differentfirom mailing): Name of Local Government Staff Person THEO MCCLAMMY Responsible for Self -Evaluation and Coordinating Section 504 Compliance: Title: PROGRAM MANAGER Department: PLANNING AND LAND USE Email: TMCCLAMMY@NHCGOV.COM Phone Number: 910-798-7180 Date Survey/Evaluation Completed: 09/30/2025 II. PROGRAM POLICY This section evaluates the program local government policies and their effect on individuals with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. 1. Describe briefly the local government programs and services, including their purpose, scope, activities, and participants New Hanover County provides a broad range of public services including planning, infrastructure development, water and sewer services, public health, social services, housing assistance, and emergency management. These programs are intended to improve community well-being, support economic development, and ensure equitable access to services for all residents, including individuals with disabilities. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 4 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 109 2. How does your agency incorporate provisions to ensure equal opportunity for individuals with disabilities into its policy and program initiatives? (e.g., Guidelines highlight equal opportunity for persons with disabilities under important information, review criteria, and/or Equal Opportunity issues are discussed with policy and/or service groups; Office undertakes specific effort to enhance equal opportunity for people with disabilities, by: Equal Opportunity for people with disabilities is a consideration when the office conducts special initiatives such as research, studies, symposia and/or future planning efforts.) N Yes ❑ No (explain below) ❑ N/A (explain below) The County incorporates equal opportunity provisions into its policies and programs by ensuring that all new initiatives consider accessibility and nondiscrimination requirements. Program guidelines and policy discussions consistently highlight equal opportunity provisions, and departments are trained in compliance with Section 504 and ADA requirements. The Office of Civic Engagement and Human Resources undertakes specific effort to enhance opportunities for people with disabilities. 3. Does your agency provide opportunities when developing or amending its policies for qualified people with disabilities to participate as? Check applicable responses and explain efforts. N Staff - Specify efforts: New Hanover County provides equal opportunity for qualified individuals with disabilities to apply for and serve in staff roles related to the development and amendment of policies. The County's hiring process complies with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, including providing reasonable accommodations during recruitment, onboarding, and employment. Staff are notified of participation opportunities through official postings, countywide communication channels, and internal training programs to ensure accessibility. N Consultants/Panelists - Specify efforts: The County invites consultants, panelists, and subject matter experts, including qualified individuals with disabilities —to participate in advisory roles during policy development and amendment processes. Requests for proposals, panel solicitations, and professional service contracts include nondiscrimination clauses and accessibility requirements. When applicable, reasonable accommodations such as assistive technology, interpreters, and accessible meeting formats are provided to ensure meaningful participation. N Other - Specify efforts: The County also promotes public participation from qualified individuals with disabilities in stakeholder meetings, public hearings, and community engagement initiatives. Outreach efforts include publishing accessible meeting notices, offering virtual and in -person attendance options, ensuring ADA-compliant facilities, and making auxiliary aids available upon request. These efforts are designed to guarantee that residents with disabilities have full and equitable opportunities to contribute to the County's policy decisions. 4. How does your agency support any accommodation needed for visitors, staff, or other meeting participants who may have disabilities? (e.g., certified sign language or oral interpreter, a reader or taping printed material). Check applicable responses and explain if "other" is selected. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 5 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 110 0 Funds are set aside in the agency's administration budget for use by all offices? ❑ Access accommodation as line -item in the office's budget? N Other (Specify): Accommodations are handled on a case -by -case basis. 5. Is your agency able to modify its programs/activities, if necessary, to provide reasonable accommodation to individuals (staff or the public) with disabilities? 0 Yes: Click or tap here to enter text. ❑ No — Explain: Click or tap here to enter text. 6. Is agency staff aware that programs/activities may have to be modified in order to accommodate individuals with disabilities? 0 Yes: Internally, staff are trained and made aware of ADA requirements, including the obligation to provide reasonable accommodation to both members of the public and employees. Information on accommodation procedures is available through the Accessibility Committee, Human Resources, Civic Engagement, Risk Management and County policies. ❑ No — Explain: Click or tap here to enter text. 7. Does your agency notify individuals with disabilities that they may request reasonable accommodation, including modification of office policies? If so, please identify how such notification is provided, and to whom (public or staff)? N Yes: Public -Facing Notices: County meeting agendas, legal notices, and public hearing advertisements typically include an ADA accommodation statement. This statement informs members of the public that if they need accommodation (such as auxiliary aids, services, or policy modifications), they may request them in advance by contacting the County. County Website: The County's official website includes accessibility and ADA/504 compliance information, with instructions on how to request reasonable accommodation or modifications. A reasonable accommodation package is available. Meeting Locations: Signage and printed agendas at public meetings often include the accommodation statement as a standard practice. ❑ No — Explain: Click or tap here to enter text. 8. Are there any instances where your agency has been unable to modify a policy because such modification would either fundamentally alter the nature of the program, or result in an undue financial or administrative burden? ❑ Yes - Explain: Click or tap hereto enter text. 0 No — Explain: New Hanover County government has not identified any specific instances to date where a policy could not be modified due to a fundamental alteration of the program or because the modification would create an undue financial or administrative burden. However, the County recognizes that such circumstances could arise in limited situations. In those cases, the County is committed to conducting an individualized assessment, fully documenting the reasons CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 6 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 111 for the determination, and ensuring that alternative methods of providing accessibility are considered and implemented to the greatest extent feasible. This approach aligns with the requirements of Section 504 and the ADA, ensuring that individuals with disabilities continue to have meaningful access to County programs and services 9. Is access for people with disabilities a consideration when your agency undertakes special policy related efforts? ❑X Yes: Access for people with disabilities is always a consideration when New Hanover County undertakes special policy -related efforts. Public meetings are held in ADA-compliant facilities, notices include information on requesting accommodations, and materials can be provided in accessible formats upon request. Staff are trained to coordinate with ADA/504 compliance officers to ensure both physical and programmatic accessibility so that individuals with disabilities can fully participate in policy development and implementation. ❑ No — Explain: Click or tap here to enter text. 10. Do you have staff members who serve on an emergency evacuation committee to assist visitors and staff with disabilities? ® No — Explain: There is not an emergency evacuation committee. New Hanover County has staff members trained to assist with emergency evacuation procedures, including support for visitors and staff with disabilities, and staff is made aware of areas of refuge. As part of this process, designated staff are assigned specific evacuation duties and are trained to assist individuals with disabilities in safely exiting County facilities during an emergency. 11. Do staff members receive training in emergency evacuation? ® Yes: Employees receive information, annual instruction, and training from the Safety Committee and Risk Management, as well as participate in fire drills coordinated with New Hanover County Risk Management, to ensure preparedness. ❑ No — Explain: Click or tap here to enter text. 12. Please complete the chart below, using the following instructions (add more rows to the below table as needed): • Identify all of the policies and practices from your completed program policy section that do not or may not meet the requirements of Section 504, and may create barriers for individuals for individuals with disabilities. • List all proposed actions or actions that have been or will be taken by your Agency to modify your policies/practices to ensure compliance with Section 504. • Has the proposed action/action been identified as a financial and administrative burden? If so, how the conclusions were reached and list any alternative actions that may be CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 7 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 112 taken that do not constitute a financial and administrative burden. List target dates for which action may be taken by your Agency to modify your policies/practices. Barrier Proposed Could the action result in an undue Target date of Identified Actions/Modification to financial/admin. burden or alter the nature action Remove Barrier of the Program/Activity (if yes, explain conclusion and list alternatives) Lack of signage for Post clear ADA/504- TTY/relay compliant signage in all No undue burden. Cost minimal and Q1 2025 services in facilities and update absorbed in existing signage/printing budgets public wayfinding maps buildings Policy modifications not Establish formal policy consistently review checklist for all No undue burden —integrated into existing Ongoing, begin evaluated for new/amended policies to staff review workflows Q1 2025 impact on ensure 504 compliance persons with disabilities No centralized Create log/database to tracking monitor requests and No undue burden. Use existing County IT Q4 2025 system for systems with minimal adjustments accessibility agency responses requests CDBG-I Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 8 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 113 III. PROGRAM ACCESS This section evaluates the program local government access for individuals with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. 1. Describe the analysis of all programs and activities and all aid, benefits and services to determine the degree to which they are accessible to qualified handicapped persons: All programs and activities have been reviewed to ensure accessibility. Facilities and services are subject to ADA standards, and reasonable modifications are made when barriers are identified. Input from disability advocacy groups and individuals has been sought through public hearings and outreach activities. 2. Describe methods that have been used to involve handicapped persons (or organizations representing handicapped persons) in the development of activities designed to achieve program accessibility: New Hanover County consults disability advocacy groups, community organizations, and the public during planning and compliance activities. The county holds quarterly Accessibility Committee meetings to identify potential barriers and evaluate best practices. The committee invites input from organizations representing handicapped persons such as the disAbility Resource Center serving the Cape Fear Region. 3. Are there boards, councils or similar bodies on which program participants sit? ® Yes - List steps to ensure equal opportunities for selection to, and participation in, such boards by persons with disabilities: New Hanover County ensures equal opportunities for persons with disabilities to be selected for and participate in appointed boards and advisory committees by advertising vacancies through multiple channels with an ADA accommodation statement, evaluating applicants based on experience and qualifications without limitation due to disability, and holding all meetings in ADA-compliant facilities with accommodations available upon request. County staff supporting these boards also receive training on ADA/504 requirements to promote full and meaningful participation by members with disabilities. ❑ No — Please explain: Click or tap here to enter text. 4. Does the local government notify participants, applicants, beneficiaries, employees, unions of professional organizations, and the general public (posted notices, newspaper ads, office memoranda, etc.) that the grantee does not discriminate on the basis of disability in its federally assisted programs and activities? CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 9 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 114 N Yes - New Hanover County notifies the public about non-discrimination policies through multiple methods, including postings on the County's official website, inclusion in public meeting notices, services contracts, partnership agreements, and legal advertisements, and printed statements on key public documents and outreach materials. Information is also made available in County facilities, and accommodation statements are included to ensure accessibility and compliance with ADA/504 requirements. ❑ No- Modification or corrective action: Click or tap here to enter text. IV. PUBLIC OUTREACH This section evaluates the local government's public outreach for individuals with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. COMMUNICATION AND NOTIFICATION 1. Does the recipient engage in any meetings or oral presentations, printed materials, advertisements, or other methods to recruit program participants, or otherwise inform persons or the program's existence? N Yes- Describe briefly the activities involved and the materials used. New Hanover County engages in a variety of outreach methods to inform the public about the CDBG-I program and to encourage participation. Outreach includes public meetings and oral presentations where program details are discussed, legal advertisements and public notices published in local media, postings on the County's official website and social media, and the distribution of printed materials when appropriate. These methods are designed to reach a broad audience and ensure that residents, including those in low- and moderate -income areas, are aware of the program's existence and opportunities to participate. ❑ No —Explain Click or tap hereto enter text. 2. Has the local government taken appropriate steps to ensure effective communication with applicants, program participants, and members of the public by providing auxiliary aids where necessary so that individuals with speech, vision, or hearing impairments can have the opportunity to participate in, and enjoy the benefits of local government programs and activities? N Yes- Proceed to Question 3 ❑ No- Modification or corrective action: Click or tap here to enter text. 3. Describe approaches and special procedures adopted to ensure effective communications with project beneficiaries and/or members of the general public with disabilities, especially those vision, speech, and hearing impairments (Methods include, but are not limited to: provision or auxiliary aids or presentation or materials in alternative formats qualified sign CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 10 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 115 language and oral interpreters, readers, or the use of taped, large print, closed -captioned video, and Braille materials.) New Hanover County has taken appropriate steps to ensure effective communication with applicants, program participants, and members of the public by providing auxiliary aids and services when necessary. Reasonable accommodation would be provided when requested. This includes making assistive listening devices, sign language interpreters, large -print or alternative - format materials, and other accommodation available upon request. Public notices, advertisements, and meeting agendas include ADA accommodation statements with contact information so individuals with speech, vision, or hearing impairments can request assistance in advance. These measures ensure that all individuals can participate in and benefit from County programs and activities. 4. Describe how the local government advertises to the public availability of auxiliary aids and services for effective communication to participate in the local government programs and services. New Hanover County advertises the availability of auxiliary aids and services for effective communication through consistent inclusion of ADA accommodation statements in public meeting notices, legal advertisements, agendas, and outreach materials. These statements inform the public that auxiliary aids and services, such as sign language interpreters, assistive listening devices, or materials in alternative formats, are available upon request and provide contact information to arrange accommodation in advance. In addition, the County's official website and social media are used to share information about public meetings and programs, and these postings include instructions on how individuals with disabilities may request auxiliary aids to ensure full participation in local government programs and services. 5. Describe how the local government will ensure that meetings, hearings, and conferences will be accessible for individuals with communication disabilities. New Hanover County will ensure that meetings, hearings, and conferences are accessible for individuals with communication disabilities by holding all public gatherings in ADA-compliant facilities and providing auxiliary aids and services upon request. Accommodation statements are included in all meeting notices and agendas, advising the public of the availability of services such as sign language interpreters, assistive listening devices, and alternative -format materials. Requests for accommodation are coordinated through designated County staff to ensure timely arrangements. In addition, staff receive training on ADA/504 requirements to support effective communication and to ensure that individuals with communication disabilities have equal opportunity to participate in and benefit from County programs and activities. 6. Describe how an individual with a disability may request assistance and express their preference for auxiliary aids and services from the local government. An individual with a disability may request assistance and express their preference for auxiliary aids and services from New Hanover County government by contacting the designated staff member listed in public notices, agendas, or advertisements. Each notice includes an ADA accommodation statement with a phone number and/or email address where requests can be submitted in advance of a meeting or program. When making a request, the individual may specify the type of auxiliary aid or service they prefer —such as a sign language interpreter, assistive listening device, or materials in CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 11 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 116 large print or electronic format —and the County will work to provide the requested accommodation to ensure full participation. 7. Describe how the local government will provide auxiliary aids or services on request. New Hanover County government will provide auxiliary aids or services upon request by coordinating with the individual to identify their specific needs and preferred method of communication. Once a request is received through the contact information provided in public notices, agendas, or advertisements, County staff arrange for the appropriate aid or services such as sign language interpreters, assistive listening devices, large -print or Braille materials, or electronic formats —in advance of the meeting, program, or service. The County works to ensure that these accommodations are available at no cost to the individual, allowing full and equal participation in all government programs, services, and activities. 8. List steps to ensure inclusion or a notice of the recipient's compliance with Section 504 in all materials and advertisements. New Hanover County ensures inclusion of a Section 504 compliance notice in all materials and advertisements by standardizing the use of non-discrimination and accommodation statements, training staff to apply these requirements consistently, and reviewing documents prior to release. The notice is included across all communication platforms —such as print media, the County website, and social media —and always provides clear contact information for individuals requesting accommodation or raising concerns, thereby ensuring compliance and equal access. 9. Has the local government installed a reader, developed Braille materials, audio recordings or other similar services and devices for persons with impaired vision? ® Yes ❑ No - Modification or corrective action: Click or tap here to enter text. 10. Does the recipient provide services or information to the general public over the telephone? ❑ Yes- There is a teletypewriter (TTY - also referred to as a Telecommunication Device for the Deaf - TDD) or other equally effective system available so that public entities can communicate with individuals with hearing or speech impairments? ® NO- List steps to ensure effective communications with individuals with hearing or speech impairments. This can include providing a TTY or relying on a third party relay service. The Justice Department encourages public entities that have extensive phone contact with the public to have TTYs to assure more immediate access. If required, NC Relay service will be used. NC Relay is free telecommunication services that enable people who are Deaf, Hard of Hearing, or Deafblind, to place and receive phone calls. 11. What is the TTY/TDD number listed in directories and disseminated information? N/A: NC Relay service would be used. Text Telephone/Teletypewriter (TTY) Relay Service 711 or 800-735-2962 for English 888-825-6570 for Spanish CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 12 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 117 12. Is signage concerning the location of TTY-equipped pay phones or portable TTYs available? ❑ Yes ❑N No -Modification or corrective action: Update public communications to add TTY symbols reflecting locations where TTY services are available. 13. Are all 911 emergency response centers equipped with TTYs or other equally effective technology to make the service accessible to individuals with hearing or speech impairments? Separate, seven -digit phone numbers and/or reliance on a third -party relay service is not an acceptable alternative for making 911 services accessible. ® Yes ❑ No- Modification or corrective action: Click or tap hereto enter text. 14. Is signage at inaccessible entrances directing people with disabilities to an accessible entrance or a location with information about an accessible entrance? ❑X Yes ❑ No- Modification or corrective action: Click or tap here to enter text. 15. What steps, if any, have been taken to ensure that all of the programs' web site(s) are accessible? New Hanover County ensures its program websites are accessible by designing them in compliance with Section 508 and WCAG 2.0 A and AA standards, supporting common assistive technologies such as JAWS, NVDA, and VoiceOver, and enabling full keyboard -only navigation. The County provides an accessibility statement on its website with contact information for users to request materials in alternative formats or report issues and offers guidance on browser accessibility tools and Adobe Reader resources for screen reader compatibility. Users are encouraged to provide feedback to support continuous improvement and ensure equal access to all online programs and services. Web site reviews are conducted by the Communications Department along with a contracted service to evaluate web accessibility. 16. List all local government activities where a sign language and/or oral interpreter, readers, and assistive listening devices might be needed to ensure that persons with hearing and visual impairments can fully participate in the program or activity (e.g. securing services in expeditious manner, department responsible for ensuring such services, policy source and date, date policy distributed to stafj). County Meetings and Hearings • Board of Commissioners meetings • Planning Board meetings • Board of Adjustment hearings • Other appointed boards and advisory committee meetings • Public hearings on ordinances, rezonings, budgets, and policy updates Public Engagement & Community Programs CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 13 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 118 • Community workshops and open houses (e.g., Comprehensive Plan forums, environmental initiatives) • Public information sessions (such as emergency preparedness briefings or development updates) • Library programs, lectures, and community classes • Parks and Recreation events, including camps, cultural events, and public programs Government Services & Transactions • Services provided at the Government Center (planning and permitting counters, tax office, elections office) • Public health clinics, outreach events, and educational programs • Social services intake, interviews, and assistance programs Legal and Judicial -Related Proceedings • Quasi-judicial hearings before the Board of Adjustment or Planning Board • Public hearings involving appeals, variances, or special use permits Emergency and Safety Programs • Emergency management presentations and training sessions • Fire and rescue safety education events • Disaster preparedness and recovery information sessions Employment and Staff Training • Job interviews for applicants with disabilities • New employee orientations • Staff training sessions or workshops INFORMATION DISSEMINATION 1. Can copies of written materials be reasonably obtained by individuals with disabilities? ❑N Yes ❑ No 2. Have disability groups been included in the dissemination process? ❑X Yes ❑ No 3. Does the local government use all available print and broadcast media to ensure that all individuals with disabilities receive appropriate notification? ® Yes ❑ No 4. Does the local government disseminate information to all agencies or organizations that deal with persons with disabilities in the local government service jurisdiction? ❑X Yes ❑ No 5. Does all of the information disseminated by the local government include current non- discrimination polices? ® Yes ❑ No CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 14 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 119 If there are NOs to any of the above questions (#1-5), you must provide a modification or corrective action below: Click or tap here to enter text. PRINTED MATERIALS 1. Are written materials including posters with non-discrimination notices placed in physically accessible locations? ❑N Yes ❑ No 2. Can small print of posted announcements be read from a wheelchair? ❑X Yes ❑ No 3. Are all words in printed materials clearly legible? ❑X Yes ❑ No 4. Would color blind individuals be able to distinguish all contents in printed materials? ❑X Yes ❑ No 5. Are representations of disabled individuals free of patronizing stereotypes? ❑X Yes ❑ No 6. Do graphics in printed material permit easy reading of the contents? ❑x Yes ❑ No 7. Is all necessary program information included in printed material? ❑x Yes ❑ No 8. Are procedures for providing program access to disabled individuals stated clearly? ❑X Yes ❑ No 9. Do all appropriate local government documents include policy statements about non- discrimination on the basis of disabilities? 0 Yes ❑ No 10. Are the Section 504 contact person's name, address, and phone number listed in printed material? 0 Yes ❑ No CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 15 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 120 If there are NOs to any of the above questions (#1-10), you must provide a modification or corrective action below: Click or tap here to enter text. V. PROGRAM ELIGIBILITY/ADMISSION CRITERIA This section evaluates the local government's program eligibility and admission criteria for individuals with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. 1. Are there any limitations on the number of qualified persons with disabilities who may participate in or be admitted to the program? ❑ Yes - List steps to be taken to eliminate the limitations. Click or tap here to enter text. ® No 2. Has the local government examined all policies pertaining to program eligibility and admission criteria to determine if they had the purpose or effect of excluding or limiting the participation of individuals with disabilities in local government's programs and activities? © Yes ❑ No- Modification or corrective action: Click or tap here to enter text. 3. Has the local government, in examining its polices on program eligibility and admission criteria, paid particular attention to those incorporating or establishing: (1) physical or mental fitness or performance requirements; (2) safety standards; (3) testing requirements; (4) educational requirements; (5) work experience requirements; (6) income level requirements (7) credit rating requirements; (8) requirements based on disability; (9) requirements that prohibit participation because of disability; and (10) insurability requirements? ® Yes ❑ No- Modification or corrective action: Click or tap hereto enter text. 4. Has the local government altered or eliminated policies that have the direct or indirect effect of excluding or limiting the participation of individuals with disabilities in local government's programs and activities? ❑ Yes - List any policies that have been altered or eliminated. Click or tap here to enter text. ❑ No - Modification or corrective action: Click or tap here to enter text. ® N/A - Explain (e.g. no such policies found in review), then proceed to Question 6. New Hanover County's stated practice is to ensure compliance with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act by providing reasonable accommodations, maintaining non-discrimination policies, and ensuring equal access to services, CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 16 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 121 programs, and activities. County policies and procedures are structured to prevent exclusion and to remove barriers rather than to create them. 5. Has the local government communicated the policy changes to staff members and the public? ❑N Yes ❑ No- Modification or corrective action: Click or tap here to enter text. 6. Are any criteria or tests used in the admission process? ❑ Yes Proceed to Question 7 ❑X No - Proceed to Question 8 7. List all criteria (e.g., good health, residency requirements, letters of recommendation) and tests (including the skill, level of achievement, or other factors being tested, whether they are written or oral tests and the method of administration) used in the admissions process, that have or could have a disproportionately adverse impact on program applicants with disabilities. Discuss briefly the potential negative impact for each and indicate how they relate to the program. Discuss alternative criteria or tests that will be used to ensure nondiscrimination. The use of a criterion or test may have to be suspended as long as this does not result in an undue hardship or fundamental alteration to the program. New Hanover County has no criteria, tests, or similar activities which limit accessibility of individuals with disabilities. The only criteria used are those critical to the performance of a particular activity requirement which cannot be altered with accommodations. 8. List steps to be taken to make potential program participants, including those with hearing and vision impairments and learning disabilities, aware of alternative testing/criteria and interview processes. New Hanover County will ensure potential CDBG-I program participants, including those with hearing, vision, or learning disabilities, are aware of alternative criteria, testing formats, and interview processes by including accessibility notices in all advertisements and applications, providing information through multiple accessible channels, and offering staff assistance to explain requirements and coordinate accommodations such as interpreters, readers, or extended time. Program staff are trained to respond to accommodation requests, and all notices include clear contact information for the ADA/504 coordinator to ensure equal access. 9. List steps to provide admission forms in alternative formats. New Hanover County will respond to reasonable accommodation requests by providing admission forms in alternative formats by making them available in large print, Braille, and electronic text upon request, ensuring digital forms meet Section 508 and WCAG accessibility standards, and offering staff assistance for individuals unable to use standard formats. All materials include an ADA accommodation statement with contact information for requesting alternative formats, and the County ensures requested forms are delivered promptly to avoid delays in participation. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 17 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 122 10. List steps to ensure that applicants are not asked pre -admission inquiries as to the nature and extent of a disability, and that no forms or other written materials make mandatory inquiries related to disability. New Hanover County ensures that applicants are not asked pre -admission questions about the nature or extent of a disability by maintaining application forms and materials free of mandatory disability -related inquiries, training staff on ADA/504 requirements, and adopting policies that prohibit such practices. Disability information is only requested when an applicant voluntarily seeks accommodation, and staff provide guidance on how to request assistance without requiring disclosure of medical details. Forms and procedures are periodically reviewed to confirm ongoing compliance. VI. PROGRAM PARTICIPATION This section evaluates the local government's program participation for individuals with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. 1. Are post -admission inquiries made regarding disability status to make accommodations for persons with disabilities? ❑X Yes - List steps to ensure that information is gathered voluntarily, not used to adversely affect any person with a disability and kept confidential. Post -admission inquiries may be made solely for the purpose of arranging reasonable accommodation for individuals with disabilities. New Hanover County does not require disclosure of disability status; however, once an individual is admitted or enrolled in a program, staff may ask if accommodations are needed and coordinate auxiliary aids or services —such as interpreters, assistive listening devices, or alternative -format materials —to ensure equal access and full participation. ❑ No 2. Is there an orientation for new participants? ® Yes - Describe briefly the orientation and materials used, and list steps to ensure effective communications and usable materials in alternative formats for all participants. New Hanover County provides an orientation for new participants that includes an overview of program goals, requirements, schedules, and available services. Orientation materials typically include written guides, presentations, and handouts, along with access to staff for questions and assistance. To ensure effective communication for all participants, including those with disabilities, the County makes materials available in alternative formats such as large print, Braille, plain language, and electronic text, and ensures digital documents meet Section 508 and WCAG standards for screen readers. Auxiliary aids —such as sign language interpreters, assistive listening devices, and captioning —are provided upon request. Staff are trained in CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 18 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 123 ADA/504 compliance to ensure all orientation communications are accessible, usable, and nondiscriminatory. ❑ No 3. Review all written materials, tools, equipment or other aids or devices used for the program. Do any need modification? N Yes - List steps such as the provision of auxiliary aids and equipment modification to ensure that program materials and equipment are accessible and usable. New Hanover County provides orientation through written program guides, public notices, and staff presentations that explain program requirements, participation procedures, and available resources. Materials are made accessible by offering large print, Braille, electronic text, and plain -language versions upon request, and by ensuring digital documents comply with Section 508 and WCAG standards for use with screen readers. To ensure effective communication, the County includes ADA accommodation statements in all notices, provides auxiliary aids such as sign language interpreters and assistive listening devices when needed, and trains staff to respond promptly to requests. These steps guarantee that all participants, including those with hearing, vision, or learning disabilities, receive usable materials in alternative formats and can fully engage in County programs. ❑ No 4. Would any steps pose an undue financial or administrative burden? ❑ Yes- List alternative methods of providing accessibility that would not impose an undue financial or administrative burden. FI � 5. Are any of the following services or benefits provided to program participants? (Check all that apply. If none provided, proceed to Question 6.) None ❑ Transportation services ❑ Health services and insurance/benefits ❑ Housing ❑ Counseling services ❑ Employment services ❑ Food services ❑ Financial aid ❑ Social, recreational or athletic activities 6. List steps to ensure that information concerning program schedules and activities are effectively communicated to all program participants, including those with impaired vision, speech, and hearing. • List steps to ensure that: • The service/benefit is equally effective for and usable by persons with disabilities. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 19 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 124 The administration of the service/benefit will be free from discrimination based on disability. Communications will reach all persons, including those with hearing and sight impairments. Effective application procedures to receive the services exist for persons with disabilities, including those with hearing and vision impairments New Hanover County ensures program schedules and activities are effectively communicated to all participants, including those with vision, speech, and hearing impairments, by providing notices in multiple accessible formats (large print, Braille, electronic text), offering auxiliary aids such as interpreters, captioning, and assistive listening devices, and ensuring all digital postings meet Section 508 and WCAG standards. Information is distributed through varied channels with ADA accommodation statements and clear contact information, while staff are trained to administer services free from discrimination. Application forms are available in alternative formats with staff assistance as needed, ensuring equally effective, accessible, and nondiscriminatory participation for all individuals with disabilities. VII. EMPLOYMENT POLICY AND PRACTICE This section evaluates the local government's employment policy and practices to ensure equal opportunity employment for persons with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. GENERAL 1. Describe and discuss safeguards that have been used to ensure that all employment decisions are made without discrimination on the basis of handicap, and that such decisions do not limit, segregate or classify applicants or employees based on handicap in a way that adversely affects their opportunities or status. New Hanover County ensures that all employment decisions are made without discrimination on the basis of disability by maintaining and enforcing equal employment opportunity policies consistent with the Americans with Disabilities Act. Employment decisions are based solely on job -related qualifications and the ability to perform essential job functions, with or without reasonable accommodation. Safeguards include training for supervisors and hiring officials, accurate job descriptions that identify essential functions, a structured process to provide reasonable accommodations, and strict confidentiality of medical information. The Human Resources Department reviews employment practices to ensure compliance and provides employees with clear avenues to raise concerns. These safeguards collectively prevent applicants or employees from being limited, segregated, or classified in a manner that would adversely affect their opportunities or status. 2. Describe procedures that have been established to make certain that there are no formal relationships regarding employment (e.g. those with labor unions, employment agencies, and so forth) that have the effect of discriminating against qualified persons with disabilities. New Hanover County does not maintain any formal relationships with labor unions, as collective bargaining agreements for public employers that are prohibited under North Carolina law, nor with external employment agencies that would restrict or adversely affect the employment opportunities CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 20 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 125 of qualified persons with disabilities. Recruitment and hiring are managed directly by the County's Human Resources Department, which ensures that all vacancies are publicly advertised and accessible to any qualified applicant. Employment opportunities are posted on the County's website and through other broad recruitment sources to reach a diverse applicant pool, including protected groups. All recruitment announcements contain equal employment opportunity assurances, and the County's EEO Policy strictly prohibits discriminatory practices by any party involved in the hiring process. By retaining direct oversight of recruitment, selection, and onboarding, and by requiring that all personnel decisions are based on job -related qualifications and the ability to perform essential duties with or without reasonable accommodation, the County ensures that no external or internal employment relationships create barriers for applicants or employees with disabilities. 3. Does the local government have 15 or more employees (full or part-time)? ❑N Yes ❑ No 4. Do the local government's hiring and promotion practices prohibit discrimination against otherwise qualified handicapped individuals (not a separate policy)? ® Yes- Proceed to Question 5. ❑ No -Modification or corrective action: Click or tap hereto enter text. 5. Analyze the following aspects of employment and describe any alterations to make certain that no discrimination based on disability exists, including discrimination that occurs due to an inaccessible facility: • Recruiting and advertising. • Processing applications. • Interviewing and orientation. • Hiring, upgrading, promotion, award of tenure, demotion, transfer, layoff, termination, right of return from layoff and rehiring. • Rates of pay or any other form of compensation and changes in compensation. • Job assignments, job classifications, organizational structures, position descriptions, lines of progression and seniority lists. • Leaves of absence, sick leave or any other leave. • Fringe benefits (opportunities for and financial support of training opportunities, conferences, health and insurance benefits) available by virtue of employment, regardless of whether they are administered by the recipient. • Selection and financial support for training, including apprenticeship, professional meetings, conferences and other related activities, and selection for leaves of absence to pursue training. • Employer -sponsored activities, including social and recreational programs. • Any other term, condition or privilege of employment. Recruiting and Advertising New Hanover County's Human Resources Department manages all recruitment postings and ensures that vacancies are advertised widely through the County's website and other sources, always including equal employment opportunity assurances. Advertisements are provided in a format accessible to individuals with visual impairments (e.g., screen -reader compatible postings, large -print notices upon request). Processing Applications CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 21 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 126 Applications are processed centrally by Human Resources, with screening based strictly on job -related qualifications, skills, and experience. The County maintains an accessible online application portal compliant with ADA standards, provides alternative submission formats when needed, and ensures that disability -related accommodations requested in the application process are consistently honored. Interviewing and Orientation Structured interviews are used, and evaluations are based on qualifications and the ability to perform essential duties with or without reasonable accommodation. Interview sites are physically accessible, and accommodations such as ASL interpreters or accessible technology are available upon request by the applicant. Orientation materials are provided in accessible formats, including captioned videos and screen - reader compatible documents. Hiring, Promotion, and Employment Status Changes All employment decisions —including hiring, upgrading, promotion, demotion, transfer, layoff, termination, and return from layoff —are based on job -related qualifications and the ability to perform essential duties with or without reasonable accommodation. The County tracks these decisions to ensure equity and maintains clear procedures to guarantee that employees returning from disability -related leave may return to their position or an equivalent role without adverse impact. Compensation and Pay Practices The County's EEO Policy prohibits discrimination in compensation. The County maintains a structured pay plan, with positions assigned to specific grades that include minimum, market (midpoint), and maximum rates of pay. Human Resources is responsible for administering and maintaining the position classification and compensation plans, reviewing market data, and ensuring that employees with disabilities receive equal pay for equal work, with accommodations having no adverse effect on compensation. Job Assignments and Organizational Structures Assignments, classifications, and progression opportunities are based on skills and qualifications. The County provides reasonable accommodations such as modified duties, assistive technology, and flexible scheduling when appropriate, and supervisors are trained to avoid assumptions that could limit opportunities for employees with disabilities and recognize requests for disability related accommodations. Leave Policies Employees have access to a variety of leave benefits, and the County is in full compliance with the Family and Medical Leave Act (FMLA), the Americans with Disabilities Act (ADA), and the Americans with Disabilities Act Amendments Act (ADAAA). Disability -related leave, including intermittent leave for medical treatment, is administered equitably and does not negatively affect promotion or return -to -work opportunities. Fringe Benefits All employees have equal access to health insurance and training benefits. Health plans do not exclude disability -related coverage, and training opportunities are provided in accessible facilities or with necessary accommodations as requested. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 22 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 127 Training and Professional Development Employees with disabilities have equal access to professional development, conferences, and other training opportunities. Selection processes are reviewed for fairness, and accommodations such as interpreters or assistive devices are provided when needed. Employer -Sponsored Activities County -sponsored programs, social events, and recreational activities are held in ADA-compliant facilities, with accommodations provided to ensure full participation by employees with disabilities. Other Terms, Conditions, or Privileges of Employment The County's overarching safeguard is its EEO Policy, which prohibits any discrimination in the terms, conditions, or privileges of employment. Ongoing staff training emphasizes ADA and Section 504 of the Rehabilitation Act compliance, employees have a grievance process to report concerns, and the County routinely evaluates its facilities, policies, and practices to identify and remove barriers. Summary New Hanover County's employment practices are fundamentally aligned with equal opportunity standards. By ensuring physical and digital accessibility, maintaining clear accommodation procedures, and monitoring employment practices across all stages of the employment relationship, the County safeguards against discrimination and ensures that applicants and employees with disabilities are fully included and afforded equal opportunity. EMPLOYMENT CRITERIA 1. Does the local government administer tests which accurately reflect the applicant's or employee's job skills or aptitude rather than the applicant's or employee's impaired sensory, manual, or speaking skills (except where those skills are the factors that the test is designed to measure)? ❑ Yes - Please answer Question 2. ❑ No - Modification or corrective action: Click or tap here to enter text. © N/A - Explain (e.g. no such test/criteria used), then proceed to Next Section: Pre -Employment Inquiries. New Hanover County does not administer pre -employment or promotional tests that measure sensory, manual, or speaking skills unless those abilities are essential to the position being filled. When tests are used, they are designed to evaluate the applicant's or employee's job -related knowledge, skills, and aptitude in relation to the essential duties of the position. In keeping with the Americans with Disabilities Act, the County provides reasonable accommodations during testing —such as extended time, alternative formats, or assistive technology —so that individuals with impaired sensory, manual, or speaking skills are not disadvantaged. This ensures that any assessment accurately reflects the person's qualifications and ability to perform the essential duties of the job, rather than the impact of a disability. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 23 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 128 2. What employment tests or criteria are used for judging potential employees and describe procedures to ensure that these criteria or tests do not discriminate against persons with disabilities, unless they are shown to be consistent with job necessity? New Hanover County evaluates potential employees based on job -related criteria that are directly tied to the essential duties of the position. The County does not use general aptitude or physical ability tests that could have the effect of screening out persons with disabilities unless those skills are demonstrably required for the performance of essential job functions. When employment assessments are used, they are validated for job necessity and administered in a manner that ensures equal opportunity. In accordance with the Americans with Disabilities Act, reasonable accommodations —such as alternative testing formats, extended time, or assistive technology —are provided to ensure that applicants with disabilities are evaluated on their actual skills, knowledge, and ability to perform essential duties, rather than the impact of a disability. 3. If the local government uses an employment test or other criteria for selection that screens out or tends to screen out individuals with disabilities, can the local government show that the test score or other selection criteria is job related? ❑ Yes - Please answer Question 4. ❑ No - Modification or corrective action: Click or tap here to enter text. ❑x N/A - Explain (e.g. no such test/criteria used), then proceed to Next Section: Pre -Employment Inquiries. Click or tap here to enter text. 4. Describe methods to identify the job -related characteristics of tests and criteria used in employment decisions, since job -related tests are permitted even if they screen out persons with disabilities. New Hanover County ensures that any tests or criteria used in employment decisions are directly tied to the essential duties and responsibilities of the position. Job analyses and classification studies are conducted by the Human Resources Department to identify the knowledge, skills, and abilities necessary for successful performance. Position descriptions specify these essential duties, and any assessment methods —such as structured interviews, required certifications, or skills demonstrations —are selected and validated against those identified requirements. In accordance with the Americans with Disabilities Act, reasonable accommodations are provided so that applicants with disabilities are not unfairly excluded. This process ensures that all tests and criteria measure legitimate, job -related characteristics and are consistent with business necessity, and are consistent with business necessity, measuring only the ability to perform essential job duties with or without reasonable accommodation. PRE -EMPLOYMENT INOUHUES 1. Describe steps to ensure that no pre -employment inquiries are made as to whether an applicant is a person with a disability or as to the nature or severity of a disability. Is the local government aware that it cannot make a pre -employment inquiry or conduct a medical examination of an applicant to determine whether the individual is a person with disability unless the local government is undertaking affirmative action efforts or conditioning an offer of employment on the results of a medical examination given to all prospective employees in the same job category? © Yes - Proceed to Question 2. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 24 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 129 ❑ No - Modification or corrective action: Click or tap here to enter text. 2. Does your organization conduct or require any medical examinations after making conditional offers of employment? Has the local government informed job applicants that an employment offer may be conditioned on the results of a medical examination if all entering employees in a job category must take an examination regardless of disability, and the examination accurately reflects the employee's job skills? ❑X Yes - Proceed to Question 3. ❑ No - Modification or corrective action: Click or tap here to enter text. 3. Has the information obtained by the local government concerning the medical condition or history of job applicants been collected and maintained on separate forms and accorded confidentially as medical records? ❑N Yes - Describe procedures to ensure that (a) all employees entering that position are subject to medical exams, (b) all offers of employment are conditional based on the results of the exams, (c) the medical results gathered arc not used in a discriminatory manner, and (d) all information gathered is kept confidential. When medical information is obtained during the hiring process, New Hanover County collects it on separate forms and maintains it in confidential files in accordance with the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and applicable state law. Only a limited number of positions require a post -offer, pre -employment physical examination, and when required, the following safeguards apply: (a) All individuals entering the same job category are subject to the same post -offer medical examination, administered only after a conditional offer of employment is made. (b) All offers of employment are explicitly conditional upon the results of the examination, which are reviewed only to confirm the applicant's ability to perform the essential duties of the position with or without reasonable accommodation. (c) Medical results are used strictly to determine fitness for duty and are never applied in a manner that would discriminate against qualified individuals with disabilities. If a reasonable accommodation enables performance of the essential duties, the applicant remains eligible for employment. (d) All medical information is stored in separate, confidential medical files apart from personnel records and maintained in strict compliance with federal and state confidentiality requirements. These safeguards align with the County's Equal Employment Opportunity Policy and ensure that all medical information is obtained, used, and maintained in a manner that is consistent, confidential, and nondiscriminatory, protecting the rights and opportunities of qualified applicants and employees with disabilities. ❑ No- Modification or corrective action: Click or tap here to enter text. 4. Review job application forms and interview questions to ensure that applicants are not asked about the existence of or nature or severity of a disability. Inquiries about the candidate's ability to perform job functions are permitted. Ensure that applicants are not asked about their relationship or association with an individual with a disability. List any job forms and questions that were amended. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 25 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 130 New Hanover County has reviewed its job application forms and interview questions to ensure full compliance with the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. Applicants are not asked whether they have a disability, nor about the nature or severity of any disability, and no questions are permitted regarding an applicant's relationship or association with an individual with a disability. Instead, inquiries are limited to whether the applicant can perform the essential functions of the position, with or without reasonable accommodation. Human Resources reviewed standardized application forms and hiring guidance and confirmed they could not be interpreted as seeking medical or disability -related information, and ensured that all materials focus strictly on qualifications, skills, and the ability to perform job duties. Interview training materials were reviewed and confirmed to reinforce that only job -related, performance - based questions are permitted, and that discussions of accommodation occur solely in the context of enabling performance of essential functions. 5. Review existing job descriptions for each job position in your organization. Determine the essential and marginal functions of job positions in the organization and identify what job accommodations can be made, when necessary, for an applicant or employee. List any job descriptions that were amended. New Hanover County maintains formal job descriptions for all classified positions, developed through its position classification and pay plan system. Each job description identifies the essential duties and responsibilities of the position, as well as any marginal functions that may be performed. These descriptions are periodically reviewed by the Human Resources Department in consultation with department leadership to ensure they remain accurate and job -related. In compliance with the Americans with Disabilities Act, essential functions are distinguished from non -essential tasks so that reasonable accommodations can be identified and provided when necessary. Examples of accommodations may include modified work schedules, job restructuring, provision of assistive technology, or reassignment of marginal duties. No recent amendments to job descriptions have been required solely for compliance purposes; however, job descriptions are updated as positions evolve to ensure they remain accurate, and the County's accommodation process provides flexibility to address individual employee needs without altering the integrity of essential job functions. 6. Describe any training or other measures taken to ensure that employees and supervisors do not subject individuals with disabilities to discrimination because insensitivity or lack of knowledge. New Hanover County provides regular training and guidance to employees and supervisors to ensure a workplace free from discrimination, including discrimination against individuals with disabilities. All employees receive orientation on the County's Equal Employment Opportunity (EEO) Policy, which prohibits discrimination on the basis of disability as well as training on workplace harassment and fostering a respectful workplace where all employees feel respected and valued. Supervisors and hiring managers receive additional training on fair employment practices, including how to evaluate applicants and employees based on job -related qualifications and the ability to perform essential duties with or without reasonable accommodation, as well as procedures for accommodation requests. The Human Resources Department distributes updated policies and procedures to staff, reinforcing expectations of nondiscriminatory practices and respectful workplace conduct. Annual and refresher training available to all employees includes topics such as FMLA and CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 26 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 131 medical leave, ADA/Section 504 requirements, accessibility in recruitment and hiring, preventing workplace harassment, and fostering inclusive environments. Employees are also informed of grievance and complaint procedures to ensure that any incidents of discrimination or insensitivity can be reported promptly and addressed. These measures not only prevent unintentional bias that may result from insensitivity or lack of knowledge but also ensure accountability and compliance with federal nondiscrimination requirements. 7. When the local government is undertaking affirmative action efforts, voluntary or otherwise, and inviting applicants for employment to indicate whether and to what extent they are disabled, does the local government meet the following conditions: a. State clearly either orally or in writing that the requested information is intended for the local government's affirmative action efforts? N Yes ❑ No b. State clearly that the information is being requested on a voluntary basis, that it will be kept confidential and that refusal to give the information will not subject the applicant or employee to any adverse treatment? N Yes ❑ No If there are NOs to any of the above questions(#a —b) you must provide a modification or corrective action: Click or tap here to enter text. VIII. OUTSIDE PERSONS AND ORGANIZATIONS This section evaluates the local government's use and interaction with outside persons and organizations persons with disabilities. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. 1. List below all outside persons and organizations that are involved in the provision of any aid, benefit or service for the program as discussed in Sections II through IX. Include secondary recipients in your discussion. New Hanover County partners with a range of outside persons, agencies, and organizations in the provision of aid, benefits, and services to the public. These partnerships include both primary providers and secondary recipients who deliver programs and services on behalf of the County. Examples include: State and Federal Agencies — The County coordinates with the North Carolina Department of Health and Human Services, the North Carolina Department of Environmental Quality, and federal agencies administering programs such as CDBG and FEMA disaster recovery. Regional and Local Partners — Collaborations occur with the Wilmington Metropolitan Planning Organization (WMPO), Cape Fear Public Utility Authority (CFPUA), New Hanover County Schools, and Cape Fear Community College to deliver transportation, infrastructure, educational, and training services. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 27 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 132 Nonprofit and Community -Based Organizations — The County works with local nonprofits and advocacy groups such as Cape Fear Habitat for Humanity, Good Shepherd Center, Disability Resource Center (formerly disAbility Resource Center), and Coastal Horizons to provide housing, shelter, counseling, and supportive services. Private Contractors and Consultants — The County contracts with private engineering firms, planning consultants, and healthcare providers for specific projects and services (e.g., Coastal Protection Engineering, P1anIt Geo for environmental studies, and medical providers for occupational health screenings). Secondary Recipients — Subgrantees or subcontractors receiving federal or state funds through the County, such as local housing developers or community service agencies, are also required to comply with ADA and Section 504 nondiscrimination provisions. As part of all contractual agreements, New Hanover County requires compliance with federal and state nondiscrimination laws, including assurances that persons with disabilities are not excluded from or denied the benefits of any aid, service, or program. The County monitors these relationships to ensure accessibility and equal opportunity in the delivery of services. 2. List steps to inform those listed in Question Number #1 of the organization's commitment to nondiscrimination on the basis or disability. New Hanover County takes multiple steps to ensure that all outside persons, organizations, contractors, and secondary recipients are fully informed of the County's commitment to nondiscrimination on the basis of disability: Contractual Assurances — All contracts, grant agreements, and memoranda of understanding include nondiscrimination clauses requiring compliance with federal and state equal opportunity laws, including Section 504 and the ADA. These provisions explicitly prohibit discrimination against persons with disabilities. Public Notices and Policies — The County publishes its Equal Employment Opportunity and Nondiscrimination Policies on its website, in bid solicitations, and in program -related documents, making clear to outside entities that nondiscrimination is a condition of partnership. Grant & Subrecipient Monitoring — Subrecipients and contractors receiving federal or state funds are required to sign compliance assurances and are subject to monitoring by County staff to verify adherence to accessibility and nondiscrimination standards. Training and Guidance — County staff provide orientation and technical assistance to contractors and partner organizations on ADA/Section 504 requirements, ensuring awareness of obligations to provide equal access for individuals with disabilities. Complaint Procedures — All outside organizations are notified of the County's established grievance procedures, which allow individuals to report concerns about accessibility or discrimination. Partners are expected to cooperate in resolving such complaints promptly. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 28 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 133 Through these steps, New Hanover County ensures that its nondiscrimination commitment is communicated clearly, contractually binding, and reinforced through ongoing oversight and technical support. 3. List those persons or organizations from Question Number #1 that receive significant assistance from the organization in the provision of aids, benefits or services to program participants. For example, list organizations which rent or otherwise use your facilities; that depend on your organization for informing its participants of the aid, benefit or service; that have employees of your organization spending time to assist in or coordinate the provision of the aid, benefit or service; and so forth. New Hanover County provides significant assistance to a number of outside organizations in the delivery of aids, benefits, and services to program participants. Examples include: Cape Fear Public Utility Authority (CFPUA) — The County partners closely on water and sewer extension projects, such as the Scotts Hill Water Main Extension, providing funding, staff coordination, and facility support. Wilmington Metropolitan Planning Organization (WMPO) — County staff participate in planning and coordination of regional transportation projects, ensuring that services and outreach are accessible to all community members, including those with disabilities. New Hanover County Schools and Cape Fear Community College — County facilities are used for joint programs, meetings, and training initiatives that support educational and workforce development services. Nonprofit Service Providers (e.g., Good Shepherd Center, Coastal Horizons, Disability Resource Center, Cape Fear Habitat for Humanity) — These organizations receive County support through grant funding, program coordination, and joint outreach, with County staff often providing technical assistance or referral services. Contracted Consultants and Service Providers — Finns such as Coastal Protection Engineering and P1anIt Geo rely on County staff, data, and facilities to conduct environmental, planning, and infrastructure studies that ultimately provide services to the public. Community -Based Programs and Events — Nonprofits and civic groups rent or utilize County facilities (e.g., Government Center meeting rooms, libraries, parks, and community centers) to host events, programs, and outreach activities that extend benefits to residents. In each of these partnerships, the County provides resources such as funding, use of facilities, staff time, data support, and communication channels to ensure that programs are effectively delivered. All organizations receiving such significant assistance are required to comply with ADA and CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 29 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 134 Section 504 requirements to guarantee accessibility and nondiscrimination for individuals with disabilities. 4. List steps to ensure that persons or organizations listed in Question Number #3 do not discriminate on the basis of disability in the provision of any aid benefit or service to your program participants. Such steps may include changes in the program, facility alterations, and/or changes in or discontinuation of the relationship. New Hanover County has established multiple safeguards to ensure that outside persons, organizations, and secondary recipients receiving significant assistance do not discriminate on the basis of disability in the provision of any aid, benefit, or service. These steps include: Contractual Requirements — All agreements with contractors, subrecipients, and partner organizations include ADA/Section 504 nondiscrimination clauses, requiring compliance as a condition of receiving County funding, facility access, or other support. Monitoring and Oversight — County staff conduct program and financial monitoring of subrecipients to confirm that services are provided in an accessible and nondiscriminatory manner. This includes reviewing policies, inspecting facilities, and evaluating complaint records. Accessibility of Facilities — Partners using County facilities (such as libraries, parks, and community centers) must operate in ADA-compliant spaces. Where deficiencies are identified, the County either makes facility alterations or requires the partner organization to provide accommodations to ensure accessibility. Technical Assistance and Training — The County provides guidance and training to outside organizations on ADA and Section 504 requirements, including how to identify and remove barriers, respond to accommodation requests, and ensure equal participation. Complaint and Grievance Procedures — The County requires partner organizations to notify participants of the right to file discrimination complaints. The County's own grievance procedures are available to address complaints that arise in connection with outside organizations delivering services on the County's behalf. Corrective Action or Discontinuation — If an organization is found to be discriminating on the basis of disability, the County may require immediate corrective action, impose conditions on future assistance, or discontinue the relationship if compliance cannot be achieved. Through these measures, New Hanover County ensures that all persons and organizations delivering services with County support maintain full compliance with ADA and Section 504, protecting program participants from discrimination. IX. USE OF CONTRACTORS This section evaluates the local government's use of contractors. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 30 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 135 1. List contractors that are used by the local government to conduct programs or activities on behalf of the agency. New Hanover County utilizes outside contractors to conduct certain programs and activities on behalf of the agency. For the Scotts Hill Water Main Extension Project, a CDBG-I funded initiative, the County has engaged the following contractors: Ardurra Group North Carolina — Provides administrative and management support services to ensure compliance with CDBG-I program requirements, including project oversight, reporting, and coordination with funding agencies. Cape Fear Public Utility Authority (CFPUA) — Provides engineering, design, and construction services necessary for the implementation of the Scotts Hill Water Main Extension, ensuring technical standards are met and that infrastructure improvements are delivered effectively. Both contractors are required to comply with all applicable federal and state nondiscrimination requirements, including Section 504 of the Rehabilitation Act and the ADA, to ensure that no qualified individual with a disability is excluded from participation in or denied the benefits of services provided through this project. 2. Describe steps that have been taken to ensure that local government procurement officials understand Section 504 requirements as they apply to contractors. New Hanover County has implemented several steps to ensure that procurement officials understand and apply Section 504 requirements in contracting processes: Standard Contract Language — All County contracts include nondiscrimination and accessibility clauses requiring compliance with Section 504 of the Rehabilitation Act and the ADA. Procurement staff are trained to ensure that these provisions are included in every agreement. Policy & Training — Procurement staff participate in mandatory trainings offered by the North Carolina Department of Environmental Quality. Also, the County's Finance Department and Procurement Office provide training for staff involved in purchasing and contracting. This training covers federal and state civil rights laws, including Section 504, and emphasizes the County's responsibility to ensure that contractors do not discriminate against persons with disabilities. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 31 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 136 Bid & Solicitation Requirements — Requests for Proposals (RFPs), Requests for Qualifications (RFQs), and bid documents explicitly notify prospective contractors of the County's nondiscrimination requirements. Vendors must certify their compliance as part of the procurement process. Monitoring & Oversight — Contract administrators and project managers are instructed to monitor contractors' compliance with accessibility and nondiscrimination provisions. In cases where contractors deliver direct services to the public, the County ensures that facilities and programs are accessible and inclusive. Corrective Action — If deficiencies are identified, procurement officials have authority to require corrective action, withhold payments, or terminate contracts if compliance cannot be achieved. Through these measures, New Hanover County ensures that procurement officials consistently apply Section 504 requirements and that all contractors are held accountable for nondiscriminatory practices in the delivery of programs, services, or benefits. 3. Provide language included in a local government contracts to ensure that contractors are aware of their obligations to take steps to facilitate the participation of individuals with handicaps in programs and activities they operate on behalf of the agency. This contract language ensures contractors are aware of their obligations under Section 504 and the ADA to facilitate the participation of individuals with disabilities: Nondiscrimination Clause "No otherwise qualified handicapped individual shall, solely by reason of his/her handicap, be excluded from participating in, be denied the benefits of, be denied employment in, or be discriminated against under any program or activity receiving federal assistance. Title II of the Americans with Disabilities Act of 1990 (42 U.S.C. 12131-12165) and Section 504 of the Rehabilitation Act of 1973, as amended, (29 U.S.C. 794). " This clause, combined with the Equal Employment Opportunity, Fair Housing, and Section 504 Compliance sections of the contract scope, legally binds the contractor to ensure that all programs and services carried out on behalf of New Hanover County are accessible to and inclusive of individuals with disabilities. Contractors are required to: • Implement Section 504 grievance procedures and assist in maintaining the County's Section 504 self -evaluation plan. • Identify and address potential accessibility barriers in facilities, programs, and services. • Ensure compliance with all federal nondiscrimination laws (Title VI, Section 504, ADA, Section 109 of the Housing and Community Development Act, and related executive orders). • Take affirmative steps in contracting and service delivery to prevent exclusion or discrimination of persons with disabilities CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 32 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 137 4. Indicate the appropriate policy source to include information about Section 504 requirements as they apply to contractors. New Hanover County Personnel Policies & Procedures, Article 4.2 — Equal Employment Opportunity Policy, together with the County's Procurement Plan and Policy and Equal Employment Opportunity Plan, provide the policy framework for applying Section 504 requirements to all contractors and subcontractors engaged in County -funded or federally assisted projects. Specifically: • New Hanover County Personnel Policies & Procedures, Article 4.2 — Equal Employment Opportunity Policy — This establishes the County's overarching nondiscrimination framework, prohibiting discrimination based on disability in all personnel decisions and employment - related actions. • New Hanover County Procurement Plan and Policy (CDBG-I and federally funded projects) — As reflected in the Scotts Hill Water Main Extension contract, procurement policies incorporate nondiscrimination clauses and require all contractors and subcontractors to comply with Section 504 of the Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act (ADA). • Equal Employment Opportunity (EEO) Plan and Policy — Maintained by Human Resources, this plan outlines compliance with federal nondiscrimination laws for both County operations and contractors, and serves as the foundation for contract language requiring accessibility and equal participation. 5. Give a date that the policy was established and distributed to staff and give a citation for the policy. New Hanover County's Section 504 requirements for contractors are established in the Personnel Policies & Procedures, Article 4.2 — Equal Employment Opportunity Policy, originally adopted in May 1977 and most recently revised on November 16, 2020. The policy is distributed to all County staff through HR onboarding packets, published on the County intranet, and reinforced in contract compliance documents issued during procurement and grant administration. Together with the County's Equal Employment Opportunity (EEO) Plan and Policy and Procurement Plan and Policy, this framework requires that all contractors and subcontractors engaged in County - funded or federally assisted projects comply with Section 504 of the Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act, ensuring that no qualified individual with a disability is excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any program or activity conducted on behalf of the County. X. GRIEVANCE PROCEDURES This section evaluates the local government's grievance procedures. Please respond to the following questions with either a Yes, No, N/A, a description, list, or explanation when appropriate. If a question does not apply to your local government, then write "N/A" next to the question and explain. 1. What procedures have been established to ensure that at least one person has been designated to coordinate compliance with Section 504? CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 33 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 138 New Hanover County has established a formal grievance procedure to ensure compliance with Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA). The County has designated Franklin Juarez, Jr., Safety Officer/ADA Coordinator, as the individual responsible for coordinating compliance efforts. The grievance procedure provides that any person alleging discrimination on the basis of disability in the County's services, programs, or activities may file a complaint in writing, by personal interview, or through alternative accessible formats. Upon receipt, the ADA Coordinator will meet with the complainant within 15 calendar days to discuss the issue and potential resolutions, and a written response will be issued within 15 calendar days thereafter in an accessible format. If the complainant is not satisfied, an appeal may be submitted within 15 calendar days to the County's Risk Manager or designee, who will provide a final written resolution. All complaints, appeals, and responses are retained by the County for a minimum of three years. These procedures are publicly posted on the County's website and distributed through County policy documents to ensure staff and the public are aware of the designated coordinator and the process for addressing grievances. The New Hanover County ADA/Section 504 Grievance Procedure was formally established in 2013 through the Office of the County Attorney — Risk Management, and the County's Personnel Policies and Procedures, originally adopted in May 1977 and most recently revised on November 16, 2020, reaffirm the County's commitment to nondiscrimination and equal access. Attachment: Grievance Procedure 2. Have there been obvious difficulties or complaints about the local government services from individuals with disabilities? ❑ Yes — Proceed to Question 3 ❑X No - Proceed to Question 4 3. Describe how resolution of complaints and steps to resolve concerns/complaints is documented? N/A 4. What written procedures have been established to ensure that appropriate initial and continuing steps to notify participants, beneficiaries, applicants, etc. that the local government does not discriminate on the basis of handicap (24 CFR 8.54)? New Hanover County has not experienced any widespread or systemic complaints regarding access to local government services from individuals with disabilities. The County has established a formal grievance procedure, designating the Safety Officer/ADA Coordinator as the compliance lead, with an appeal process available through the Risk Manager. In addition, the County provides multiple accessible methods for fling complaints and ensures that accommodation such as interpreters, Braille, large print, and other auxiliary aids are available upon request to remove barriers to participation. Complaints, when received, are addressed promptly in accordance with these procedures, and individuals have the option to escalate concerns through the Office of Civic Engagement to state or federal enforcement agencies such as HUD or the North Carolina Human Relations Commission. These policies and practices demonstrate the County's proactive commitment to ensuring accessibility and resolving any concerns raised by individuals with disabilities. Attachments: Grievance Procedure and Civic Engagement Policy 5. Does the local government have a written grievance procedure/policy for handling the prompt and equitable resolution of any complaints of discrimination based on disability? CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 34 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 139 N Yes - ATTACH a copy of the current local government policy which should include the date the policy was established, the date the policy was distributed to staff, and the citation for the policy. ❑ No - Modification or corrective action: Click or tap here to enter text. 6. Has the local government adopted procedures that incorporate due process standards and allow for prompt resolution of any complaints or alleged discrimination based on disabilities (24 CFR 8.53)? N Yes - ATTACH a copy of your current grievance procedures and the name of the person or unit responsible for receiving and processing complaints. ❑ No - Modification or corrective action: Click or tap here to enter text. 7. Has the local government notified staff and program participants about the grievance procedures? N Yes ❑ No -Modification or corrective action: Click or tap hereto enter text. 8. Is the grievance procedure and/or nondiscrimination policy published in the newspaper at least once a grant cycle (or once a year)? ❑ Yes N No -Modification or corrective action: Based on the County's current ADA/Section 504 grievance procedure and related public -facing materials provided, there is no documentation showing that the grievance procedure or a nondiscrimination notice is published in a newspaper once per grant cycle (or annually). The County does notify staff and program participants via the ADA/Section 504 Grievance Procedure, the ADA Compliance webpage, and Personnel Policies, but the records reflect web/intranet posting and internal distribution rather than newspaper publication. 9. Does the grievance procedure inform individuals of their rights to file a complaint with a state or federal agency and include the agency's addresses? ❑ Yes N No -Modification or corrective action: Revise the County's grievance procedure to include a clear statement of individuals' rights to file complaints with state and federal agencies, along with the agencies' mailing addresses, phone numbers, and electronic contact information. Updated procedures will be distributed to staff, posted on the County website, and made available in accessible formats to ensure all participants are informed of their external complaint rights. CDBG-1 Program Section 504 Self -Evaluation Survey (Updated 5/2020) Page 35 of 35 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 140 Intentionally left blank New Hanover County CDBG-I Program Manual Page 46 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 141 New Hanover County Code of Ethics New Hanover County CDBG-I Program Manual Page 47 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 142 NEW HANOVER COUNTY BOARD OF COMMISSIONERS RESOLUTION ADOPTING A CODE OF ETHICS WHEREAS, North Carolina General Statute (NCGS) 160A-86 requires local governing boards to adopt a code of ethics; and WHEREAS, New Hanover County citizens deserve to be served by public officials who maintain the highest ethical standards; and WHEREAS, the stability and proper operation of democratic representative government depends upon public confidence in the integrity of the government, and upon responsible exercise of the trust conferred by the citizens upon their elected officials; and WHEREAS, Board members must act in a manner that maintains their integrity and independence and be responsive to the interests and needs of those they represent; and WHEREAS, Board members must know how to distinguish among their various roles, to determine when each role is appropriate, and to act accordingly: 1. As advocates, who strive to advance the legitimate needs of their citizens; 2. As legislators, who balance the public interest and private rights in considering and enacting ordinances and resolutions, and 3. As fair and impartial decision -makers, when making quasi-judicial and administrative determinations. NOW, THEREFORE, BE IT RESOLVED, that the New Hanover County Board of Commissioners does hereby adopt the following Code of Ethics to guide the Board of County Commissioners in its decision -making. The Board of Commissioners directs all County boards and committees to respect and abide by this Code of Ethics in the performance of their duties. CODE OF ETHICS Purpose. The purpose of this Code of Ethics is to establish guidelines for ethical standards of conduct for the Board of County Commissioners. It should not be considered a substitute for the law or for a Board member's best judgment. Section 1. A. Board members should obey all laws that apply to their official actions. The spirit as well as the letter of the law should guide their actions. Board members should feel free to assert policy positions and opinions without fear of reprisal from fellow Board members or citizens. B. Board members should endeavor to keep themselves current, through the County Attorney and other sources, of the most pertinent constitutional, statutory, and other legal requirements with which they must be familiar in order to meet their legal responsibilities. C. Board members shall comply with NCGS 160A-87 in receiving two clock hours of ethics education within twelve months of each election or appointment to office. Section 2. Board members should act with integrity as they exercise the functions of their offices. Characteristics and behaviors that are consistent with this standard are: A. Behaving consistently and with respect towards everyone with whom they interact. B. Exhibiting trustworthiness. C. Living as if they are on duty as elected officials regardless of where they are or what they are doing. Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 143 D. Using their best independent judgment to pursue the common good, while being able to consider the opinions of others, presenting their opinions to all in a forthright manner. E. Remaining incorruptible, self-governing, and not subject to improper influence. F. Disclosing contacts and information about issues that they receive outside of public meetings and refraining from seeking or receiving information about quasi-judicial matters outside of the quasi-judicial proceedings. G. Treating other Board members and the public with respect and honoring the opinions of others even when they disagree. H. Being careful not to reach conclusions on issues until all sides have been heard. I. Recognizing that individual Board members are not generally allowed to act on behalf of the Board but may only do so if the Board specifically so authorizes because the Board must take official action as a body. Section 3. Board members should be faithful in the performance of the duties of their office. Board members should faithfully attend and prepare for meetings. They should carefully analyze all credible information that is properly submitted to them, mindful of the need not to engage in communications outside the meeting in quasi-judicial matters. They should demand full accountability from those over whom the Board has authority. Section 4. Elected members of local governing Boards should conduct the affairs of their Boards in an open and public manner. They should comply with all applicable laws governing open meetings and public records, recognizing that doing so is an important way to be worthy of the public's trust. They should remember when they meet that they are conducting the public's business. They should also remember that the records of their local government belong to the public. A climate of openness is to be maintained at all times. They should take deliberate steps to ensure that any closed sessions held by the Board are conducted lawfully, and that such sessions do not stray from the purposes for which they are called. Section 5. This Code of Ethics shall be effective upon adoption, unless modified, amended, or repealed. ADOPTED this the 9th day of January, 2023. NEW HANOVER COUNTY r "tze_ WilliarrA. Rivenbark, Chair ^ LeAnn Pierce, Vice -Chair f �_ /� -//-I/ �_ 'M rf� Barfield, r., Co my Commj sioner Deb Hays, County Co i sioner Zapple, y-CDmit"iis/oner ATTEST: n +L KVerleigh G. Crow , Clerk to the Board O `i- ............ F'Tnnns" tn„ Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 144 New Hanover County Excessive Force Provision New Hanover County CDBG-I Program Manual Page 48 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 145 Office of the Sheriff New Hanover County, NC Standard Operating Policy - Policy# Subject •, h R 262 Civil Disturbance Unit Pages Effective Date Last Update 6 1 2017-Ma -1 2024-Se t-23 References 262.1 PURPOSE The purpose of the New Hanover County Sheriff's Office Civil Disturbance Unit (CDU) is to provide a core of specially trained personnel to respond to active critical incidents, in -progress or pre -planned civil disorders, and large scale disasters. The CDU mission is to guard, maintain or establish a safe environment for citizens of New Hanover County through great vigilance, professionalism, and integrity so that citizens may exercise their constitutional right to peacefully assemble, in conjunction with federal law and any federal requirements. 262.2 GENERAL A. The CDU primarily responds to incidents within New Hanover County. However, with approval, assistance may be provided to any agency under the direction or order of the Sheriff or his designee. The CDU may be augmented with personnel from municipal law enforcement agencies who have successfully completed the NHCSO CDU training and/or equivalent Federal or State approved training. B. The CDU shall operate in compliance with New Hanover County Sheriff's Office policy and all statutory requirements/ordinances regarding dispersal during civil disorder/disturbance. C. A crowd will be dispersed pursuant to NCGS 14-288.5 which states that a law enforcement officer may issue a command to disperse if he or she reasonably believes that a riot, or disorderly conduct by an assemblage of three or more persons, is occurring or it is imminent that a riot or disorderly conduct will occur. The command to disperse shall be given in a manner reasonably calculated to be communicated to the crowd. D. In the event of a multi -agency response within the county of New Hanover, all assisting agencies will abide by the standards, rules, and guidelines set forth by the New Hanover County Sheriff's Office. 262.3 CIVIL DISTURBANCE UNIT COMPONENTS SOP 262 Civil Disturbance Unit Page 1 of 6 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 146 A. The CDU is comprised of the following operational components: 1. Line Unit 2. Less -Lethal Operator 3. Grenadier Team 4. Arrest Team 5. Bicycle Team B. The CDU also contains the following support components: 1. Logistical Support 2. Intelligence Element 3. Emergency Medical Staff 4. Precision Riflemen 5. Videography 262.4 SELECTION CRITERIA A. CDU members working with direct or indirect contact with the public must be a sworn member of the New Hanover County Sheriff's Office. B. Non -sworn CDU members can only participate in an additional support position such as logistic, incident command, training and technical support. C. Members of the arrest team must be a sworn member of the New Hanover County Sheriff's Office. 262.5 CDU ACTIVATION A. Any NHCSO Deputy may request CDU activation through their chain of command. Requests for activation will be evaluated by the on -duty Watch Commander, and if activation is deemed necessary, will notify the Patrol Division Commander. Only the Sheriff or Chief Deputy, or designee may authorize activation of the CDU. B. Once activated, the CDU Commander will be responsible for operation of the unit. The CDU Commander will be independently responsible for determining the tactics SOP 262 Civil Disturbance Unit Page 2 of 6 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 147 employed to accomplish the mission. The CDU Commander will coordinate with the Incident Commander at all times in order to successfully resolve the incident. C. The CDU may be deployed to any incident located outside NHCSO jurisdiction with authorization from the Sheriff or Chief Deputy. 1. An agreement with the requesting jurisdiction is required to authorize NHCSO personnel to act as local law enforcement while deployed for the specific incident. 2. Operational control of the CDU shall remain with the CDU Commander. 3. NHCSO CDU personnel shall operate in compliance with NHCSO SOP at all times. 262.6 CDU TRAINING A. Line Unit Training 1. Training is mandatory 2. All deputies/detention officers with the exception of the ranks of First Sergeant and above, as well as full time members of the Canine (K9), and Emergency Response Team (ERT), must attend the civil disturbance, crowd management training program and the annual recurring training on the civil disturbance & crowd management training approved by the Sheriff or their designee. B. Civil Disturbance Unit Positions (Collateral Duty) 1. Specialized Positions within the Civil Disturbance Unit: a. Less Lethal Operator: an individual who has received specialized training in the use and dispersal of less lethal munitions, projectiles and launching platforms (ie. PepperBall Launchers, Shotguns & Handheld Aerosol & Powder Dispersal). b. Grenadier: an individual who has received specialized training in the use and dispersal of less lethal munitions, projectiles launching platforms (ie. 40mm Launcher, Hand thrown CTS Grenade). c. Arrest Team: an individual who has received specialized training in the process of Mass Arrest & Field Booking Process. d. Rifleman: an individual who has received specialized training in the use of tactical & long-range weapons. SOP 262 Civil Disturbance Unit Page 3 of 6 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 148 e. Bicycle Team: an individual who received specialized training in Police Bicycle Response Team Tactics. f. All deputies/detention officers with the exception of the ranks of First Sergeant and above, as well as full time members of the Canine (K9) and Emergency Response Team (ERT), shall complete all required training commensurate with their assigned position within the Civil Disturbance Unit prior to any deployment. g. Reciprocal or joint training may be conducted with other agencies or law enforcement organizations at the discretion of the Sheriff or their designee. 2. Training and Records Keeping a. Less Lethal Operator, Grenadier, and Arrest Team Training shall be documented, and maintained on file by the CDU Commander. b. Rifleman training shall be documented and maintained on file by the Range Master. c. Bicycle Team Training shall be documented and maintained on file by the Bike Team Commander. 262.7 CDU EQUIPMENT A. The CDU Quartermaster is responsible for storing, inventorying, issuing, and collecting (upon deactivation) all issued CDU equipment. The Quartermaster may also be required to secure issued equipment from deactivated members. B. All CDU equipment shall be stored in a secure manner. C. All CDU personnel will be issued necessary equipment commensurate with their assignment in the unit. Personnel shall be responsible for the care and maintenance of all issued equipment, including maintaining all equipment in mission -ready status at all times. D. Specialized component members will be issued the required equipment commensurate with their assignment prior to deployment. E. The CDU Commander shall ensure that a complete and accurate inventory of all CDU equipment is maintained at all times. F. Inspections of CDU equipment shall be conducted by visual observation and physical examination. Equipment inspections shall be conducted at the discretion of the CDU Commander, but no less frequently than quarterly for operational readiness. SOP 262 Civil Disturbance Unit Page 4 of 6 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 149 G. CDU equipment and munitions requiring specialized certifications will remain under the direct control of those certified CDU members. 262.8 DOCUMENTATION A. The CDU Commander will complete an After Action Report detailing the activation and operations of the team, at the conclusion of all operations, including significant training events. B. The After Action Report will identify positive and negative operational factors and to develop corrective action(s) for any deficiencies or negative factors for future operations. C. The After Action Report will be submitted within seven days. D. The After Action Report will specify the following: 1. Agency case number 2. OCA or event number 3. Date of deployment 4. Location of deployment 5. Reason for deployment 6. Requesting entity 7. Resources utilized 8. CDU team/entities roster 9. Total hours event lasted 10. Relevant comments or observations by the submitting supervisor 11. Complete packet from the Operational Component(s) that consist of a SIM/Munitions and Equipment used during the event 12. Any NHSO Use of Force reports 13. Copy of Arrest, Charge log SOP 262 Civil Disturbance Unit Page 5 of 6 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 150 262.9 OTHER SUPPORTING DOCUMENTATION NHSO SOP 264- Use Of Force NHC- Excessive Force Policy 262.10 COMPLIANCE All NHSCO personnel shall adhere to and abide by the rules and regulations as set forth on this policy. APPROVED BY: Signature on File Edward J. McMahon Sheriff New Hanover County, N.C. SOP 262 Civil Disturbance Unit Page 6 of 6 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 151 Intentionally left blank New Hanover County CDBG-I Program Manual Page 49 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 152 Intentionally left blank New Hanover County CDBG-I Program Manual Page 50 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 153 CDBG-I Program BABA Guidelines New Hanover County CDBG-I Program Manual Page 51 of 60 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 154 Build America, Buy America (BABA) Guidance for North Carolina Community Development Block Grant -Infrastructure (CDBG-1) Grant Projects for Inclusion in Project Manual Bid Documents Enacted in the Infrastructure Investment and Jobs Act signed by President Biden on November 15,2021. This guidance summarizes the requirements under Title IX of the Infrastructure Investment and Jobs Act, Build America, Buy America (BABA), that requires any infrastructure project funded by any "Federal Financial Assistance" (FFA) apply a domestic content procurement preference, meaning that all iron, steel, manufactured products, and construction materials used in the infrastructure project have been produced in the United States, unless the awarding agency (HUD) has issued a waiver of this requirement. This is called the "Buy American Preference" (BAP) and the specific requirements are codified in 2 C.F.R. Part 184. The U.S. Department of Housing and Urban Development (HUD) has provided full guidance on the requirements at the following website: https://www.hud.gov/baba and at https://www.hudexchange.info/resources/. Contents Applicability HUD's Phased Implementation of BAP NIST Manufacturing Extension Partnership ............................... Roles and Responsibilities......................................................... Compliance and Implementation .............................................. Non -Compliance with BABA and its BAP ................................... HUD General Waivers............................................................... HUD Project/Product Specific Waivers ...................................... Recordkeeping......................................................................... Appendices............................................................................... BAP Compliance Certification Statement for CDBG-1 Projects 4 4 10 11 12 13 BAP De Minimis Waiver for CDBG-1 Projects.......................................................................................14 BAP Manufacturer's Compliance Certification for CDBG-1 Projects.....................................................16 Materials and Products Covered by BABA CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 1 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 155 17 Applicability The BAP references that all infrastructure projects are included, an infrastructure project is defined broadly as any project that includes construction, maintenance, alternation, or repair. Examples of CDBG-funded activities that may be subject to the BAP: • Rehabilitation of buildings and real property • Construction of public facilities and improvements, such as streets sidewalks, neighborhood, centers, and the conversion of buildings for eligible purposes • Utility installation or improvements, • Water systems (drinking water and wastewater) • Electrical transmission facilities and systems • Broadband infrastructure • Transportation infrastructure Examples of CDBG-funded activities that MAY NOT be subject to the BAP: • Acquisition of real property • Relocation and demolition • Public services • Shelter or public facility operating expenses • Supportive services • Short-term payments to prevent homelessness • Special economic development activities • Administrative activities • Disaster and emergency response All CDBG-1 grant subrecipients (grantees) fall under compliance with BABA since CDBG is a federal grant that will fund utilities, water systems (drinking water and wastewater). Grantees of CDBG-I awards made with FY23 and newer federal CDBG funds must comply with BABA requirements and the HUD's phased implementation of BAP. HUD's Phased Implementation of BAP While BABA became effective on May 14, 2022, HUD published a series of waivers to allow for a phasing -in of BAP. HUD waived application of the BAP until certain effective dates depending on the program and the product listed in HUD's Phase Implementation Waiver. Pursuant to BABA, Grant Subrecipient that are awarded funding for infrastructure projects beginning in Program Year 2023 must ensure that the required construction items used in the project are produced in the United States. HUD's phased implementation will apply BABA documentation requirements to additional items each year — new grant awards must comply with BABA requirements applicable to the period in which they are awarded. After program year 2025, all projects will be required to document all BAP materials. Existing proiects that receive additional funding from federal funds with BAP requirements will trigger compliance with BAP. CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 2 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 156 Construction Item Description* BABA Requirements Apply to New Awards Beginning of Program Years All Iron and Steel 1/1/2023 (FY 2023 appropriated funds) and subsequent CDBG awards Specifically Listed Construction Materials requirements, plus 1/1/2024 (FY 2024 appropriated iron and steel requirements for infrastructure projects funds) and subsequent CDBG awards Not Listed (All Other) Construction Materials and Manufactured Products requirements, plus above items as 1/1/2025 (FY 2025 appropriated well as specifically listed construction materials and iron and funds) and subsequent CDBG awards steel for infrastructure projects Not applicable for BABA documentation: a) Tools, equipment, and supplies, such as temporary scaffolding, brought to the construction site and removed at or before the completion of the infrastructure project. b) Equipment and furnishings, such as movable chairs, desks, portable computer equipment, that are used at or within the finished infrastructure projects, N/A c) Purchases that are not intended for construction, alteration, maintenance, or repair of infrastructure, d) Section 70917(c) materials (defined in 2 CFR 184.3) means cement and cementitious materials, aggregates such as stone, sand, or gravel, or aggregate binding agents or additives. *White House memorandum M-22-11 and HUD Public Interest Phase Implementation Waiver Products covered under the BAP include Iron and Steel, Construction materials, and Manufactured Products. Products should be classified into just one of these categories. As outlined in HUD's "CPD Implementation Guidance for the Build America. Buv America Act's domestic content procurement preference as part of the Infrastructure Investment and Jobs Act,"the classification must be made based on the product's status when brought to the work site. HUD Construction Materials Grou Iron and Steel. Items that consist completely or predominantly of iron, steel, or a combination of both. "Predominantly" means the cost of the iron and steel content exceeds 50% of the total cost of all the item's components. o All manufacturing processes, starting from the initial melting stage and continuing through the application of coatings, must occur in the United States. • Construction Materials. Articles, materials, or supplies used for construction activities that consist of only one of the items described below. For the purposes of the HUD Phased CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 3 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 157 Implementation timeline described below, construction materials are divided into two categories: specifically listed construction materials and not listed construction materials. All manufacturing processes for the construction material must occur in the United States (2 CFR 184.6) o Specifically Listed Construction Materials include (1) non-ferrous metals; (2) lumber; and (3) composite building materials; and (4) plastic- and polymer based pipe and tube. o Not Listed (All Other) Construction Materials include (1) all other plastic- and polymer - based materials (such as polymers used in fiber optic cables), (2) glass, (3) fiber optic cable, (4) optical fiber, (5) engineered wood, and (6) drywall. Manufactured Products. Manufactured products include articles, materials, or supplies that have either been: 1) Processed into a specific form or shape, or 2) Combined with other articles, materials, or supplies to create a product with different properties than the individual articles, materials, or supplies. o A manufactured product may include components that are construction materials or iron and steel products unless the manufactured product also meets the definition of iron and steel or construction materials. In such instances, the product should be recategorized in the appropriate category. o To determine the cost of components for manufactured products (2 CFR 184.5), Manufactured products must meet two production requirements. First, the final product must be manufactured in the United States. Second, at least 55% of the cost of the components making up the manufactured product must be associated with components that were mined, produced, or manufactured in the United States NIST Manufacturing Extension Partnership Grantees should leverage the North Carolina Manufacturing Extension Partnership NCMEP network to locate domestic suppliers. NCMEP will provide supplier scouting service that will conduct a nationwide search for U.S. manufacturers with the capabilities and business interests to supply the needed item. The summarized results typically takes 30-45 days. Roles and Responsibilities The following lists all relevant stakeholders involved with BABA compliance. Made in America Office (Federal office at the Office of Management and Budget/OMB) Charged with enforcing compliance with the application of BAP for federal financial assistance programs for infrastructure, providing guidance, and establishing the procedures to review general and/or project specific waivers requests. HUD (Federal agency). Communicates BABA requirements; provides guidance on the proper implementation of the requirements and trainings; and CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 4 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 158 NC Department of Environmental Quality / Division of Water Infrastructure (State). Oversee and reinforce BAP implementation. Type of involvements includes BABA required clause in agreements of activities funded by the federal program, technical assistance, monitoring, and waiver request assistance. Grant Subreciaient (Grantee). Communicate BAP requirements to engineer and potential bidders, contractors, document BAP compliance for project; ensure BABA clause in all relevant contracts; ensure compliance through gathering, tracking, and maintaining BABA documentation; submit waiver, if applicable, to the State. Engineer. Communicate BAP requirements to potential bidders, contractors, document BAP compliance for project; ensure BABA clause in all construction contracts (prime and subcontractors); ensure compliance through gathering, reviewing, tracking, and maintaining BAP documentation; submit waiver, if applicable, to the State. Contractor and Subcontractors. The prime contractor and subcontractors (of any tier) must ensure compliance with the BAP requirements and maintain records that verify compliance with BAP. Prime contractors must sign and submit a "BAP Certification Statement for CDBG-I Projects"; coordinate BAP compliance needs with suppliers/ distributors; procure BAP compliant products; and obtain necessary BAP manufacturer certifications from product manufacturers as early as possible in construction and bid process and submit with each relevant construction pay application. Supplier/ Distributor. Procure BAP products; obtain necessary BAP certifications from product manufacturers; When ordering products, let manufacturers know that BAP applies. Product Manufacturer(s) Product Manufacturer. Supply BAP products; provide BAP certification letters documenting all manufacturing processes for product occurred in the U.S.; provide other relevant product documentation regarding BAP requirements (i.e. cost calculation showing a product is not primarily iron or steel (<SO%) when necessary or requested by assistance recipient). Compliance and Implementation Grantees must ensure the products delivered to the construction site are accompanied by proper documentation that demonstrate compliance with the law and is made available to the State. The following sections discusses how to ensure compliance with BAP. Contract Requirements. 1. Specific contract language (the BABA clause) regarding BAP must be included in all contracts, including administration, engineering, and construction (including subcontractors). See the most recent updated Contract Provisions document on Division website. CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 5 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 159 The engineer contract should also include, as a basic service, obtaining, reviewing, tracking and maintaining all BAP documentation (particularly manufacturers' certifications) during construction, which shall be transferred to the grantee. The contractor (and all subcontractors)agreements must include: a. The prime contractor and all subcontractors must comply with the requirements of the BABA Act, 41 USC 8301 note, and all applicable rules and notices, as may be amended, as applicable to the Community Development Block Grant (CDBG) infrastructure projects. Pursuant to the U.S. Department of Housing and Urban Development's (HUD's) notice, "Public Interest Phased Implementation Waiver for FY2022 and 2023 of Build America, Buy America Provisions as Applied to Recipients of HUD Federal Financial Assistance" (88 FR 17001), any funds obligated by HUD on or after the applicable listed effective dates, are subject to BABA, BAP requirements, unless excepted by a waiver. Bid Requirements. Advertisement for Bids. The following statement must be included in the advertisement for bids. • This project is subject to the Build America, Buy America Act (BABA) requirements under Title IX of the Infrastructure Investment and Jobs Act ("IIJA"), Pub. L. 177-58. Absent an approved waiver, all iron, steel, manufactured products, and construction materials used in this project must be produced in the United States, as further outlined by the Office of Management and Budget's Memorandum M-22-11, Initial Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure, April 18, 2022. Instructions to Bidders. The following statements must be included in the instructions to bidders. • Grantees must select the appropriate language to reflect the BAP -covered materials and products items required by HUD's Phased Implementation Schedule: "Materials and Workmanship Domestic Preferences (Buy America Preference) - As appropriate and to the extent consistent with law and to the greatest extent practicable under a Federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States (including but not limited to iron, aluminum, steel, cement, and other manufactured products). The requirements of this section must be included in all contracts and purchase orders for work or products under this subaward. For purposes of this section: (1) "Produced in the United States" means, for iron and steel products, that all manufacturing processes, from the initial melting stage through the application of coatings, occurred in the United States. (2) Iron and Steel products, Manufactured Products, and Construction Materials] used in this project comply with the Build America, Buy America Act (BABA) requirements mandated by Title IX of the Infrastructure Investment and Jobs Act ("IIJA"), Pub. L. 177-58. (3) "Manufactured products" means the manufactured product was manufactured in the United States, and the cost of the components of the manufactured product that are mined, produced, or manufactured in the United States is greater than 55 percent of CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 6 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 160 the total cost of all components of the manufactured product, unless another standard that meets or exceeds this standard has been established under applicable law or regulation for determining the minimum amount of domestic content of the manufactured product. (4) "Construction materials" means that all manufacturing processes for the construction material occurred in the United States. Bid Form. In the bidder's representation section, add: • Bidder is familiar with all laws and regulations that may affect cost, progress, and performance of the work, including BABA requirements. Certifications_ Certification creates a paper trail which document the Iron and Steel products, Manufactured Products, and Construction Materials [depending upon HUD's implementation schedule] and the location of the manufacturing process involved with the production of said materials. A certification is the acknowledgement of the requirements and is a process by which each handler (supplier, fabricator, manufacturer, processor, etc.) of the materials certifies that their step in the process was domestically performed. Each time a step in the manufacturing process takes place, the manufacturer delivers its work along with a certification of its origin. Grantees need to certify that all BAP -covered materials and product used in their projects are Made in America, based on HUD's Phased Implementation Waiver. Thus, the following tasks must be completed and documented. 1. The Engineer must identify and list all BAP -covered materials/products [based on HUD's implementation schedule] in the Bid and Design Document (Plans and Specs). a. If it is determined that if any additional construction materials are needed that were not included in the itemized application budget, then the grantee and their engineer are required to inform the State via the Bid and Design Document and ensure BAP requirements are implemented as needed. 2. The bid tab must be sufficiently detailed to itemize each separate projector material and indicate BABA applicability, OR a separate schedule must be attached to identify BAP applicability for all products or materials. a. If a change to the contract includes new products or materials, an updated itemization must be submitted with change order. The "BAP Certification Statement for CDBG-I Projects" must be completed by the prime contractor and Grantee at the time of the pre -construction conference. This certification statement must be submitted with the Bid Documentation Submission package. 4. The awarded contractor will then begin submitting manufacturer certifications for each BAP covered product or material to the Engineer with their submittals. a. Grantees will take the engineer's list of BAP -covered products and the contractor's corresponding certifications and include that information into a tracking spreadsheet for the project. CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 7 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 161 Grantees will be required to keep records of the certification documentation consistent with CDBG records retention requirements. Certification submittals should begin prior to the start of construction. No construction activity claims will be approved without certification that the contractor has met BAP requirements for that respective claim. a. For each construction activity claim, the contractor and engineer will certify that materials used for that respective pay application is BAP -compliant. 6. Grantees will submit, via the Division's Online Supporting Documentation Submittal portal copies of manufacture's certification documentation and a copy of the tracking spreadsheet, as support documentation for each construction pay application. a. It is the responsibility of the Grantee to ensure that each BAP applicable product and/or material from the Bid and Design Document (Plans and Specs) has a corresponding and appropriate certification as well as tracking any change orders in the project that will utilize new BAP -covered products. b. If the grantee does not have a manufacturer's compliance certification for a specific product and/or material, it cannot be certified as meeting BAP and funding will be held until that manufacturer's compliance certification is documented or an approved waiver is on file. Manufacturer Compliance Certification Letter. A signed certification letter from the manufacturer for the project is the most direct and effective form of compliance documentation for ensuring products used on site are BAP compliant prior to their installation. Basic elements of sufficient documentation: • Project name, project location, contract number, or project number. • Description of product(s) (simple explanation sufficient to identify the product(s)), or an attached purchase order, invoice, or bill of lading (a contract issued by a transport company to a shipper that spells out the quantity, type, and destination of the goods being shipped). • Attestation statement referencing Infrastructure Investment and Jobs Act ("IIJA"), or the Bipartisan Infrastructure Law (BIL) and Build America, Buy America (BABA) requirements. • Manufacturing location(s). • Signature of representative certifying knowledge of manufacturing processes. It will be the contractor's responsibility to hand these manufacturers' certifications to the Grantee and their engineer. CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 8 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 162 Non -Compliance with BABA and its BAP What is considered non-compliance with BABA? Intentional or unintentional use of a nondomestic materials and products that is covered under the BABA requirements. How to address non-compliance? Failure to comply with applicable BABA requirements constitutes a violation of the terms and conditions of your grant agreement and can result in reducing the amount of the award, withholding future funds, and/or terminating the award, the need for removing and replacing completed work at your cost, termination from the contract and potentially even debarment from performing federally funded work. In cases of fraud, it can lead to criminal investigation and prosecution. The State would notify grantee of potential non-compliance; evaluate alternatives (i.e., can the product be covered by a waiver); if grantee does not take corrective action, the State would issue a non- compliance letter and notify HUD of the finding that would potentially be a ground for issuance of sanction to the future Federal Funding Assistance to the project owner (grantee). HUD General Waivers Exigent Circumstances Waiver HUD issued a public interest waiver for exigent circumstances, "Public Interest Waiver of Build America, Buy America Provisions for Exigent Circumstances as Applied to Certain Recipients of HUD Federal Financial Assistance". This waiver applies when there is an urgent need by a CPD grantee to immediately complete an infrastructure project because of a threat to life, safety, or property of residents and the community (Effective until November 23, 2027, or such shorter time as HUD may announce via Notice). • This type of waiver is not applicable to the regular CDBG-1 Program. It could apply to any future strictly urgent need projects that meet the exigent circumstances waiver definition. De Minimis. Small Grants. and Minor Components Waiver HUD also issued a public interest de minimis, small grants, and minor components waiver titled "Public Interest De Minimis and Small Grants Waiver of Build America, Buy America Provisions as Applied to Certain Recipients of HUD Federal Financial Assistance." This waives the BAP for all infrastructure projects whose total cost (from all funding sources) is equal to or less than the simplified acquisition threshold at 2 C.F.R. 200.1 which is currently $250,000. This Notice also waives the application of the BAP for a de minimis portion of an infrastructure project, meaning a cumulative total of no more than five percent (5%) of the total cost of the iron, steel, manufactured products, and construction materials used in and incorporated into the infrastructure project, up to a maximum of $1 million. (Effective until November 23, 2027, or such shorter time as HUD may announce via Notice). Small Grants. BABA requirements do not apply to infrastructure projects whose total cost (from all sources) is equal to or less than the current Simplified Acquisition Threshold of $250,000. This waiver is currently in effect as of November 23, 2022. De Minimis. BABA requirements do not apply for a De Minimis portion of an infrastructure project, meaning a cumulative total of no more than five percent (5%) of the total cost of the CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 9 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 163 iron, steel, manufactured products, and construction materials, up to a maximum of $1 million. The total cost of all covered materials includes all iron and steel, construction materials, and manufactured projects used in the project, regardless of whether the BAP currently applies under the HUD Phased Implementation wavier. This waiver is currently in effect as of November 23, 2022. The above waivers are handled by the Division; therefore, these waiver requests must be submitted to the Division for review and approval by CDBG-I staff in a timely manner. HUD Project/Product Specific Waivers A Grantee may request a project/product specific waiver from the BAP for covered federal financial assistance on a limited, case -by -case basis. HUD may grant a project specific waiver after consultant and review with the OMB's Made in America Office (MIAO) after State and HUD's review, a public comment period, and final approval from the Office of Management and Budget's Made In America Office (MIAO). As with the general waivers, under Section 70914(b), HUD may issue a project -specific waiver to the BAP if it is determined that a waiver falls into one of the following three categories: • Public Interest - When applying the domestic content procurement preference would be inconsistent with the public interest (has a high bar for documentation), or • Nonavailablity - When types of iron, steel, manufactured product, or construction materials are not produced in the United States in sufficient and reasonably available quantities or of a satisfactory quality (definition of "nonavailability" determined by MIAO), or • Unreasonable Cost - Where the inclusion of those products and materials will increase the cost of the overall project by more than 25 percent (25%). A waiver for a specific project may vary depending upon the circumstances of the project, and specific items, products, or materials in question. Protect/Product Specific Waiver Process If a grantee wants to submit a waiver, they must work with the State agency to submit a waiver. In the case of CDBG-I funds, the State agency is the NCDECl/Division of Water Infrastructure (Division). • If more than one Federal agency is funding an infrastructure project, project -specific waivers will require coordination among those Federal agencies prior to a determination by the Made in America office (MIAO). A grantee seeking a project/product specific waiver must demonstrate the criteria for one or more of the project -specific waiver categories are met. CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 10 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 164 For HUD to consider a project or product -specific waiver it must: 1. Have a detailed justification for the use of goods, products, or materials mined, produced, or manufactured outside the United States. A certification that there was a good faith effort to solicit bids for domestic products supported by terms included in requests for proposals, contracts, and nonproprietary communications with potential suppliers. 3. In addition, at a minimum and to the greatest extent practicable, each proposed waiver submitted for consideration by the MIAO should include the following information, as applicable. The BABA Waiver PDF Form must be completed and submitted with the required supporting documentation, following the instructions on the form, for project/product specific waiver consideration. Prior to the waiver documentation is submitted to the Division, the Grantee is responsible to confirm its completeness. The Division will review the documentation and if it is confirmed to be complete, will submit the required waiver request information and additional documentation to our lead CDBG state agency (Dept. of Commerce) for their review prior to them forwarding it onto the appropriate HDU representative for further review and processing. A waiver must be approved by the Division, lead state agency, HUD, and the MIAO prior to an entity proceeding with using any construction items subject to the BAP for the CDBG project that are not produced in the United States. A project/product specific wavier process could take several months and could significantly delay your proiect. Therefore, due to the time restraints attached to CDBG-1 projects, the Division will only approve waivers sent in a timelv manner be sent to the Deaartment of Commerce (lead CDBG Aeencv) for submission to HUD and MIAO. Recordkeeping Grantees are required to maintain documentation in accordance with applicable program requirements for recordkeeping and record retention. It is the grantee's responsibility to ensure all records related to BABA compliance are properly maintained, included any records kept by third parties (engineers, contactors, vendors, etc.), or exemption due to a waiver in accordance with program -specific recordkeeping requirements and 2 CFR 200.334 as applicable to federal grants. CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 11 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 165 Appendices The following templates, forms and lists are provided. • BAP Compliance Certification Statement for CDBG-I Projects • BAP De Minimis Waiver for CDBG-I Projects • BAP Manufacturer's Compliance Certification for CDBG-1 Projects • Materials and Products Covered by BABA CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 12 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 166 BAP Compliance Certification Statement for CDBG-1 Projects Grant Subrecipient (Owner): Grant Number Project Name: The (Grant Subrecipient) certifies that their contractors (including subcontractors) performing construction, alteration, maintenance, and repair of the public wastewater systems and/or public drinking water systems (infrastructure project) under the above -mentioned grant number will comply with the Build America, Buy America ("BABA") Act. Pub. L. 117-58, sections 70911-70917, Buy America Preference (BAP) requirements (codified in 2 C.F.R. Part 184). The Act expands the coverage and application of Made in America requirements in Federal financial assistance programs for infrastructure projects. The contractor will provide the necessary documentation to show compliance with BAP, unless a waiver is approved. Contractor (print) (sign and date) Grant Subrecipient (Owne (print) (sign and date) Attach a list of all covered material and products slated to be procured and used in the infrastructure project. Submit via the Division's Online Supporting Documentation Submittal portal, Attention CDBG-1 Unit Engineer CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 13 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 167 BAP De Minimis Waiver for CDBG-1 Projects Grant Subrecipient (Owner): Grant Number Project Name: This waiver is being requested for a portion of the materials / products used in the above infrastructure project due to the cumulative cost of these materials / products does not exceed five percent (5%) of the total cost of covered products used in the project (up to $1 million). We understand in such cases, the BAP would be waived for part of the project, but the rest would still need to comply with the BAP. The total cost of all covered materials includes all iron and steel, construction materials, and manufactured projects used in the project, regardless of whether the BAP currently applies under the HUD Phased Implementation wavier. Enter Total Cost of All Covered Materials: Multiply the above total by 0.05 (5%): Enter the lower of the number calculated in the row above or $1,000,000: (this amount is the De Minimis limit for the project) The BAP can be waived for covered materials from foreign or unknown sources at a cost not to exceed the De Minimis limit of 5% of the total cost of materials or $1,000,000 (whichever is less). The BAP will still apply to other covered materials used in the project. Attach a list of covered materials and their associated costs to which the De Minimis limit has been applied. Contractor Grant Subrecipient (Owner) (print) (print) (sign and date) (sign and date) Submit via the Division's Online Supporting Documentation Submittal portal, Attention CDBG-1 Program Manager CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 14 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 168 De Minimis List of Covered Materials Product Service Code Item (PSC) / North Carolina Quantity Price / Cost Industry Classification System (NAICS) CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 15 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 169 BAP Manufacturer's Compliance Certification for CDBG-1 Projects [This letter must be provided on the manufacturing company's letterhead.] Manufacturer's Company Name: Company Address: CDBG-I Project Name and Project Number: Subject: Build America, Buy America (BABA) Certification I, (company representative), certify that the following products and/ or materials shipped / provided to the above -mentioned project are in full compliance with the Buy America, Build America (BABA) requirements, as mandated in U.S. Department of Housing and Urban Development (HUD). Item, Product and/or Materials and relevant Product Service Code (PCS) and North American Industry Classification System (NAICS) code: 1) a 3) Such product manufacturing process took place at the following location: If any of the above compliance statements change while providing material to this project, we will immediately notify the prime contractor and the project engineer. (signature and title of company representative) Printed name of company representative Professional title of company representative Email address Phone number (date) CDBG-1 Program BABA Guidance: Updated 10/11/2024 Page 16 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 170 Materials and Products Covered by BABA The following list (Table 1) is not comprehensive. Table 1: Products Likely made "Primarily" of Iron and Steel to be Classified as Iron and Steel under BABA Lined and Unlined Pipe Lined and Unlined Fittings Tanks Flanges Pipe Clamps and Restraints Structural Steel Valves Hydrants Pre -Cast, Iron/Steel Reinforced Concrete (of all types, regardless of iron/steel content percentage) Manhole Covers and other Municipal Castings Access Hatches Ballast Screens Iron or Steel Benches Bollards Cast Bases Cast Iron Hinged Hatches Cast Iron Riser Rings Catch Basin Inlets Cleanout/Monument Boxes Construction Covers and Frames Curb and Corner Guards Curb Boxes Curb Openings Curb Stops Detectable Warning Plates Downspout Shoes Drainage Grates Drainage Grate Frames and Curb Inlets Inlets Junction Boxes Lampposts Manhole Rings and Frames Manhole Risers Meter Boxes Service Boxes Steel Hinged Hatches Steel Riser Rings Trash Receptacles Tree Grates Tree Guards Trench Grates Valve Boxes Valve Box Covers and Risers Access Ramps Aeration Pipes and Fittings (separate from aeration/blowers) Angles Backflow Preventers/Double Check Valves Baffle Curtains Iron or Steel Bar Bathroom Stalls Beam Clamps Cable Hanging Systems Clarifier Tanks Coiled Steel Column Piping Concrete Reinforcing Bar, Wire, and Fibers Condensate Sediment Traps Corrugated Pipe Couplings Decking Digestor Covers Dome Structures Door Hardware Doors Ductwork Expansion Joints Expansion Tanks (diaphragm, surge, and hydropneumatics) Fasteners Fencing and Fence Tubing Fire Escapes Flanged Pipe Flap Gates Framing Gate Valves Generic Hanging Brackets Grating Ground Testing Boxes Ground Test Wells Guardrails HVAC Registers, Diffusers, and Grilles Joists Knife Gates Ladders Lifting Hooks, J-bar, Connectors within, and Anchors for Concrete CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 17 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 171 Lockers Man Baskets and Material Platforms Manhole Steps Mud Valves Municipal Casting Junctions Non -mechanical (aka stationary) Louvers and Dampers Overhead Rolling Doors/ Uplifting Doors (manual open, no motor) Pipe Connectors Pipe Hangers Pipe Pilings (any type of steel piling) Pipe Spool (pipe, flanges, connectors, etc.) Pipe Supports Pitless Adaptors Pre -Fab Steel Buildings/Sheds (simple structure, unfurnished) Pre -stressed Concrete Cylinder Pipe (PCCP) Railings Reduced Pressure Zone (RPZ) Valves Roofing Service Saddles Sheet Piling Sinks (not part of eyewash systems) Solenoid Valves Stairs Static Mixers Stationary Screens Surface Drains Tapping Sleeves Telescoping Valves Tipping Buckets Trusses Tubing Valve Stem Extensions Valve Stems (excluding handwheels and actuators) Wall Panels Wall Sleeves/Floor Sleeves Welding Rods Well Casing Well Screens Wire Wire Cloth Wire Rod Wire Rope and Cables CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 18 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 172 The following list (Table 2) is not comprehensive. Table 2: Products Likely made "Primarily" of Iron and Steel to be Classified as Manufactured Products under BABA Actuator Superstructures/ Support Structures Aeration Nozzles and Injectors Aerators Analytical Instrumentation Analyzers (e.g., ozone, oxygen) Automated Water Fill Stations Chemical Feed Systems (e.g., Blowers/Aeration Equipment Boilers, Boiler Systems polymer, coagulant, treatment chemicals) Chemical Injection Quills Chemical Injectors Clarifier Mechanisms/Arms Compressors Controls and Switches Conveyors Cranes Desiccant Air Dryer Tanks Dewatering Equipment Drives (e.g., variable frequency Dewatering Roll -offs Disinfection Systems drives) Electric/Pneumatic/Manual Electrical Cabinetry and Housings Accessories Used to Operate Valves (such as electrical Electrical Conduit (such as electric valve actuators) boxes/enclosures) Electrical Junction Boxes Electronic Door Locks Elevator Systems (hydraulic, etc.,) Emergency Life Systems (including eyewash stations, emergency safety showers, fire extinguishers, fire Exhaust Fans Fall Protection Anchor Points suppression systems including sprinklers /piping/valves, first aid, etc.) Filters (and appurtenances, Fiberglass Tankw/Appurtenances including underdrains, backwash Flocculators systems) Galvanized Anodes/Cathodic Fluidized Bed Incinerators Protection Gear Reducers Generators Geothermal Systems Grinders HVAC Dampers (if appurtenances to Heat Exchangers HVAC (excluding ductwork) aerators/blowers) Intake and Exhaust Grates (if HVAC Louvers (mechanical) appurtenances to aerators/blowers) Instrumentation Laboratory Equipment Ladder Fall Prevention Systems Ladder Safety Posts Mechanical or Actuated Lighting Fixtures Lightning and Grounding Rods Louvers/Dampers Membrane Bioreactor Systems Membrane Filtration Systems Metal Office Furniture (fixed) Meters (including flow, wholesale, water, and service connection) Motorized Doors (unit) Motorized Mixers Motorized Screens (such as traveling screens) Motors Pelton Wheels Pipeline Flash Reactors (like injectors) Plate Settlers Precast Concrete without Iron/Steel Reinforcement Furnished Pre -Fab Buildings (such as furnished with pumps, mechanics Presses (including belt presses) Pressure Gauges inside) Pump Cans/Barrels and Strainers Pumps Mechanical Rakes CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 19 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 173 Sampling Stations (unless also act Safety Climb Cable as hydrant) Scrubbers Sensors Sequencing Batch Reactors (SBR) Steel Shelving (fixed) Steel Cabinets (fixed Slide and Sluice Gates Spray Header Units interior/furniture) Supervisory Control and Data Valve Manual Gears, Actuators, Acquisition (SCADA) Systems Tracer Wire Handles Water Electrostatic Precipitators Voltage Transformer (WESP) Water Heaters Weir Gates CDBG-I Program BABA Guidance: Updated 10/11/2024 Page 20 of 20 Board of Commissioners - October 20, 2025 ITEM: 9 - 3 - 174 This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: Planning PRESENTER(S): Rebekah Roth, NHC Planning & Land Use Director CONTACT(S): Rebekah Roth, Katia Boykin, NHC Planning & Land Use Community Planning Supervisor SU BJ ECT: Presentation of the NHC Destination 2050 Comprehensive Plan Update Final Goals and Future Land Use Map BRIEF SUMMARY: Destination 2050 is an update to New Hanover County's Comprehensive Plan adopted in 2016. In response to the county's ongoing growth and evolving community needs, residents, stakeholders, elected and appointed officials, and planning staff have worked collaboratively to shape this updated plan over the past year. Destination 2050 serves as a roadmap to guide policy decisions, influence development patterns, direct public investments, and safeguard natural resources through the year 2050. On May 1, 2025, the Board of Commissioners and the Planning Board held a joint meeting where staff were given further input and were instructed to reduce the original ten goals to four. This presentation identifies the consolidated four goals with objectives, key policies, and the proposed Future Land Use Map. These recommended goals and strategies will serve as a roadmap to guide policy decisions, shape development patterns, direct public investments, and protect natural resources. Staff is seeking final direction on these remaining components of Destination 2050. This guidance will allow staff to incorporate the Commissioners' direction into a draft document for public review as part of the plan adoption process. The draft of NHC Destination 2050 will then be released in November, in advance of the Planning Board's public hearing meeting. The Planning Board will hold its hearing in January 2026, and the Board of Commissioners' consideration will then be scheduled for February 2026. STRATEGIC PLAN ALIGNMENT: Sustainable Land Use & Environmental Stewardship o Natural areas and critical environmental features are enhanced and protected. ■ Ensure development compliments natural features. RECOMMENDED MOTION AND REQUESTED ACTIONS: Provide final direction to the draft goals, objectives, Future Land Use Map and key policies ATTACHMENTS: Goals, Objectives, and Policies - Commissioner Rexiew Draft Board of Commissioners - October 20, 2025 ITEM: 10 Future Land Use Classification and Maps - Commissioner Review Draft Staff Presentation COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend direction to staff on draft goals, objectives, Future Land Use Map and key policies. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 10 Destination 2050 - Draft Goals, Objectives, Policies, and Future Land Use Recommendations In 2016, New Hanover County adopted its first comprehensive plan, Plan NHC.• Charting the Course. Since then, our community has continued to grow, new challenges have emerged, and major investments have been made to put the plan's vision into action. These include reorganizing and modernizing the County's development regulations into a Unified Development Ordinance, extending water and sewer trunk lines to serve the "Last Frontier," and creating a stormwater services program to address drainage concerns tied to historic development patterns. With much of that work completed, we also recognize that planning is not a one-time exercise. As our community evolves, we must continually adapt in order to meet future needs. The Board of Commissioners began to set the direction for this work when they approved the new Strategic Plan in July 2023 with a focus area that includes Sustainable Land Use and Environmental Stewardship. For those reasons, in 2024 the County began a full update to the comprehensive plan —Destination 2050. Over the past year, staff have gathered input from residents, business owners, technical experts, and public officials to better understand community values and priorities for the next 25 years. We have heard consistently that while residents see the need for new housing and commercial services, they also want to preserve the qualities that make New Hanover County special —its unique character, strong sense of place, and high quality of life. The Board of Commissioners has emphasized the importance of protecting our natural environment, coordinating growth with infrastructure capacity, and improving planning processes so residents can more easily understand and participate in decisions. In response, staff have developed four broad goals for Destination 2050. These goals describe the outcomes we want to achieve: • Create vibrant, lasting places by balancing local character with future needs • Support long-term community needs through fiscally responsible growth, infrastructure, and services • Promote stewardship of natural resources and strengthen coastal resilience • Strengthen collaboration and engagement to guide community planning Each goal will be supported by objectives, policies, and actions. Objectives will provide measurable targets that help us track whether progress is being made. Policies will serve as guiding principles for the Board of Commissioners when considering public investments and development decisions. Actions will outline the specific steps County staff and partners will take to implement the plan. Together, these goals and policies will inform the place type recommendations on the Future Land Use Map. Together, these elements create a clear framework for how New Hanover County will grow, adapt, and thrive through 2050. Board of Commissioners - October 20, 2025 ITEM: 10- 1 - 1 Quality of Place Goal: Create vibrant lasting places by balancing local character with future needs Objectives Policies Promote a strong sense of place that The County's unique cultural, historical, and environmental assets should be enhanced, protected, and enhances community character and safeguarded as central to community identity and sense of place. access to shared resources New development and redevelopment should be designed to complement the existing built environment and highlight natural landscapes. Vibrant, people -centered spaces and mixed -use hubs should be encouraged to strengthen social connections, support small businesses, and provide walkable, community -oriented destinations. A connected network of parks, trails, greenways, water access, and cultural facilities should be supported to ensure equitable access. Inclusive design and accessibility should be supported to allow all residents, including those with disabilities, to fully utilize public spaces and shared resources. Strengthen the long-term viability of Neighborhood reinvestments and adaptive reuse should be promoted to sustain long-term viability neighborhoods and corridors while minimizing impacts on established communities. Master planned developments should provide a range of housing types and community amenities to accommodate residential demand while preserving land for commercial and employment use. New development should incorporate appropriate transitions in scale, design, and intensity to protect the character and stability of existing neighborhoods. Commercial development should be focused along roadway corridors where it can capture existing traffic, deliver new services for residents, and support multimodal connections. Infrastructure and development along corridors should be designed to accommodate future needs and development patterns that can shift with economic and demographic changes. Enhance opportunities for vibrant and Development of community hubs and public spaces should be encouraged to strengthen identity, civic distinctive gathering places engagement, and year-round activity. Master planned developments and large-scale mixed -use projects should incorporate distinctive public spaces —such as squares, plazas, and forecourts —that support civic, commercial, and cultural life. Walkable centers that concentrate commercial, civic, and cultural uses should be promoted as focal points for vibrant gathering places. Programs and events that animate public spaces and foster cultural identity and social cohesion should be supported. Increase connectivity between Expansion of multimodal networks should be pursued to provide safe, convenient, and accessible neighborhoods, corridors, and travel options for motorists, bicyclists, and transit users. destinations Connectivity across neighborhoods, jurisdictions, and property lines should be strengthened through roadway, bicycle, and pedestrian linkages that integrate new development with existing and planned networks. Land use and development patterns should support walkable, bike -friendly, and transit -accessible communities by encouraging connections between residential areas, commercial services, schools, parks, and employment centers. Street design should be context -sensitive and consistent with complete streets principles, reflecting the character and needs of surrounding neighborhoods while enhancing safety and multimodal access. Master planned developments should incorporate the future street recommendations of this plan and provide internal and external connections that improve mobility and access to key destinations. Board of Commissioners - October 20, 2025 ITEM: 10- 1 - 2 Infrastructure & Support Services Goal: Support long-term community needs through fiscally responsible growth, infrastructure, and services Objectives Policies Support safe and reliable infrastructure Essential public infrastructure in established neighborhoods should be maintained and upgraded as that sustains existing residents and required to ensure equitable access and reliable service delivery. neighborhoods Private and public investments that expand access to public water, sewer, and other essential services for existing communities should be encouraged. Master planned developments, especially larger projects that incorporate space for new community services (fire stations, schools, parks, etc.), should be supported and guided by clear standards and processes. Resiliency and sustainability should be incorporated into infrastructure systems so they are able to withstand environmental impacts and can support long-term community health. Infrastructure planning and investment should be aligned with land use goals, prioritizing infill, redevelopment, neighborhood stabilization, and master planning of new communities. Align public investments to accommodate Infrastructure and public facilities planning should be coordinated with future land use patterns to fiscally responsible future growth and ensure fiscally responsible and well -sequenced growth. changing community needs Public infrastructure investments should be prioritized for areas targeted for growth and redevelopment to maximize community benefits. Future development should be encouraged in locations with existing or planned infrastructure in order to reduce long-term public costs. Public -private partnerships should be leveraged to expand infrastructure capacity and increase return on public investments. Strengthen community safety and well- Development and redevelopment should incorporate design strategies that enhance public safety, being visibility, and safe access for all residents. Green space, active transportation networks, and design features that support physical health, mental well-being, and social connection should be promoted. Site designs that enhance visibility, activity, and safe access for residents should be supported, while gated access and street designs that hinder emergency response should be discouraged. Hazard -sensitive design should be integrated into development to ensure reliable emergency access and community safety during storm events. Foster a resilient and diverse local Place -based and diversified economic development that leverages natural resources, cultural assets, economy and regional attractions while broadening opportunities through entrepreneurship, small business growth, and innovation should be promoted. Master planned developments that integrate regional destinations and amenities and strengthen supporting infrastructure should be encouraged to attract investment and enhance community vitality. Development standards that support high -wage industries, reduce impacts on county services and natural resources, and ensure readiness for future economic and technological shifts should be supported. Efforts to build a resilient and inclusive business environment, such as partnerships with educational institutions and workforce programs, should be supported to enable businesses and residents to adapt to changing environmental, economic, and social conditions and promote sustainable long-term growth. Board of Commissioners - October 20, 2025 ITEM: 10- 1 - 3 Environmental Stewardship & Resilience Goal: Promote stewardship of natural resources and strengthen coastal resilience Objectives Policies Increase preparation for changing natural The extension of new public infrastructure in areas with increased environmental hazards should be hazards evaluated carefully and may require additional safeguards and maintenance agreements or may be prohibited when risks are too great. The risk tolerance framework outlined in this plan should guide the analysis, prioritization, and approval of capital projects and major community investments. New development in hazard prone areas should incorporate resilient building and site design, including landscaping that mitigates saltwater flooding and frequent tidal inundation. Sustainable resource management, including the conservation or restoration of natural systems that enhance coastal resilience and reduce community vulnerability, should be promoted. Reduce community vulnerability to Decisions on zoning and development standards should incorporate the 2025 Northern New Hanover flooding and storm impacts County Watersheds Flood Study and other technical studies related to flooding and storm impacts that are accepted or approved by the Board of Commissioners. Development in wetlands, floodplains, and other flood prone areas should be discouraged or mitigated, with new development directed toward lower -risk locations. Higher -risk uses should be discouraged in areas with existing flooding concerns. Community preparedness and capacity to withstand flooding and storm events should be strengthened by proactive planning and investment. Protect and enhance natural resources, Lower intensity development and other conservation alternatives should be encouraged in sensitive water quality, and water supply areas such as wetlands, floodplains, and high flood hazard zones to safeguard water quality and ecosystems. Estuarine waters, primary nursery areas, outstanding resource waters, and shellfishing waters should be protected by limitations on dredging and marine development to scientifically justified, low -impact circumstances. (NOTE: More details would be outlined in the plan for CAMA purposes.) Stormwater and drainage systems should be designed to align with predevelopment hydrology and to minimize direct discharges to surface waters. Water resources and supplies should be safeguarded and sustainably managed through practices that consider aquifers and minimize contamination risks. Sustain a healthy and diverse tree canopy Tree canopy should be protected and expanded throughout unincorporated New Hanover County. and connected ecosystems Tree plantings and landscaping in new developments should be designed to contribute to ecosystem health, provide shade, and reduce urban heat impacts, with a focus on native species. Open space should be connected to strengthen biodiversity and ecological resilience. Community stewardship and education should be promoted to support the long-term care and appreciation of trees and natural systems. Expand and improve open space for Development patterns and practices (e.g. stormwater design) that preserve natural areas, buffers, and ecological and community benefits significant trees, while minimizing adverse environmental impacts of the built environment, should be encouraged. The identification and preservation of open spaces should be incorporated into early development planning and review to ensure new projects coordinate and connect open spaces to create cohesive natural areas and wildlife corridors. Conservation of lands that protect natural resources, wildlife habitat, and biodiversity, while supporting educational and passive recreational opportunities, should be promoted. Uses on undeveloped barrier and estuarine system islands should be limited to research support and passive recreation. Preserve coastal and community Resilient shoreline and habitat infrastructure that protect coastal systems and maintain ecosystem infrastructure essential to ecosystem functions should be encouraged. health and quality of life Floating home development without adequate pump -out or sewer facilities should be prohibited to protect public trust waters and reduce risks to people and property. Land use and infrastructure decisions for hazard prone areas should minimize risks to life, property, and ecosystem health. Public utility extensions and infrastructure improvements should balance community resilience needs with the protection of sensitive natural systems. Board of Commissioners - October 20, 2025 ITEM: 10- 1 - 4 Coordination & Engagement Goal: Strengthen collaboration and engagement to guide community planning Objectives Policies Expand opportunities for the public to Broad access to engagement opportunities should be encouraged so that residents of all backgrounds share community perspectives that can participate in the planning process. inform planning decisions Communication strategies should be transparent, accessible, and inclusive of residents with different languages, abilities, digital access, and civic experience. Community planning efforts should support ongoing and consistent relationships with the community to build trust and support informed participation. Strengthen partnerships with regional Coordinate regional planning efforts to align infrastructure investments, transportation systems, and and local organizations to align efforts growth strategies across jurisdictional boundaries to support shared goals and reduce duplication of and leverage resources resources. Leverage partnerships with community groups, nonprofit organizations, and other local governments to advance the goals and implementation actions of this plan and enhance community benefits and shared outcomes. Expand cross -sector collaboration with public, private, and institutional partners to address complex community challenges, maximize available resources, and strengthen long-term resilience and prosperity. Improve public understanding of Planning information should be presented in clear, straightforward language and provided in accessible planning concepts and processes formats so that it can be easily understood by residents and stakeholders. Educational opportunities should be provided to support residents' and stakeholders' understanding of planning concepts, processes, state regulations, and decision -making considerations. Community engagement activities should be structured to support meaningful participation so residents have the information and context needed to contribute effectively at key decision points. Administrative and compliance processes should be conducted in a clear, transparent, and predictable manner to build community trust and confidence in planning decisions. Board of Commissioners - October 20, 2025 ITEM: 10- 1 - 5 This page intentionally left blank. Destination 2050 - Place Type Classifications In the current 2016 Comprehensive Plan, future land use is designated by eight classifications, including the Riverfront Conservation district created in 2024. A total of nine place types are proposed for the Destination 2050 plan. New place type classifications for Resilient Mixed Use and Corridor Commercial have been added to the current palette of land use classifications, and Urban Mixed Use has been removed. This represents a shift away from promoting residential development along major roadway corridors in order to retain sufficient land for commercial services in a market with strong residential demand and a recognition that resilient design is an important factor in some areas where a mix of uses might be appropriate. Place Type Application & Purpose Density/Intensity Types of Uses Applies to areas of the County that are preserved for conservation or are intended to remain as open space rather than accommodate new development. open space, low -impact ° UPDATED Conservation These areas protect the natural environment, water quality, wildlife habitat, and in some cases cultural or archaeological resources. They may also Very Limited recreation, ° coincide with areas of known environmental hazards, where limiting development reduces community vulnerability. environmental education v Applies specifically to parcels on the Western Bank across from downtown Wilmington, which is unique due to its industrial history, environmental low -impact public ° ° Riverfront sensitivities, high visibility, and partial inclusion in the National Register Historic District that covers downtown Wilmington. It is intended to protect the Limited recreation and potentially civic and low- u Conservation natural environment, water quality, wildlife habitats, important cultural and archaeological resources, and areas prone to natural hazards. The vision is intensity non-residential to maintain the area's existing condition or reduce land use intensity. No residential development would be allowed. uses Applies to the Castle Hayne area given its primarily agricultural existing character and limited infrastructure. The intent is to preserve rural character, agriculture, forestry, UPDATED Rural protect working lands and open space, and allow for residential development that is compatible with these settings. Residential uses are generally Very Low open space, recreation, Residential limited to single-family homes on larger lots, with agriculture, forestry, recreation, and open space as predominant and ongoing land uses. Clustering of low -density residential v homes may be appropriate where it helps conserve farmland, open space, or environmental resources and reinforces the rural character of the area. v Infill Focuses on lower -density housing within or near established neighborhoods. New development is expected to be consistent with the density, scale, and low -density residential, NEW Residential coastal character of surrounding residential areas and in line with current zoning. It emphasizes high -quality design that incorporates open space, tree Low civic, recreational canopy, roadway and bicycle/pedestrian connectivity, and resilient building practices. Encourages compact, mixed -use development, while placing a strong emphasis on environmental stewardship and risk reduction. Because these areas Resilient may be subject to flooding, located near wellhead protection zones, or otherwise environmentally sensitive, projects must be designed to minimize risk residential, retail, office, NEW Mixed Use and protect natural systems. Clustering of development is encouraged to reduce exposure to hazards, preserve open space, and safeguard water quality Low to Moderate services, institutional, and tree canopy.Moderate residential densities of u to 17 dwelling units per acre may be appropriate where conditions allow or as art of master p g p Yp recreational planned developments. Water and sewer are required. Emphasizes compact, mixed -use development patterns that create active centers. Community Mixed Use places are intended to create vibrant, lasting Moderate (individual Community places that will meet the needs of future residents. A mix of uses within a single project or larger master planned development is preferred, with parcels) to residential, retail, office, x UPDATED Mixed Use opportunities for higher residential densities and taller building heights where appropriate transitions in height, density, and character can be achieved. Moderate -High services, institutional, 75 For smaller or standalone parcels, building height is generally limited to 1-3 stories, and residential densities are expected to remain moderate (up to 17 (master planned recreational units per acre). developments) Identifies areas that serve as hubs for jobs and production, with office, light industrial, and supporting commercial uses as the primary focus. These office, light industrial, UPDATED Employment centers are designed to strengthen the local economy, and provide a wide range of employment opportunities. They may also include moderate density Moderate employee services, Center residential, civic, and recreational uses when designed to complement the primary employment function. Building heights may range from 1-7 stories, medical, civic, residential, with taller buildings most appropriate in areas with adequate infrastructure and transitions to surrounding development. recreation Applies to properties along major roadway corridors and is intended to provide residents with convenient access to basic goods and services close to v home. By reducing the need to travel long distances for daily needs, these areas can help ease congestion and stresses on the surrounding roadway retail, commercial NEW Corridor network. Development should be attractive, pedestrian -friendly, and designed to reflect a high quality of place, with attention to buffering and Moderate (transitions) services, office, medical, U Commercial transitions that protect nearby neighborhoods. Portions of corridors will be designated as either transitional —locations with lower -intensity uses and to High (nodes) impacts —or as nodes —commercial centers where higher intensities and building heights above three stories may be appropriate when paired with civic Lnquality Ln site design and sensitive transitions to adjacent neighborhoods. Residential uses are not encouraged. QJ Commerce Provides space for the County's primary employment and production activities, with a focus on heavy commercial and light and heavy industrial uses. industrial, heavy � UPDATED Office and complementary commercial uses may be appropriate where they support the overall function of the area. Unlike Employment Centers, N/A commercial, commercial m Zone residential development is not allowed. services, office Board of Commissioners - October 20, 2025 ITEM: 10- 2 - 1 This page intentionally left blank. L Coun Brunswick County NHC Conservation k�"' W a 0 N CD 2 nder While there has been very little change to where Conservation is / ' applied from the 2016 Plan, new / land that has been conserved in the past few years is now designated as Conservation... o � v � 1 ...and land that is no X longer subject to conservation restrictions is now re-classified (see Resilient Mixed Use X and Community Mixed X Use Maps for more information). 17th o This place type applies to areas of the County that are preserved for conservation or are intended to remain as open space 0 rather than accommodate new development. These areas protect the natural environment, �0` water quality, wildlife habitat, and in some p�neGl cases cultural or archaeological resources. ers r They may also coincide with areas of known environmental hazards, where limiting �`0 development reduces community vulnerability. Density/Intensity: A• None to Very Limited Types of Uses: ;�� • Open space, Low -impact Recreation, Environmental education of mmi - ctof r 20, 2025 IT Riverfront Conservation Coun k�"' w a G c c c G G U° G Pender County 2 �o� S\dburY � U 1 a \ G Y a, ,.�Ct�Vw1l This conservation place type D applies specifically to parcels Oleander This desi within New Hanover County on Sh;p,,rd natural the western banks of the Cape i Fear and Northeast Cape Fear habitats, i Rivers, located between the Cape 17th o resource Fear Memorial Bridge and the The s' n r Isabel Holmes Bridge, across from 0, the ii downtown Wilmington. This area p'd 10 o is unique due to its industrial e0d o� history, environmental sensitivities, high visibility, and partial inclusion in the National A'ne Register Historic District that Sanders covers downtown Wilmington. �o c� As this place type was created in 2024, no updates have been made to those policy recommendations. a X .0%00 0% NHC 0 Board of �r Rural Residential /Z Pen r Coun Brunswick County w a v 2 17th M611 1.1 Board of NHC 0 This place type is proposed for the same area - Castle Hayne - as in the 2016 Comprehensive Plan G G Np��Y C G G v S�`e\fie G G U Pender u County U S;dburY u u u U 1 O \G nder X / • ' • Rural Residential areas are intended to maintain the County's agricultural and open space character while allowing for limited single-family homes on larger lots. Farming, forestry, recreation, and conservation remain the primary uses, with new housing designed to fit the rural setting. Homes may be clustered to help preserve farmland or natural areas, provided the overall rural character is maintained. Density/Intensity: • Low (1 unit or less per acre) Types of Uses: • Low -Density Residential, Civic, Recreational 20, 2025 New Resilient Mixed Use Pen r Coun I k " tj This area is currently classified Conservation, but these properties have similar environmental conditions as others in northern NHC. The primary difference is their proximity to CFPUA wellheads, so development that utilizes public water and sewer could reduce the impacts of development. The proposed classification will retain protections to CFPUA wellheads while allowing development in line with what is available for other nearby properties. Reclassifying this area also means that Conservation place type recommendations can be updated to clearly designate land \ that is to be preserved. n Brunswick County Both of these areas are classified as Community Mixed Use in the 2016 Plan but are located in places where coastal hazard areas and/or tidal flooding would need to be considered in future developments. NHC ,.�iju 2 \AO" nder 1 G G G G Pender u County ` o dburY � u a U 1 O \G G 17th o o J This place type encourages walkable, c�^ mixed -use centers that bring together °� ,� o homes, shops, offices, and civic spaces while deed o� protecting the environment. Development is designed to reduce exposure to flooding and other risks, with utilities and open space A�ned planned to support long-term community Sanders needs. By clustering new buildings in safer areas and preserving sensitive natural features, these places can grow in a way that is vibrant, connected, and resilient. Density/Intensity: • Low to Moderate (up to 17 units/acre when conditions allow or as part of master planned developments) Types of Uses: ,�Q • Residential, Retail, Office, Services, Board of mmis oars - cto r 20, 20251nstitutional, Recreational IT . 0 2-6 \. In general, areas in northern New Community Mixed Use Hanover County that are classified as Community Mixed Use in the 2016 ` Plan keep that designation. Some / areas such as N. College and along / No\\y el Gordon Rd. that were previously sre�� Urban Mixed Use now fall under this - classification. However, if sites are master planned higher densities and Pen ► 2 �° intensities could still be possible. Coun ,s Gs v �p r U i� a tw .. 00 Only the area immediately r along Castle Hayne Rd. south �l y o I'Wi(mington �¢Q` of 1-140 was designated ���� ��, - a Community Mixed Use in the D oleander 2016 Plan. This classification is now applied to more Shipyard This place type emphasizes compact, mixed parcels as the approval of the use development patterns that create active Moores Crossing Planned 17th Q centers and vibrant, lasting places. A mix of Development has created J uses within a single project or larger master opportunities for a larger c, planned development is preferred and could mixed use node. 0, o provide opportunities for higher densities �de�d o� and taller buildings when transitions are Brunswick °� �m possible. Smaller sites should remain more County limited in scale (up to 17 residential units Arne per acre and no more than 3 stories in n Sanders height). These areas should be designed to protect natural features, include transportation connections, and provide public facilities that support growth. Density/Intensity: • Moderate (smaller parcels) to High (mixed use centers and master planned developments) Types of Uses: 0 �Q • Residential, Retail, Office, Services, Destinati Board of mmis oars - ctot r 20, 2024nstitutional, Recreational NHC ,.iju IT ;.aa 7 \ L P\n r Coun ki Employment Center Brunswick (( This area is classified Commerce Zone in the 2016 Plan. Recently approved residential development immediately adjacent to the parcel make an Employment Center classification more appropriate, as it could serve as a transition between the residential uses and existing industry. rNJI-ON NNIMEN k 2 fh Oleander 77a J O� ^off o d 0 e0 o1� ane d Sanders �o C9 Board ofinis ors - 01 m IT .(W,2 - 8 These areas are designated as Commerce Zone and Community Mixed Use respectively in the / 2016 Plan. Given existing and / planned residential and commercial in the area, an \ Employment Center classification may be more appropriate as it i supports a mixture of uses. s' Nis [is [: Employment Centers are areas focused on jobs and industry, designed to strengthen the local economy and connect workers and businesses to the larger community. These areas primarily include office, light industrial, and supporting commercial uses, with opportunities for housing and civic spaces when they fit well with the employment focus. Residential densities are expected to remain modest, and building heights can range from one to seven stories, with taller building most appropriate in areas with adequate infrastructure and transitions to surrounding development. Density/Intensity: • Moderate (up to 8 units per acre for single family and 10-17 units per acre for multi -family) Types of Uses: • Low -Density Residential, Civic, Recreational 20, 2025 Corridor Commercial 7 P\ n r Coun L a This new place type replaces current recommendations for Community Mixed Use and Urban Mixed Use the County's major roadway corridors to clearly outline a vision for commercial services for residents, not multi- family housing. Brunswick County 17th MUu IC1161" VW I f 101 Board of NHC ,.�iju 1 G G G G Pender County ` dburY U U 0 U 1 O \G G nder Corridor Commercial areas provide convenient shopping and services along the County's major roadways, reducing the need for long trips and helping ease traffic on surrounding P streets. Development here should be attractive, 0 well designed, and respectful of nearby �m neighborhoods. Some areas will be transitional with smaller, lower -impact uses, while others d will be nodes -- larger centers where taller buildings and more activity may be appropriate if carefully designed. Housing is not encouraged, keeping the focus on providing accessible goods and services for residents. Density/Intensity: • No residential; moderate (transitions) to high (nodes) for nonresidential Qc Types of Uses: ? • Retail, Commercial services, Office, Medical, Civic Ctot r 20, 2025 2-9 \\ Commerce Zone P\n r Coun w a Brunswick County 2 17th / The Hermitage Rd. area and the land north of the airport were designated Employment Center in the 2016 Plan and have continued to transition to heavy commercial and light industrial areas in recent years. Given the small amount of existing residential in these areas, dbury ° they are proposed to be 3 u Commerce Zone to communicate G° that new residential is not G° envisioned in these locations. G nder Jf X'>\/'></ L A.WA!zMLA"Y a 0 CC This place type provides space for the County's primary employment and 0 production activities, with a focus on heavy commercial and light and heavy industrial uses. Office and complementary ane a commercial uses may also be appropriate, r but residential development is not allowed. o Building height may range from one to seven stories, depending on use and site design. Density/Intensity: • N/A Types of Uses: • Industrial, Heavy commercial, aQ Offices, Commercial services M1116u111a116111yfi VVI r I.' Board of NHC ,.�iju - Oct(jgtr 20, 2025 Future Land Use: Base Map rd Brunswick County ZN'H ation 20', 17th 40/ eander 1 0 m Pender County 01 Place Types 2050 PlaceType Conservation Riverfront Conservation Rural Residential ` Infill Residential Resilient Mixed Use 1 Community Mixed Use Employment Center Corridor Commercial Commerce Zone of This page intentionally left blank. NEW HANOVER COUNTY BOARD OF COMMISSIONERS REQUEST FOR BOARD ACTION MEETING DATE: 10/20/2025 Regular DEPARTMENT: Commissioners PRESENTER(S): Chair Bill Rivenbark CONTACT(S): Kym Crowell, Clerk to the Board SU BJ ECT: Committee Appointments BRIEF SUMMARY: Vacancies exist on the following boards and committees: New Hanover County Commission on African American History, Heritage, and Culture New Hanover County Inspections Department Advisory Council New Hanover County Jury Commission New Hanover County Juvenile Crime Prevention Council STRATEGIC PLAN ALIGNMENT: • Good Governance o Effective County Management ■ I ncrease transparency and awareness about county actions RECOMMENDED MOTION AND REQUESTED ACTIONS: Make appointments. ATTACHMENTS: 2025-10-20 CAAHHC 2025-10-20 IDAC 2025-10-20 Jury 2025-10-20 JCPC COUNTY MANAGER'S COMMENTS AND RECOMMENDATIONS: (only Manager) Recommend appointments. COMMISSIONERS' ACTIONS: Board of Commissioners - October 20, 2025 ITEM: 11 This page intentionally left blank. Committee Appointments New Hanover County Commission on African American History, Heritage, and Culture Vacancies to appoint at this time: 1 Categories: 1 -At-Large Terms: Unexpired Term, expiring 8/31/2027 NOTE: Advertising is ongoing for Civil Rights Community category. Applicant: Eligible for Category Nominations Reappointment Carolyn Beatty At -Large Attachments: Committee Information Sheet Application Board of Commissioners - October 20, 2025 ITEM: 11- 1 -1 NEW HANOVER COUNTY COMMISSION ON AFRICAN AMERICAN HISTORY, HERITAGE AND CULTURE Number of Members: 13 members, appointed in the categories as follows: 5 At -Large, 2 Business Community, 2 Civil Rights Community, 2 Education Community, 2 Faith Community Terms: Staggered initially; 3 years thereafter; per County policy, no member shall serve more than two (2) full consecutive terms unless there is a break of at least one (1) full term between appointments. Regular Meetings: Second Thursday of every month at 4:30 p.m. at the New Hanover County Government Center, 230 Government Center Dr., Wilmington, NC 28401. Statute or cause creating Board: BOCC bylaws adopted May 20, 2019. Brief on the functions: The commission shall be organized for the purpose of researching, investigating, discovering, preserving, collecting, cataloging, and celebrating African American culture, history, historical areas, sites and/or landmarks of focus in the county through collaboration with the Cape Fear Museum, New Hanover County Library, City of Wilmington Commission on African American History, NAACP, Arts Council of Wilmington and New Hanover County, UNCW, the North Carolina African American Heritage Commission, and other institutions, agencies and individuals with historical knowledge and expertise. The commission shall educate the community on historical areas and/or landmarks and establish programs and initiatives that preserve and protect New Hanover County's African American history, heritage, arts and culture. The commission shall collaborate with the City of Wilmington Commission on African American History on special events and projects. TERM OF OFFICE CURRENT MEMBERS CATEGORY APPOINTMENT EXPIRATION Kiara Bennerman Unexpired 5104 Christian Drive 8/31/24 At -Large 11/23 Wilmington, NC 28401 8/31/27 First 8/19/24 First /1 910-352-8906 (H) Sabrina Canty 17Apple Road Faith Unexpired 6/16/25 8/31/25 Castle Hayne, NC 28429 Community First 8/18/25 8/31/28 910-228-7477 (C) Veronica Carter -Edwards 903 Sheffield Drive First 8/23/21 8/31/24 At -Large Wilmington, NC 28411 Second 8/19/24 8/31/27 910-794-7943 (H) 910-258-0029 (C) Rebecca Clark 3910 River Front Place, Unit 103 Education First 8/18/25 8/31/28 Wilmington, NC 28412 Community 919-601-4687 (C) Board of Commissioners - October 20, 2025 ITEM: 11- 1 -2 NEW HANOVER COUNTY COMMISSION ON AFRICAN AMERICAN HISTORY (CONT.) TERM OF OFFICE CURRENT MEMBERS CATEGORY APPOINTMENT EXPIRATION Bernadette Correa 6313 Branford Road At -Large First 8/19/24 8/31/27 Wilmington, NC 28412 910-538-8808 (C) 910-727-4147 (W) Daniel Jones 403 Dock Street Unexpired 3/18/24 8/31/24 Wilmington, NC 28401 At -Large First 8/19/24 8/31/27 919-816-6354 (H) 910-726-9504 (W) *Unable to Serve* Curtis Levy 5040 Market Street, Apt. 251 Business Wilmington, NC 28405 Community First 8/22/22 8/31/25 315-877-0453 (H) Nadira Nash 5616 Old Garden Road, Apt. 106 At -Large First 8/19/24 8/31/27 Wilmington, NC 28403 910-399-2045 (H) 201-563-2296 (C) Terrilyn Phillips 809 Bluebird Lane Business Unexpired Wilmington, NC 28409 Community 12/16/24 8/31/27 910-200-4742 (C) 919-901-1206 (W) Deborah Robinson 321 Wallington Road Education Unexpired 7/17/23 8/31/25 Wilmington, NC 28409 Community First 8/18/25 8/31/28 910-617-0738 Sunni Walker Faith 4120 Hearthside Dr., Apt. 304 First 8/18/25 8/31/28 Wilmington, NC 28412 Community Civil Rights VACANT Community Civil Rights VACANT Community Staff liaison: Linda Thompson Chief Civic Engagement Officer 230 Government Center Dr., Suite 120 Wilmington, NC 28403 Revised: 8/2025 910-798-7414 Board of Commissioners - October 20, 2025 ITEM: 11- 1 - 3 Still Interested 9/8/25 From: noreolv(a)civicolus. com To: Crowell. Kvm; Long. Melissa Subject: Online Form Submission #14246 for Board and Committee Application Date: Friday, September 13, 2024 10:37:53 AM ** External Email: Do not click links, open attachments, or reply until you know it is safe ** Board and Committee Application Board or Committee New Hanover County Commission on African American History, Being Applied to Heritage and Culture Commission on African At -Large American History, Heritage & Culture Categories First Name Carolyn Last Name Beatty Email carolyne-stepupwilmington.ora Home Phone 7044952749 Cell Phone 7044952749 Business Phone 910-343-8469 Fax Field not completed. Home Address 621 North 4th St. City Wilmington State NC Zip Code 28401 Mailing Address (if 621 North 4th St. different from home address) City Wilmington State NC Zip Code 28401 Years Living in New 50 Hanover County Board of Commissioners - October 20, 2025 ITEM: 11- 1 - 4 Personal information collected below is to assure a cross-section of the community is represented. Gender Race Age Occupation Applicant's Employer Female Black 62 Community Engagement Manager StepUp Wilmington Professional Activities Networking, Public Speaking, Community Engagement, Presentations, Workshops, Webinars, Mentoring, Shadowing, Performance Management, Conflict Management, Communications Volunteer Activities Community Development Activities, Church Activities, School Activities, Non -Profit Activities, Volunteer Sports Team Mom, Soup Kitchen Volunteer Why do you wish to The love that I have for my community and city where I was born serve on this board or and raised, along with attaining more knowledge about our committee? African American Culture and sharing our culture and heritage with others. Also bonding our community together with education and knowledge. What areas of concern Focus on making sure that the information on African American would you like to see Culture is shared with everyone and to use other media outlets addressed by this such as social media to share. corn m ittee? Qualifications for Leadership, Communication, Ethnics, Passion, Willing to learn, serving Experience, Education, Diversity, Reliable, Finance, Planning, Compatible, Lack of Conflict, Community Development Other municipal or UNCW- Advisory Board, NHC Endowment community Advisory county boards / Council ( CAC) committees on which you are serving Do you have a family No member employed by New Hanover County? List three local personal references and phone numbers Board of Commissioners - October 20, 2025 ITEM: 11- 1 - 5 Reference 1 Kim Pacheco Reference 1 Phone 919-880-5078 Reference 2 Kimberly Graham Reference 2 Phone 910-398-1810 Reference 3 Daren Beatty Reference 3 Phone 910-352-6247 Additional comments I love the city that I was born and raised in, this is why I feel that it is so important that we all are more educated and have awareness of our heritage and culture, so that we can share and spread the news of the importance of how far we have come and how much more work there is to do. Upload additional Field not completed. information Date 9/13/2024 Consent � I understand that any board or committee appointee may be removed without cause by a majority of County Commissioners., � I understand that information on this application is public record and may be disclosed. Email not displaying correctly? View it in your browser. Board of Commissioners - October 20, 2025 ITEM: 11- 1 - 6 Committee Appointment New Hanover County Inspections Department Advisory Council Vacancy to appoint at this time: 1 Category: At -Large Term: 3 years, expiring 7/31/2028 Applicant: Eligible for Category Nominations Reappointment Greg Wallace At -Large Attachments: Committee Information Sheet Application Board of Commissioners - October 20, 2025 ITEM: 11- 2 - 1 NEW HANOVER COUNTY INSPECTIONS DEPARTMENT ADVISORY COUNCIL Number of Members: 8, appointed in categories as follows: Commercial Builder, Electrical Contractor, Engineer, Mechanical Contractor, Plumbing Contractor, Residential Builder, and 2 At -large Term of Office: Three years - may not serve more than two consecutive terms and cannot be reappointed until at least one year after the last term. Regular Meetings: The Council shall meet at least quarterly and may, at its discretion, establish a more frequent meeting schedule. Meetings are held at the New Hanover County Government Center, 230 Government Center Drive, Wilmington, NC. Action Creating Council: The County Commissioners established the Council on June 15, 1998. Membership increased to 8 on July 13, 1998. Purpose: The Council will provide advice and guidance to the Building Safety Department to ensure consistent, timely, economical, professional, and efficient service as an integral part of the department's purpose to protect the lives and property of the citizens living in New Hanover County. TERM OF OFFICE CURRENT MEMBERS CATEGORY APPOINTMENT EXPIRATION Wesley Daniel Residential First 7/21/25 7/31/28 1930 Deep Creek Run Builder Wilmington, NC 28411 919-524-7139 (H) 910-512-3060 (W) Johnny Milam Plumbing First 7/22/24 7/31/27 212 Cornubia Drive Contractor Castle Hayne, NC 28429 910-540-8318 (c) 910-399-2030 (W) Adam Sisk Engineer Unexpired 4/18/22 7/31/24 708 Monroe Avenue First 7/22/24 7/31/27 Carolina Beach, NC 28428 910-465-2895 (H) 910-343-8007 (W) Shawn Sweeley Mechanical First 7/13/21 7/31/24 5208 Carolina Beach Road Contractor Second 7/22/24 7/31/27 Wilmington, NC 28412 910-274-4568 (H) 910-791-7888 (W) Kirby Trundle At -Large First9/16/24 7/31/27 211 Racine Drive #101 Wilmington, NC 28403 919-896-2368 (C) Greg Uhl Commercial First 7/11/22 7/31/25 313 Colonial Drive Builder Second 7/21/25 7/31/28 Wilmington, NC 28403 910-231-1806 (C) Board of Commissioners - October 20, 2025 ITEM: 11- 2 - 2 TERM OF OFFICE CURRENT MEMBERS CATEGORY APPOINTMENT EXPIRATION Andrew Ward Electrical Unexpired 9/16/24 7/31/25 3405 Osprey Lane Contractor First 7/21/25 7/31/28 Wilmington, NC 28409 910-538-5096 (C) *VACANT* At -Large 7/31 /28 Hans Schult, Inspections Director Revised: 7/2025 New Hanover Building Safety Department 230 Government Center Drive, Suite 110 Wilmington, NC 28403 / 910-798-7008 Board of Commissioners - October 20, 2025 ITEM: 11- 2 - 3 From: noreolv(a)civicolus. com To: Crowell. Kvm; Long. Melissa Subject: Online Form Submission #27925 for Board and Committee Application Date: Thursday, September 25, 2025 8:45:48 AM ** External Email: Do not click links, open attachments, or reply until you know it is safe ** Board and Committee Application Board or Committee New Hanover County Inspections Department Advisory Council Being Applied to Inspections At -large Department Advisory Council Categories First Name Greg Last Name Wallace Email area richardwallacebuilder.com Home Phone 910-279-0364 Cell Phone 901-279-0364 Business Phone 910-520-5056 Fax Field not completed. Home Address 616 Hamlet Ave City Carolina Beach State NC Zip Code 28428 Mailing Address (if 616 Hamlet Ave different from home address) City Carolina Beach State NC Zip Code 28428 Years Living in New 27 Hanover County Board of Commissioners - October 20, 2025 ITEM: 11- 2 - 4 Personal information collected below is to assure a cross-section of the community is represented. Gender Male Race white Age 50 Occupation Residential General Contractor Applicant's Employer I am the owner and president of Richard Wallace Builder, Inc. Professional Activities Builder Board of Directors for the Wilmington Cape Fear home Builders Association Volunteer Activities Set-up Team at Lifepoint Community Church Why do you wish to As a NC licensed General Contractor with 20+ years of serve on this board or experience in residential construction I feel that I can provide committee? insight from the General Contractors point of view and collaborate with the Building Inspectors and Code Officials on how to improve existing building codes and offer insight on code education for the building community. What areas of concern While I have no specific areas of concern at this time, my goal is would you like to see to serve as a constructive voice for both the building community addressed by this and the Inspections Department- fostering collaboration and committee? transparency while offering guidance and strategic input to the Building Safety Department. Qualifications for serving Other municipal or county boards / committees on which you are serving Do you have a family member employed by New Hanover County? NC Licensed General Contractor None W List three local personal references and phone numbers Reference 1 Ralph Konrady Reference 1 Phone 910-228-9621 Board of Commissioners - October 20, 2025 ITEM: 11- 2 - 5 Reference 2 Cameron Moore Reference 2 Phone 910-540-1154 Reference 3 John Jarvis Reference 3 Phone 910-599-2630 Additional comments Field not completed. Upload additional Field not completed. information Date 9/24/2025 Consent � I understand that any board or committee appointee may be removed without cause by a majority of County Commissioners., � I understand that information on this application is public record and may be disclosed. Email not displaying correctly? View it in your browser. Board of Commissioners - October 20, 2025 ITEM: 11- 2 - 6 Committee Appointments New Hanover County Jury Commission Vacancies to appoint at this time: 1 Terms: 2 years, expiring 10/31/2027 Applicant: Eligible for Nominations Reappointment Sheila Nicholson X Gary Owens Attachments: Committee Information Sheet Application Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 1 NEW HANOVER COUNTY JURY COMMISSION Number of Members: 3, appointed as follows: 1 appointed by County Commissioners 1 appointed by Senior Resident Superior Court Judge 1 appointed by Clerk of Superior Court Term: 2 years - may be reappointed Compensation: paid by New Hanover County Qualifications: qualified voter of New Hanover County Regular Meetings: every two years in October Statute or cause creating Board: NCGS Art. I, Chapter 9-1 and 9-2. Each member must take an oath of office. Brief on functions: To prepare a list of prospective jurors utilizing the tax lists of the County and voter registration records, exercising reasonable care to avoid duplication of names. TERM OF OFFICE CURRENT MEMBERS APPOINTMENT EXPIRATION Sheila Nicholson First 10/16/23 10/31/25 3610 Kirby Smith Drive Wilmington, NC 28409 919-302-6285 (C); 910-458-2999 (W) *Desires Reapp intment* Scott Cromartie, Superior Court Judge appointee Timothy J. Kelly, Clerk of Court appointee Clerk of Court: Jan Kennedy Revised 10/2023 316 Princess Street Wilmington, NC 28401 Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 2 From: noreolv(a)civicolus. com To: Crowell. Kvm; Long. Melissa Subject: Online Form Submission #27577 for Board and Committee Application Date: Thursday, September 4, 2025 4:51:08 PM Desires Reappointment ** External Email: Do not click links, open attachments, or reply until you know it is safe ** Board and Committee Application Board or Committee New Hanover County Jury Commission Being Applied to First Name Sheila Last Name Nicholson Email sonicholsonZ-outlook.com Home Phone 919-302-6285 Cell Phone Field not completed. Business Phone 910-458-2995 Fax Field not completed. Home Address 3610 Kirby Smith Drive City Wilmington State North Carolina Zip Code 28409 Mailing Address (if Field not completed. different from home address) City Field not completed. State Field not completed. Zip Code Field not completed. Years Living in New 14 Hanover County Personal information collected below is to assure a cross-section of the community is represented. Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 3 Gender Female Race White Age 59 Occupation Administration Applicant's Employer Town of Carolina Beach Professional Activities Field not completed. Volunteer Activities Field not completed. Why do you wish to I currently serve on this board and would like to continue if serve on this board or possible. com m ittee? What areas of concern Field not completed would you like to see addressed by this com m ittee? Qualifications for I am a qualified voter in New Hanover County and have serving experience working with large amounts of data Other municipal or None county boards / committees on which you are serving Do you have a family Yes member employed by New Hanover County? County Employee's Anna Penny Name What department? Social Services List three local personal references and phone numbers Reference 1 Kim Ward Reference 1 Phone 910-458-2992 Reference 2 Ed Parvin Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 4 Reference 2 Phone 910-465-2766 Reference 3 Brenda Butler Reference 3 Phone 910-352-6927 Additional comments Thank you for considering my application. Upload additional Field not completed. information Date 9/4/2025 Consent � I understand that any board or committee appointee may be removed without cause by a majority of County Commissioners., � I understand that information on this application is public record and may be disclosed. Email not displaying correctly? View it in your browser. Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 5 From: nore ply(d) civicpl us. com To: Crowell. Kym; Long. Melissa; Tribley. Danielle Subject: Online Form Submission #28095 for Board and Committee Application Date: Friday, October 3, 2025 2:05:51 PM External Email: Do not click links, open attachments, or reply Until YOU know it is safe Board and Committee Application Board or Committee New Hanover County Jury Commission Being Applied to First Name Gary Last Name Owens Email clowens2e-amail.com Home Phone 9102005355 Cell Phone 9102005355 Business Phone Field not completed. Fax Field not completed. Home Address 623 TIMBER LAKE LN City WILMINGTON State NC Zip Code 28411 Mailing Address (if Field not completed. different from home address) City Field not completed. State Field not completed. Zip Code Field not completed. Years Living in New 20 Hanover County Personal information collected below is to assure a cross-section of the community is represented. Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 6 Gender Male Race Caucasian Age 72 Occupation Retired (Owner GOProperty Mgt) Applicant's Employer Was self employed Professional Activities Field not completed. Volunteer Activities 20 years on the Downers Grove, IL Board of Police and Fire and the Downers Grove Heritage Festival Committee;muliple terms as vestry members at my church Why do you wish to Retired and now have the time. Also, I've always been inerested serve on this board or in civics, as evidenced by prior Board of Fire and Police committee? Commissioner. Also, served as a jury foreman on a trial in NHC a few years back and found it to be a very rewarding experience. What areas of concern Not aware of any concerns. would you like to see addressed by this com m ittee? Qualifications for Prior experience as a business owner and a Police and Fire serving Commissioner. Other municipal or None county boards / committees on which you are serving Do you have a family No member employed by New Hanover County? List three local personal references and phone numbers Reference 1 Charles Meier (Attorney) Reference 1 Phone 910-231-1034 Reference 2 Alan Perry (Owner Perry's Emporium) Reference 2 Phone 910-619-9329 Reference 3 Kevin Peters (Retired Assistant Capital DefencdeR) Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 7 Reference 3 Phone 910-262-7287 Additional comments Field not completed. Upload additional Field not completed. information Date 10/3/2025 Consent � I understand that any board or committee appointee may be removed without cause by a majority of County Commissioners., � I understand that information on this application is public record and may be disclosed. Email not displaying correctly? View it in your browser. Board of Commissioners - October 20, 2025 ITEM: 11- 3 - 8 Committee Appointments New Hanover County Juvenile Crime Prevention Council Vacancies to appoint at this time: 1 Category: 1 - Faith Community Terms: 2 years, expiring 9/30/2027 Note: Advertising is ongoing for the Juvenile Defense Attorney and UnderAge 21 categories. Applicant: Eligible for Reappointment Category Nominations Faith Terry Smith Community Faith Janel Washington Community Attachments: Committee Information Sheet Application Board of Commissioners - October 20, 2025 ITEM: 11- 4 -1 NEW HANOVER COUNTY JUVENILE CRIME PREVENTION COUNCIL Members: Limited to no more than 26. 12 appointed by the Commissioners in the following categories: Member of faith community, 2 school students under age 21, juvenile defense attorney, member of business community, 6 at -large, and 1 county commissioner or designee. Agency Representatives: School superintendent or designee, chief of police or designee, local sheriff or designee, chief district judge or designee, district attorney or designee, chief court counselor or designee, AMH/DD/SA director or designee, substance abuse professional, county manager or designee, health director or designee, DSS director or designee, and United Way or other non-profit member. Terms: 2-year terms (Changed from 3-year terms to reflect requirements of General Statutes) Regular Meetings: Meetings are held seven times a year (3rd Friday at 12:00 p.m.) in the auditorium of the New Hanover County Schools Dave K. Spencer Building, 1802 S. 15th Street, Wilmington, NC. Statute or Cause Creating Task Force: NC General Assembly established JCPC on 12/21/98. Revised membership GS 14313-846. House Bill 593 was passed as of July 1, 2020 which updated the Under Age category to age 21 (changed from the Under Age 18). Purpose: The JCPC is to assess, prioritize and identify ways to meet needs of youths who are at - risk of delinquency or who have been adjudicated, undisciplined, or delinquent; identify community risk factors; recommend allocation of state funding for youth programs that address these risk factors; and evaluate the effectiveness of these programs. TERM OF OFFICE CURRENT MEMBERS APPOINTMENT EXPIRATION Business Community First 9/15/25 9/30/27 Greg Savad 3606 Pine Bark Court Wilmington, NC 28409 732-735-2272 (C) Faith Community 9/30/27 *VACANT* juvenile Defense Attorney 9/30/27 VACANT Under Age 21 (2 members required) VACANT 9/30/27 Reagan Faulkner First 12/16/24 9/30/26 Wilmington, NC Members -at -Large Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 2 JUVENILE CRIME PREVENTION COUNCIL (CONT.) TERM OF OFFICE CURRENT MEMBERS APPOINTMENT EXPIRATION Nikki Bascome First 12/16/24 9/30/26 4104 Waylon Road Wilmington, NC 28411 910-233-7011 (C) Wendy Dale Unexpired 2/19/24 9/30/25 7780 Cypress Island Drive First 9/15/25 9/30/27 Wilmington, NC 28412 910-228-9939 (H) Clyde Lynn First 9/16/24 9/30/26 4808 Grouse Woods Drive Wilmington, NC 28411 252-714-8455 (C) 910-470-8455 (W) Zachery Mitcham Unexpired 1/24/22 9/30/22 6909 Eschol Court First 9/19/22 9/30/24 Wilmington, NC 28409 Second 9/16/24 9/30/26 910-233-2359 (H) Brittany Patterson First 9/19/22 9/30/24 2511 Sapling Circle Second 9/16/24 9/30/26 Wilmington, NC 28411 910-617-4879 (H) Brittany Spell First 3/15/25 9/30/27 909 Robert E Lee Drive Wilmington, NC 28412 617-460-3538 (C) County Commissioners' Designee 8/18/25 Undesignated Lisa Wurtzbacher, Assistant County Manager 230 Government Center Drive Wilmington, NC 28403 910-798-7161 Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 3 JUVENILE CRIME PREVENTION COUNCIL (CONT.) TERM OF OFFICE CURRENT MEMBERS APPOINTMENT EXPIRATION Agency Representatives: DistrictAttorney's Office: Mary "Ashton" Herring Undesignated DSS: Holly Royals Health Department: Jocelyn Graham Judge of District Court: Judge JH Corpening, Chair Juvenile Justice / Courts: Robert Speight NHC Schools: Julie Varnum Public Defender's Office: Lyana Hunter Sheriff Department: Lt. Chris Smith Substance Abuse Center: Ryan Estes Trillium Health Resources - Southern Regional Area Board: Inesha Trahan United Way: Tommy Taylor Wilmington City Police: Melissa Moore Youth Empowerment Program: Michelle Taylor NC JJ&DP Consultant: Pamela Stokes Revised: 9/2025 Staff liaison/support: Wendy DuBose Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 4 From To: Crowell. 1ym; Long. Melissa;]ribleyJDaobelle Subject: Online Form Submission #zouy7for Board and Committee *wpnomon External Email: Do not click links open attachments, orreply Until YOU know itissafe Board and Committee Application Board or CODlDlitt88 New Hanover County Juvenile Crime Prevention Council Being Applied to Juvenile Crime Faith community Prevention Council C@begO[i8S First Name Terry LastName Smith m Email Home Phone 910-833-5888 Cell Phone 910'228'3901 Business Phone Q1O'833-5888 Fax 910'833'5127 Home Address 229TanbhdgeRd City Wilmington North Carolina am na Zip Code 284O5 Mailing Address (if POBox 7388 different from hOrD8 @ddn8SS\ City Wilmington am na North Carolina Zip Code 284O8 Y8@[S Living in NewNew28 Hanover County Board ofCommissioners October 2O.2025 Personal information collected below is to assure a cross-section of the community is represented. Gender Race Age Occupation Applicant's Employer Male Male 68 CPA Smith Group Advisors Professional Activities Own Smith Group Advisors, LLC a full service CPA firm. Volunteer Activities Finance Chair for Basilica Shrine of St. Mary, Serve as Treasurer for the parish under Bishop Luis Zamara of the Diocese of Raleigh, Rotary District 7730 Treasurer, UNCW Seahawk Club Board Member, Serve on Together We Read program at DC Virgo Why do you wish to Inspired by the work of Ben David and Jay Corpening serve on this board or corn m ittee? What areas of concern Focus on victims so they don't become tomorrow's perpetrators would you like to see addressed by this corn m ittee? Qualifications for Strong Commitment to the community. Worked and supported serving DREAMS in its infancy which gave me an understanding of the vision and more important the need for this service. I am a team player with positive input and able to see goals/projects are accomplished. Other municipal or county boards / committees on which you are serving Do you have a family member employed by New Hanover County? Chair City of Wilmington Parks & Rec Advisory Board W List three local personal references and phone numbers Rob Zapple Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 6 Reference 1 Reference 1 Phone Reference 2 Reference 2 Phone Reference 3 Reference 3 Phone Additional comments Upload additional information Date Consent 910-619-2464 Jason Smith 910-604-1417 Tracy Wilkes 910-538-4544 My application is to become a Board Member representing the Faith Community of the Basilica Shrine of St. Mary Parish and School where I have served in a religious capacity educating the youth of our parish. A Reference for that work is the Very Reverend Fr. Jairo Maldonado Pacheco, 910-762-5491 Field not completed. 10/3/2025 � I understand that any board or committee appointee may be removed without cause by a majority of County Commissioners., � I understand that information on this application is public record and may be disclosed. Email not displaying correctly? View it in your browser. Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 7 From: noreolv(a)civicolus. com To: Crowell. Kvm; Long. Melissa Subject: Online Form Submission #27787 for Board and Committee Application Date: Thursday, September 18, 2025 11:08:30 AM ** External Email: Do not click links, open attachments, or reply until you know it is safe ** Board and Committee Application Board or Committee New Hanover County Juvenile Crime Prevention Council Being Applied to Juvenile Crime Faith community Prevention Council Categories First Name Janel Last Name Washington Email pricecathedraloutreache-amail.com Home Phone 9106324074 Cell Phone 9106324074 Business Phone Field not completed. Fax Field not completed. Home Address 4502 Coddington Loop City Wilmington State NC Zip Code 28405 Mailing Address (if Field not completed. different from home address) City Field not completed. State Field not completed. Zip Code Field not completed. Years Living in New 41 Hanover County Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 8 Personal information collected below is to assure a cross-section of the community is represented. Gender Female Race Black Age 41 ............................................. ___ Occupation Program Coordinator at Smart Start New Hanover County Applicant's Employer Smart Start of New Hanover County Professional Activities Community engagement, building relationships with multi level partners, seminars, group facilitator .................................... ......... Volunteer Activities Director of Community Engagement at PCAMEZion Church, ED of PCAMEZion Non Profit, Community Opportunities ......... ......... ......... ....................................................................................................................... Why do you wish to Committee serve on this board or corn m ittee? What areas of concern Initiatives to bridge the gap between community efforts and would you like to see available resources to prevent challenges addressed by this committee? Qualifications for I am a community advocate, rooted in the Wilmington serving community, strong faith leader Other municipal or None county boards I committees on which you are serving Do you have a family No member employed by New Hanover County? List three local personal references and phone numbers ......... ........ Reference 1 Joshua Walker .................................................................................................................................................... . Reference 1 Phone (302) 345-8386 Reference 2 Adrienne Debouse Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 9 Reference 2 Phone (910) 442-7564 Reference 3 Trudy Evans Reference 3 Phone (910) 540-4044 Additional comments Field not completed. Upload additional Field not completed. information Date 9/18/2025 Consent � I understand that any board or committee appointee may be removed without cause by a majority of County Commissioners., � I understand that information on this application is public record and may be disclosed. Email not displaying correctly? View it in your browser. Board of Commissioners - October 20, 2025 ITEM: 11- 4 - 10