Dear Ms. Davis,

The City of Alexandria, Virginia (City), appreciates the opportunity to provide public comments to the Virginia Department of Conservation and Recreation (DCR) on the Round 6 Community Flood Preparedness Fund (CFPF) Draft Manual a pursuant to the June 16, 2025, Notice in the Virginia Register of Regulations.

The City experienced three severe storm events in less than 14-months which caused widespread flooding and damage and prompted the creation of Flood Action Alexandria initiative in 2021. This initiative focuses on making the City more resilient to these more frequent, intense storms by accelerating flood mitigation capital projects and implementing programs to create a more resilient City. The community has benefited greatly from the Community Flood Preparedness Fund which is helping to accelerate our highest priority projects while incorporating green infrastructure in flood-prone areas.

Comments directed to the draft Manual are as follows:

Part IV. Award Categories, A. Capacity Building & Planning
Page 19.  Please clarify what is meant by the term “overlapping local governments” as it relates to demonstrating collaboration.

Part IV. Award Categories, C. Projects
Page 21.  There is a section that mentions entering “project applications” into the DCR Coastal Web Explorer. Please list this as a discrete requirement for coastal community applicants by also listing it on page 27, under Supporting Documents for Project Applications, if that is accurate. Further, Part V.B.5.a. (page 26) states that DCR will be populating project data in Coastal Web Explorer. Please advise if DCR wishes the applicant to submit projects into the Coastal Web Explorer prior to application submission or, instead, by submitting the application, consent is given for DCR to populate the project(s).
Page 22.  Typo in the Long Term Grant “Fuse loans” should be “use loans”.

Part V. Required Application Components, C. Budget Narrative
Page 30.  Please clarify what is meant by: Final reimbursement costs for contractor support may not exceed 5% of the contract amount submitted in the application. Appendix B provides the Budget Narrative Template (page 38) and “Contracts” is one cost type. Is “contractor support” defined as “Contracts” and, if so, is DCR willing to reimburse costs over what was agreed to in the Budget for that cost type up to 5%. For large flood mitigation construction projects, costs may increase due to a multitude of external factors including design issues, utility constraints, material costs, etc. Further, grant applications are developed based on cost estimates at the time of the proposal and may incur additional costs (or, sometimes a cost reduction) over time. An alternative is that the grantee could notify DCR if the costs of the project are anticipated to increase over a certain percentage in advance of the “final reimbursement”.

If you have any comments, please contact Jessica Lassetter, Senior Environmental Scientist at jessica.lassetter@alexandriava.gov or 703-746-4127.

Respectfully yours,

Jesse E. Maines, Division Chief
Stormwater Management
Transportation and Environmental Services