The Society for a Secure and Sustainable Water Future (S4SSWF) appreciates the Virginia Department of Conservation and Recreation's opportunity to provide input on the Round 7 Community Flood Preparedness Fund Manual. S4SSWF is a Virginia-based 501(c)(3) nonprofit advancing rainwater harvesting, alternative water supplies, and practical water conservation. Our organization has implemented rainwater harvesting projects at George Mason University's Presidents Park Greenhouse and Norfolk's Purpose Park community garden. We encourage DCR to explicitly recognize rooftop rainwater harvesting and beneficial stormwater reuse as potential components of eligible flood-resilience projects when applicants can demonstrate measurable stormwater management benefits. Rainwater harvesting is often discussed primarily as a water conservation measure. However, properly designed systems can also reduce runoff volumes by capturing rainfall and subsequently using that water for irrigation, toilet flushing, cooling, or other appropriate nonpotable purposes. These systems can complement rain gardens, bioretention, and other nature-based solutions. Their potential flood-mitigation contribution depends on available storage capacity, water demand, drawdown between storms, overflow design, and local rainfall conditions.

We respectfully recommend that DCR:

1. Clarify that eligible flood-resilience projects may incorporate rainwater harvesting, detention, and beneficial stormwater reuse when their proposed flood-reduction benefits are appropriately demonstrated.

2. Encourage evaluation of decentralized storage and reuse alongside conventional drainage improvements and nature-based solutions, particularly where combined approaches offer measurable community benefits.

3. Allow eligible applicants to propose feasibility assessments, performance monitoring, and maintenance planning for these approaches within applicable funding categories.

4. Consider the accessibility of appropriately designed, smaller-scale demonstration projects serving low-income communities, where such projects contribute to a broader flood-resilience strategy.

We are not suggesting that every rainwater collection system should qualify as flood-control infrastructure or that stored water should automatically receive the same treatment as nature-based solutions. Rather, we encourage a performance-based approach that recognizes measurable stormwater benefits alongside water conservation. At Norfolk's Purpose Park, our rainwater harvesting installation complements an existing community rain garden and supports irrigation for a neighborhood garden. At George Mason University, our approximately 850-gallon system captures rooftop runoff for irrigation and has already displaced at least 1,000 gallons of potable water. These experiences illustrate how distributed rainwater systems can serve multiple purposes while creating opportunities for community engagement and environmental education.

We respectfully ask DCR to consider incorporating clear language addressing these practices into the final Round 7 Manual and future program guidance.

Thank you for your consideration!!