Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
Comment Period Ended on 10/26/2022
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10/26/22  4:25 pm
Commenter: City of Hampton

Virginia Should Maintain a Dedicated Source of Funding to Support Localities’ Resilience

The City of Hampton is providing this comment to voice its support for a dedicated source of funding for the Commonwealth Community Flood Preparedness Fund (CFPF). Currently, proceeds from the Regional Greenhouse Gas Initiative (RGGI) allowance auctions are the sole source of funding for the CFPF. Since March 2021, RGGI has generated more than $203.5 million to enable the CFPF to provide grants and loans[1] to localities throughout the state in support of resilience projects. These funds have provided a meaningful source of financial support for localities throughout the state. Cities, towns and counties need substantial resources to adapt to changing realities of flooding driven by sea level rise, as well as shifting patterns of precipitation and storm events. The scale of this need is illustrated by the number of applications and awards CFPF has seen to date. To date, 76 applications have been awarded funds, while an additional 32 applications were selected for supplemental review.

Like many localities, Hampton’s existing challenges with flooding are expected to become more severe in years to come. According to modeling completed for the Virginia Coastal Resilience Master Plan, in the next forty years as much as 65 percent of the City’s land area will be at risk of flooding from coastal events alone as a result of sea level rise.[2] Low-lying roads and land throughout the City are already regularly underwater with nuisance tidal flooding as a result of our changing climate.

Hampton has dedicated significant local resources to holistically address the increasing challenge of recurrent flooding, sea level rise, and shoreline erosion. Efforts have included completing multiple local resilience plans and identifying dozens of new implementable projects to reduce the impacts of flooding to our community now and into the future. At the same time, we must continue to invest in maintaining the City’s aging infrastructure to ensure it remains functional in the face of these threats. The City’s stormwater infrastructure network struggles to keep pace with increasing stormwater loads and tidal backflow. The financial burden associated with monitoring and planning for changing flooding impacts, adapting public infrastructure and lands to reduce the severity of flooding, and protecting citizens from these natural hazards far surpasses the City of Hampton’s available financial resources.

The scale of this challenge requires that localities, Planning District Commissions, the Commonwealth, and the federal government come together to identify multiple pathways by which the built and natural environment will adapt. Hampton is grateful to have received 7 awards totaling more than $9.5 million from the state through the CFPF to date. This funding option has provided us with a financial tool with fewer barriers and greater opportunity for success when compared to federal-level funding opportunities. As a result, we are advancing needed projects that are aligned with the Commonwealth’s stated values and goals for coastal resilience more quickly, and are able to dedicate our limited financial resources to other identified project needs.

The City of Hampton urges the Administration to continue to build upon the success of the CFPF by either keeping Virginia enrolled in RGGI, or to otherwise ensure that there remains a dedicated source of revenue to finance the CFPF, thus continuing to serve all Virginian citizens through flood mitigation benefits.

[1] “Auction Results,” Regional Greenhouse Gas Initiative, 2022,

[2] “Hazards,” Virginia Coastal Resilience Web Explorer Ver 1.0,

CommentID: 199921