July 17, 2025

Ms. Angela Davis, C.F.M.

Division Director, Floodplain Management 

Virginia Department of Conservation and Recreation 

600 East Main Street, 24th Floor 

Richmond, Virginia 23219 

Re: Round 6 Community Flood Preparedness Fund (CFPF) Draft Grant Manual 

Dear Ms. Davis:  

This letter is on behalf of the City of Norfolk’s Office of Resilience’s comments on the 2025 Funding Manual for the Virginia Community Flood Preparedness Fund Round 6, marked draft for public comment.

I.             INTRODUCTION 

The City of Norfolk faces growing threats from coastal flooding and severe storm events due to one of the highest rates of relative sea level rise (RSLR) on the Atlantic coast. In response, the City, in partnership with the U.S. Army Corps of Engineers (USACE), has launched the Resilient Norfolk Coastal Storm Risk Management (CSRM) Project, a comprehensive initiative aimed at reducing flood risk and enhancing long-term climate resilience. The CSRM Project is designed to protect Norfolk from nor’easters, hurricanes, and other major coastal storm events through a combination of structural, nonstructural, property-specific, and natural and nature-based solutions.

The City’s Office of Resilience has reviewed the 6th Round 2025 Draft Manual and provides the comments below for the Department’s consideration. The City of Norfolk appreciates the opportunity to comment.  

II.           COMMENTS 

 Keep the Caps for the CFPF Grant and Loan the Same as $7.5M, with a One-to-One Match

The manual describes funding for three award categories, including Capacity Building and Planning, Studies, and Projects. The City’s CSRM project’s funding would fall in line with funding opportunities within option C, Projects. The purpose of this category is to assist local governments with flood prevention or protection activities to prevent loss of life and reduce property damage caused by coastal, riverine or inland flooding. Design and specification development is considered a project.

The City of Norfolk recommends keeping the funding cap for project grants and loans related to the projects award category to remain at $7,500,000, with a one-to-one match. This will result in increased fundings for local governments and federally or state-recognized Indian tribes in Virginia.

For Larger Projects Utilizing both the CFPF Loan and Grants, the Program Guidelines Should Be Revised to Better Incentivize the Effective Use of Funds

As the Norfolk Coastal Storm Risk Management Project is the first of its kind in the region focused on pre-disaster mitigation, it is critical that projects of this magnitude receive increased state funding support. The total project cost is currently estimated at $2.66 billion project, with the Non-Federal Sponsor, the City of Norfolk, responsible for 35% of the funding.  

To support larger-scale projects like this through the Community Flood Preparedness Fund, we recommend the following program modifications:

• Increase the cap for both the CFPF grant and loan to $25 million each, for a maximum total funding amount of $50 million, for bundled applications supporting major infrastructure projects.
• Allow the CFPF loan to serve as the match for the grant under this increased cap.
• Extend the execution window from 3 years to 5 years to accommodate the scale and complexity of large resilience efforts.
• Defer interest accrual and loan repayment until project closeout, similar to the federal WIFIA program, for which CSRM projects are currently ineligible.

Increasing the cap for both the grant and loan as a bundled option would encourage more communities to participate in the statewide grant and loan program. Allowing the CFPF loan to serve as the match for the grant under the increased cap would reduce administrative burden, as the RVRF loan would no longer be needed for matching purposes. Extending the execution window and deferring the interest accrual and loan repayment until project closeout would allow recipients to effectively use their funds.

The Definition of Community-Scale Benefits Should Be Reconsidered

The manual defines a “Community-scale project” as a flood prevention and protection project that provides flood mitigation benefits to no less than 25% of the geographic area or population with the designated census block of the project location.

In dense areas like Norfolk, it will be challenging for the City to implement community-scale projects. According to the scoring criteria on page 40, the community-scale benefits category can earn up to 30 points, however, under these conditions, the City would not receive any points.   

The City of Norfolk agrees with VAMSA’s request for DCR to consider alternative approaches for community-scale projects that would be inclusive for dense localities.  

Implementing these recommendations will enhance the effective use of funds and more strategically support communities working to build long-term climate resilience.

Thank you for taking our comments into consideration.

Sincerely, 

Kyle Spencer

Chief Resilience Officer, City of Norfolk