Angela Davis
Division Director, Floodplain Management
600 East Main Street, 24th Floor
Richmond, 23219
Dear Angela Davis,
On behalf of the Chesapeake Bay Foundation, Environmental Defense Fund, Lynnhaven River Now, Southern Environmental Law Center, Virginia Conservation Network, and Wetlands Watch, we jointly offer the following comments on the draft 2025 Funding Manual for the Virginia Community Flood Preparedness Fund Round 6 (“draft manual”).
Virginia’s Community Flood Preparedness Fund (“CFPF”) program remains one of the most essential funding tools Virginia has to address growing flood risks through equitable, science-based, and community-scale interventions that prioritize natural solutions. We sincerely appreciate the Department of Conservation and Recreation's (“DCR”) ongoing commitment to public engagement and its track record of continually improving the manual over time in response to stakeholder input. Additionally, we welcome back the inclusion of Tribes in this manual pursuant to HB2077 (2025).
The draft manual references the Resilient Virginia Revolving Fund (RVRF) as a potential match funding source for CFPF projects. Historically, the RVRF has focused on property-scale investments and has been positioned as a flexible tool to complement programs like the CFPF. However, the most recent RVRF draft manual (2025) appears to significantly narrow eligibility, stating the assistance will be limited to communities impacted by Tropical Storm Helene (2024) and the February 2025 storm events.
If this change is reflected in the final RVRF manual, we recommend that the CFPF manual explicitly clarify whether the limited eligibility and geographic focus of the current RVRF round as described in the draft RVRF manual will also apply to this round of the CFPF, or if the match will still apply statewide. We suggest that the opportunity to use RVRF as match apply uniformly throughout the state. Without this context, applicants may misunderstand their ability to use RVRF funds as a match for CFPF projects, especially those located outside the designated disaster-impacted areas.
In the interest of transparency and informed planning, we recommend that DCR:
Clarify in the CFPF manual whether RVRF match funding is available statewide or only to disaster-impacted communities in Round 6. We recommend that this matching opportunity apply statewide.
Apply a consistent and cohesive approach to management of both the RVRF and CFPF grants.
Provide a publicly available crosswalk or FAQ to help applicants evaluate whether their proposed CFPF projects are eligible for RVRF match support.
Adjust the WebGrants Portal settings to clarify whether the RVRF match is only available to localities eligible under the proposed RVRF draft manual, or if it is still available to all localities. This simple filter will help prevent applicant confusion and streamline the review process.
Aligning messaging across these two programs will ensure localities can strategically pursue funding combinations that maximize the effectiveness of their flood resilience work.
We appreciate the new notation in the draft manual that project applications in coastal communities must be entered into the DCR Coastal Resilience Web Explorer for final funding eligibility, and we applaud DCR’s commitment to assist communities with the tool. We look forward to continuing to align the priorities of the Coastal Resilience Master Plan, the Virginia Flood Protection Master Plan, and available resources including the CFPF. Moving forward, this process can be used for tracking resilience projects and eventually align with scoring of projects for awards or prioritization of projects in resilience plans.
We are grateful for the CFPF Flood Funds Advisory Review Committee’s important role in the application review process. To further DCR’s transparency commitment, we encourage DCR to create a webpage or webpage section dedicated to the newly established CFPF Flood Funds advisory review committee, listing its members.
Also related to transparency, we remain concerned by delays in executing award agreements. Communities, especially those with seasonal planting timelines for nature-based solutions, require more predictable timelines. We urge DCR and VRA to jointly review their internal processes and collaborate on a target between the award announcement and the executed contract. To help applicants plan effectively, we recommend that DCR’s CFPF webpage publish a committed timeline for each funding round that includes the agency’s best estimates of the timing of the application deadline, the committee’s review, the announcement of awards, and the expected execution of final contract agreements.
Additionally, based on the May 2025 meeting of the Advisory Review Committee and announcement of the Round 5 CFPF awards, we suggest incorporating any conclusions reached during these Committee meetings that could help clarify scoring and prioritization of funds for Round 6, and we appreciate where some changes have been proposed in the draft manual with this in mind. For example, all applications that included acquisition of private property, as well as many shoreline projects, were noted for further Committee discussion, and the draft manual includes a proposed change to specify that land acquisition projects must be “explicitly and demonstrably tied to community-scale flood mitigation benefits.” We recommend including clarifying language in the final grant manual that reflects the outcome of these Review Committee discussions and elaborates on related proposed changes to the manual to help future applicants prepare more comprehensive applications and help the Committee save time during future meetings. Clarification would be particularly helpful around how community-scale benefit will be determined and scored for land acquisition projects, and on how project lifespan will be determined.
Additionally, we understand that there was hesitation to award additional funds to communities with multiple early-stage CFPF projects underway, and we note a proposed addition in the draft manual stating that “the Committee may consider progress and management of active grants in making recommendations.” Applicants would be better able to prioritize proposals for submission if the final manual clarifies how a locality having other active CFPF grants will be factored into decision-making.
The Round 6 Manual and Cover Memo mention capping per-grant amounts for capacity and study grants, as well as for the development of resilience plans. We are concerned that a cap of $200,000 for Resilience Planning is not enough (Part IV, Part A). Ensuring that these plans are meaningful and actionable is crucial for localities to prepare for flooding and to continue to secure funding. Resilience Plans are instrumental for communities to initiate the process of securing CFPF funding, as they are required for project funding and for coordinating within their region to mitigate flood risk.
Notably, many Resilience plans have already been funded by the CFPF at an amount near or over the $200,000 limit 1. Also, the requirements for Resilience Plans have also increased over time, and creating more robust plans that meet these requirements can increase the cost of the plans.
Capping the funding for resilience plans will weaken localities' ability to participate in the CFPF and to plan for and address their flood risk. We urge DCR not to cap the funding amount for these plans, or to at least significantly increase it, so as not to hinder some localities from initiating the application process.
1. For example, in Round 5 of the CFPF, the Town of Craigsville was awarded $210,000 to establish a town resilience plan. According to the census, Craigsville has a population of around 1,000 people. This example demonstrates that development of effective resilience plans for even smaller applicants located in the western part of the state–much less more populous localities in the coastal plain–can exceed $200,000.
Currently, the manual allows for 15% of the value of a grant award to be provided in advance if requested within the application and agreed upon with VRA. In our previous comment letter on proposed revisions to the draft Round Five CFPF Manual, we advocated for allowing low-income communities to request 50% of their award up-front. This recommendation was not incorporated into the final manual for Round Five, but we reiterate it here.
If DCR is concerned that 50% is too high a threshold, we recommend that low-income communities be invited to request up to 25% of their full award upfront. We appreciate DCR’s continuing commitment to prioritize funding for activities in designated low-income communities, which has exceeded the statutory mandate of 25% of CFPF awards. However, more flexibility is needed to further the equitable accessibility of the CFPF and to help communities with limited on-hand funds to initiate work. We understand that the procurement process can create challenges for upfront funding awards, but we recommend that the CFPF allow for funding advances of up to 25% for grant awards in low-income geographic areas to advance the equity goals of the program.
We offer the following thoughts on the two items DCR specifically highlighted for public feedback in its CFPF Round 6 Cover Memo. First, we agree with the concept of allowing applicants to “renew” a capacity-building grant used to hire new staff for one additional cycle of funding.
Second, DCR also requested feedback for limiting capacity building grants for the hiring and training of staff to low-income geographic areas. We believe that capacity building grants for hiring and training staff should be prioritized in low-income geographic areas, but other regions should not be left out. We recommend against completely excluding any eligible applicants from funding for the hiring and training of staff.
In closing, thank you for the opportunity to comment on the draft 2025 Funding Manual for the CFPF , Virginia’s only statewide flood risk reduction program. This program provides important resources to Virginia’s localities, soil and water conservation districts, and Indigenous tribes to increase their resilience to flooding and related disasters.
We look forward to continuing to collaborate with DCR on the CFPF and on building awareness across the state for this effective and crucial flood program.
Sincerely,
Jay Ford
Chesapeake Bay Foundation
Emily Steinhilber
Environmental Defense Fund
Karen Forget
Lynnhaven River Now
Morgan Butler
Southern Environmental Law Center
Mary Rafferty
Virginia Conservation Network
Mary-Carson Stiff
Wetlands Watch