Dear Ms. Davis:
The staff of the Hampton Roads Planning District Commission (HRPDC) appreciates the opportunity to provide comments on the Draft 2025 Funding Manual for the Virginia Community Flood Preparedness Fund Round 6, which was posted by the Department of Conservation and Recreation (DCR) for public comment on June 16, 2025. Our comments reflect the views of the HRPDC staff and incorporate feedback from our member jurisdictions and other regional stakeholders. We respectfully request DCR’s consideration of the following comments.
Community-Scale Projects
Part I.B. 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 within the designated census block of the project location.” This definition does not account for the importance or impact of community infrastructure and facilities to users beyond the immediate area or how they work as part of larger infrastructure and service systems. This benefit is partially recognized in Part IV.C.(10) (page 23), which states “Projects proposing to protect or provide flood mitigation benefits either to or using public recreation areas (parks/beaches/etc.) will also be evaluated on their benefits to areas outside of the public access area…Applicants asserting community-scale use of these areas must provide evidence that supports their assertion [of] flood mitigation outside of the project area itself.” This standard should be applied to all public infrastructure and facilities.
Project Time Limits
We appreciate that the draft manual has increased the time allowed for capacity building and planning grants to 60 months. However, studies and projects must still be completed within 36 months. Based on our localities’ experiences, three years is not enough time to complete many projects given delays with permitting,
contracting, procuring materials, labor challenges, and high demand for services. Although extensions are allowed, the HRPDC recommends that DCR increase the default time allowed for project completion to 60 months and allow requests for longer time periods to be made as part of the application process.
Benefit-Cost Analysis
Performing a quantitative benefit-cost analysis for projects is time-consuming, expensive, and burdensome. The HRPDC recommends that the threshold for requiring a benefit-cost analysis be raised from $2,000,000 to $5,000,000.
Maximum Grant Awards
The draft manual caps the maximum grant amount for capacity building and planning activities at $1,500,000 ($200,000 for resilience plans) and the maximum grant amount for studies at $1,000,000. Based on previous requests and input from our localities, these caps are lower than what is needed to fund the types of activities that have been historically funded by the CFPF. The HRPDC recommends that the cap for all categories be set at $7,500,000. Furthermore, the HRPDC recommends including a provision in the manual that would allow DCR and the Chief Resilience Officer to waive the cap for critical or exceptional projects with justification.
Project Budget Narratives
In Part V.C. (page 30), the draft manual states “final reimbursement costs for contractor support may not exceed 5% of the contract amount submitted in the application.” The HRPDC requests that DCR clarify whether this means that a successful applicant could receive additional funding above the original grant reward if costs are higher than budgeted.
Repetitive Loss and/or Severe Repetitive Loss Properties
Part V.B. (page 27) includes a statement that “the NFIP requires all records of flooding to be maintained by the participating locality in perpetuity.” This sentence should be removed. It is not clear what NFIP requirement is being referenced to support this statement. FEMA record retention requirements from 44 CFR 59.22 (a)(9)(iii) refer to maintaining records such as permits and elevation certificates for floodplain ordinance administration. The statement on page 28 and similar language in Appendix F that “all flooding involving these properties should be tracked and addressed by the community” should also be removed, since this requirement is beyond the scope of the grant manual.
Since DCR requests information on repetitive and severe repetitive loss properties for both study and project proposals, the language used on pages 27 and 28 should be identical.
Project Scoring
The draft manual maintains the project scoring criteria from previous grant rounds. Since benefit-cost analyses are required for project applications over $2,000,000, the HRPDC recommends that DCR develop a metric that would score project proposals based on the BCA score or another metric that would be directly related to a project’s benefit to the community.
Other Potential Grant Manual Changes
As part of the public comment solicitation, DCR has requested feedback and comments on two potential changes to the grant manual:
The HRPDC supports allowing applicants to renew capacity-building grants to fund new staff.
The HRPDC opposes limiting capacity building grants for hiring and training staff to low-income communities.
We appreciate DCR’s efforts in developing and implementing the Community Flood Preparedness Fund and appreciate your consideration of these comments and suggestions. We would be happy to discuss these comments with you further. Please contact Whitney Katchmark (wkatchmark@hrpdcva.gov) or Ben McFarlane (bmcfarlane@hrpdcva.gov) if we can be of any assistance.
Sincerely,
Benjamin J. McFarlane
Chief Resilience Officer
Hampton Roads Planning District Commission