On behalf of the Virginia Municipal Stormwater Association (VAMSA), thank you for providing this opportunity to comment on the Resilient Virginia Revolving Fund Draft Notice of Funding Opportunity (“Notice”) and for your consideration. VAMSA submits this narrow comment to avoid potential confusion and to clarify that the Notice’s “eligible applicants” definition includes local governments themselves, e.g., cities, counties, and towns.

The Notice uses the following definition:

“‘Eligible Applicants’ for all categories are Planning District Commissions, and Industrial Development Authorities, that encompass one or more locality that meets the definition detailed below.”

VAMSA suggests a clarification that local governments are eligible applicants and proposes the following revision for DCR’s consideration:

‘“Eligible Applicants’ for all categories are local governments as defined below and include Planning District Commissions, and Industrial Development Authorities, that encompass one or more locality that meets the definition detailed below.”

This clarification is consistent with statute and DCR’s apparent intent in the remainder of the Notice. Va. Code § 10.1-603.2 provides for “distribution of loans or grants from the Fund to particular local governments” without limitation to Planning District Commissions or Industrial Development Authorities. Page 1 of the Notice states that “Per the Code of Virginia, the Fund is authorized to provide grants and loans to local governments for the following flood resilience activities: . . .” and on page 3 states that “[a] list of these eligible local governments is available at TBD WEBSITE.”

This small, but important, clarification will assure local governments that they may apply for and help utilize the Fund to achieve its purpose.