The Community Flood Preparedness Fund is a great opportunity to invest in resiliency efforts to combat climate change. As noted, the funding for this new grant program is coming from the Regional Greenhouse Gas Initiative (RGGI) for carbon allowances. As a mitigation program, it is important to note that forests and wetlands serve as some of the most critically important sequesters of carbon. They also are important natural resources for filtering stormwater and preventing flooding.
I am delighted to see the Fund will provide a long-term, consistent funding source to promote flood resilience in Virginia and that one of the priority solutions is the preservation of open space. However, the Guidelines should be further refined to explain how this will be done and which partners are best suited to assist.
According to the draft guidelines, grants from the Fund will support activities including the "conservation and restoration of floodplains, coastal barriers, and other natural capital, including through protection or acquisition of flood-prone properties consistent with local or regional flood preparedness and resilience plans and guided by the ConserveVirginia model." This implies that the property must be identified by the Floodplains & Flooding Resilience Category of ConserveVirginia. What about properties identified as Resource Protection Areas and Resource Management Areas of the Chesapeake Bay Program, which presumably have similar outcomes? Should they be explicitly referenced in the guidelines? Why wouldn't the protection or acquisition of forested woodlands and/or wetlands have a similar desired outcome of storing stormwater and preventing flooding?
Also, is the word protection used to imply a perpetual conservation easement versus acquisition of fee simple title. The use of easements is not once referenced in the guidelines. Should they not play a role to ensure the investment of the fund are enforceable?
As it relates to eligible entities, should state agencies and 501(c)3 non-profit land trusts not also be included? State agencies support significant land preservation. Likewise, accredited land trusts should be eligible as a tool to assist in the protection and acquisition of the properties. It should be noted that many urban localities do not have a Soil & Water Conservation District or a government-operated land preservation program. They relay on the partnership with non-profits. This is critically important in underserved communities where the locality may not have the capacity to prepare grant applications and facilitate the land acquisitions or easements.
Finally, other activities that are funded through the grant guidelines would suggest that dams are reasonable projects. "Construction of new infrastructure, or modification of existing infrastructure, necessary to reduce flooding or mitigate flood damage or risk." How are these considered in connection with natural resource conservation? Are these publicly or privately owned dams? Will grant funds be available to support maintenance of private dams?
I welcome the Community Flood Preparedness Fund and look forward to assisting in its implementation to conserve and protect our land and water resources during this era of dramatic climate change.
Sincerely,
Parker C. Agelasto