4 comments
Dear Ms. Davis,
The City of Alexandria, Virginia (City), appreciates the opportunity to provide public comments to the Virginia Department of Conservation and Recreation (DCR) on the Round 6 Community Flood Preparedness Fund (CFPF) Draft Manual a pursuant to the June 16, 2025, Notice in the Virginia Register of Regulations.
The City experienced three severe storm events in less than 14-months which caused widespread flooding and damage and prompted the creation of Flood Action Alexandria initiative in 2021. This initiative focuses on making the City more resilient to these more frequent, intense storms by accelerating flood mitigation capital projects and implementing programs to create a more resilient City. The community has benefited greatly from the Community Flood Preparedness Fund which is helping to accelerate our highest priority projects while incorporating green infrastructure in flood-prone areas.
Comments directed to the draft Manual are as follows:
Part IV. Award Categories, A. Capacity Building & Planning
Page 19. Please clarify what is meant by the term “overlapping local governments” as it relates to demonstrating collaboration.
Part IV. Award Categories, C. Projects
Page 21. There is a section that mentions entering “project applications” into the DCR Coastal Web Explorer. Please list this as a discrete requirement for coastal community applicants by also listing it on page 27, under Supporting Documents for Project Applications, if that is accurate. Further, Part V.B.5.a. (page 26) states that DCR will be populating project data in Coastal Web Explorer. Please advise if DCR wishes the applicant to submit projects into the Coastal Web Explorer prior to application submission or, instead, by submitting the application, consent is given for DCR to populate the project(s).
Page 22. Typo in the Long Term Grant “Fuse loans” should be “use loans”.
Part V. Required Application Components, C. Budget Narrative
Page 30. Please clarify what is meant by: Final reimbursement costs for contractor support may not exceed 5% of the contract amount submitted in the application. Appendix B provides the Budget Narrative Template (page 38) and “Contracts” is one cost type. Is “contractor support” defined as “Contracts” and, if so, is DCR willing to reimburse costs over what was agreed to in the Budget for that cost type up to 5%. For large flood mitigation construction projects, costs may increase due to a multitude of external factors including design issues, utility constraints, material costs, etc. Further, grant applications are developed based on cost estimates at the time of the proposal and may incur additional costs (or, sometimes a cost reduction) over time. An alternative is that the grantee could notify DCR if the costs of the project are anticipated to increase over a certain percentage in advance of the “final reimbursement”.
If you have any comments, please contact Jessica Lassetter, Senior Environmental Scientist at jessica.lassetter@alexandriava.gov or 703-746-4127.
Respectfully yours,
Jesse E. Maines, Division Chief
Stormwater Management
Transportation and Environmental Services
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:
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
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
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