RE: Community Outreach and Engagement Plan
Dear Mr. Dalon,
On behalf of the AMMD Pine Grove Project, Center for Sustainable Communities, Chesapeake Bay Foundation, Environmental Defense Fund, Friends of the Rappahannock, James River Association, Lynnhaven River NOW, Natural Resources Defense Council, Sierra Club Virginia Chapter, Southern Environmental Law Center, The Nature Conservancy, Virginia Conservation Network, Virginia Environmental Justice Collaborative, Virginia Interfaith Power & Light, the Virginia League of Conservation Voters, and Wetlands Watch, we jointly offer these comments as you finalize the Community Outreach and Engagement Plan (COEP). Our organizations have been involved in the development of the COEP and have participated in several of the Department of Conservation and Recreation’s (DCR) Flood Resilience Outreach Coordination meetings on the COEP over the past several months. We appreciate this opportunity to provide further feedback on the Community Outreach and Engagement and Planning process, as we understand how integral it is to the development and implementation of both the Virginia Coastal Resilience Master Plan (CRMP) and the Virginia Flood Protection Master Plan (FPMP).
Our organizations appreciate DCR’s efforts to develop the CRMP and FPMP in an equitable manner by obtaining local stakeholder feedback through a statewide outreach process. Virginians statewide experience the impacts of flooding through sea level rise and increased rainfall, and in some areas, both. Providing spaces for community members to share their experiences and including these perspectives in the Plans can help ensure the success of the initiatives the State intends to implement. Additionally, we are grateful that DCR plans to dedicate resources to hire consultants to carry out the COEP once finalized. However, little detail has been provided in the COEP on how this outreach and engagement process will be conducted. Planning a statewide outreach effort is a monumental task, and it is critical that it is done thoughtfully in order to engage the maximum number of community members and perspectives possible.
With that in mind, we offer the following comments:
DCR staff and the hired consultant(s) should utilize existing networks and community spaces to engage community members.
Compiling perspectives in a “whole community” approach, as the COEP outlines, includes meeting community members where they are. This is especially true in low-income and underserved communities, as these populations typically have acutely limited access to meetings scheduled during work hours and in government buildings. The hired consultant will need to dedicate considerable time and resources upfront in the planning process to identify existing community meeting spaces. In some instances, the consultant will need to contact community leaders multiple times, through multiple different avenues, in order to solidify a meeting space and time that works best for them. The consultant should also provide community leaders with as much advance information as possible that explains the intent of the meeting and provides helpful background so that participants can prepare and provide informed, relevant feedback. Other barriers for participation may be present, and it will be important for the consultant to work to identify these and collaborate with community members to address them. For example, the hired consultant(s) will likely need to invest in language translation tools to expand meeting accessibility. Technological advancements make real-time translation over virtual formats easier and cheaper than in the past, and we strongly encourage DCR to provide Spanish language translation at a minimum. Community champions, who are typically well-respected individuals of the community with significant knowledge of the community’s population and culture, can also be leveraged to maximize participation.
Furthermore, a portion of community members will likely be wary of the intent of these meetings due to an overall distrust of government. The hired consultant(s) should identify and analyze any previous outreach initiatives that may have been conducted in the communities they plan to engage, and avoid duplicate efforts when possible. Community members will not appreciate feeling as if they are a part of another “one and done” meeting situation, so it is critical for the consultant to do as much research on the communities prior to the actual outreach process. Being as open and straightforward as possible about the process and desired outcomes of the meetings will lead to more meaningful feedback from the community members. Leveraging existing networks and taking the time to establish good-faith partnerships with community leaders can help break down these barriers, and should be utilized wherever possible.
We are grateful that DCR has listed a portion of these considerations in the draft COEP, and we encourage DCR staff to dedicate significant resources to the hired consultant(s) to ensure that they are carried out adequately. FEMA’s “Building Alliances for Equitable Resilience” resource highlights the importance of equitable community planning and includes several planning tools and resources that the hired consultant(s) can utilize as they develop their outreach strategy.
DCR should consider creating regional citizen and stakeholder committees to collect region-specific flood information and to encourage more robust engagement.
Flooding impacts vary widely throughout the state, and it would therefore be worthwhile for DCR to consider creating regional citizen and stakeholder committees to host recurring community meetings to collect feedback. Several reports and “lessons learned” resources, some of which are linked at the end of this section, have shown that successful community outreach plans involve establishing a network of local community members to participate in workshops and listening sessions. Offering a series of meetings will lead to greater participation and allow the meeting facilitator to address multiple points of local concern that will ultimately lead to well-rounded planning documents. Holding only one meeting per region may feel disingenuous to community members, as it limits the amount of time for them to understand what is being asked of them, collaborate on potential solutions, and provide sufficient feedback. Additionally, the size of many regions can make a single meeting logistically impossible for large portions of communities to attend (e.g. hosting a Hampton Roads meeting in Williamsburg would be challenging for residents of the Eastern Shore). Although it is important to provide as much information on the content of the meetings in advance as possible, community members may still be limited in their ability to review that information prior to the meeting due to life and work obligations. Limited outreach has been conducted thus far on the CRMP and FPMP, so for many communities this will be the first time they are learning about the process.
Additionally, organizing the regional committees will allow for the hired consultant(s) to compile feedback that will best inform the statewide master planning effort. DCR staff have mentioned that the FPMP will most likely be sectioned by watershed, so mirroring the outreach process similarly to this will aid the consultant(s) in organizing the feedback they receive in the most useful way. Community members will be able to provide anecdotal evidence on how their region is impacted by flood events that is otherwise impossible to collect. The consultant(s) should also plan to dedicate more time for the committees established in non-coastal regions, as significantly less resources have been spent to date understanding flood risks in these areas.
As an added benefit of the regional committee approach, DCR will also be able to utilize these established networks in the future to collect additional feedback when needed, disseminate the completed Plan(s), and share funding and training resources. Most importantly, local stakeholders and community members will be able to leverage these networks themselves when making critical decisions on flood resilience planning for their community. We have collected the following community outreach resources, which provide helpful guidance we hope the hired consultant(s) can use in creating these regional networks:
DCR should dedicate resources to compensate community members for their time to encourage community member participation.
DCR staff and the hired consultant(s) will need to determine how best to compensate community members for their time and feedback. For example, providing food, transportation, and/or childcare would make the meetings more accessible to a broader diversity of participants, especially if the meetings are scheduled in the evening. People tend to be unmotivated to attend meetings held after 9-5 work hours due to their normal day-to-day responsibilities; however, if resources can be dedicated to aid individuals with those tasks, it will increase meeting attendance. Moreover, attending these community engagement meetings to provide local expertise can be a large commitment for those who may have to miss work shifts or forego attending other important community meetings or family engagements to be there. Asking community members to volunteer their time for free will exclude low-income populations and lead to an inequitable approach to the engagement process. In some cases, it might be appropriate to provide direct financial compensation or a higher level of recognition if a community champion is involved and assists with meeting facilitation.
The City of Richmond’s approach to community engagement is a great example of how the master planning process would benefit from providing compensation to community members. When developing the City’s masterplan, “Richmond 300 – A Guide for Growth,” city staff realized they were not receiving as diverse feedback as they had hoped when they asked residents to volunteer their time for free. To remedy this, the City identified specific populations they wanted to include and offered the final participants in their engagement process a stipend. Although DCR may not be able to provide direct financial support to community members, learning from Richmond’s process of engaging community members to become involved could provide valuable insights to the Scope of Work created for the hired consultant(s).
To the maximum extent possible, meeting agendas should be community-led. Community members should be encouraged to share any and all anecdotal information they are willing to share, and these meetings should ultimately be utilized as listening sessions with a few guiding questions.
As mentioned previously, for many community members the upcoming rounds of engagement conducted as part of the COEP will be the first time they are learning of the two master planning processes. Participants may have many questions about these processes and what these plans mean for their communities, and ample time should be allotted to have these discussions. If regional stakeholder committees are formed, it may be beneficial for the entire first meeting agenda to focus on Q&A and planning priorities set by community members that will be addressed in future meetings. Community members will likely want to discuss how flood events have impacted them in the past, and it may take a significant amount of time before they are prepared to contemplate what flood risk will look like for their community in the future. Planning for future flood risk could involve drastically re-envisioning what their community looks like, and these topics should be treated with extreme sensitivity.
If meetings are too agenda-focused, it could lead to the omission of critical local information that would surface if a more collaborative listening approach is used instead. Additionally, the hired consultant(s) should restrain from initially providing any potential solutions to the community’s flood problems, as it may limit community members’ feedback on what could be possible. Outlining solutions should be a collaborative effort with participants, and it should not take place until the end of the meeting, or, if regional stakeholder committees are formed, until the last few meetings. FEMA’s “Building Alliances for Equitable Resilience” is a useful resource that outlines these key themes in community planning, as well as others the hired consultant(s) can incorporate.
DCR should carefully examine and clearly describe its goals and objectives for the Outreach and Engagement Plan.
A concise outline of the Department’s intent will help localities understand the approach and their role in the process, and it will also provide a helpful framework for tracking progress. The more information DCR is able to provide at the beginning of the Community Outreach and Engagement process, the more our organizations can help engage community members. Additionally, DCR should outline how community feedback will be integrated into the CRMP and FPMP and explain how information collected will be disseminated back to community members for their own planning purposes. This will be the first time that Virginia has conducted a statewide outreach effort on flood resilience, and it is therefore important that clear timelines and organized work plans are developed so that DCR staff and the hired consultant(s) can maintain, and keep track of, their progress. A portion of the scope of work for the consultant will need to involve identifying key communities that have not been engaged in any previous outreach efforts. DCR staff and hired consultant(s) should be prepared to dedicate more resources and potentially develop alternative strategies to reach and engage these communities. A great example of how assessments of previous outreach efforts can be outlined and utilized to craft outreach goals and objectives can be found in the City of Escondido’s draft Community Outreach and Engagement Plan.
The draft COEP also mentions that the COEP will be a living document that will continue to be updated throughout the implementation of the CRMP and FPMP. DCR should provide additional information on how updates to the COEP will be disseminated and how DCR will measure progress. DCR should also provide transparent reports on the engagement process to state and local stakeholders as the COEP is updated. This degree of reporting will benefit DCR’s goal of improving transparency in planning processes and allow for traceable accountability around the execution of the plan.
DCR staff should consider ways to share and solicit public input on a “scope of work” for the COEP before an RFP is finalized.
Given that the update to the CRMP is due by the end of 2024, the consultant hired to execute the COEP will need clear specifications from DCR laying out what is required in order to conduct a meaningful outreach and engagement process under such a limited time frame. Those specifications include things like defining the targeted communities, detailing the extent and frequency of outreach that must be conducted, and setting clear timelines within which those activities will be effectively conducted. Those are the types of “scope of work” details where public comment could be most valuable to DCR, but they have not been included in the draft COEP, and that, in turn, has limited our ability to provide the level of input that we believe would be most helpful. We therefore urge DCR to give serious consideration to ways it can share and solicit public input on the more specific “scope of work” details–and to do so before they are finalized. Some potential ways to do this might include sharing an outline of a draft scope of work for feedback before the RFP is finalized, or publishing a Request for Information (or similar type of submission) that includes a potential scope of work and requests feedback on it. Some of our organizations have extensive experience with conducting outreach initiatives across the state, and we would be happy to submit additional recommendations for improving this Community Outreach and Engagement process as more details are developed and made available.
Conclusion
Virginia has the opportunity to be a leader in how states plan for flood resilience, and a crucial portion of this work must include meaningful engagement with community members. Storm surge, sea level rise, coastal erosion, and increased rainfall all contribute to flooding impacts felt by Virginians across the Commonwealth, and it is critical that perspectives from all regions are collected to understand how these factors directly impact communities. We appreciate that DCR wants to incorporate a “whole community” approach for the COEP; however, minimal details have been provided regarding how this will be accomplished. In addition to the recommendations offered above, we encourage DCR staff and the hired consultant(s) to review the following resources to help inform the finalized Community Outreach and Engagement Plan and process:
North Carolina Department of Environmental Quality’s Public Participation Plan
Maryland Climate Adaptation and Resilience Framework Recommendations
Thank you for your consideration of our comments and for the important work you are doing to advance climate resilience for the Commonwealth. We look forward to meaningfully collaborating with DCR staff and the hired consultant(s) to implement the finalized Community Outreach and Engagement Plan, and we are ready to offer our assistance and support as needed.
Sincerely,
Sonja Branch Wilson
President
AMMD Pine Grove Project
Garry Harris
Managing Director
Center for Sustainable Communities
Peggy Sanner
Virginia Executive Director
Chesapeake Bay Foundation
Emily Steinhilber
Virginia Director, Coasts & Watersheds
Environmental Defense Fund
Brent Hunsinger
Tidal Programs Manager
Friends of the Rappahannock
Tom Dunlap
James RiverKeeper
James River Association
Karen W. Forget
Executive Director
Lynnhaven River NOW
Walton Shepherd
Virginia Policy Director, Climate & Clean Energy Program
Natural Resources Defense Council
Ann Creasy
Acting Deputy Director
Sierra Club Virginia Chapter
Morgan Butler
Senior Attorney
Southern Environmental Law Center
Nikki Rovner
Associate State Director
The Nature Conservancy
Patrick L. Calvert
Director of Water & Land Conservation
Virginia Conservation Network
Queen Zakia Shabazz
CEO
Virginia Environmental Justice Collaborative
Faith Harris
Executive Director
Virginia Interfaith Power & Light
Michael Town
Executive Director
Virginia League of Conservation Voters
William "Skip" Stiles
Executive Director
Wetlands Watch