August 4, 2025
VIA ELECTRONIC SUBMISSION (lisa.mcgee@dcr.virginia.gov)
Lisa McGee
Policy and Planning Director
600 East Main Street, 24th Floor
Richmond, VA 23219
Dear Lisa McGee,
Thank you for the opportunity to comment on the periodic review of DCR’s Public Participation Guidelines, 4 VAC 3-11, 4 VAC 5?11, and 4 VAC 50-11. On behalf of Nature Forward, Virginia Interfaith Power & Light, Lynnhaven River NOW, American Rivers, the Virginia Conservation Network, the Friends of Dyke Marsh, and Wetlands Watch, we respectfully recommend that this regulation be retained in its current form.
According to the National Centers for Environmental Information at NOAA, the first 120 days of 2025 saw 83 unique flooding events in 31 Virginia counties, resulting in one fatality and more than $10.7 million in property damage. As the frequency and severity of flooding and other climate-related hazards increase across the Commonwealth, it is more important than ever that the public has clear, accessible opportunities to participate in the development of policies that affect their safety, property, and communities.
The Public Participation Guidelines (PPGs) remain essential for ensuring transparent, inclusive, and equitable engagement of Virginians in natural resource and flood resilience planning. As the Commonwealth experiences more frequent and severe flooding, members of the public must have meaningful opportunities to shape how the Commonwealth prepares and adapts. Without buy-in from the public, these plans will sit on shelves.
DCR’s Community Outreach and Engagement Plan (COEP) reinforces the importance of public input in developing state-led flood resilience plans, such as the Virginia Coastal Resilience Master Plan and the Virginia Flood Protection Master Plan. The COEP sets a framework that ensures DCR invites the public to participate at every step of the process. By providing clear principles, goals, and strategies, the COEP aligns directly with the intent and structure of the Public Participation Guidelines.
Retaining the current PPG regulation supports:
The protection of public health, safety, and welfare, especially in flood-prone communities;
Effective implementation of the COEP and state flood plans, by ensuring procedural transparency and stakeholder inclusion;
The regulation is already well-written and understandable for agencies and the public alike;
Minimized economic impacts on small businesses, nonprofit organizations, and local governments that rely on consistent public processes to participate without undue burden.
Maintaining this regulation in its current form will ensure that the public continues to play an integral role in shaping policies that affect their communities and environments. Thank you again for the opportunity to comment.
Sincerely,
Mary-Carson Stiff, Executive Director
Wetlands Watch
Renee Grebe, Executive Director
Nature Forward
Faith Harris, Executive Director
Virginia Interfaith Power & Light
Karen Forget, Executive Director
Lynnhaven River NOW
Pat Calvert, Virginia Director of Conservation
American Rivers
Mary Rafferty, Executive Director
Virginia Conservation Network
Glenda Booth, President
Friends of Dyke Marsh