The Piedmont Environmental Council (PEC), a non-profit organization with a near fifty-year history of promoting and protecting the rural economy, natural resources, history and beauty of Virginia’s Piedmont, respectfully submits the following comments regarding the draft guidelines for the Virginia Community Flood Preparedness Fund (the Fund).

PEC was, and remains, an enthusiastic supporter of the Commonwealth officially becoming the first southern state to join the Regional Greenhouse Gas Initiative (RGGI) in July 2020. As Secretary of Natural Resources Matthew J. Stricker noted at the time, “RGGI provides a framework for meaningful action on climate change” that will help to “capture the environmental, health, and economic benefits from the clean economy for all Virginians.” PEC is grateful to the Northam Administration for its leadership on this issue in ensuring that the Commonwealth took this long overdue step to help combat climate change and reduce carbon pollution. We also commend the General Assembly for passing both the Virginia Clean Economy Act and the Clean Energy and Community Flood Preparedness Act during the 2020 regular session, the latter of which created the Fund that we comment on today.

Given that the Virginia Community Flood Preparedness Fund could generate as much as $40 million per year for flood resilience projects and planning across the Commonwealth, we believe that it is critically important for regional equity to be a guiding principle in the administration of this Fund and grant award decisions. The Commonwealth appropriately invested a significant amount of time and resources in developing the Virginia Coastal Resilience Master Planning Framework to help inform the development and implementation of Virginia’s first Coastal Resilience Master Plan. The Commonwealth demonstrated the importance of ensuring that Virginia’s coastal communities have the resilience framework and planning in place to adapt to rising seas, increased nuisance flooding, and more frequent and intense storms that result from climate change -- this same level of commitment is necessary for all regions of Virginia.

There is a significant degree of variance in the extent to which localities across the Commonwealth have access to both the data and staff capacity necessary to develop actionable and effective climate and flood resilience plans. In many of the state’s rural counties, which have vastly different concerns with regard to climate change impacts than coastal Virginia, these needs are often particularly acute. Moreover, in many parts of Virginia, particularly the inland regions, the current 100-year flood maps are in dire need of updating. In certain regions, these maps are so outdated as to impede the ability of landowners and localities to make informed land use decisions. In short, numerous communities outside of coastal Virginia have significant needs with regard to the data and planning necessary to identify and undertake meaningful climate and flood resilience projects, and it is incumbent upon the state to help bridge these gaps.

Accordingly, PEC proposes that at least 25 percent of the annual grant funds awarded by the Fund go towards applications in the categories of (1) planning, and (2) studies and data collection of statewide and regional significance. Doing so will help to ensure that localities in all regions of the state have the opportunity to develop comprehensive climate and flood resilience plans that can serve to inform future applications to the fund for project specific grants. This would help to create a more level playing field with regards to the project grants and make it less likely that any locality or region would be at a disadvantage in identifying and developing shovel ready projects.

PEC appreciates the opportunity to provide these comments and we look forward to this fund helping to ensure that communities in the Virginia Piedmont and across the state have the data and support they need to develop resilience plans and meaningful projects to combat the impacts of climate change.