To Whom It May Concern,

Thank you for the opportunity to provide comments on the draft 2021 Grant Manual for the Virginia Community Flood Preparedness Fund.

This fund provides a new and exciting opportunity for Virginia to assist cities and counties in flood preparedness whether these are regularly occurring events or related to extreme weather.  Regular flooding and the threats posed by our changing climate, rising sea levels and increased storm activity are a reality facing all of our coastal communities.  Using these funds wisely and carefully is our collective responsibility.

I would like to begin by stating that I have reviewed the thorough and thoughtful comments provided by Wetlands Watch and I affirm our agreement with their comments.  With that said, I would like to highlight several areas of most concern to Lynnhaven River NOW in Virginia Beach.

1. Maximizing the effectiveness and impact of these funds is our shared goal.  With that in mind, we should be allowing the use of other non-state grants to be used as match for these funds and the use of these funds for match for other flood resiliency grants, federal and private.  Especially for community with few resources, this will provide the capacity to apply for funding and will expand the projects that can be considered.
2. Please provide an example of a community-scale hazard mitigation activity.  Presently it is unclear what projects meet that criterium.
3. Please provide clarity on who is eligible to apply for funding.  The local government designation is unclear and may include unintended entities and exclude others.  Likewise, it is unclear whether regional and state agencies are eligible to apply for funds under this program.
4. It is unclear what projects or phases of projects are eligible.  Can a grant application apply only to the design and planning phase of a project with the implementation and installation in a separate subsequent application?  What are the various funding categories referred to in the draft manual?
5. Reliance on the Virginia Floodplain and Flooding Resilience Mapping tool is problematic.  That tool is currently incomplete and inaccurate especially in our urban areas.
6. Establishing the overall match based on a percentage of cost in a project that includes both green and gray infrastructure creates a cost structure that penalizes the implementation of projects that combine both.  Nature based solutions are generally much more cost effective.  The match should be based on the percent of the area served by each strategy, nature-based and hardened structures.
7. Non-governmental organizations (NGOs) and land trust groups have many years of experience in the implementation of nature-based solutions and the acquisition of property for conservation.  This program should prioritize partnering with NGOs and land trust organizations.

Thank you for the opportunity to provide these comments.

Sincerely,

Karen W. Forget