To Whom It May Concern:

Thank you for the opportunity to comment on the Grant Manual for the Community Flood Preparedness Fund (the Fund). The Virginia Eastern Shore Land Trust (VES Land Trust) conserves the farms, forests, wetlands, and heritage of Virginia’s Eastern Shore through donated conservation easements. With the generosity of local landowners, we protected 14,000 acres in Northampton and Accomack. Much of that land is located on the creeks and wetlands of the Chesapeake Bay and Atlantic Ocean. We hope that the Department of Conservation and Recreation (DCR) will take our comments into consideration when finalizing the Grant Manual.

The Grant Manual should encourage partnership with non-governmental organizations (NGO’s). Many localities do not have the capacity and expertise to navigate the grant process and, as such, are at a strategic disadvantage. NGO’s can support shared equity objectives by providing needed technical expertise in both grant writing and nature-based design. The grant manual should provide clear language allowing and encouraging localities to partner with the non-profit community.

The Grant Manual should highlight opportunities for localities to partner with nonprofits and other groups to help execute projects, specifically those dealing with acquisition. Localities should be encouraged to partner with land conservation organizations when applying for projects such as land acquisition, as these groups are experts in determining how conserved land should be managed and stewarded after acquisition occurs.

The Grant Manual should require or incentivize a deed restriction or conservation easement over parcels once acquisition and structural demolition occurs. The acquisition of property is the highest scoring grant activity, but few details are provided regarding the stewardship of property post-acquisition. A deed restriction or conservation easement are commonplace for the FEMA acquisition program and help ensure no future development occurs on the property.

We ask DCR allow the Fund to be used as a match. This will leverage the Fund and multiply the positive effect of grant awards.  

We strongly support the Commonwealth’s dedication of a portion of the Regional Greenhouse Gas Initiative auctions to the Fund. This is a big step toward a more resilient Virginia. Thank you for considering our comments.

Sincerely,

Hali Plourde-Rogers, Executive Director