Thank you for providing an opportunity to comment on the draft 2021 Grant Manual for the Virginia Community Flood Preparedness Fund. 

The Indian River community in Chesapeake, Virginia is on Eastern Branch of the Elizabeth River.  The entire northern part of our community is in low lying areas at risk of flooding during storm surges, which will get worse as sea levels rise.   Even at higher elevations, which reach a high of about 15' about sea level, we are at increasing risk of flooding due to more severe heavy precipitation event, increasing land development, and overwhelmed stormwater management systems.  Our community also has a broad demographic range, from expensive water front properties to low income communities.  

Flood mitigation is an important concern in our community that will grow over the coming years.  We are pleased to see the coming of this grant program.  But we believe that it is very important that the funding even more strongly emphasizes nature-based solutions.  Gray infrastructure solutions like rip/rap, bulkheads, infill, channelized streams, and concrete storm sewers ultimately exacerbate problems by constricting waterways, destroying habitat, and increasing water pollution.

Specific comments:

Under Commonwealth Resilience Planning Principles, #5, "Recognize the importance of protecting and enhancing green infrastructure", please include protection of water quality from pollutants such as sediment, nutrients, bacterial contaminants, and plastic litter.

Under Grant Matching Requirements, we would support lower matching grant levels for projects that include less than 59% nature-based/green infrastructure.  For example limit the match to 50% funding for projects with 40%-59% nature-based/green infrastructure and limit the match to 25% for projects with less the 39% nature-based/green infrastructure.  Perhaps keep the existing match limits, i.e. 55% and 50% for those respective green infrastructure thresholds, for low income communities.  

The minimum grant award amounts of $50,000 for Projects and $25,000 for Studies, Plans, and Capacity Building, seems high, considering the variable match limits.   There are small projects that may be worth doing.  Please consider lower these minimums.

Maintenance Plans should look out at least 10 years rather than just 5 years.   These projects need to be look at longer term solutions.

Thank you

Rogard Ross

President, Friends of Indian River