Continued from Part 1
Outreach efforts during Phase 1 of the process were severely hampered by the Covid-19 pandemic as well as tight deadlines and misalignment of engagement and technical deliverable timelines. We support DCR’s efforts to complete a Community Outreach and Education Plan by December 31st, 2022 and appreciate the effort to remain in close communication with non-profits who are poised to offer assistance. However, the Department is currently under equipped to fully deliver on engaging Virginians statewide to both understand their risk and co-develop solutions and projects to build resilience and reduce risk in a manner that works for each community.
Pursuant to the Virginia Environmental Justice Act, "’Environmental justice’ means the fair treatment and meaningful involvement of every person, regardless of race, color, national origin, income, faith, or disability, regarding the development, implementation, or enforcement of any environmental law, regulation, or policy” and it is “the policy of the Commonwealth to promote environmental justice and ensure that it is carried out throughout the Commonwealth, with a focus on environmental justice communities and fenceline communities.”[1] Future resilience plans must fully embrace the meaningful involvement component of the Environmental Justice Act and work closely with communities that are chronically underserved and facing increased flood risk to ensure that residents understand their risk and participate in the development of solutions to be included in future project lists.
Climate change will drive transitions along Virginia’s coasts and waterways that will cause fundamental disruptions to communities’ economies and livelihoods, mental health, and culture and way of life – particularly where communities are considering moving away from flood risks or experiencing climate-induced population growth. These transitions will raise fundamental questions of distributional equity and decision-making systems should, wherever possible, allow people to participate in choosing their own futures. The forthcoming Outreach and Engagement Plan will play an essential role in centering Virginians in decision-making processes and its implementation should be integrated with the Phase 2 CRMP and Statewide Flood Plan. Many resilience plan applications to the CFPF to date have centered community engagement and co-design of needs and projects into their planning processes. Implementing similar measures and continuing to provide opportunities for meaningful contributions from community members to inform development of the Phase 2 CRMP and Statewide Flood Plan.
The Phase 1 scope included outreach and engagement targeted initially at the Planning District Commissions within the coastal region, and in a second phase to communities with both high socioeconomic vulnerability scores and at high flood risk. Planning district commission meetings began with local and regional staff and community leaders participating in informational sessions and viewing and commenting on mapping products, and then shifted to a public facing session in the evening. At least one representative from an undersigned organization participated in most planning district meetings and public facing meetings. While state staff and the consultant were well prepared and meeting materials were informative, many of the sessions, particularly the public sessions, had few participants. Meetings were under advertised (in fact, Environmental Defense Fund ran a public media campaign to share meeting information) and often at locations away from public transit or not frequently utilized for community events like planning district buildings. Understandably, public libraries and recreation centers, which might have been more easily accessible, were not renting meeting space due to the Covid-19 pandemic and related State of Emergency.
Moving forward, and in coordination with the Outreach and Engagement plan, strategies to make meetings more accessible for all Virginians, including advanced advertisement, convenient location near transit, and other support should be prioritized.
Communities that are chronically underserved and facing increased flood risk may require extensive engagement and technical assistance from DCR to work closely with to identify projects. The meaningful involvement of and technical assistance for underserved communities could be accomplished in multiple ways.
For instance, although the Phase 1 CRMP completed an initial gap analysis, more work could be done to identify potential projects, connect them with funding sources, and highlight which data, resources, or other tools are needed to connect the dots. By identifying which localities will need the most support, DCR can better leverage their own resources and tools where they are most needed. North Carolina’s Resilient Coastal Communities Program is a great example of this kind of focused technical support and engagement. With funding from the state and the National Fish and Wildlife Foundation, localities in North Carolina’s coastal counties can apply for direct technical assistance and funding to help overcome barriers in coastal resilience and adaptation planning, boost local government capacity, and support a proactive and equitable approach to coastal resilience planning and project implementation. The CRMP’s open access data portal makes baseline vulnerability data available to locality staff, but many do not have the time or expertise to learn how to use it. DCR and the larger CRMP team could provide trainings to localities on how to use this data for their individual resilience planning efforts, reducing duplication of efforts and increasing the pace of planning.
DCR could also consider collaborating with other state agencies to bring additional resources to bear, such as partnering with existing state programs like the DEQ Office Environmental Justice and engagement professionals throughout the DEQ regions. DEQ has six regional offices across the commonwealth with dedicated staff who work with the central office and executive team to handle community outreach, engagement, and regulatory requests. DEQ is also utilizing social media in addition to traditional methods such as public meetings and comment periods to spread awareness of their role and resources. VDEM is also a natural partner for this process, with an office of Diversity, Equity, and Inclusion and having conducted an extensive series of Hazard Mitigation Assistance Grants Equity Workshops. VDEM has established a Partners in Preparedness program to provide information and resources to community partners to break down communication barriers between the agency and socioeconomically vulnerable Virginians, though the office is new and information is not yet widely available. This effort will engage a diverse swath of NGOs, faith-based communities, businesses, education spaces, community centers, and other central hubs that can provide translation services, internet access, and other critical resources.
Implementation of natural infrastructure solutions for flood resilience allows limited resources to be used efficiently and leveraged for co-benefits including water quality goals. When combined with non-structural adaptation measures, natural infrastructure practices are more cost-effective than gray infrastructure at reducing flood damages. For example, a case study from the Gulf Coast calculated a benefit-cost ratio of 3.5 for nature-based solutions while grey infrastructure practices of levees/dikes and home elevations ranged from 0.26 - 0.73 [2]. A global review in 2016 found that nature-based shorelines that consist of salt marsh can be 2 -5 times more cost effective than gray solutions at reducing damaging waves [3]. Nature-based shoreline restoration projects are also more resilient to the impacts of sea level rise and storms [4] - projects in North Carolina and California have withstood intense wave action while nearby gray infrastructure was inundated and damaged in the same storms [5]. The environmental processes that make natural infrastructure resilient also provide a wealth of co-benefits that have positive impacts year-round – unlike gray infrastructure practices which only have potential positive impacts during storms 6. In addition to flood protection, natural infrastructure can improve water quality, trap sediments that would otherwise need to be dredged, and support fisheries, tourism, and recreation 6, [6], [7].
Virginia is the first state to include climate change and sea level rise in its tidal wetlands permitting and development actions subject to the Chesapeake Bay Preservation Act, but we could lose the majority of our tidal wetlands and coastal shoreline by mid-century without vigorous enforcement of these regulations. This necessitates more consistency across planning documents and program guidelines, as well as decision-maker education by agency staff.
The Framework lists, as initial actions, to coordinate the changes to the Chesapeake Bay Preservation Act (CBPA) and Tidal Wetlands Act (TWA)and integrate project review and compensatory mitigation of unavoidable impacts, resilience, and future impacts. Though steps have been taken to coordinate the efforts by reference in the CBPA guidance and TWA guidelines, on which many signers of this letter have commented, more action is needed to realize these goals in practice. The CBPA and TWA share overlapping jurisdiction, necessitating clear regulatory coordination. To further emphasize the importance of coordination, as sea levels rise, the landward buffer under CBPA jurisdiction today will become tidal wetlands in the future. Local government staff, already overburdened and under-resourced, need examples of how local wetlands and CBPA boards should review permits under the new regulations.
Although the Framework documents some departments and programs that should coordinate to leverage resources and Gov. Northam’s Executive Order 45 established a workgroup to ensure statewide compliance with resilient building standards, this level of coordination does not fully leverage the commonwealth’s staffing and funding resources to coordinate across state government. The Commonwealth could establish a body of resilience points of contacts at each agency charged with implementing resilience throughout programs within that agency. Several other states are taking a look at how to coordinate interdisciplinary resilience work across agencies and provide a potential path forward.
In New Jersey, Gov. Murphy’s 2019 Executive Order 89 established an Interagency Council on Climate Resilience comprised of 16 state agencies. The group was tasked with developing short- and long-term action plans to promote the long-term mitigation, adaptation, and resilience of the state’s economy, communities, infrastructure, and natural resources. The New Jersey Climate Change Resilience Strategy, released in 2021, charts a path forward for the Interagency Council and participating agencies to actualize plans and engage stakeholders and the general public.
In Louisiana, Gov. Edwards issued Executive Order 2020-19, directing each state agency to identify a resilience coordinator to lead collaboration for the Adaptive Governance Initiative. The involvement of many additional agency staff helped make the project a success and a useful framework for agencies moving forward. Agencies first conducted a vulnerability assessment of their physical assets like infrastructure and social assets, including programs, services, and employees. This exercise helped agencies identify priorities around mission-critical impacts, establish buy-in by identifying concrete examples within each department, and lay the groundwork for developing adaptation options. After identifying specific adaptation needs, agencies turned to potential implementation partners and pathways, resource needs, and ways to collaborate across agencies to get the job done. Louisiana’s Adaptive Governance Initiative has momentum thanks to dedicated leadership by the Chief Resilience Officer and buy-in across agencies’ resilience coordinators, but permanent structures, processes, and resources are needed to give agencies the capacity to plan and implement long-term adaptation solutions.
As the federal government rolls out increased funding for resilience programs and incorporates resilience into other programs, increased coordination is essential and must be a component of the CRMP Phase 2 and statewide planning efforts.
At the completion of the Phase 1 planning process, many members and advisors of the Coastal Resilience Technical Advisory Committee signed on to a set of forward-looking recommendations as the commonwealth moved forward in its planning and implementation processes. These recommendations were sent by Dr. Carl Hershner to legislators, the Northam administration, and the incoming Youngkin administration on December 15, 2021, and while some were generally incorporated into Chapter 495 of the 2022 Acts of Assembly or reiterated above, they bear repeating. The recommendations that have not already been implemented are summarized as follows:
Although the Framework prioritized an initial focus on managed retreat, this was met with understandable confusion and frustration by local and regional governments. Students and researchers, in coordination with the TAC, developed a literature review and case study detailing how managed coastal retreat had been used elsewhere, which was not included in the CRMP Phase 1. In the future, conversations around strategic relocation must be done in partnership with communities and local government through an extensive engagement process. The commonwealth must move at the speed of trust to ensure communities do not feel taken advantage of or left behind in this process.
Conclusion
Virginia must move urgently by investing in staff, external support, data acquisition, and technical assistance programs to develop comprehensive plans, tools, and then implement these plans. Although the deadlines imposed upon the DCR for the revised Phase 2 CRMP and the Virginia Flood Protection Master Plan may appear to be years away, we have learned from the Framework and Phase 1 processes that this work is complicated and to do it well will take time. Progress can be made now by staffing and embarking on a robust engagement plan to co-develop projects and incorporate frontline community knowledge into the planning process. Moving forward with best-available science will also necessitate incorporating new data, such as the MARISA projections for increased intensity, duration, and frequency of precipitation and the revised 2022 NOAA sea-level rise projections.
Virginia can continue to build resilience across the Commonwealth by moving forward to fulfill its obligations to develop, revise, and implement resilience plans in the coming years. Environmental non-profits stand ready to provide technical advice and support meaningful engagement across the commonwealth.
Sincerely,
Victoria Higgins
Virginia Director
Chesapeake Climate Action Network
Jay Ford
Virginia Policy and Grassroots Advisor
Chesapeake Bay Foundation
Emily E. Steinhilber Patrick Calvert
Director, Virginia Coasts & Watersheds Senior Policy & Campaigns Manager –
Environmental Defense Fund Land Conservation & Healthy Rivers
Virginia Conservation Network
Erin Reilly
Senior Staff Scientist Michael Town
James River Association Executive Director
Virginia League of Conservation Voters
Karen W. Forget
Executive Director Robin Broder
Lynnhaven River NOW Deputy Director
Waterkeepers Chesapeake
Matt Gove
Mid-Atlantic Policy Manager Skip Stiles
Surfrider Foundation Executive Director
Wetlands Watch
Nikki Rovner
Associate State Director
The Nature Cons
[1] Virginia Environmental Justice Act, Va. Code Ann. § 2.2-234-5 (2020).
[2] Reguero, Borja G., Michael W. Beck, David N. Bresch, Juliano Calil, and Imen Meliane. “Comparing the Cost Effectiveness of Nature-Based and Coastal Adaptation: A Case Study from the Gulf Coast of the United States.” PLOS ONE 13, no. 4 (April 11, 2018): 1–24. https://doi.org/10.1371/journal.pone.0192132.
[3] Narayan, Siddharth, Michael W. Beck, Borja G. Reguero, Inigo J. Losada, Bregje K. van Wesenbeeck, Bregje K. van Wesenbeeck, Nigel Pontee, et al. “The Effectiveness, Costs and Coastal Protection Benefits of Natural and Nature-Based Defences.” PLOS ONE 11, no. 5 (May 2, 2016). https://doi.org/10.1371/journal.pone.0154735.
[4] Sutton-Grier, Ariana E., Kateryna Wowk, and Holly Bamford. “Future of Our Coasts: The Potential for Natural and Hybrid Infrastructure to Enhance the Resilience of Our Coastal Communities, Economies and Ecosystems.” Environmental Science & Policy 51 (August 1, 2015): 137–48. https://doi.org/10.1016/j.envsci.2015.04.006.
[5] Jean Judge et al., “Surfers’ Point Managed Shoreline Retreat Project, Case Studies of Natural Shoreline Infrastructure in Coastal California: A Component of Identification of Natural Infrastructure Options for Adapting to Sea Level Rise (California’s Fourth Climate Change Assessment,” The Nature Conservancy, at 9-15 (2017), https://scc.ca.gov/files/2017/11/tnc_Natural-Shoreline-Case-Study_hi.pdf.
[6] Davis, Jenny L., Carolyn A. Currin, Colleen O’Brien, Craig Raffenburg, and Amanda Davis. “Living Shorelines: Coastal Resilience with a Blue Carbon Benefit.” PLOS ONE 10, no. 11 (November 16, 2015): e0142595. https://doi.org/10.1371/journal.pone.0142595.
[7] Gittman, Rachel K., Charles H. Peterson, Carolyn A. Currin, F. Joel Fodrie, Michael F. Piehler, and John F. Bruno. “Living Shorelines Can Enhance the Nursery Role of Threatened Estuarine Habitats.” Ecological Applications 26, no. 1 (2016): 249–63. https://doi.org/10.1890/14-0716.