April 26, 2023
Mr. Robbie Coates
Director, Grant Management & Recovery Division
Department of Emergency Management
9711 Farrar Ct.
Richmond, VA 23236
(804) 267-7730
Robert.coates@vdem.virginia.gov
Dear Mr. Coates:
Thank you for your efforts to continue to find opportunities to reduce climate risks faced by our communities. Although we are not advocating for any particular project, we would like to provide input into the development of the Resilient Virginia Revolving Loan Fund. Environmental Defense Fund (EDF) is a leading international, non-partisan, nonprofit organization dedicated to protecting human health and the environment by effectively applying science, economics, law and innovative-sector partnerships.
We are encouraged to learn that Virginia intends to apply for the FEMA STORM program. Virginia continues to be a national leader in flood resilience, as shown by investments in communities in the Community Fund Preparedness Fund (CFPF), the seed funding and establishment of the Resilient Virginia Revolving Loan Fund, coastal and statewide resilience planning, as well as other positive changes to the Code of Virginia. While the revolving loan fund (RLF) model is proven and successful, we would like to reiterate that loans are only one element of Virginia’s resilience toolbox. Grants available to communities, as well as comprehensive resilience planning, also serve an essential role, particularly for communities that are unable or unwilling to service these types of loans due to capacity or existing debt burdens.
The effort that Virginia continues to invest in pre-disaster mitigation and resilience is one that will help prepare its residents for future natural disasters and the impacts of climate change. We commend this forward-looking approach to pre-disaster versus the traditional post-disaster investments, which can cost up to 6 times more.
At EDF, we have been working nationally to help support states and to serve as a resource as they begin the development of these programs and ensure FEMA is enabling the needs of states. To that end, we have a few suggestions that we would like to offer Virginia as it considers the program set up, eligibilities, and design. These priorities include:
Finally, we would also like to extend our support to the Commonwealth of Virginia over the upcoming years as this fund is set up, seeded, and begins offering funding and financing. EDF has technical, legal and policy expertise that may be helpful. Please do not hesitate to reach out to Emily Steinhilber, Virginia Director, Climate Resilient Coasts & Watersheds at esteinhilber@edf.org if you would like to discuss further.
Sincerely,
Emily E. Steinhilber
Virginia Director, Climate Resilient Coasts & Watersheds
Environmental Defense Fund