The City of Norfolk appreciates Virginia DCR's ongoing support of important resilience work through Community Fund Preparedness Fund grants and loans, as well as your consideration of the following suggestions and requests for clarification.

1) Are there preferred metrics and dataset for identification of underserved communities? The current definition indicates factors to consider may include impacts social, economic, or environmental impacts, but does not provide criteria for assessing these impacts to identify if an area qualifies as underserved.

2) Can approved, but unutilized maintenance costs be used after the grant period of performance?  Likely project maintenance costs can be assessed, but many maintenance items extend beyond the current grant timeline or are only on an as-needed basis. By allowing funds to be retained after grant closeout, localities would have support to ensure ongoing maintenance of projects through the minimum 10 year lifespan?

3) Please consider allowing more frequent reimbursement requests for low-income communities to reduce financial burdens on larger projects.

4) The period of performance should be extended to 5 years. This would buffer grantees from increasingly common delays due to shortages in materials, in labor, or due to permitting. This would also allow for period of performance to extend through a one or two year warranty period, resulting in more successful projects if maintenance costs for this period are built into the grant request. Lastly, it would reduce administrative burden by decreasing the frequency of extension requests.

5) Please consider expanding loan terms to 30 years or the full useful life of the project. In the latter case a slightly higher interest rate may be appropriate in exchange for increased flexibility for the municipality. This change could be applies across all eligible projects or just for low-income communities.

6) Please consider allowing more than $7,500,000 per applicant if all allocated loan funds are not awarded in the application cycle.

Sincerely,

Justin Shafer

Coastal Resilience Manager

City of Norfolk Office of Resilience