We appreciate the opportunity to comment on the draft grant guidelines. We feel this program will be of tremendous benefit to coastal communities facing the effects of climate change. Below are some of the comments we have proposed:
Provide guidance for the requirements of a Locally Adopted Resilience Plan and provide the procedure for approval by DCR. Also, what is involved/required for re-approval every three years? Many localities do not have dedicated resilience plans and will need to develop a qualifying plan. It is important that we know the specific plan requirements, and the process for getting a plan approved.
Reconsider requiring projects to be complete within 3 years. Large scale projects require planning, design, permitting, land acquisition, bidding, and construction. Many high cost projects will not move forward until funding is in place, since localities don't have the funding for large scale projects.
The requirement to present alternatives is unnecessary effort. It shouldn't be a part of the scope of the grant reviewers to determine if one option is better than another.
Considering this program was just released and many aspects are still being worked out, many localities do not have a dedicated Resilience Plan. It would be unfair to exclude localities who have suitable projects, but do not have an "approved" community resilience plan for at least the first year of grant solicitations.