The City of Norfolk appreciates the opportunity to review and provide comments on the Draft Grant Manual for the Virginia Community Flood Preparedness Fund (CFPF, or “the Fund”).
The City of Norfolk firmly believes that the most important item that needs to be addressed in the Grant Manual is that the Fund needs to explicitly be allowed to serve as a local match for federal funding opportunities such as HUD, FEMA, USACE and NFWF grants, among others. The City of Norfolk is in agreement with many other stakeholders on the request issue, including the Hampton Roads Regional Planning District Commission, the Virginia Floodplain Manager’s Association and Wetlands Watch.
Some highly important flood protection projects will require partnership at the local, state, and federal level to be successfully funded. Page 23 notes that CFPF funds cannot be used as match for other grants. Page 10 suggests that grants can be sought for activities carried out in context with a federal agency cost-share. Eligibility for grant match should be reconsidered to allow best leveraging of all funding sources, but at a minimum the wording on page 10 should be clarified to explain under what circumstances CFPF funds can be used in federal cost-share agreements.
Stream restoration is called out as a specific project type and should be included within the category of “Construction or modification of existing infrastructure or construction of gray or green infrastructure necessary to reduce or mitigate flood risk”, so that all non-acquisition construction project types are compared equally.? Although the manual notes that the project types listed are only examples, stream restoration is also given a specific point allocation in the scoring matrix and should not be treated as a special type of project compared to all other flood reduction construction activities. Alternatively, at a minimum, shoreline restoration should be included with stream restoration as these project share similar benefits of floodplain enhancement and dissipation of floodwaters.
Scoring- No Accounting for Flood Reduction Benefits
Scoring in the grant manual do not fully align with the intent of the funding. Nowhere in the scoring is the benefit of a project to enhance flood prevention or protection and coastal resilience accounted for. Without accounting for metrics of benefited population, structures, infrastructure, economic value, etc, proposed projects cannot be compared to identify those that will provide maximum flood protection. Instead, they will be reviewed in the current scoring matrix based simply on their project type. This could lead to many less effective projects being chosen simply because they did not have to compete based on their flood protection merits.
Scoring- Green Infrastructure and Acquisition Emphasized Too Heavily
The emphasis on green infrastructure and acquisition will put grey infrastructure efforts at a major competitive disadvantage. Green infrastructure has an important role to play in precipitation flood management and coastal erosion protection, but for tidal flooding, no amount of trees and wetlands can provide adequate flood reduction in the face of sea level rise, compared to necessary walls, gates, and pumps. Acquisition of some threatened properties and conversion to conserved open spaces must be considered in many areas, but it is equally important to provide long-term protection for the majority of developed areas. Scoring should be modified to provide bonus point for green infrastructure or acquisition projects, but all construction projects should otherwise be scored against each other based on how much flood protection they can provide.
Scoring- Scoring Matrix Section 7
It appears scoring in section 7 (Eligible Projects) of the scoring matrix will be additive, allowing a project to qualify for more than one set of points. For instance, stream restoration may be awarded double points for its own category and the category of “Construction or modification of existing infrastructure or constructing of gray or green infrastructure necessary to reduce or mitigate flood risk.” Likewise, an acquisition projects could be awarded multiple sets of points for acquiring and then restoring a property. If this is accurate, these projects are being emphasized at the expense of other important flood reduction project types that are not specifically called out. Providing essentially double point value for these projects skews them too far above any other project type. This section should request a selection be made for the highest scoring appropriate category.
Other recommended changes that the City of Norfolk hopes to see included within the CFPF Grant Manual include:
The application process requires the total cost of the project, but the scoring does not include a benefit-cost analysis. The draft criteria award significant points to acquisition (50 points) and green infrastructure (45 points) projects. However, by comparison, structural flood protection projects, which are most effective in meeting the primary goals of the Fund, would only receive 30 points regardless of the protection, risk reduction, or other benefits provided.
A BCA for risk-reductions should absolutely be incorporated into the scoring criteria; should include a risk reduction component.
Not including a BCA into the scoring criteria would conflict with Planning Principle B.4 in the manual; B.4: Understand fiscal realities and focus on the most cost-effective solutions for the protection and adaptation of our communities, businesses, and critical infrastructure. The solutions will, to the extent possible, prioritize effective natural solutions.
Green infrastructure percentages should be broken down by total project cost rather than project area.
The criterion awarding points for stream restoration or stabilization projects should also apply to shoreline and floodplain restoration and stabilization projects. For Hampton Roads localities, shoreline restoration often provides the same important benefits as stream restoration.
The 3-year project completion requirement does not provide sufficient time for projects that involve construction. This requirement should be modified to at least 5 years.
A points multiplier should be incorporated for CRS communities, tiered by CRS Class in order to promote projects that are part of a community’s comprehensive effort to reduce flood risk and support sound floodplain managements practices.
Total Points should be multiplied by the CRS points multiplier as follows:
Class 9: 10%
Class 8: 15%
Class 7: 20%
Class 6: 25%
Class 5: 30%
Class 4: 40%
Class 3: 50%
Class 2: 60%
Class 1: 70%
Thank you for providing the City of Norfolk the opportunity to comment.