RE: Community Flood Preparedness Fund draft manual and the Resilient Virginia Revolving Load Fund draft manual

Thank you for the opportunity to provide comments on the draft manuals for the Community Flood Preparedness Fund draft manual and the Resilient Virginia Revolving Loan Fund on behalf of Lynnhaven River NOW (LRNow) in Virginia Beach, Virginia.

Sea level rise and flooding are our biggest challenges in Virginia Beach and the Community Flood Preparedness Fund has been a lifeline for our city and our region.  This program has provided the only consistent source of funding to assist the citizens in Virginia Beach and the other cities and counties in our region in tackling these challenges.

The citizens of Virginia Beach supported a bond referendum that allows the city to borrow $567 million to complete projects throughout the city that will help to prevent flooding of homes and neighborhoods.  This is just the beginning of work that needs to be done in Virginia Beach alone.  While Virginia Beach has the staffing and resources to begin to tackle these challenges, the same is not true for the other cities and counties in our region. The future stability and prosperity of our region depends on the success that every community has in tackling these challenges.

With that in mind, we offer the following comments on the draft manuals:

• We support the 25% set aside for low income communities. This is very important part of making this program work effectively for all regions of Virginia.
• We support the emphasis on nature-based solutions. These projects bring multiple benefits to our citizens.  In addition to flood control, nature-based also support water quality improvements and are often the most cost-effective approach.
• We support low-income communities being provided the opportunity to receive 50% of the funding upfront.  This will allow many more opportunities for low-income communities to take advantage of this program to develop plans for the resiliency of their economy, their neighborhoods and their citizens.
• We applaud the commitment to transparency and consistency. That includes full transparency regarding the rating scale and how projects are chosen for funding.
• It is important to understand that this work is on-going and will continue to provide new challenges to communities across Virginia.  As conditions change, new funding may be needed to maintain previously constructed projects. This needed evaluation and maintenance should be supported by the fund.

We have concerns about this aspects of the proposed draft manual:

• The increased emphasis on loans eliminates the communities that need the funds the most.  Loans are beyond the means of many counties and cities and will not help them meet their challenges.  Our regional resilience is dependent upon equal opportunity for every community to work toward greater resilience.
• Community-scale projects should include neighborhood-scale. The problems in each neighborhood and watershed are unique.  Individual projects need to meet those varying needs.
• Not all communities are able to support a certified floodplain manager on their city or county staff.  They should be allowed to contract these services and be eligible for project funding.
• Eligible funding must support the staffing needed to evaluate, plan, implement and maintain flood prevention and resiliency.
• Equity in the implementation of the Community Flood Preparedness Fund can only be achieved if match-waivers are provided.
• Equity also requires that cost-benefit analysis is not the deciding factor in which projects are funded.  Neighborhoods with higher valued properties are not more valuable than lower-valued properties to the stability of our communities, neighborhoods, and citizens.

Thank you for the opportunity to provide these comments.

Karen W. Forget

Executive Director 

Lynnhaven River NOW