July 18, 2024
Angela Davis
Virginia Department of Conservation and Recreation
600 East Main Street, 24th Floor
Richmond, Virginia 23219
RE: Public Comment Notice: Round 5 Community Flood Preparedness Fund (CFPF) draft manual
On behalf of Appalachian Voices, Chesapeake Bay Foundation, Chesapeake Climate Action Network, Environmental Defense Fund, Friends of the Rappahannock, Lynnhaven River NOW, Potomac Conservancy, Rockfish Valley Foundation, Southeast Rural Community Assistance Project, Inc., Southern Environmental Law Center, The Nature Conservancy, Virginia Association for Parks, Virginia Interfaith Power & Light, Virginia Floodplain Management Association, Virginia League of Conservation Voters, and Wetlands Watch, we jointly offer these comments on the 2024 draft manual for the Community Flood Preparedness Fund (CFPF).
The manual that guides the implementation of this important flood resilience funding program plays a crucial role in determining its effectiveness in administering the key priorities detailed in the statute that establishes the CFPF. In the past as now, we appreciate the opportunity to comment on the draft guidance and DCR’s willingness to hear and incorporate many of our comments in the past. We hope that you will again closely consider our joint comments on this updated manual as outlined below.
Availability of Short and Long-Term Loans
In response to the growing and nearly overwhelming demand for community resilience planning, the General Assembly allocated $100M to the CFPF for FY 2025, allowing this critical program to march forward in its purpose to address community-scale flooding and resilience challenges across the state. Until more localities have completed DCR-approved resilience plans, we continue to advocate for recurring allocations into the CFPF and recommend that DCR maintain a greater emphasis on the availability of grant funding in response to the growing demand.
Transparency
Definitions
Eligible Activities; Periods of Performance
Assistance for Lower-Resourced Applicants
Application Logistics
Thank you for the opportunity to comment on this important draft manual for the CFPF, the only statewide flood risk reduction program that provides resources at an accessible magnitude that begins to meet the flood risk reduction needs among Virginia’s localities and soil and water conservation districts (and Indigenous Tribes, upon the reinstatement of their eligibility to apply for CFPF funding). Our organizations feel strongly that the manual should be designed to maximize the significant flood preparedness and prevention funding opportunities that this program provides, while advancing the key priorities that are outlined in the statute that establishes it.
We look forward to continuing collaboration with DCR to build awareness of these programs and make them as effective as possible.
Sincerely,
Peter Anderson
Director of State Energy Policy
Appalachian Voices
Jay Ford
Virginia Policy Manager
Chesapeake Bay Foundation
Victoria Higgins
Virginia Director
Chesapeake Climate Action Network
Emily Steinhilber
Virginia Director, Climate Resilient Coasts & Watersheds
Environmental Defense Fund
Brent Hunsinger
Advocacy and Coastal Programs Director
Friends of the Rappahannock
Karen W. Forget
Executive Director
Lynnhaven River NOW
Ken Wright
Virginia Policy Director
Potomac Conservancy
Peter Agelasto III
Executive Director
Rockfish Valley Foundation
Hope Culpit
Executive Director
Southeast Rural Community Assistance Project, Inc.
Morgan Butler
Senior Attorney
Southern Environmental Law Center
Nikki Rovner
Associate State Director
The Nature Conservancy in Virginia
Tim Kennell
President
Virginia Association for Parks
Rev. Dr. Faith B. Harris
Executive Director
Virginia Interfaith Power & Light
Kristin Owen
President
Virginia Floodplain Management Association
Blair St. Ledger-Olson
Director of Advocacy & Campaigns
Virginia League of Conservation Voters
Mary-Carson Stiff
Executive Director
Wetlands Watch
[1] Manual Reference: Part II: General Department Grant Eligibility Criteria and Application Procedures, Section A: Department Conditions and Limitations for Making Grants and Loans, “Availability of Funding and Allocation”
[2] Manual Reference: (for adoption of definition) Part I: Introduction and Overview, Section B: Definitions; (for text regarding project failure) Part Part IV: Required Application Components, Section B. Scope of Work Narrative, d. Scope of Work Narrative - Projects, “Maintenance Plan”
[3] Manual Reference: Appendix I: Elements of a Resilience Plan
[4] Manual Reference: Part II: General Department Grant Eligibility Criteria and Application Procedures, Section A: Department Conditions and Limitations for Making Grants and Loans, “Submission and Scope”
[5] Manual Reference: Part II: General Department Grant Eligibility Criteria and Application Procedures, Section A: Department Conditions and Limitations for Making Grants and Loans, “Disbursement”