Copy this link to view a PDF version of this comment letter: https://wetlandswatch.org/s/CFPF-Guidelines-Public-Comment-Joint-Letter-Final.pdf

January 27, 2021

Lisa McGee
Virginia Department of Conservation and Recreation
600 East Main Street, 24th Floor
Richmond, Virginia 23219

RE: Community Flood Preparedness Fund Draft Guidelines


Ms. McGee:        

We appreciate the opportunity to provide our comments on the Community Flood Preparedness Fund Draft Guidelines (“Draft Guidelines”). These initial comments summarize the issues we believe are essential to address in modifying the Draft Guidelines to establish a strong funding resource critical to reduce flood risk across the Commonwealth. Transparency and full stakeholder involvement is essential in this process, as this Fund could generate as much as $90 million annually to benefit the entire state, and we appreciate the efforts that the Department of Conservation and Recreation (“Department”), and Deputy Secretary of Natural Resources Joshua Saks in particular, have been making to inform interested stakeholders about the Draft Guidelines during the public comment period.

The very general nature of the Draft Guidelines makes it difficult for stakeholders to develop comprehensive and constructive feedback on the elements of the Fund that during outreach efforts have proven to be of the most interest to stakeholders. During webinars and other conversations with stakeholders, questions repeatedly arose around the project scoring criteria, the definition of what constitutes threshold resilience plans, and many other key elements outlined below. We acknowledge the Draft Guidelines were drafted to provide very general information and are thereby intentionally nonspecific, but this approach obfuscates the submission of detailed and effective comments. 

We request that the Virginia Department of Conservation and Recreation modify the Fund Guidelines to include as much specificity as possible on the key elements of the Fund included in this comment letter and seek additional comments on those modifications. The updated version of the Draft Guidelines should be comprehensive enough to generate productive feedback that will help develop a more effective Community Flood Preparedness Fund (“Fund”) for the Commonwealth.

During stakeholder outreach, it became apparent that details on many important aspects of the Fund were likely to be pushed off to the development of a comprehensive Grant Manual and scoring criteria for the Fund. If this is the approach employed, the development of the Grant Manual and scoring criteria should be a high priority so they can be issued in time to undergo a full stakeholder review and comment period. We request a public commitment that the Fund Grant Manual and scoring criteria will be released for public comment.

The following is a list of the issues that arose repeatedly as necessary to be addressed in the formative documents for this Fund. These issues are paramount for the Department of Conservation and Recreation to address in both the revised Draft Guidelines and subsequent Grant Manual:

1. Outline the specific scoring criteria for grant and loan applications to the Fund
2. Outline how the Fund will operate to meet the requirements of the original legislation, such as the 25% allocation to low income geographic areas, prioritization of nature based solutions, and what constitutes “community-scale,” and explain how the scoring criteria will help ensure these legislative requirements are achieved
3. Include specific guidance on what constitutes an approved local or regional Resilience Plan, with an example if possible
4. Describe the application process and administration for at least the first year of the Fund. Specifically, the Draft Guidelines should explain how often money is awarded, the application process and deadlines, the kinds of projects allowed, and how the local match will work (e.g., how will the sliding scale operate and will it be detailed in the Grant Manual or known only to Department staff?). 
5. Provide estimated percentages of Fund allocations for the three categories of activities (plan, studies, and project funding) for at least the first year of the Fund, in addition to an estimated allocation for studies of state and regional significance
6. Detail how the loan portion of the Fund will operate, as well as the process for deciding whether a loan or grant is applicable
7. Explain the types of projects that will be prioritized in non-coastal areas (the Draft Guidelines note that projects in the coastal zone will be prioritized by the Coastal Resilience Master Plan)

We appreciate the opportunity to provide these summary comments and look forward to future stakeholder discussions as the Department releases additional documentation for public comment. Our organizations are available to answer any questions or engage in future dialogue as requested.

Sincerely,

William “Skip” Stiles, Jr.
Executive Director
Wetlands Watch

Daria Christian
Executive Director
Friends of the Rappahannock

Kristin Owen
President
VA Floodplain Management Association