Norfolk is concerned with the proposed use of ConserveVirginia for guidance and prioritization of restoration projects as highlighted the first bullet under Grants Applicability- Projects (Page 4).  While ConserveVirginia is an impressive tool that does a good job of identifying conservation areas in rural and suburban areas, it is not as well suited for identifying “restoration of floodplains, coastal barriers, and other natural capital” noted under the first bullet, particular in urban areas.

• • As an example, no areas under the ConserveVirginia categories of Natural Habitat & Ecosystem Diversity, Floodplain & Flooding Resilience, or Water Quality Improvements were modeled in Norfolk, though we have implemented numerous projects under each of these categories, some of significant scale.
    • The tool likewise does not adequately assess smaller scale urban conservation options such as those being reviewed by Wetlands Watch and the Living River Trust.
    • ConserveVirginia should only be used for identification of large-scale conservation areas and should be excluded as a prioritization tool for restoration and smaller scale conservation activities.