Lisa McGee
DCR Policy and Planning Director
600 East Main Street, 24th Floor
Richmond, 23219
Dear Ms. McGee:
Thank you for the opportunity to comment on DCR’s Community Flood Preparedness Fund Draft Guidelines. It would be difficult to overstate the importance of this program, given the effects of climate change that Virginia is experiencing and will experience in the future, and the significant revenues that will be available as a result of the Commonwealth joining the Regional Greenhouse Gas Initiative.
As the largest global conservation organization, The Nature Conservancy (TNC) considers climate change and coastal resilience and adaptation to be one of the world’s most urgent challenges and immediate risks to communities, economies and to our mission. Our long-term commitment to conservation and community collaboration and partnerships at the Virginia Coast Reserve (VCR) embodies our global commitment to climate change at a local level, where impacts of sea level rise and coastal flooding are not only threatening the land and seascape but the culture and economy of the Eastern Shore of Virginia. Our efforts to advance specific nature-based solutions to address coastal flooding extend to Virginia Beach where we are partnering with others to implement adaptation strategies identified in the City’s recently completed coastal resilience report.
TNC very much wants to assist the Commonwealth with building an effective Community Flood Preparedness Fund (CFPF) program, one that can serve as a model for other states.
This letter focuses on a number of specific issues raised in the Draft Guidelines. While we would not object if DCR chose to revise the Guidelines to address these topics, we believe they can all be effectively addressed in the subsequent steps of program development identified in the Guidelines: “annual requests for proposals (RFPs), a grant manual, and scoring criteria for grant and loan applications.” Our comments will focus on the grant manual because we think that is where most of these topics are likely be addressed, but we recognize that they could be also addressed in other related documents.
We also recognize that the enabling legislation for this program contemplates that the program could include both loans as grants. We believe that the grants should be the focus of the program for at least the first year or two. Localities should be given time and assistance to establish robust programs before considering how to establish funding mechanisms that would allow them to repay loans from the state.
Prioritizing Local Resilience Plans
We concur with the Guidelines’ emphasis on the need for local resilience plans. The first round of grant funding should focus on ensuring that all localities that do not currently have sufficient plans are able to develop such plans. Otherwise, localities, especially rural ones, that are not able to develop plans will be ineligible for implementation grants in subsequent rounds. It is also very important for the grant manual to clearly state what constitutes an adequate plan for grant eligibility. It is our opinion that adequate plan considerations should depend on the population and geographic size and planning capacity of the locality or PDC. For localities that will not be able to complete a robust plan otherwise, there should be a possibility of waiving match requirements for planning grants.
Smaller localities such as the towns on Virginia’s Eastern Shore must not be left out. Counties and PDCs that submit plans should be required to include towns in their proposals if those towns do not have and are not developing their own plans.
Prioritizing Low-Income, High-Risk areas
There is a set-aside in law ensuring that low-income areas receive at least some CFPF funds, but we feel this this is not enough. Low-income, high-risk areas must be the top priority for grants. To address this, DCR should provide a clear definition of what constitutes low-income and high-risk areas, as well as provide a map of such areas in the grant manual. The definition of risk should not disadvantage rural towns and villages due to small population size. We suggest using tools created by the Centers for Disease Control and Prevention and the Georgetown Climate Center to ensure consideration of social vulnerability in the definition and subsequent map of these low-income, high-risk areas in Virginia. To be useful, these maps should be created at a finer scale than counties. In addition, match requirements should be reduced or eliminated for projects in those areas identified as low-income and high-risk.
Role of Non-Government Organizations (NGOs)
We recognize that the law currently provides that only government entities can receive grants. As an NGO, we intend to assist localities and PDCs with grant proposals. However, it should be noted that for some localities, working with an NGO that has experience administering such grants would be beneficial. For over a decade, TNC, in partnership with the ANPDC, has led the Virginia Eastern Shore Climate Adaptation Working Group (CAWG) and collaborated with state, federal and local entities on resilience and adaptation grants and projects. TNC plays an integral, leadership role in this collaboration that includes grant writing and stewardship, project implementation and community engagement.
Eligible projects
In recognition that there will be few “shovel ready” projects ready for funding at this stage, the grant guidance should clearly state that all phases of projects including plan development, permitting,
research and data gathering as well as implementation and installation are eligible to apply. As a model, consider that some federal grant programs provide assistance throughout the life of a project in sequential order: an initial grant for planning, a second grant for design, and a third grant for installation. Given the complexity of projects and permitting requirements, it is also essential that grant periods are long enough to accommodate all that must be accomplished in a particular stage.
Land conservation is recognized as a cornerstone nature-based strategy throughout The Virginia Coastal Resilience Master Planning Framework. The CFPF program should catalyze increased participation in land protection efforts among state, locality and NGO partners. Use of program funds to
increase capacity of land trusts in VA’s coastal region, for example, could greatly accelerate the pace and scale of land protection in critical areas. Moreover, the land trust community’s access to additional sources of private and public capital can help leverage state CFPF grant money. Directing CFPF money to the Virginia Land Conservation Foundation grant program and establishing a new VLCF funding category (Flood Preparedness) should be considered. Providing block grants to Planning District Commissions to guide local land conservation activities may also have merit.
Process Going Forward
As stated above, we are concerned that localities have very different levels of readiness to take advantage of this program. We believe it is important for DCR to engage in a robust outreach and education program, from the start, to ensure that localities are both aware of the program and are provided assistance in applying for grants. We recommend committing to this effort throughout the entire life of this program by creating a DCR position dedicated solely to outreach and education.
We recognize that revenues will soon become available and the need to begin planning and implementing resilience projects is urgent. We also recognize establishing a brand-new program is challenging. While we appreciate the opportunity to comment on the Draft Guidelines, we agree with others who have raised concerns about the lack of specificity in the document. Therefore, we strongly urge DCR to provide an opportunity for the public to comment on a draft grant manual, so that the agency can fully benefit from the contributions of the many stakeholders who wish to make this program a success.
Summary
In summary, we recommend:
Thank you for the opportunity to comment on the Draft Guidelines.
Sincerely,
Nikki Rovner
Virginia Associate State Director
nrovner@tnc.org