January 31, 2021

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

RE: Draft Community Flood Preparedness Fund Guidelines

Ms. McGee,

The staff of the Hampton Roads Planning District Commission (HRPDC) appreciates the opportunity to comment on the Department of Conservation and Recreation’s (DCR) draft guidelines for the Community Flood Preparedness Fund (CFPF). The HRPDC supports the establishment of dedicated state funding for local and regional resilience efforts. Hampton Roads is one of the most vulnerable areas in the Commonwealth to the near-term and long-term effects of flooding and sea level rise. As a result, the HRPDC and its seventeen member jurisdictions have invested significant time and resources in considering various ways to build more resilient communities, including through the identification and implementation of specific projects and studies. Based on that experience, the HRPDC staff offers the following comments on the draft guidelines.

Engage Stakeholders

The draft guidelines state that additional details will be included in forthcoming grant manuals. As a result, the draft guidelines provide too little information on the CFPF program for stakeholders to offer detailed feedback. The draft guidelines would benefit from more clarity on program priorities, terminology, proposed criteria, project eligibility, funding levels, cost share requirements, and the process for selecting proposals, which are all critical aspects of how the program will be implemented. The HRPDC staff recommends that DCR establish a stakeholder working group to help identify criteria and develop the scoring mechanism for prioritizing projects. Local governments have significant experience with existing state and federal grant programs and can provide valuable insight into the practicality of different scoring metrics and the efforts need to put together successful applications. Establishing a stakeholder workgroup to help draft the grant manual would help to avoid some of the obstacles and challenges experienced with similar programs. This workgroup should include at minimum representatives from cities, counties, towns, planning district commissions, soil and water conservation districts, and tribal governments from across the Commonwealth. In addition, we recommend that DCR provide the public with an opportunity to review and comment on the first grant manual for a comment period of at least sixty days. This will help to ensure that the program is established in such a way that Virginia’s local and tribal governments are best able to equitably benefit. 

Adopt a Flexible Definition for Local Resilience Plans

The draft guidelines state that grant awards “will only be considered for projects that are part of a locality’s resilience plan, or determined to be of local, regional or statewide significance by the Commonwealth.” The HRPDC staff supports connecting state funding with local planning processes. There is a wide range of previous investment in resilience efforts by different communities across the Commonwealth due to various factors, including differences in capacity and in the relative importance that some communities place on these issues. However, the HRPDC staff supports requiring prior planning to be eligible for project funding. Most if not all communities already have a comprehensive plan, hazard mitigation plan, or other officially adopted plan. Instead of requiring a specific resilience plan, the HRPDC staff recommends that DCR provide a list of required elements that a locality’s or region’s plan should include to qualify as a resilience plan. Documentation of how the plan meets those minimum standards should be required in the application. In addition, DCR should specifically include applicable regional plans, such as hazard mitigation plans or other resilience-related plans, in any list of acceptable plans. 

Leverage Related Funding Opportunities

Although annual, dedicated funding for flood risk mitigation is typically not available, there are examples of state and federal programs that fund similar projects to the CFPF. Many of these are funded on a competitive or limited basis. For example, funding from the U.S. Army Corps of Engineers Civil Works program has the potential to help localities in Virginia conduct significant resilience planning and implementation efforts, but it requires congressional authorization. The HRPDC staff recommends that DCR consider setting aside funds to provide larger amounts of funding for major projects. The CFPF should allow for combining with other state programs (for example, SLAF), and include a component to assist localities with non-federal match requirements for federal grants from FEMA, NOAA, or the U.S. Army Corps of Engineers.

Establish an Adaptive and Transparent Process

The HRPDC staff recognizes that the implementation of the CFPF will change over time as lessons are learned during implementation and new policies, including the forthcoming Virginia Coastal Resilience Master Plan, are put into place. We recommend that DCR commit to annual updates of the grant program guidance and manual. The HRPDC staff also recognizes that this program is likely to be highly competitive with many applicants from across the Commonwealth. DCR should work with a stakeholder workgroup to clarify the process for selecting projects for funding. In addition, DCR should release the scores of all applications after each selection round and offer opportunities for applicants to receive feedback on their proposals. This would help ensure transparency in how funds are awarded and should improve the quality of applications over time.

We appreciate DCR’s efforts to incorporate stakeholder feedback through this public comment process and look forward to working with DCR on the successful implementation of this program.

Sincerely,

Benjamin J. McFarlane

Senior Regional Planner