May 11, 2021

Lisa McGee

Director of Policy and Planning                                                                                                       

Virginia Department of Conservation and Recreation

600 East Main Street, 24^th Floor

Richmond, Virginia 23219

RE: 2021 Grant Manual for the Community Flood Preparedness Fund

Dear Ms. McGee:

We appreciate the opportunity to review the 2021 Grant Manual for the Virginia Community Preparedness Fund.  We recognize this is a difficult program to guide and implement, so we wanted to thank the Department of Conservation & Recreation, ultimately, the Governor’s office for creating forward thinking programs to help protect and improve Virginia’s land and waters.

As you narrow the guidelines to benefit the communities in need, we are encouraged to be part of process allowing feedback and transparency. The following are a list of comments, we believe, will positively affect the process for requesting and distributing funds, and allowing stakeholders to provide best use of funding for communities at risk:

• Define the matching requirements more clearly in Part II of General Department Grant Eligibility Criteria and Application Procedures. We suggest allowing for in-kind matching to lessen the burden on communities already under budget pressure. Some of the communities in need do not have the resources to allocate a financial match, so a percentage match should be defined more openly to benefit communities of need.
• The plan calls for both wetland and stream restoration as tools to aid communities with flood preparedness. How will these wetlands and streams be protected? It is common practice for wetland and stream restoration projects to be protected by permanent conservation easements and for the projects to be monitored by the engineering firm for a minimum of 10 years to make sure they meet standards. Following this 10 year monitoring period, a Long Term Steward is typically assigned to make sure the project continues to perform to standards in perpetuity. The funding of these activities is typically paid for through the sale of the mitigation credits generated from the project. It is quite possible these stream and wetland projects created for flood mitigation will not be generating any credits to fund long term maintenance and stewardship. You mention in the draft that maintenance of these projects will be left to the communities. There is no small cost associated with making sure these projects perform in the long term and do what they say they are going to do. Leaving the maintenance up to the communities leaves them with an undue burden, and quite frankly, it is unlikely to be done correctly if done at all. We recommend that the funding process allow for the request of funds to guarantee the long term performance of these projects.
• Mapping. Using a universal mapping program to capture project data and location will lessen the burden on the grant administration to demonstrate results and program locations that may have cross grant benefits into other local, state, or federal programs.  For example, National Fish and Wildlife uses FieldDocs as a universal grant submission mapping tool.
• The draft guidelines reference a number of different qualifying metrics from other plans (Capital Improvement Plans, FEMA, Hazard Mitigation Plans, National Flood Insurance Plans, Virginia Coastal Resilience Master Plan Framework, etc.) and qualifications. A simple qualifications checklist of requirements and universal data points accepted will allow communities to have a better understanding of qualifications.
• No less than 25% of the moneys dispersed form the fund each year shall be used for projects in low-income geographic areas. We request a more defined version of this statement to help communities understand opportunity and need based funding distribution.

We appreciate the opportunity to work with the Department of Conservation & Recreation and future stakeholders to ultimately benefit Virginia communities in need. We are available to discuss or talk though any of our comments to help make this grant process stronger and more transparent.

Sincerely, 

Wade Blackwood 

Tee Clarkson 

Charlie Westbrook