We appreciate the opportunity to review and provide comments on the Draft Grant Manual. Please see questions and comments below by section. 

Part I, Section A – Overview and Authority

· How will you guarantee that 25% of the moneys will go to low-income geographic areas? If there is not enough low-income project interest, will you reduce the amount available to non-low income to meet %?

· What is the definition of “community-scale” hazard mitigation activities? Neighborhood-wide? City-wide? Please clarify.

Part I, Section C – Definitions

· Definitions include both “Community Resilience Plan” and “Resilience Plan” – please clarify the difference and which one is necessary for localities to have approval of in order to submit projects.

· Definition of low-income geographic area includes an impossibility: it states “any locality...that has a median household income that is not greater than 80 percent of the local median household income…” A locality cannot have 80% of its own local median household income; the locality would need to be compared against a larger area, e.g. the State. As written, localities overall will be unable to be defined as a low-income geographic area

Part II, Section A – Conditions and Limitations

· Will there ever be a scenario where match is not required?

· Item 2 states GI % is determined by relevant % of project implementation cost. Would things like land acquisition and design count as implementation cost? Otherwise would penalize the GI share.

· Why does low-income match only differ for studies or capacity building? Project implementation should also have a better scale.

· Minimum grant award is only for State share, correct? E.g. a non-nature based project would have to have a minimum cost of $100,000 (min project awarded is 50%, $50,000). This may be too large for some projects, e.g. capacity building. Why implement a minimum at all?

· Item 12D – will there ever be an opportunity to apply for funding for maintenance? Maintenance can be a significant burden, particularly for lower-income communities. Grant only requires verification of maintenance for five years, perhaps funding could support maintenance five years out.

Part II, Section B

#3 - Application Review and Approval

· Will projects be approved based on rank regardless of score? E.g. if all scores are very low will projects still be funded?

#4 – Project Commencement And Schedule for Completion

· Indicates projects taking longer than 36 months should be submitted in phases; is there extra points awarded for phased projects (i.e. the second phase)? Are projects penalized for being phased?

#6 – Grant Award and Administration

· Indicates copies of completed work are due 30 days after completion – are there other checkpoints required throughout project?

Part III – Section A

· Concerned about having to cover all of a locality in resilience plan. Grant is for areas that are subjected to recurrent flooding, why is the whole locality necessary? Many localities include areas outside of floodplains that would not be considered for flood resilience. Is it sufficient that this be the consideration? “The whole locality was considered, and a portion was determined to not need to be included in this plan.”

· How is best available science determined?

· Request more specific criteria in plan development. Since this will be a gatekeeper to projects, and plans take quite a bit of time to produce, localities want to get it right the first time.

· What will be the review process for plans? Are they submitted with projects, or beforehand? How will localities be notified that their plan is approved?

Part III – Section B

· Why limit applications to local governments?

· States “nothing in these guidelines prevents projects from serving a smaller geographic area within the defined locality” – is this just to indicate projects don’t need to be City-wide? Prior pages already indicates projects must be community-scale.

Part III – Section C, Scope of Work

· What is the value of the “Alternatives” requirement? Depending on details required, this is significant effort for something that will ultimately be an uninformative exercise. Likely that localities will choose alternatives that are significantly less desirable than what they are applying for.

· Item 8 requires a description of meeting the criteria. Is this required for all criteria? Recommend including space on the rubric for answers to be added where desired.

Part III – Section D, Budget

· Estimated total project cost requires estimated for work being completed by third parties; are any other cost breakdowns required? E.g. could I say “total cost $1 million; $100,000 for engineering design work” and the remaining $900,000 be unspoken for if it is all City staff work?

Appendix A

· Are project types scored against similar types? Or do hydrologic studies compete with construction of green infrastructure?

· Under the second bullet, “Evaluating” the needs for levees or other structures is not a construction of modification of existing infrastructure; it is a study. This should be a separate bullet.

· If “other” is an applicable project type, why provide a list to select from?

· Overall subheader for this is “Projects and Studies” which are two of the four possible grant types. I would have assumed there would be a second subheader that is called “Capacity Building and Planning” but there is not. If subheader is not relevant, recommend removing; if it is relevant, recommend separating out studies (sixth bullet) from implementation tools and projects, and including in capacity building and planning instead. Recommend the same for increasing outreach efforts (8th bullet), studies and data collection of statewide and regional significance (9th bullet), revisions to resilience plans (10th bullet) and capacity building (11th bullet).

· Why is acquisition given such a high point value? How would you expect a capacity building project to compete with an acquisition project? Even if the Capacity Building project obtained all other available points (from #8, 9, 10, and 11) and the Acquisition project obtained none, it would still not score as high as acquisition. This seems to be a problem.

o If projects of differing types are not meant to compete with one another, how do you divide funding between them?

· Do stream restoration projects also get points for green infrastructure?

· Is there project scoring outside of the attached rubric? More details on how projects are scored would be useful for localities in developing and selecting projects for submission.