May 12, 2021

Ms. Lisa McGee

Policy and Planning Director

Department of Conservation and Recreation

600 East Main Street, 24th Floor

Richmond, Virginia 23219

Re: Virginia Community Flood Preparedness Fund Draft Grant Manual 

Dear Ms. McGee,

The Piedmont Environmental Council (PEC), a non-profit organization with a near fifty-year history of promoting and protecting the rural economy, natural resources, history and beauty of Virginia’s Piedmont, respectfully submits the following comments regarding the draft grant manual for the Virginia Community Flood Preparedness Fund (the Fund). 

As we noted in our previous comments on the draft guidelines for the Fund, PEC is an enthusiastic supporter of this initiative. We are grateful to the Northam Administration and the General Assembly for having Virginia lead the way in becoming the first southern state to join the Regional Greenhouse Gas Initiative (RGGI), and for establishing this fund as a mechanism for utilizing the Commonwealth’s share of the proceeds from RGGI auctions to help combat climate change and improve climate and flood resilience across the state. 

With regard to the draft grant manual developed by the Department of Conservation and Recreation (DCR), PEC would align ourselves with the extensive comments offered by Wetlands Watch, and we would encourage DCR to seek to implement as much of the substance of those recommendations as possible. Our organization would again emphasize, as we did in our comments on the Fund’s draft guidelines, our desire to see the grant manual reflect the need for this fund to support planning, data collection, and projects in communities across the Commonwealth, as the impacts of climate change are not localized to coastal Virginia. Similarly, PEC would again raise the importance of a meaningful percentage of the annual grant funds awarded by the Fund to go towards applications in the categories of (1) planning, and (2) studies and data collection of statewide and regional significance. We continue to believe that such an emphasis is important in order to help ensure that localities in all regions of the state have the opportunity to develop comprehensive climate and flood resilience plans that can serve to inform future applications to the Fund for project-specific grants.

With the aforementioned points of emphasis in mind, PEC would call specific attention to the following items of interest from the draft grant manual, as identified by Wetlands Watch, that we believe should be addressed prior to the opening of the Fund’s anticipated initial grant round in June 2021. 

• The grant manual frequently references coastal areas and how they should address flooding through the use of these funds, but it does not put the same emphasis on the non-coastal areas of the state that also experience frequent flooding. PEC shares this concern that the lack of inclusion of these non-coastal areas in the grant manual could lead to minimal allocation of funds to these areas in subsequent grant rounds. 

• It would appear that the scoring criterion in the draft grant manual does not accurately reflect the separate grant categories, and as currently presented severely disadvantages applications for planning, studies, and capacity building. The grant manual should include a separate scoring criterion for each category of grant (i.e. planning and capacity building grant applications should not be competing against project grant applications). 

• The grant manual makes no reference to opportunities for localities to partner with non-profit organizations to strengthen their project proposals. The grant manual should highlight such opportunities, particularly with regard to acquisition projects, as non-profit organizations can provide necessary expertise and help encourage innovative approaches. 

• PEC concurs with the suggestion that the ConserveVirginia Floodplain and Flooding Resilience layer should be omitted or given less emphasis in the grant manual. This layer is not comprehensive or accurate enough to be included in the highest scored project activity. 

• We believe that the $25,000 minimum award for planning/capacity-building grants should be substantially reduced or eliminated. As Wetlands Watch notes, this level of minimum award is likely to be too high and burdensome for local governments seeking small incremental levels of support to build capacity. 

• PEC would echo the suggestion that DCR should adopt a phased approach to the grant manual’s ASFPM CFM requirement. We are concerned that as presently construed in the grant manual that this requirement will, in the initial years of the Fund’s operation, unfairly disadvantage those localities that have not previously had staff obtain ASFPM CFM certification. 

Thank you for the opportunity to provide these comments. We continue to look forward to this fund helping to ensure that communities in the Virginia Piedmont and across the state have the data and support they need to develop resilience plans and meaningful projects to combat the impacts of climate change. 

Sincerely, 

Adam Gillenwater

Senior Policy Manager