COMMENTER: A. M. Lindemann, Norfolk VA, Private Citizen

TO: Virginia Department of Conservation and Recreation

SUBJECT: COMMENTS on DRAFT 2021 Grant Manual for the Virginia Community Flood Preparedness Fund

Greetings, and thank you for receiving my comments concerning the upcoming 2021 Community Flood Preparedness Fund and Grants program in Virginia.

I currently live in Virginia, am a Virginia native, and have lived and worked both in this great State and several of our neighboring States as well. I am a former award-winning NASA engineer turned entrepreneur who, along the way, have founded or led several innovative environmentally protective science-driven economic development programs in a variety of distressed urban and rural areas in the greater mid-Atlantic and Appalachian regions.

With respect to flooding, I know of and have experienced the ravages of flooding both at the coast and up in the mountains, so I have some insight into the disparate factors at play in different: terrains/water systems; economies; and – also of critical importance – wildlife habitats.

I am pleased for the opportunity of this important program, and the urgency with which it is being “stood up.”

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My comments and wishes for the program are as follows:

0) “Resilience” and “Flood Resilience” – terms/referents used both vaguely and non-equivalently in the Draft manual – require explicit definition.

1) Flooding mitigation is not something that always happens in close or immediate proximity to the flood location. For example, mass deforestation inland (e.g., from rampant land development that currently plagues Virginia) not only catastrophically destroys wildlife habitat, it sets up ecosystems at a distance for flooding problems owing to a host of science-demonstrated reasons too numerous to detail here (e.g., from pollution, carbon, heat, erosion, far more). It is entirely within the scope of this program to consider potential projects that relate to addressing “inland” matters that not only affect their immediate localities but also others at a distance, so please and importantly do not lose sight of this reality when considering all projects submitted. In association, this potential “benefit at a distance” effect may not – or ever – be captured, or even capturable, in a proposing locality’s “flood resilience” plan, so some re-thinking is in order about the necessity of requiring the reconciliation of an applicant’s proposed effort with some resilience plan for that applicant’s locale.

2) I urge “equity” in the scope of projects considered for support. This is a term that is receiving a lot of use these days, so I want to be clear that what I mean by “equity” here relates to:
a) Assurance that diversity in human communities and economies are equitably supported;
b) Assurance that diversity in terrain and types of water system (e.g., mountain stream vs Atlantic Ocean coast) are equitably supported;
c) Assurance that diversity in at-risk wildlife habitats are equitably supported.

3) There is power in supporting projects that may not have precedent but in their success have the promise to serve as important “pilots” or models for yet more programs (supported by other means, and on larger scales) to follow. This further argues for ensuring diversity (as addressed above) of projects selected.

4) In association with assuring diversity (as addressed above), widely distribute notice of/invitation to the opportunity of this program throughout all types of communities and potentially eligible organizations/efforts being clear to invite creativity/innovation and to stress that no scale is too small if value can be credibly argued!

5) Essentially, relative to project selection criteria embraced and communicated:
a) Each applicant must demonstrate/make a credible case for the flood mitigation benefit(s) its project will confer, such as those alluded to above:
   i) as well as how the ultimate results will be quantified/qualified,
   ii) and by when results should be forthcoming, including an ongoing management plan if the benefits will take some years to realize;
b) Priority should be given to those projects that protect and enhance water quality;
c) No project should be funded or supported in any way that degrades water quality or wildlife habitat (e.g., no non-nature-based shoreline modifying efforts such as shoreline hardening or filling should be allowed).

6) As soon as practicably possible, publicize outcomes from projects supported both to demonstrate value of the program but also – of critical importance – to spur on the launch of yet more such important projects.

7) At the culmination of each funding year, produce and distribute lessons from both travails and successes encountered in the administration of this program to be used to help improve the program in the future, as well as inform future different programs and/or projects including non-governmental efforts.

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I appreciate this opportunity to submit my comments relative to this important program. I support the effort wholeheartedly, and will happily further address any questions you may have.

Sincerely yours,

A. M. Lindemann
Norfolk VA