In previous rounds, there was an option for low-income applicants to request a waiver of the standard match for applications up to a set amount. That was very appreciated by those communities for needs with a smaller total budget. Adding back in a low-income match waiver for smaller applications would be recommended, even if there is a further constraint on it (such as nature-based approaches). Plus, it could help the CFPF program better achieve its % goals for low-income areas.

There are two major issues we face when considering applying for the CFPF program:

1. Indirect Costs: The prohibition against billing indirect costs to this grant is the biggest reason our organization cannot afford to participate. Indirect costs are the cost of doing business: without them, we would not have internet or facilities to use to carry out the work of the grant. We are largely grant-funded, so we also cannot use any of our other grants to make up the difference by covering the indirect costs associated with the time to complete CFPF work. 

2. Existing Staff Labor:  It is better for us to assign existing staff to work on grants like this, as they bring institutional knowledge of other resilience projects and partners. This does not supplant their salary--it means they would be assigned to work some percentage of their time on a CFPF grant instead of other work. This is much more feasible than hiring a new staff person for a temporary grant period. 

Allow the CRS Enrollment or Classification Improvement points to be awarded to an application within a CRS Community even if the applicant isn't a CRS member themselves.

Please clarify Eligibility and provide a definition for “Regional government.”

The draft manual states the grant is open to local governments as defined by §?10.1?603.24 of the Code of Virginia.  Per §?10.1?603.24. Definitions. “Local government" means any county, city, town, municipal corporation, authority, district, commission, or political subdivision created by the General Assembly or pursuant to the Constitution of Virginia or laws of the Commonwealth.

Regarding regional government, the draft manual states:

1. “Regional government applicant is limited to Capacity Building & Planning or Studies” (Appendix C: Checklist, page 17) and,
2. “Regional governments are encouraged to coordinate and partner with localities to support the implementation and execution of flood risk reduction projects and may serve as third-party administrators on behalf of eligible localities.” (page 6)

However, there is no definition or Code of Virginia reference for “Regional government” in Draft Manual. 

Reason for inquiry: Although our district provides services to multiple cities and counties, it is not designated as a regional government within the Commonwealth Authorities, but rather a political subdivision. Given these definitions, I interpret that this district is within the local government definition and is eligible, as it was in past years.  Is this correct?  

Thank you.