Please accept The Pew Charitable Trusts’ (Pew’s) comments on the Virginia Department of Conservation and Recreation’s (DCR’s) draft grant manuals for the Community Flood Preparedness Fund (CFPF) and Resilient Virginia Revolving Fund (RVRF).

Pew believes DCR’s latest proposals for these grant manuals provide a solid foundation for future CFPF and RVRF awards.  Since it was established in 2020 and through three award rounds, the CFPF has resourced nearly $100 million in capacity-building and resilience projects across the State of Virginia,  and the RVRF can complement this record of accomplishment at the property scale.  To optimize the effectiveness of the CFPF and RVRF, Pew offers the following recommendations:

Prioritize Grants for Capacity-building
The Clean Energy and Community Flood Preparedness Act authorizes both loans and grants to be issued from the CFPF.  Pew recognizes the value of a diversified financing approach, and we commend the draft manual’s prioritization of funding for capacity-building to bolster local staff and resilience planning. That said, we recommend maintaining an emphasis on grantmaking for localities that are still in the initial stages of resilience planning, meet criteria as low-income or underserved communities, or have never received CFPF funding before. DCR could consider enhanced emphasis on loan opportunities for communities that have already received extensive grants for projects during past CFPF award rounds. We encourage DCR to clarify that communities may submit joint applications for local program capacity-building and local flood resilience program capitalization from the RVRF, allowing for coordination and resource-sharing among small and low-capacity communities.  

Transparent Funding Allocation and Committee Review
Funding decisions should be primarily based on verified application scores shared publicly with grant award announcements, ensuring transparency and accessibility for all localities. This approach will help guide localities in preparing applications and align funding decisions with clearly understood requirements. Further, we encourage transparency concerning makeup of the CFPF and RVRF’s Review Committee and urge that multiple agencies and departments are represented. Pew recommends consideration of Committee members from outside state government, including resilience experts and local government representatives, to the extent such participation would not give rise to conflicts of interest in the loan and grant-issuing process.

Flexibility in Required Review of a Certified Floodplain Manager
It is a laudable goal to encourage localities across the Commonwealth to hire and maintain dedicated certified floodplain manager (CFM) capacity. Broad use CFMs will enhance the long-term effectiveness of local resilience planning and CFPF monies. However, we suggest that DCR phase in any requirement that CFM capacity not be contractor-based, especially for communities seeing capacity-building grants in this round for local floodplain management. This phased approach can mitigate the limited availability of CFM training in some areas. In the interim, DCR could weigh dedicated CFM staffing as a factor in its scoring criteria, particularly for non-capacity-building projects.

Match Waivers
We applaud DCR for proposing capacity-building match waivers and urge expanding such waiver opportunities to low-income and underserved communities that apply for project grants.

Emphasis on Nature-based Solutions
The Clean Energy and Community Flood Preparedness Act directs that CFPF funding should be prioritized for projects that entail community-scale benefits and deploy nature-based mitigation solutions.  Pew appreciates DCR’s strong prioritization of acquisition of open space, as well as developed property, that offer flood mitigation benefits, and of other nature-based solutions—such as wetland and floodplain restoration—in proposed scoring criteria. The RVRF is authorized to provide funding for home buyouts and enhancement of the natural flood mitigation capacity of floodplains; accordingly, it should mirror CFPF’s emphasis on nature-based solutions. The manual and scoring criteria should clarify that restoration of natural floodplain after the demolition or removal of bought out structures is an eligible expense. DCR should also strategize how the CFPF, RVRF, and other funding sources can support long-term management of bought out properties and enhance conservation, habitat, and recreation benefits in reclaimed open space.

Design and Maintenance for the Full Project Lifespan
The CFPF commits applicants to replacing projects at the project owner’s expense or paying back grant funding to DCR in the event a project fails over the life of the project. This may unintentionally discourage grant applications for projects with long lifespans or those that are innovative. To support long-term project performance, applicants should be allowed to set aside some CFPF project funding for long-term maintenance, while DCR could create a separate maintenance category in future application rounds. CFPF project funding selection criteria should prefer projects designed using higher scenarios for precipitation and flooding, or use a long planning horizon (for instance, planning to mid-century precipitation and sea level rise projections) to ensure long-term benefits and returns on CFPF project investments.

Thank you for your consideration of Pew’s comments on the current draft CFPF and RVRF grant manuals.  As DCR finalizes changes to these important programs, we encourage the Department to consider seriously the diverse perspectives and needs of localities across the State of Virginia.  Please feel free to contact Kristiane Huber at Pew, khuber@pewtrusts.org, should you have any questions about these comments.