Please consider allowing awards to include indirect costs. These expenses support work under the grant by providing the overhead and contractual services we need to remain operational, such as the laptops and software we use to complete studies and reports, as well as our accounting and payroll contract that is necessary for grant reporting/processing. These costs are critical. We encourage DCR to examine options, such as an indirect cap, similarly to the Virginia Coastal Zone Management Program. Not allowing for indirect expenses to be charged to this grant program puts low income geographic areas and planning district commissions at a distinct disadvantage and is a common point of concern among communities who are otherwise interested in pursuing funding from the CFPF. 

Additionally, please consider allowing existing staff to charge time to the grant. It is not always feasible to create a new role, and much easier and less costly to allocate existing staff time towards completing projects and administering grants. This would ultimately free up funding because it is far more cost efficient to charge a percentage of existing staff time than create an entirely new FTE, especially when we cannot charge indirect expenses.