April 9, 2025

Office of Environmental Education (via email to environmentaleducation@dcr.virginia.gov)
Virginia Department of Conservation and Recreation
600 E. Main Street, 24th Floor
Richmond, VA 23219 

 Submitted online to the Virginia Regulatory Town Hall at: https://townhall.virginia.gov/l/ViewNotice.cfm?GNID=3073 

RE: Public Comment on Virginia’s K-12 Environmental Literacy Strategic Plan (2025–2030)

Dear Office of Environmental Education,

Wetlands Watch is a 501(c)3 nonprofit organization, based in Norfolk and working statewide on the conservation and protection of Virginia’s wetlands. On behalf of Virginia Interfaith Power & Light and the York River Steward, we thank you for the opportunity to provide input on the Virginia K-12 Environmental Literacy Strategic Plan (2025–2030). We commend your team for the vision and collaborative effort that shaped this document, which lays a strong foundation for advancing environmental education across the Commonwealth.

We respectfully submit the following recommendations to enhance the plan’s effectiveness, with references to relevant goals and strategies:

1. Meaningful Metrics to Track Environmental Literacy Progress

While the Virginia K-12 Environmental Literacy Strategic Plan (2025–2030) presents a strong vision and framework, it currently lacks the depth and specificity expected of a State Environmental Literacy Plan (SELP).   As identified in the North American Association for Environmental Education’s (NAAEE) 2019 State Environmental Literacy Plans Status Report (p. 4), an SELP should include several key components that are either underdeveloped or absent in the plan:

• Specific content standards, content areas, and courses or subjects where instruction will take place 

• Clear articulation of high school graduation requirements that ensure students are environmentally literate upon completion 

• Detailed descriptions of professional development programs for educators that build environmental content knowledge, issue-focused instruction, and field-based pedagogy

• Defined methods of measuring student environmental literacy across grade levels and/or regions

• A robust implementation plan that outlines how the plan will be carried out, including securing long-term funding and support from the Virginia Department of Education and other stakeholders. 

Without these critical elements, the plan risks remaining aspirational rather than actionable. Strengthening these areas would better position Virginia to track progress, attract national funding, and institutionalize environmental literacy statewide.

2. Climate Change Education and Changing Weather Patterns

While the plan includes important content on environmental stewardship and sustainability, we recommend explicitly integrating climate change into the Environmental Literacy Framework and across the four goal areas. Virginia is experiencing more intense weather patterns, rising sea levels, and shifting seasons—all of which directly affect the ecosystems students are learning about. Specifically, coastal Virginia experiences the highest relative sea level rise rate on the eastern U.S. coast. This nationally significant risk is critical for students to understand as they navigate the highly local, and sometimes daily, implications of these climate-driven changes.

Specifically, climate change education could be embedded in:

• Goal 1: Network Cultivation (p. 17-19) through building capacity for climate education by modeling and leveraging partnerships with community-based organizations working directly with local climate issues;

• Goal 2: Educator Support (p. 20–23) through offering professional learning pathways focused on teaching local climate impacts;

• Goal 3: A Student-Centered Approach (p. 24–27) by using climate science as a context for MWEEs and interdisciplinary exploration;

• MWEE Framework (p. 12–13) by encouraging projects that investigate the local causes and consequences of climate change.

Creating intentional learning experiences in which students can explore, understand, and investigate climate-related issues in the local context reinforces the core objectives of environmental literacy, furthering a student’s ability to help preserve Virginia’s future by examining and stewarding the challenges directly around them. 

3. King Tides and Coastal Resilience in Environmental Learning

For students in Virginia’s coastal regions, king tides and sea level rise are becoming more frequent and can disrupt daily life and, in some cases, cause transportation issues. These visual and prevalent issues should be highlighted as case studies for MWEEs and other field-based investigations, offering students firsthand opportunities to observe and investigate local environmental change.

This aligns with:

• Goal 2: Educator Support (p. 20–23) through establishing supportive case study materials and community partnerships that highlight local environmental education providers and organizations working on local sea level rise and flooding adaptations;

• Goal 3 strategies for hands-on learning and real-world environmental challenges, particularly reinforcing a student’s personal connection with climate change;

• MWEE “Issue Definition” and “Outdoor Field Experiences” elements, leading to climate-related “Environmental Action Projects” (p. 12-13);

Incorporating regional examples like wetland loss, saltwater intrusion, shoreline migration, flood impacts to local infrastructure and community lifelines, and water quality degradation would strengthen the curriculum's relevance and support coastal resilience education.

4. Community Science as a Tool for Student Engagement and Knowledge Creation

We strongly recommend that the plan explicitly incorporate community science (also called citizen science) as a strategy for both student engagement and scientific learning. Community science empowers students to participate in real research while gaining skills and literacy in STEM concepts, and exists for many topics of interest from biodiversity tracking to water quality and king tide flood monitoring. 

This would enhance:

• Goal 1: Network Cultivation (p. 17–19) by encouraging schools to partner with and receive classroom training from environmental nonprofits, agencies, and platforms like the Sea Level Rise phone app, iNaturalist, or Virginia-centric apps like MapMyShore and ShoreWatch;

• Goal 3: Student-Centered Approach by adding a field-based approach for student participation in authentic data collection and analysis;

• Goal 4: Resources (p. 28–31) by providing students an opportunity to help optimize and contribute to real, local scientific research by submitting crowdsourced data to existing programs such as iSEE VA, MapMyShore, ShoreWatch, Catch the King, etc.

5. Nature-Based Solutions with Multi-Benefit Impacts

Virginia’s schools and communities stand to gain from a deeper integration of nature-based features—such as rain gardens, native plantings, living shorelines, bioswales, and tree canopies—into educational spaces. These installations provide hands-on learning opportunities while delivering environmental co-benefits like flood mitigation, improved air quality, habitat restoration, and student well-being. Students are valuable local stakeholders who may further enforce their personal connection to local solutions by being meaningfully involved in these features' design, installation, and stewardship practices.

These features could be:

• Incorporated in Goal 3 (p. 24–27) under student-led sustainability projects and environmental career pathways, especially for MWEE project opportunities;

• Highlighted in Goal 4 (p. 28–31) as assets for both local infrastructure and classroom instruction, supported by strategic mapping in iSEE VA and grant databases;

• Promoted through partnerships with local government and business partners as part of green infrastructure education.

6. Green career exploration and future workforce development

Providing Virginia’s students and educators with opportunities for professional development related to green industries is a quintessential element of sustainable environmental literacy. As one example, a train-the-trainer model and entry-level training opportunity is available through the Chesapeake Bay Landscape Professionals certificate program and is offered to high schools in Virginia. This certificate program (CBLP-Associates, or CBLP-A) is designed to introduce students to the concepts of nature-based stormwater practices and conservation landscapes, and build competencies for their design and implementation. CBLP-A also trains formal and informal educators as certified professionals and CBLP-A “partners” and provides classrooms with learning materials, green industry career opportunities, and local examples of adaptation.

This would enhance: 

• Goal 2 (p. 20-23) by providing opportunities for teachers to actively participate in learning opportunities that build understanding of local green infrastructure practices and best approaches;

• Goal 3 (p. 24-27) by creating pathways and credentials for high school students to access training and information related to local green career opportunities; 

• Goal 4 (p. 28-30) by offering mentorship and internship opportunities that support student career interests, and builds capacity for green school yard designs, construction, and stewardship.  

Conclusion
These enhancements would build upon the strong framework already present in the plan, ensuring that Virginia’s students are prepared to understand and respond to today’s most urgent environmental challenges with clarity, creativity, and civic purpose.

Thank you again for your commitment to advancing environmental literacy, and for considering these recommendations.

Sincerely,
Mary-Carson Stiff
Executive Director, Wetlands Watch

Reverend Dr. Faith Harris
Executive Director, Virginia Interfaith Power & Light

Leslie Anne Hammond
York River Steward