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. 

Previous rounds of CFPF have included a match waiver up to $50,000 for low income geographic communities. This provision allowed localities in our regional footprint to access critical funds they otherwise would not have been able to for capacity building and studies. This is the largest CFPF round yet--why remove something that helps to level the playing field across localities? Please consider amending this year's manual to reinstate the match waiver request for low income communities. 

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. 

Planning District Commissions have previously been eligible to apply for project funding, while this manual restricts PDCs to CB/P and Studies applications. PDCs apply for project funding when localities do not have appropriate capacity, or in instances of cross-jurisdictional projects/initiatives where the PDC is the entity best-suited to manage. This is particularly pertinent for PDCs with resilience plans, and those who may be interested in developing regional resilience plans, as this provision may discourage them from doing so. We appreciate the note about PDCs acting as 3rd party administrators and feel that should remain an option for those who would like to go that route. Please consider allowing PDCs to apply directly for project funding.