June 3, 2026
VIA ELECTRONIC SUBMISSION (Flood.Resilience@dcr.virginia.gov)
Matt Dalon
Resilience Planning Program Manager
Department of Conservation and Recreation
600 East Main Street, 4th Floor
Richmond, VA 23219
Dear Matt Dalon,
On behalf of Wetlands Watch, the Environmental Defense Fund, the Chesapeake Bay Foundation, Lynnhaven River NOW, and the York River Steward, we are pleased to submit the following comments on the Virginia Coastal Resilience Master Plan Phase II (CRMP). We want to begin by recognizing the significant work that the Department of Conservation and Recreation Office of Resilience Planning has invested in this Plan. Phase II represents a meaningful advance in the Commonwealth’s understanding of flood risk: the multi-source modeling, incorporating tidal, pluvial, and riverine flooding across five planning scenarios, is a substantial improvement in analytical scope. The expanded inventory of projects and initiatives enables a finer understanding of needs and readiness for flood mitigation across the coastal region, and the Technical Advisory Committee’s 20 recommendations provide a useful framework for future action. We acknowledge that these efforts have been gargantuan and appreciate DCR’s continued pursuit of public outreach under shifting political conditions. These efforts reflect a genuine commitment to the planning process, and we are grateful for them.
We offer the following recommendations to strengthen the current plan or suggest where the next planning cycle presents opportunities to go further. Additionally, we acknowledge that this report was initially drafted towards the end of 2025 and that its release was delayed. We observed that, throughout the report, some components seem out of date, while others have been updated. We recommend updating sections that have become outdated or at least acknowledging at the outset of the report that this delay may have resulted in some out-of-date statements being included in the report.
We look forward to continued collaboration as we help advance the Commonwealth toward a more flood-resilient future.
We appreciate that the CRMP was developed in alignment with the State Resilience Planning Principles for flood resilience established by the Coastal Resilience Master Planning Framework and codified in statute, and that these principles were called out in Chapter 1. We also note that throughout the report, the difficulty of adhering to the principles is repeatedly noted. Recognizing that the Commonwealth intends to lead by example by integrating flood resilience principles into decision-making processes, we recommend:
Using the Case Study callout format used throughout the CRMP, adapt and annotate key analytical and planning choices throughout the plan to explicitly show which State Resilience Planning Principles are being applied and how, making the principles operational rather than simply aspirational.
For example, expand the use of case studies to demonstrate how the principles are being actualized in practice. The Jamestown case study (page 43), for instance, focuses primarily on structural mitigation. We encourage DCR to complement or update that example to reflect other work underway at the site, such as the wetlands restoration, which more fully illustrates how principle III is applied at a historic site.
Use the forthcoming adaptive management plan as an opportunity to establish performance metrics tied to each of the five principles, so that future plans can demonstrate measurable progress against them.
The Plan explicitly declines to prioritize the projects and initiatives in the current inventory, citing limitations in data completeness and the absence of an adopted prioritization methodology. We understand that decision for this phase and hope the DCR Office of Resilience Planning, Floodplain Management Division, and the Virginia Office of Resilience can begin to lay the groundwork to develop a project-based plan in coordination with local and regional plans, as well as the statewide plan. We recommend that the Phase 2 report clearly articulate a stakeholder process and timeline that commit to a project-based plan and to the integration of local, regional, and statewide plans with the CRMPs. The adaptive management plan for implementation may be one pathway, but continued broad stakeholder engagement and transparency through published concepts and drafts in the early stages are critical.
Additionally, all opportunities should be taken in case studies or call-outs to clearly identify how projects were funded. For example, “federal funding” is often used when the specific program should be mentioned in addition to projects specifically funded by CFPF or other resources. This way, decision-makers can understand where former or current programs are having an impact, while localities and practitioners can expand their understanding of potential resilience funding resources.
The plan acknowledges that the Virginia Flood Protection Master Plan (VFPMP) is currently under development and notes that the Flood Resilience Advisory Committee (FRAC) will advise DCR on both the VFPMP and the CRMP. This coordination structure is a foundational step, though we recommend DCR to begin to build out data logistics and plan superstructures to support clear coordination, given that flood risk is not confined to the coastal zone, and how these plans work together has significant practical implications for communities across the Commonwealth. We recommend that DCR:
Publish a clear coordination framework on how CRMP and VFPMP will share data, align project inventories, and harmonize prioritization, and include in the CRMP the components relevant to Phase II here, or at a minimum, a commitment to do so in the VFPMP.
Clarify in this report how the FRAC will ensure both plans are held to the same planning principles and equity standards, and consider convening subcommittees that involve community, academic, and other subject-matter experts to work through alignment to capture more than the agency-to-agency coordination the FRAC primarily enables.
Consider and list future data needs and stewardship opportunities by developing a data management plan for CRMP, VFPMP, and future phases that connect the need for stormwater data.
We genuinely appreciate the Plan’s multi-source flood modeling and the acknowledgment on page 31 that compound flooding–the simultaneous or sequential occurrence of multiple flood drivers–has not yet been systematically evaluated and that future phases may address it. Analyzing compound flooding is a complex challenge that many states developing coastal flood resilience master plans are facing; combined flooding analysis does not fully capture the amplified and cascading risk that compound events produce, and this distinction warrants clear disclosure. Coastal Virginia faces precisely the conditions that produce compound events: high tides, storm surge, land subsidence, and intense precipitation increasingly coincide, and the combined scenario regularly diverges from the sum of individual flood drivers modeled separately. We recommend that DCR:
Include clear, non-technical language on the differences and similarities between the approaches used for combined and compound flood modeling.
Name compound flood modeling as a defined deliverable in the next planning cycle, with a scope, timeline, data needs, and identified research partners. If there are clear barriers to compound flood modeling in Coastal Virginia, that should also be acknowledged in this report.
Include consideration of groundwater flooding, where such data is available, in future plans, and incorporate it into compound flooding analyses
Incorporate “chronic flooding” occurring multiple times a year. This is a missing recurrence interval that would illustrate where true high-tide flooding is occurring and which communities are beginning to see tangible impacts of accessibility and infrastructure degradation. This could include an alignment with NOAA’s high tide flooding threshold per location, or incorporating a 1.5ft above MHHW threshold or similar metric.
Add a planning principle that acknowledges that no combination of structural or nature-based measures can eliminate all flood risk. Plans that omit residual risk accounting can generate false confidence in the adequacy of proposed solutions, particularly under higher sea-level rise scenarios. The adaptive management plan should establish how residual risk will be tracked and communicated over time.
Include an acknowledgment in the CRMP that there is significant uncertainty underlying the modeling (and inherent in all flood modeling) and in the structure damage estimates due to uncertainty in building inventories and depth-damage curves. Ideally, the CRMP could present estimates of damages and total economic impact in a way that conveys the lack of certainty–perhaps by using a range of potential cost figures rather than a specific figure.
Coordinate compound flood research with the Virginia Office of Resilience to leverage existing Virginia-based modeling experience.
Phase II primarily utilizes the CDC Social Vulnerability Index as its equity tool, creating a matrix to highlight those communities at highest flood hazard exposure and highest vulnerability. While the CRMP does use it to analyze flood impacts, an equity commitment expressed primarily through a mapping layer will not, on its own, ensure that the CRMP effectively serves the communities most exposed to flood risk.
Relatedly, the CRMP provides a valuable section on Virginia’s eleven federally- and state-recognized Tribal nations and highlights several Tribal flood resilience projects. We appreciate this attention and highlight the case studies for proactive flood resilience. We do note that because Tribal nations are sovereign governments with distinct legal standing, a single meeting with the EPA Regional Tribal Operations Committee may not be sufficient engagement (Appendix C). Future CRMP cycles should establish a sustained consultation process, co-designed with tribal input, that reflects Tribal sovereignty and builds an ongoing relationship that meaningfully co-creates and develops resilience strategies.
We recommend revising this report to reflect a true commitment to the Commonwealth resilience principle that emphasizes the need to identify and address socioeconomic inequities and work to enhance equity, as well as Virginia’s Environmental Justice Act, which states that it is the “policy of the Commonwealth to promote environmental justice and ensure that it is carried out throughout the Commonwealth, with a focus on environmental justice communities and fenceline communities.” For example, the CRMP should highlight specific examples of low-income and fenceline communities developing resilience plans and implementing projects, and provide a report on how many fenceline or low-income communities received technical assistance, submitted projects, or received services. The CRMP should also include clearly stated goals for improved outreach and engagement with these communities in future plans.
Phase II provides documentation of the extent, condition, and economic value of coastal Virginia’s natural infrastructure, including tidal wetlands, dunes, living shorelines, and subaqueous habitats. The CRMP’s documentation that natural and nature-based projects represent 20% of the projects inventoried is helpful and important context for understanding the current state of flood resilience investment in coastal Virginia.
These features are not just supplemental to Virginia’s flood resilience system; they are key components of it. Tidal wetlands slow coastal erosion and attenuate wave energy; forested buffers help absorb rainfall before it becomes runoff. Living shorelines stabilize the coastline and, in appropriate conditions, can migrate with sea-level rise to continue providing co-benefits. Recognizing that structural solutions dominate all Projects by Hazard except for “Shoreline Erosion” (p.72), there is a need to close the gap by making the case for co-benefits of nature-based projects more clearly and encouraging decision-makers to evaluate projects on more than cost-benefit analyses alone.
We recommend that DCR:
Expand existing case studies to capture more of the co-benefits of nature-based projects, such as water quality, carbon sequestration, fisheries habitat, recreational access, cultural value, and wave attenuation. Cost-benefit comparisons that account for only flood risk reduction systematically undervalue nature-based approaches relative to gray infrastructure.
Revise two sections that risk sending a misleading signal about the economic case for nature-based approaches. The first being the characterization of structural projects on page 71, which are “generally reported to be less costly,” which lacks citation and methodology, and conflicts with lifecycle cost research. The second being the framing of ecosystem services on page 56, which should lead with advances the field has made rather than its historical limitations, particularly given that the CRMP itself highlights the VIMS SHORE-BET tool in the Middle Peninsula right below.
Incorporate co-benefit valuation guidance throughout the tools and resources DCR makes available on the CRWE and Open Data Portal.