Thank you for the opportunity to comment on the Draft Virginia Coastal Resilience Master Plan (VRCMP) Phase II.

Overall, we believe the draft provides a strong foundation for advancing flood resilience across the Commonwealth. Future iterations would benefit from a stronger focus on implementation and governance, including clearer prioritization methods, coordination across state agencies and related planning efforts, measurable accountability, and the broader policy implications of adaptation, infrastructure investment, and long-term community resilience.

We appreciate the inclusion of riverine, coastal, and pluvial flooding in the Phase II document, which helps address flooding outside traditional FEMA flood hazard areas, particularly in urbanized regions. However, limitations in the pluvial analysis, including the absence of stormwater infrastructure data and the lack of compound flooding considerations, may lead to an underestimation of flood risk in these areas. The plan would be strengthened by discussing how these issues will be addressed in future iterations. Specifically, the document should clarify whether stormwater infrastructure data will be incorporated into future pluvial analyses, how compound flooding will be addressed in future updates or related planning efforts, and whether interim measures or parallel efforts are underway to help address these gaps in the meantime.

Relatedly, the plan would benefit from further discussion of its alignment and integration with other state planning documents, such as the VDOT Resilience Plan, and from explaining how Phase II and future updates will be implemented in coordination with other state planning processes. While coordination among state agencies is expected to be a core component of the Virginia Flood Protection Master Plan, the CRMP Phase II could more clearly define the current and anticipated roles of these agencies in implementing the plan’s recommendations and addressing potential analytical gaps.

We also appreciate the plan’s recognition of ongoing local and regional efforts to incorporate climate change projections into infrastructure design. However, the discussion of design guidance should be more specific, particularly in acknowledging that this work is fundamentally a response to the current lack of authoritative precipitation data from NOAA. More clearly identifying the challenges local governments are facing, as well as the steps they are taking to address these information gaps, would strengthen the plan and better convey the urgency of this work.

This discussion also presents an opportunity to emphasize the value of integrating resilience considerations into existing and planned infrastructure investments. Capital improvement and flood mitigation projects should not be viewed solely as municipal expenditures, but as proactive investments that reduce future damages, infrastructure losses, emergency response costs, and long-term financial burdens on communities. Incorporating resilience measures into routine infrastructure upgrades and related projects can produce significant cost savings while improving overall community resilience.

Lastly, the plan should more directly address the level of effort required to pursue and manage available funding streams. Current programs can impose a significant administrative burden on local governments, particularly those with limited staff capacity and technical resources. The plan should prioritize ensuring that the Community Flood Preparedness Fund (CFPF) is administered effectively and efficiently, rather than emphasizing loan programs that remain out of reach for many communities.

Thank you again for the opportunity to provide comments on the draft plan. We look forward to continued engagement in this process and remain committed to supporting the Commonwealth’s efforts to build a more resilient future for Virginia communities.

Respectfully,