The CRMP notes several important regulatory milestones in Chapter 1 (pp. 8-9): the Chesapeake Bay Preservation Act (CBPA) was amended to incorporate sea-level rise considerations and to include a new purpose focused on coastal resilience and climate adaptation; and VMRC updated the Tidal Wetlands Guidelines in 2021 to designate living shorelines as the preferred approach for shoreline stabilization. These are meaningful advances, and we are pleased to see them in the timeline of Virginia resilience history. However, having documented these regulatory changes, the CRMP does not follow through to explain how they should shape flood resilience planning in practice.
The CBPA and Wetlands Act are the two primary regulatory frameworks governing development and shoreline management in coastal Virginia. Their influence extends directly into flood resilience decisions this plan is designed to inform. The CBPA’s resource protection area buffers, for instance, preserve the vegetated upland buffers that slow rainfall-driven runoff. As sea levels rise, the landward migration of tidal wetlands will bring more upland areas under VMRC jurisdiction, creating a boundary between CBPA and Wetlands Act that local Wetlands Boards will need clear guidance on how to navigate. The CRMP’s own marsh gains and losses section makes this jurisdictional shift visible in the data, but does not connect it back to the regulatory framework that will govern how it is managed on the ground.
The living shorelines policy shift also deserves more prominent treatment as a coastal flood resilience tool. Since 2020, living shorelines have been the preferred alternative for tidal shoreline stabilization statewide, and the CRMP notes that an increase in living shoreline projects has resulted. This is a direct example of regulatory policy driving nature-based flood resilience outcomes in Virginia. The CRMP should recognize that the VMRC’s guidelines, CBPA amendments, and the CRMP are part of an integrated regulatory and planning ecosystem, and that their combined effect on flood resilience is greater than that of any single instrument. With the recent passage of HB237 in 2026, marsh migration corridors will need to be identified in the CRMP. We recommend that DCR:
Connect the marsh migration analysis explicitly to the CBPA and Wetlands Act regulatory context, noting that rising seas will shift jurisdictional boundaries and recommending that DCR, VMRC, and DEQ develop coordinated guidance for local boards and government staff managing permits at this evolving interface.
Revise the timeline (pp. 8-9) to note that the General Assembly passed SB 776 in 2020, which modified the Wetlands Act to both require living shorelines as the default shoreline stabilization technique unless it is unfeasible and to require sea level rise standards to be applied to shoreline stabilization practices, and that VMRC issued Tidal Wetlands Guidance in 2021 (not 2020).
Incorporate CRMP flood hazard data into guidance materials for local Wetlands Boards, Planning Commissions, and other decision-makers, so that the CRMP’s sea-level rise projections and multi-source flooding analysis are readily accessible to all available to the permit-level decision-makers applying these regulatory standards at the project scale.
Include in the adaptive management plan explicit recommendations for continued alignment between the CBPA, Wetlands Act, and CRMP, including guidance on how resilience-oriented permit review can reduce the cumulative flood risk in the CRMP.
DCR’s outreach for Phase II was more structured and broad than prior planning cycles, and the TAC’s Outreach and Coordination subcommittee recommendations provide a framework for future engagement. We encourage DCR to build on this foundation in ways that deepen reach into underserved communities.
We recommend:
Leverage the VOR’s university collaborative and research partnerships to design, implement, and evaluate engagement processes, with particular attention to populations with high flood risk and low planning capacity who have not been well-represented in the CRMP engagement to date.
Continue to partner with regional and local partners, including PDCs and trusted community organizations as primary engagement intermediaries for future plan cycles, both for community outreach and supporting local planning processes. Since HRPDC member localities are already required to incorporate sea-level rise impacts into their comprehensive plans and SWCDs are developing watershed plans that draw on the same data that the CRMP contains, we see an opportunity for DCR to position the CRMP as a resource for these required local planning efforts, ensuring that planners and district staff know how to use its projections and inventory in their own work.
Ensure future engagement timelines are aligned with technical deliverable timelines, so that community input can meaningfully shape analytical choices rather than occurring after those choices have been made
Outline the extent of Technical Assistance provided from the publication of Phase II until now, and discuss future needs while acknowledging that this may require additional staff.
We recognize that strategic relocation and managed transition are among the most difficult conversations coastal planning asks of communities. We recognize these are genuinely complex topics to address in a public planning document. In Chapter 4, Phase II notes the Commonwealth’s role is first to lead by example, embracing three core resilience strategies of protection, adaptation, and relocation. Focusing on relocating state-owned facilities is understandable and notes the state’s role in relocating state-owned facilities outside of flood risk areas.
We see an opportunity to reframe and expand the paradigm of strategic relocation. Tidal marsh migration is already discrete and visible evidence of a changing coastline, and we believe it can serve as a constructive entry point for community and state conversations about long-term transition, one that begins with what people can observe in their own backyards. As a proxy for future potential flooding conditions, tidal marsh migration serves as both a signal and a tool for reducing flood risk in the Commonwealth. Through other tools and mechanisms, like conservation easements and acquisition programs, connecting an observable ecological process can become an actionable and community-driven planning opportunity. We recommend that DCR:
Expand the treatment of managed transition and relocation in future plan cycles beyond state-owned facilities and emphasize the need for meaningful conversations about relocation can only occur in a sustained partnership with affected communities at the speed of trust.
Frame the tidal marsh migration as both an ecological process and a community planning signal, one that creates opportunities for proactive conversations about land use, conservation, and voluntary relocation before flood risk forces the issue.
Connect the marsh migration analysis to the financial mechanisms and land management tools that would need to be in place for voluntary relocation to be a real option for households and communities, such as the CFPF and RVRF, and updates to the CRWE with relevant data as soon as possible before the next CRMP update is necessary.
Revisit a landscape analysis of strategies, approaches, and case studies that have been deployed in other regions addressing these complex topics.
The CRMP is a comprehensive technical document well-suited to planners, engineers, and researchers. It is less accessible to the residents most affected by flooding and to local elected officials who make the budget and land-use decisions that determine whether flood-resilience investments actually happen. A state plan is only as strong as the localities working toward the same state goals and resilience planning principles through smart local planning and policy. Developing additional materials will support localities, particularly those with lower capacity, and build support and buy-in for the plan. Converting planning data into political will and capital investments requires meeting decision-makers where they are at. We recommend that DCR develop:
A plain-language public summary, in multiple written and online video formats, that conveys the Plan’s key findings on flood risk, the scale of the economic consequences, and the most actionable step communities can take, written for a general audience without technical prerequisites.
A briefing document providing local elected officials with a concise, two-to-three page summary of flood risk in their specific jurisdiction, the status of local projects in the CRWE inventory, and a clear statement of what state programs and resources are available to them.
Stronger data portal integration throughout the CRMP, using QR codes and hyperlinks to connect statements and findings directly to their underlying data sources in the CRWE/Open Data Portal/Appendices, reducing the distance between the findings and the evidence behind them.
A commitment to translate future plan documents and summary materials into languages spoken by coastal Virginia residents with limited English proficiency, ensuring that the people most exposed to flood risk can access and engage with the planning process in their own language.
We also note a procedural issue that affects the utility of the CRMP for other planning uses. The CRMP will carry a Summer/Fall 2026 release date, but it contains data from earlier effective dates. We recommend that this and future phases include an explicit statement of both the release date and the effective date of the data/analysis in the plan, so that localities, planners, and others can accurately represent the information they rely on.
Phase II is the second iteration of the CRMP, building on the Planning Framework and Phase I, and is a genuine accumulation of data, modeling, and planning experiences. That foundation is something to be proud of, and we encourage DCR to let the confidence of that record show more clearly in the Plan’s language. In some places, generalized statements using “may” and “could” are used when the evidence base would support stronger, more useful guidance for localities and decision-makers. Where uncertainty remains, we think being specific about its nature and source is actually more helpful than hedged language. For example, using clauses like “it is likely” or “future data collection on X will allow us to determine whether” gives readers a clearer sense of what is known, what is expected, and what still needs to be learned. We also recommend:
Revise many of the CRMP’s data visualizations to improve general data literacy and accessibility. Several graphs use percentage-based y-axes in ways that are likely to be misread by non-technical audiences, especially given that they have absolute acreage values as data labels. It can be difficult to discern the relationship between percentages and absolute acres for one of the many planning scenarios. Clear labeling, plain-language annotations, and, where appropriate, absolute values alongside percentages would make the CRMP findings more legible to a diverse range of audiences it needs to reach.
We recognize that the clustered bar graphs were probably selected to show multiple scenarios over each of the coastal PDCs in order to reduce page space; the clustered nature of the bar graphs often makes it difficult to read what the difference is between scenarios. We advise asking whether the takeaway from a clustered bar graph is working, or whether the information is better represented as a combination of graphs and tables.
The CRMP is a strong foundation for the Commonwealth’s continued flood resilience work. The multi-source modeling, expanded CRWE projects and initiatives inventory, and the Open Data Portal all represent an excellent step forward in better understanding Virginia’s flood risk exposure and where the Commonwealth needs to position itself for the next planning cycle and for the development of the statewide VFPMP.
The comments we have offered reflect our shared investment in seeing this work succeed. The state resilience planning principles are leading towards a more resilient future, and the data infrastructure DCR has built is substantial to track progress towards those principles and goals. The undersigned organizations remain committed to partnering with DCR in this work. We invite meetings to discuss our comments in more detail, and we stand ready to support engagement, technical review, and public communication efforts as the Commonwealth advances toward the VFPMP and the next CRMP cycle.
Sincerely,
Mary-Carson Stiff, Executive Director
Wetlands Watch
Leslie Anne Hammond
York River Steward
Dylan Mason, Public Policy Manager
Lynnhaven River NOW
Emily Steinhilber, Director, Flood Resilience
Environmental Defense Fund
Jay Ford, Virginia Policy Manager
Chesapeake Bay Foundation
Morgan Butler, Senior Attorney
Southern Environmental Law Center