The staff of the Hampton Roads Planning District Commission (HRPDC) appreciates the opportunity to provide comments on the Virginia Coastal Resilience Master Plan (CRMP) Phase II, which was posted for public comment by the Department of Conservation and Recreation (DCR) on May 4, 2026. Our comments reflect the views of the HRPDC staff and incorporate feedback from our member jurisdictions and other regional stakeholders. We respectfully request DCR’s consideration of the following comments.

The HRPDC staff appreciates the efforts DCR has put into completing the CRMP Phase II. However, developing a single comprehensive plan that is simultaneously intended for multiple audiences, including decision-makers, technical staff, and the general public, is a challenge. We recommend that DCR consider developing additional products for specific audiences, both for the current plan to assist in its implementation and for future CRMPs. Additionally, we recommend that DCR develop and implement a stakeholder engagement process that would allow for additional time to review and provide input to CRMP scoping and products before the required public comment period. This would allow for improvements to be made prior to substantial completion.

The CRMP Phase II improves on the coastal/tidal flooding analysis from the CRMP Phase I by adding both pluvial and fluvial flooding. In particular, the pluvial flood modeling, which incorporates future increases in precipitation, will be of significant value to local governments. However, the pluvial analysis is limited by the absence of stormwater infrastructure, which is critical to account for in urban areas. Incorporating stormwater infrastructure into these models would be a substantial improvement in the next CRMP. In addition, the next CRMP should also account for potential changes to riverine flooding from climate change, which is not addressed in the current plan, and incorporate compound flooding analysis instead of combined flooding analysis. The CRMP Phase II should address these deficiencies and identify potential paths forward to address them. One specific step that DCR should consider is whether to become a Cooperating Technical Partner (CTP) with the Federal Emergency Management Agency (FEMA), which would allow for the Commonwealth to improve flood hazard mapping that would benefit both coastal and statewide planning efforts and local floodplain management programs.

Coastal Virginia is a diverse area, so developing and communicating metrics that accurately and meaningfully apply to communities from the Eastern Shore and Middle Peninsula to Hampton Roads and Northern Virginia is a challenge. However, although using percentages may seem like an effective way to convey and compare impacts to the various subregions of Coastal Virginia, this minimizes the actual impacts to population, structures, or areas affected. The HRPDC staff recommends that figures throughout the CRMP Phase II use actual units of measurement as opposed to percentages as the y-axis on charts and figures.

We appreciate the assessment of the Commonwealth’s role in flood resilience included in Chapter 4. However, several key responsibilities are missing. Specifically, the Commonwealth’s role in funding resilience improvements is not included, although it is referenced in the plan in discussions of the Community Flood Preparedness Fund (CFPF). The lack of recognition for the importance of state funding beyond the CFPF and the continued lack of direct coordination between the CRMP and CFPF is a missed opportunity to better address the Commonwealth’s resilience challenges in a more strategic way. Similarly, the chapter omits discussion of the state’s role in supporting and promoting innovative practices through both funding and regulatory programs. In particular, the lack of discussion of the application of beneficial use of dredge material or marsh enhancement, along with other innovative, nature-based approaches, is a gap that should be addressed.

The climate planning scenarios developed for the CRMP Phase II, which account for both future sea level rise and precipitation along with risk tolerance, are a significant improvement over the scenarios used in the Phase I report. In particular, the inclusion of scenarios for less and more risk tolerance is a welcome addition. We appreciate this development and recommend that DCR build on this by incorporating projections for changes to riverine flood risk and compound flood risk.

The HRPDC appreciates the efforts that DCR and its consultant team have put into developing the CRMP Phase 2. The plan represents significant investments in both time and resources by the Commonwealth and by stakeholders, including local governments and planning district commissions, and serves as an important milestone in the Commonwealth’s progress towards building and supporting more resilient coastal communities. We appreciate the leadership of DCR in this effort and look forward to working with the Department on its implementation.

Sincerely,

Benjamin J. McFarlane

Chief Resilience Officer

Hampton Roads Planning District Commission