I have concerns with the current Virginia Floodplain Management Standards as adopted. While they are framed as a step forward, they fail to address the most critical gaps in Virginia’s flood resilience and risk management. These standards read more like administrative guidance than a functional framework for protecting people, property, and infrastructure from today’s and tomorrow’s flood threats.

The standards apply primarily to state-owned or leased properties, leaving the vast majority of Virginians’ homes, businesses, and local infrastructure outside their direct reach. Flooding doesn’t respect property boundaries, and rules limited to state facilities won’t meaningfully reduce statewide risk.

Also, the standards rely heavily on FEMA-style flood maps and historical rainfall data. This is dangerously outdated. They do not require climate-adjusted precipitation, sea-level rise allowances, or compound flood event analyses. By ignoring non-stationarity, these standards will lock Virginia into under-designing critical infrastructure for decades.

There is no clear funding mechanism tied to these new requirements. Agencies are told to comply, but without guaranteed capital, they will value-engineer resilience out of projects. There’s also no strong accountability framework, no measurable performance metrics, no public scorecards, and no meaningful consequences for noncompliance.

Local governments remain on a separate, patchwork system of ordinances and voluntary programs. State standards don’t compel local alignment, which guarantees uneven application and gaps right where flood risk is highest.

These standards miss an opportunity to target investments and protections for the most flood-vulnerable communities, which are often lower-income or historically underserved. Without clear priorities and requirements, the communities most at risk remain least protected.

In short, the Virginia Floodplain Management Standards is document is long on process and mapping tools, but short on enforceable, future-focused design requirements. It neither funds nor mandates the level of action Virginia’s growing flood risk demands. If adopted as-is, it will amount to little more than a policy collecting dust while storms intensify, sea levels rise, and communities bear the cost.

I urge DCR and the Administration to revise these standards to:

• Mandate climate-adjusted rainfall and sea-level rise data for all projects.
• Tie compliance to funding. No state dollars without proof of conformance.
• Require annual agency performance reporting.
• Issue a model local ordinance with mandatory higher standards like climate-adjusted rainfall (Atlas 15, Volume 2) to close the local-state gap.
• Integrate pluvial and compound flood risks into all reviews, not just mapped zones.

Anything less is not resilience.