Shoreline armoring puts flood insurance at risk

Before and after composite view at the site of a 2013 bulkhead-removal project on the shore of Penrose Point State Park in Pierce County. Composite: Kris Symer, PSI; original photos: Kristin Williamson, South Puget Sound Salmon Enhancement Group

Before and after composite view at the site of a 2013 bulkhead-removal project on the shore of Penrose Point State Park in Pierce County. Composite: Kris Symer, PSI; original photos: Kristin Williamson, South Puget Sound Salmon Enhancement Group

Communities across Puget Sound must consider salmon-safe alternatives to shoreline armoring or risk losing their flood insurance, according to requirements established by FEMA’s National Flood Insurance Program.

The requirements stem from a Biological Opinion issued by NOAA in 2008 finding that shoreline armoring and other development in the floodplain (so-called “Special Flood Hazard Areas”) can damage critical salmon habitat. The opinion protects threatened Chinook salmon, Hood Canal summer chum and endangered Southern Resident killer whales which rely on Chinook for much of their food. Newly-permitted shoreline structures are expected to demonstrate “no adverse effect” on species listed under the Endangered Species Act. Exceptions are allowed in some cases where property is at risk or additional permits are issued, according to NOAA.

Compliance with the FEMA requirement is voluntary, but without the endorsement of FEMA, flood insurance can be more expensive or difficult to obtain.

Shoreline armoring includes a variety of shoreline structures such as bulkheads and seawalls that are typically created to stave off beach erosion. New science shows that these structures interfere with natural processes critical to beach function and diminish food and habitat for a variety of fish species.

“If you’re a fish, it’s like living in a neighborhood where there is no grocery store,” says Janet Curran, a biologist at NOAA Fisheries. [You can read more about shoreline armoring in our series “Rethinking shoreline armoring” in the Encyclopedia of Puget Sound.] “You could starve trying to find food.”

Charting changes in Puget Sound shoreline armoring length (2005-2015)

Charting changes in Puget Sound shoreline armoring length (2005-2015)

Curran says that the Biological Opinion sets a higher standard for shoreline use and development by adding an additional layer of regulatory protection. “I would not say that it’s going to stop all shoreline armoring,” she said, “but it strengthens the toolkit for salmon protection.” Currently, the Puget Sound region adds the equivalent of a mile of new armoring per year, although that number is offset by the removal of old armoring. About 25% of Puget Sound is classified by the state as armored.

According to FEMA, 122 Puget Sound municipalities such as counties, cities and tribal governments are potentially affected. FEMA doesn’t enforce shoreline armoring regulations or permits, but asks local communities to certify that they are in compliance. A “community” in this case is defined by FEMA as any local government or collective responsible for issuing a permit.

FEMA says that all 122 such groups are currently in compliance with the National Flood Insurance Program, but that the agency is working closely with some groups that need special help meeting the “no adverse effect” requirement for shoreline structures. The FEMA standards are more stringent than “no net loss” requirements for state permits, which allow for some impacts as long as they are mitigated.

There are several options for meeting the FEMA standards. Known as “doors”, these pathways include review of structures on a case by case basis, or satisfaction of a checklist of requirements that meet the equivalent of the Biological Opinion. If communities don’t meet the requirements, they can be placed on probation, which includes an additional charge of $50 per year for insurance premiums and a year to satisfy the requirements. If a community is out of compliance for more than a year, it risks suspension, which means it would be ineligible to participate in the National Flood Insurance Program.

Although local governments are responsible for their own enforcement, FEMA works to correct minor violations through what it calls “community assistance visits,” says John Graves, floodplains management and insurance branch chief at FEMA, Region 10. “It’s like a tune-up on your car — preventative maintenance,” Graves says.

Marine Shoreline Design Guidelines report cover

Marine Shoreline Design Guidelines report cover

The goal, Graves says, is to correct potential violations and satisfy the Biological Opinion, not to put people on probation or deny endorsement for flood insurance.

“We provide technical assistance,” says Graves, “and teach that there are alternatives to hard armoring.” Ultimately, he says, it’s up to the local communities to decide how they want to respond.  “You can’t do it solely on the back of the FEMA Flood Insurance Program,” he says. “We need to have people understand that hard armoring isn’t always the solution.”

FEMA and NOAA often refer communities and developers to the state’s Marine Shoreline Design Guidelines for information about salmon-safe shoreline development. Removal of shoreline armoring is designated as a key “vital sign” of Puget Sound health by the state’s Puget Sound Partnership. It is part of a new series of Implementation Strategies funded by the Environmental Protection Agency aimed at Puget Sound recovery.

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Removing Puget Sound’s ‘Great Wall’

before-afterCan we really wait 700 years to remove all of the armoring along Puget Sound’s shoreline? Let’s do some of the math.

Senior Writer Christopher Dunagan reports in Salish Sea Currents this week that armor removal now exceeds new creation by somewhat less than a mile per year. At first glance, that’s a good thing. It is a reversal in a 100-year trend that has added more than 700 miles of bulkheads and other anti-erosion structures to Puget Sound beaches. It happened for the first time in modern memory in 2014 and the trend continued in 2015. But consider that number: 700 miles.

In the simplest terms, less than a mile per year of net removal adds up to a timeline of more than 700 years. That doesn’t tell the whole story, of course. The fact is, not all of the region’s shoreline armoring is meant to be removed, nor should it be. Some of it is considered necessary. No one is expecting to breach the downtown seawall, or surrender endangered houses to the waves. But it does give a sense of the scale of the project.

Recent peer-reviewed studies show that armoring clearly and unambiguously causes damage to the ecosystem, giving increasing urgency to the need to remove it wherever possible. Just how much of it is vital and how much can stand to be removed or replaced with more environmentally sensitive structures is not yet clear, but what is clear is that 700 miles of it — more than 25% of Puget Sound’s shoreline — is hurting the environment. Put another way, 700 miles adds up to a ‘Great Wall’ stretching further than the ocean-facing coasts of Washington and Oregon combined. It’s going to have an impact.

So why not just get rid of it? That’s easier said than done. For example, between 2012 and 2016 the state of Washington, with support from the EPA, spent about $8 million dollars on seven armor removal projects. They were just some of the many such projects underway across the region, but were bundled together as part of a series of grants from the state’s Marine and Nearshore Grant Program [also a funder of some of the work at the Puget Sound Institute]. Those projects did more than just remove concrete bulkheads. They restored beaches and in some cases added new ‘softshore’ structures that took the place of more damaging ones. But simply measured by linear feet, total armoring removal in those projects added up to less than a mile. It is clear that it will be difficult and expensive for state and federal agencies to simply engineer their way out of the problem, and those agencies recognize that other strategies have to be considered as well.

One approach is to look at where most of the armoring is occurring. Studies show that about 57% of Puget Sound’s shoreline is privately owned, and that is where the state believes much of the change will happen. State-sponsored efforts such as Shore Friendly provide information to shoreline owners and building contractors on alternatives to armoring. The state is also looking at ways to ramp up enforcement against un-permitted, illegal shoreline armoring. Removal numbers may be modest so far, but the hope is that once the roller coaster crests the hill, it will start to roll faster down the other side.

Read our series ‘Rethinking shoreline armoring’ for more background.

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PSI armoring report featured on KUOW

KUOW's John Ryan interviews Aimee Kinney about the ecological impacts of shoreline armoring.

KUOW’s John Ryan interviews Aimee Kinney about the ecological impacts of shoreline armoring. Photo by Jeff Rice.

KUOW interviewed PSI’s Aimee Kinney today about the impacts of shoreline armoring on the Puget Sound ecosystem. Kinney was the lead author of an analysis report of recent nearshore studies funded by the Washington Department of Fish and Wildlife. New studies reveal that shoreline armoring degrades beach ecology and hurts Puget Sound species like forage fish and salmon. Read the analysis report on the Encyclopedia of Puget Sound.

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Sources of sand: maps show crucial ‘feeder bluffs’

Feeder bluff and beach at Fort Flagler Historical State Park. Marrowstone Island, WA. Photo: Kris Symer (CC BY-NC-ND 4.0)

Feeder bluff and beach at Fort Flagler Historical State Park. Marrowstone Island, WA. Photo: Kris Symer (CC BY-NC-ND 4.0)

For more than a hundred years, property owners have seen shoreline erosion as the enemy. They have battled it with startling amounts of concrete and have lashed together so many protective beach structures that about a third of Puget Sound’s shoreline is now classified as armored. It’s a fitting term for this longstanding battle against the elements. But it turns out that in many cases erosion is actually a good thing—crucial, according to scientists— because it provides the sand and gravel needed for healthy beaches. Now environmental agencies are encouraging the removal of bulkheads or their replacement with more natural erosion controls. New maps identify locations where bulkhead removal is likely to provide the greatest ecological benefits.

Read the final installment of our series on shoreline armoring in Salish Sea Currents on the Encyclopedia of Puget Sound. 

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Studies show high amounts of illegal shoreline armoring

Chart: Local shoreline changes in King County (2012-13). Source: King County, 2014

Chart: Local shoreline changes in King County (2012-13). Source: King County, 2014

Our series on shoreline armoring continues today with two new stories. Studies show that a significant number of shoreline structures are being built illegally without required permits. We also report on efforts to educate shoreline property owners about alternatives to environmentally-damaging concrete bulkheads.

Read these stories and others from the series in the Encyclopedia of Puget Sound.

 

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Series looks at shoreline armoring

Storm surges against the bulkheads protecting beach houses at Mutiny Bay, WA. Photo: Scott Smithson (CC BY-NC-ND 2.0) https://www.flickr.com/photos/dtwpuck/15725058917

Storm surges against the bulkheads protecting beach houses at Mutiny Bay, WA. Photo: Scott Smithson (CC BY-NC-ND 2.0) https://www.flickr.com/photos/dtwpuck/15725058917

Our online magazine Salish Sea Currents launches a six-story series today focusing on shoreline armoring in the Puget Sound region. Close to a third of Puget Sound’s shoreline is classified as armored with bulkheads and other structures meant to hold back storm surge and erosion. But new studies reveal the often significant toll this is taking on the environment. The series kicks off with a look at armoring’s impact on beach ecology and forage fish habitat.

Read the series on the Encyclopedia of Puget Sound.

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The question of unpermitted shoreline armoring in Puget Sound

Chart: Local shoreline changes in King County (2012-13). Source: King County, 2014

Chart: Local shoreline changes in King County (2012-13). Source: King County, 2014

Last year, we reported on an exciting trend related to shoreline armoring in Puget Sound. For the first time, state agencies actually noted a decrease in new armoring in which removal of these controversial beach structures outpaced new permits for development.

That was good news for state and federal agencies trying to reverse more than 100 years of near constant development along Puget Sound’s shoreline. Armoring such as seawalls, bulkheads, revetments and the like is meant to protect beaches and property from erosion, but increasingly, the science shows that such structures harm the ecology and in many cases are simply unnecessary.

That’s why the Puget Sound Partnership has set removal of armoring as a key recovery target, and its 2014-2015 Action Agenda seeks a net loss of these structures by 2020. From that perspective, the figures showing a decline in permits in 2014 seemed to be heading in the right direction. There was little debate on the numbers. In 2014, permits showed that 1,530 feet of armoring was constructed in the 12 Puget Sound counties. Meanwhile 3,710 feet of armoring was removed. That’s a significant decline—more than 2 to 1—that had not been seen in the region in modern times. But the story gets more complicated.

While the decline in permits may be accurate, it doesn’t take into account the number of un-permitted structures. New studies funded by the EPA’s National Estuary Program show that unauthorized construction may be more of an issue than previously thought. Research conducted in two Puget Sound counties identified un-permitted armoring in up to half of the study sites, while many of the permitted structures were found to be out of compliance. The study’s authors say they are cautious and that more work needs to be done—2 out of 12 Puget Sound counties is far from an exhaustive survey, they say—but the results do raise some questions. Among them: Just how much shoreline armoring is not being counted across Puget Sound, and how significant are the permit violations?

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