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

By Jeff Rice, Puget Sound Institute

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.