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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.

Special report for Puget Sound policymakers

2016-17 Special Report for Puget Sound Policymakers
Download the 44-page 2016-17 Special Report for Puget Sound Policymakers (PDF)

It used to seem easier to spot the polluters. There were the usual suspects: Industrial pipes pumped toxic chemicals into the water; dams blocked the way for salmon; natural resources were over-harvested. Those problems still persist, but ecosystem management in Puget Sound has become increasingly complicated since the 1970s and 1980s.
Scientists now recognize that what happens on the land is intricately tied to the health of the water. We face climate change and unprecedented population growth, and scientists have identified thousands of different human-caused pressures on the ecosystem. The headlines include new threats like stormwater, emerging contaminants and widespread declines in species and habitats. Given limited resources, how can managers and policymakers make informed decisions about where to focus their recovery efforts?
To help with this, we have created a new collection of stories from Salish Sea Currents. This is our second booklet of this type, and it includes reporting on new and emerging science that we believe everyone should read. The stories are wide-ranging, but, like an ecosystem, are connected in important ways.
We start with a look at the impacts of seals and sea lions on the region’s threatened Chinook populations. As many as one in five juvenile Chinook are eaten before they can migrate to open waters. That means many fewer are maturing to adulthood and returning to spawn. It also means significantly less food for the region’s endangered killer whales, which depend on Chinook for about 81% of their diet.
Seal vs Salmon. West End, Vancouver, BC. Photo: cesareb (CC BY-NC 2.0)
Seal vs Salmon. West End, Vancouver, BC. Photo: cesareb (CC BY-NC 2.0)

It is a classic illustration of the food web. Seals and sea lions have been increasing due to federal protections, but they have always had a healthy appetite for salmon. Are they the villains here, or is something else at play? Scientists suspect a variety of threats make the Chinook more vulnerable to what should otherwise be a normal pressure. Contaminants in the water as well as habitat loss from shoreline armoring are just two examples of threats that could be weakening Chinook, and we have several stories in this collection that intersect.
Not everything is bad news. We close out the collection with a story about the return of the harbor porpoise. Known as “the puffing pig,” the harbor porpoise had all but disappeared from Puget Sound in the 1970s due to factors like gillnetting and industrial pollutants. The species is still considered to be at risk in the Salish Sea, but its population is on the rise and it is hoped that Puget Sound cleanup efforts can ensure healthy numbers in the future. It is just one reminder that we can make a difference if we understand the ecosystem’s problems and their causes. Good science reporting can help to build that understanding, and we hope this collection of stories continues that tradition.
You can download the 44-page report as a PDF, or contact us if you would like a print version. We’ll also have many new stories in the coming months on the Encyclopedia of Puget Sound. Funding for the report was provided by the Environmental Protection Agency.