NFPPR COASTAL SECTION L 11-18-14
(by category, including beach nourishment)
Recommendations
FUNDING
Explanation/rationale
1. Federal funding agencies should provide
preferential support (grants and cost share) and
other incentives to states & localities that adopt
land use management policies that incorporate
strategic retreat from eroding shorelines.
(FEMA, NOAA, ACOE, HUD)
Funding conditions should require all coastal states to
plan for sea level rise and develop and implement a longterm plan to prevent future development and relocate
existing development from high-risk low-lying areas
vulnerable to sea level rise and other coastal flood and
storm hazards. Preserve these areas for natural floodplain
functions, natural resources, and public recreation.
2. Federal and state funding and regulatory
decisions to armor shorelines should include an
evaluation and assignment of long-term costs
to mitigate potential adverse impacts of
armoring, including erosion and scour, and loss
or degradation of environmental services.
(ACOE, NOAA, State CZM)
3. Federal funding agencies should provide
more funds for acquisition of property and/or
easements on barrier islands, and leverage
existing funds after a disaster. Consider how
funding may be used to offset short-term
financial impacts of acquisitions on developed
communities.(FEMA, NOAA, ACOE)
Agency decisions should consider potential adverse impacts
of armoring and identify actions and funding sources that
may be required in the future to mitigate these adverse
impacts.
4. Federal funding agencies should increase
funding for programs designed to improve
public awareness of natural resource functions,
coastal risk, storm preparedness, and
evacuation. (FEMA, NOAA, ACOE)
Public awareness of natural hazards and the benefits of
natural systems in mitigating these hazards is critical to
facilitating better regulatory and funding decisions at all
levels.
More funding should be directed to acquisition of vulnerable
barrier island properties to provide long-term mitigation and
reduce repetitive loss and public disaster recovery
expenditures.
POLICY AND PLANNING
5. Federal agencies should establish a national Planning and associated policy decisions need to account for
policy to consider expanded coastal changing conditions in the future in order to reflect the most
management planning horizons (e.g., 50, 100 cost-beneficial actions and investments over the long-term.
years) that account for: (1) a realistic estimated Conservative assumptions should be applied to address
lifetime of a given action/investment; (2) the uncertainties and promote more sustainable solutions.
long-term, cumulative impacts and costs of
erosion, sea level rise, subsidence, and changes
in storm intensities and frequencies over that
timeframe; and (3) explicit consideration of
uncertainty in both the hazard information and
other factors that can lead to premature loss of
the resource or investment. Also see A.3
NFPPR Rec and rationale
Page 1 of 11
draft 11-18-14
(NOAA, FEMA, ACOE, HUD)
6. Federal and state mitigation projects should Structural solutions intended to protect people and property
avoid the use of hard structures to protect along vulnerable coastal and riverine shorelines should
shorelines and riverbanks unless No Adverse demonstrate that adverse impacts will be avoided or
Impact (should we include a link or footnote minimized.
for those who don’t know what NAI is?) can In order to reduce potential adverse impacts which often
be demonstrated. In order to support resilience result from structural solutions, nonstructural and natureover the long term, Federal funding programs based solutions should receive funding priority.
should give preference to strategic retreat or
natural/nature-based mitigation approaches, or
combinations thereof. (FEMA, ACOE, NOAA,
State NFIP and CZM Programs)
7. Federal and state agencies should plan,
design, build and retrofit highways and other
transportation networks to meet current and
future community needs to effectively evacuate
the population in events up to and including
the 0.2%-annual-chance event. (FHA, DOT,
FEMA, HUD)
8. Federal agencies should require
comprehensive planning for coastal
acquisitions to ensure that acquired lands are
dedicated to resource restoration and
enhancement to increase level of natural
protection, and to promote public access to
public lands.(NOAA, FEMA, ACOE)
9. Flood and storm warning and evacuation
plans should be tested annually and involve
local governments, businesses and the general
public to improve public awareness.( FEMA,
State OEMs)
10. National Estuarine Research Reserve
provisions should be modified to allow
acquisition of uplands to facilitate landward
migration of wetlands, restoration of protective
dunes and natural systems, and preservation of
floodplains. (NOAA)
11. Through a periodic review of programmatic
activities, federal agencies should enhance
their interagency coordination, and
coordination with coastal states, to better
integrate coastal zone, floodplain and
emergency management programs and to
identify actions to align programs and goals.
NFPPR Rec and rationale
Given the critical importance of storm evacuation, mitigation
of future flood and storm impacts to a higher standard should
be a primary consideration of all roadway projects.
Restoration of preserved lands will provide enhanced
ecosystem services and mitigation benefits.
Public use and enjoyment of these preserved lands will
advance efforts to acquire and restore property for public
benefit.
9(b) Regular testing of storm warning and evacuation plans
will ensure greater levels of compliance.
Expanding the acquisition program will enhance the
protective capacity of natural systems and help mitigate
adverse impacts of floods and storms.
Conflicting goals and priorities between agencies often
impede progress on the implementation of cost-effective
mitigation activities.
Reconciliation of program priorities will enhance efficiencies
and promote more effective long-term solutions.
Page 2 of 11
draft 11-18-14
(NOAA, FEMA, ACOE, EPA)
MAPPING
12. Coastal flood maps should be improved by
integrating bathymetric and topographic maps
to show additional hazards, including storm
surge, wave runup, overland waves, tsunamis
(where applicable), erosion areas and increased
water surface elevations from future
conditions. X-ref to other sections (FEMA)
13. All erosion hazard areas, both coastal and
riverine, should be delineated on FIRMs in
order to increase awareness of erosion hazards
and vulnerability among property owners, local
governments and developers. Move or Xref to
other sections (FEMA)
14. Erosion hazards should be mapped on
FIRMs and communities should be required to
manage coastal erosion hazards just like
flooding, in order to qualify for Federal flood
insurance. X-ref this with similar rec’s in
other sections-LL (Congress, FEMA)
15. The LiMWAs should be delineated on all
coastal flood maps and enhanced design
standards should be adopted for construction of
new buildings in these areas. (This is both
mapping and regulation) See A 21 latter is
covered elsewhere (FEMA)
REGULATIONS
16. Communities exposed to coastal flood
hazards should adopt floodplain ordinances
requiring a construction freeboard standard of
3 feet which accounts for: (a) the projected
future increases in sea level that are based on
the best-available historical local relative sea
level rise projection published by the National
Oceanographic and Atmospheric
Administration; (b) full build-out of the
watershed; and (c) other future conditions that
will exacerbate flood hazards. (FEMA, States,
local municipalities)
17. A coastal A Zone definition should be
developed and adopted in the CFR. See F.22
(FEMA)
18. Enforcement of the protection of dunes and
mangroves as required in NFIP regulations
should be enhanced. (FEMA, States)
NFPPR Rec and rationale
Inclusion of additional hazard data on coastal flood maps will
promote greater awareness of the range of hazards and
result in better decision-making at the state and local level.
Coastal and riverine erosion presents a significant hazard that
should be recognized on FIRMs to enhance awareness and
promote better decision-making at the state and local level.
Erosion presents a significant hazard that often results in
significant damage to coastal buildings. Requiring erosion
hazard areas to be mapped and communities to manage
development in erosion hazard areas will help mitigate storm
damages and associated public recovery costs.
Buildings located within areas subject to LiMWAs are
vulnerable to scour and erosion from moderate wave action
which results in foundation damage and failure. Mapping this
hazard will increase awareness of damage potential and
adoption of enhanced design standards will help mitigate
structural damages.
A three-foot freeboard requirement for building construction
will mitigate future damages to structures from flood and
storm events that exceed the minimum standards by
accounting for higher flood heights over time. The relatively
small additional construction cost will be offset by reduced
damages and associated recovery costs.
Coastal A zones present unique hazards that should be
defined and specifically regulated under the NFIP to mitigate
hazards in these areas.
Dunes and mangroves provide significant protection to
people and property in coastal areas and strict enforcement
of the NFIP provisions related to these natural systems is
Page 3 of 11
draft 11-18-14
19. The Coastal Barrier Resource System map
inventory should be modernized and
monitoring/enforcement/penalties for noncompliance of provisions of the Coastal Barrier
Resources Act should be strengthened.
(USFWS)
20. The removal of protected natural,
wilderness or federally owned areas from
Coastal Barrier Resources System should be
prohibited. (Congress.)
BEACH NOURISHMENT
critical in maintaining and enhancing their protective
capacity.
CBRS maps need to be maintained to reflect the most current
areas to ensure protection as mandated in the Act. Enhanced
enforcement and compliance is critical to meeting the goal of
the Act to limit development in high hazard areas and reduce
taxpayer costs associated with inappropriate development
decisions.
Existing areas within the CBRS should be maintained in order
to protect the beneficial functions of natural systems and to
limit taxpayer expenditures associated with development in
vulnerable coastal areas.
21. Federal agencies that plan, fund and/or Quite often, storm hazard mitigation projects are ignored in
conduct beach nourishment operations should favor of beach nourishment which is an expensive, temporary
demonstrate that the Federal interest in beach solution. Federal funding for beach nourishment should be
nourishment exceeds the Federal interest in provided only in cases where other mitigation options have
other, more permanent mitigation options that been shown to provide lesser benefits over the long-term.
are more sustainable and don’t require ongoing Taxpayer funds should not be expended on nourishment
expenditures. This evaluation should include projects that fail to provide the greatest level of benefits as
an objective benefit-cost analysis, with compared to other mitigation options.
adequate public input, to select and fund
mitigation projects that will have the greatest
benefit at the lowest Federal cost over the long
term. (ACOE, FEMA)
22. Federal agencies that plan, fund and/or
conduct beach nourishment operations should
adopt standards to define the scope of specific
benefits that should be considered in
demonstrating when a particular project is in
the federal interest. Once determined, do not
use beach nourishment in any federally funded
projects, unless a clearly defined federal
interest will be met from the project. (ACOE,
FEMA)
23. Benefit-cost analyses for federal beach
nourishment projects should be required to
consider all mitigation alternatives, particularly
non-structural options including acquisition
and land use management, and should
demonstrate that these options are not costbeneficial before considering nourishment.
(ACOE, FEMA)
24. Benefit-cost analyses for federally funded
NFPPR Rec and rationale
Federal funding for nourishment should only be provided
when there is a clearly defined federal interest. Defining the
scope of what constitutes a “federal interest” is critical to
ensuring appropriate spending of taxpayer dollars on
nourishment.
Alternatives to beach nourishment are often less costly over
the long-term because they represent more permanent
mitigation solutions. Therefore, the long-term benefits and
costs of these alternatives should be carefully and objectively
considered before Federal funds are expended on
nourishment.
Failure to accurately define and consider full costs of beach
Page 4 of 11
draft 11-18-14
nourishment projects should identify and
evaluate full costs, including periodic
renourishment, increased costs for locating and
acquiring suitable material, long-term project
maintenance and required protection of
induced development and redevelopment.
Public funding for these projects should be
limited to projects that clearly demonstrate that
benefits will exceed costs. (ACOE, FEMA,
OMB)
25. The cost-sharing agreements for federal
beach nourishment projects should be revised
to 35% Federal, 65% non-federal, in order to
shift more of the cost to the non-federal
sponsors who receive a majority of the project
benefits. (Congress)
26. Federal beach nourishment projects should
be monitored and evaluated periodically to
determine: if the project has actually performed
as planned and justified based on initial costs;
if the project should be abandoned or the
design should be amended to reflect changing
conditions; or to increase efficiencies, reduce
costs and provide greater benefits. (Congress,
ACOE)
27, Planning, benefit-cost analyses, design and
construction of federal nourishment and renourishment projects, including previously
authorized projects, should account for sea
level rise over the 50-year project life.
(Congress, ACOE)
28. Specific requirements (not guidance) for
public access to and use of beaches nourished
with federal dollars should be included as a
condition of funding, including minimum
number of access points, parking and rest
rooms that provide “meaningful” public access.
(ACOE, FEMA)
FLOOD INSURANCE
29. The impact of expanding the mandatory
purchase requirement to require flood
insurance for all buildings in coastal storm
surge zones located outside of the 1% annual
chance SFHA should be evaluated. (Congress,
FEMA, OMB.)
NFPPR Rec and rationale
nourishment as a long-term mitigation option results in
skewed Federal funding and may preclude funding for more
cost-effective solutions. This results in ongoing Federal
expenditures required for periodic, repetitive nourishment,
which often exceed the project benefits.
As a matter of taxpayer equity, states and local municipalities
receive the greatest benefits of nourishment projects and
therefore should contribute a greater share of the costs.
A 50-year authorization for nourishment projects does not
account for changing conditions which might suggest an
alternative design or, in some cases, might cause the
authorized project to fail a benefit-cost analysis. Periodic
evaluations during the 50-year project life will provide an
opportunity to implement project modifications which could
increase benefits and reduce long-term costs.
Many federal nourishment projects have not been planned
and designed in consideration of sea level rise over the 50year project life. Failure to consider the effects of sea level
rise may impact project performance and may skew the
benefit-cost analysis and project selection.
Since taxpayers continue to fund a large share of
nourishment projects, funding agencies should require that
members of the public have meaningful access to these
resources.
In addition to appropriate pedestrian access points along a
nourished beach, “meaningful access” should include
sufficient parking and rest room facilities to support public
use.
Buildings located in storm surge zones outside of the 1%
annual chance SFHA are vulnerable to significant damages
during storm events, resulting in expenditure of public
recovery funds. Requiring flood insurance for these structures
would result in more resilient construction and would reduce
taxpayer liability.
Page 5 of 11
draft 11-18-14
Section L Coastal
Organized in priority order, including beach nourishment
1. Federal funding agencies (FEMA, NOAA,
ACOE, HUD) should provide preferential
support (grants and cost share) and other
incentives to states & localities that adopt land
use management policies that incorporate
strategic retreat from eroding shorelines.
Funding conditions should require all coastal
states to plan for sea level rise and develop and
implement a long-term plan to prevent future
development
and
relocate
existing
development from high-risk low-lying areas
vulnerable to sea level rise and other coastal
flood and storm hazards. Preserve these areas
for natural floodplain functions, natural
resources, and public recreation.
2. FEMA should improve coastal flood maps
by integrating bathymetric and topographic
maps to show additional hazards, including
storm surge, wave runup, overland waves,
tsunamis (where applicable), erosion areas and
increased water surface elevations from future
conditions. X-ref to other sections
3. (a) FEMA should delineate all erosion
hazard areas, both coastal and riverine, on
FIRMs in order to increase awareness of
erosion hazards and vulnerability among
property owners, local governments and
developers. Move or Xref to other sections
3. (b) FEMA should map erosion hazards and
require communities to manage coastal erosion
hazards just like flooding, in order to qualify
for Federal flood insurance. X-ref this with
similar rec’s in other sections-LL
4. Federal agencies should establish a national
policy to consider expanded coastal
management planning horizons (e.g., 50, 100
years) that account for: (1) a realistic estimated
lifetime of a given action/investment; (2) the
NFPPR Rec and rationale
Page 6 of 11
draft 11-18-14
long-term, cumulative impacts and costs of
erosion, sea level rise, subsidence, and changes
in storm intensities and frequencies over that
timeframe; and (3) explicit consideration of
uncertainty in both the hazard information and
other factors that can lead to premature loss of
the resource or investment. Also see A.3
5. FEMA, states and/or municipalities should
require local floodplain ordinances for
communities exposed to coastal flood hazards
to include a construction freeboard requirement
of 3 feet which accounts for: (a) the projected
future increases in sea level that are based on
the best-available historical local relative sea
level rise projection published by the National
Oceanographic
and
Atmospheric
Administration; (b) full build-out of the
watershed; and (c) other future conditions that
will exacerbate flood hazards.
6. Federal agencies that plan, fund and/or
conduct beach nourishment operations should
demonstrate that the Federal interest in beach
nourishment exceeds the Federal interest in
other, more permanent mitigation options that
are more sustainable and don’t require ongoing
expenditures. This evaluation should include
an objective benefit-cost analysis, with
adequate public input, to select and fund
mitigation projects that will have the greatest
benefit at the lowest Federal cost over the long
term.
7. Federal agencies that plan, fund and/or
conduct beach nourishment operations should
adopt standards to define the scope of specific
benefits that should be considered in
demonstrating when a particular project is in
the federal interest. Once determined, do not
use beach nourishment in any federally funded
projects, unless a clearly defined federal
interest will be met from the project.
8. Benefit-cost analyses for Federal beach
nourishment projects should be required to
NFPPR Rec and rationale
Page 7 of 11
draft 11-18-14
consider all mitigation alternatives, particularly
non-structural options including acquisition
and land use management, and should
demonstrate that these options are not costbeneficial before considering nourishment.
9. Benefit-cost analyses for federally funded
nourishment projects should identify and
evaluate full costs, including periodic
renourishment, increased costs for locating and
acquiring suitable material, long-term project
maintenance and required protection of
induced development and redevelopment.
Public funding for these projects should be
limited to projects that clearly demonstrate that
benefits will exceed costs.
10. (a) Federal and state mitigation projects
should avoid the use of hard structures to
protect shorelines and riverbanks unless No
Adverse Impact (should we include a link or
footnote for those who don’t know what NAI
is?) can be demonstrated. In order to support
resilience over the long term, Federal funding
programs should give preference to strategic
retreat or natural/nature-based mitigation
approaches, or combinations thereof.
10. (a) Federal and state mitigation projects
should avoid the use of hard structures to
protect shorelines and riverbanks unless No
Adverse Impact (should we include a link or
footnote for those who don’t know what NAI
is?) can be demonstrated. In order to support
resilience over the long term, Federal funding
programs should give preference to strategic
retreat or natural/nature-based mitigation
approaches, or combinations thereof.
11. Federal and state agencies should plan,
design, build and retrofit highways and other
transportation networks to meet current and
future community needs to effectively evacuate
the population in events up to and including
the 0.2%-annual-chance event.
NFPPR Rec and rationale
Page 8 of 11
draft 11-18-14
12. (a) Federal and state agencies should
provide incentives to encourage coastal
communities
to
adopt
comprehensive,
functional evacuation plans and encourage
coastal development approvals to be contingent
upon provision for warning and evacuation
plans. Also see F.12, F.13, F.14
12. (b) FEMA should require that flood and
storm warning and evacuation plans be tested
annually and involve local governments,
businesses and the general public to improve
public awareness.
13. FEMA should develop a coastal A Zone
definition and adopt that definition in the CFR.
See F.22
14. FEMA should incorporate LiMWAs on all
coastal flood maps and adopt enhanced design
standards for construction of new buildings in
these areas. See A 21 latter is covered
elsewhere
15. Congress, in conjunction with FEMA and
OMB, should evaluate the impact of expanding
the mandatory purchase requirement to require
flood insurance for all buildings in coastal
storm surge zones located outside of the 1%
annual chance SFHA.
16. FEMA should enhance the enforcement of
the protection of dunes and mangroves as
required in NFIP regulations.
FEMA and NOAA should provide more funds
for acquisition of property and/or easements on
barrier islands, should leverage existing funds
after a disaster, and should consider how
funding may be used to offset short-term
financial impacts of acquisitions on developed
communities.
18. Congress should revise the cost-sharing
agreements for Federal beach nourishment
projects to 35% Federal, 65% non-Federal, in
order to shift more of the cost to the non-
NFPPR Rec and rationale
Page 9 of 11
draft 11-18-14
Federal sponsors who receive a majority of the
project benefits.
19. Congress should require that Federal beach
nourishment projects be monitored and
evaluated periodically to determine: if the
project has actually performed as planned and
justified based on initial costs; if the project
should be abandoned or the design should be
amended to reflect changing conditions; or to
increase efficiencies, reduce costs and provide
greater benefits.
20. NOAA and FEMA should require
comprehensive
planning
for
coastal
acquisitions to ensure that acquired lands are
dedicated to resource restoration and
enhancement to increase level of natural
protection, and to promote public access to
public lands.
21. (a) USF&WS should modernize Coastal
Barrier Resource System map inventory and
strengthen monitoring/enforcement/penalties
for non-compliance of provisions of the
Coastal Barrier Resources Act.
21. (b) Congress should prohibit the removal
of protected natural, wilderness or federally
owned areas from Coastal Barrier Resources
System.
22. NOAA should modify National Estuarine
Research Reserve provisions to allow
acquisition of uplands to facilitate landward
migration of wetlands, restoration of protective
dunes and natural systems, and preservation of
floodplains.
23. Congress should require that planning,
benefit-cost analyses, design and construction
of Federal nourishment and re-nourishment
projects, including previously authorized
projects, account for sea level rise over the 50year project life.
NFPPR Rec and rationale
Page 10 of 11
draft 11-18-14
24. Through a periodic review of
programmatic activities, Federal agencies
should enhance their interagency coordination,
and coordination with coastal states, to better
integrate coastal zone, floodplain and
emergency management programs and to
identify actions to align programs and goals.
25. The Army Corps of Engineers and FEMA
should include specific requirements (not
guidance) for public access to and use of
beaches nourished with Federal dollars as a
condition of funding, including minimum
number of access points, parking and rest
rooms that provide “meaningful” public access.
26. Share/redirect navigation fuel tax for
coastal and aquatic habitat restoration that will
enhance flood protection
27. NOAA and FEMA should increase funding
for programs designed to improve public
awareness of natural resource functions,
coastal risk, storm preparedness, and
evacuation.
NFPPR Rec and rationale
Page 11 of 11
draft 11-18-14