Posted on July 16, 2019
American Shore and Beach Preservation Association
Derek Brockbank, Executive Director
America’s Engineered Shoreline
America has an engineered shoreline. The most iconic beaches in the country have all been restored, renourished, and
The U.S. Army Corps of Engineers (USACE), authorized by and acting under policy established in Water Resource Development Acts (WRDAs), has been building natural infrastructure and engineering with nature for a long time. And the American Shore and Beach Preservation Association (ASBPA) has been working with USACE for nearly a hundred years.
ASBPA is an organization of beach and coastal practitioners. We are the communities, industries, and academics who build, maintain, manage and research our nation’s beaches and shorelines. We are geologists, engineers, town managers, elected officials, professors, students and coastal advocates. Our mission is to merge science and policy to protect, restore and enhance the U.S. coastline; we were founded in 1926 and have been advocating for a healthy coastline ever since.
ASBPA believes a healthy coastline, whether restored or natural, provides four interconnected values to coastal communities specifically and to the nation more broadly:
a) Protection from coastal storms, hazards and sea level rise, and as buffer to sensitive estuarine ecosystems;
b) Ecologically valuable habitat for birds, turtles, fish and other coastal plants and wildlife;
c) Economic vitality though tourism, shipping, fishing and other industries;
d) Recreation for tens (if not hundreds) of millions of Americans who visit the beach in greater
numbers than all our national parks combined.
ASBPA would like to see these values maximized in USACE’s management of our nation’s shoreline. Doing so will take USACE using the full authorities provided to them, and Congress authorizing and encouraging USACE to use a
WRDA
In the last two WRDAs, Congress has included a number of provisions that allows or directs USACE to manage the US coastline to achieve these multiple benefits. The three areas discussed here are:
1) Regional Sediment Management (RSM) and the Beneficial Use of Dredged Material (BUDM)
2) Modification of the
3) Natural Infrastructure.
Regional Sediment Management and the Beneficial Use of Dredged Material
Regional Sediment Management (RSM) is a comprehensive approach to planning and integrating riverine and coastal projects with the core principle that sediment is a finite resource not to be wasted. RSM seeks to move sediment from where it is not wanted to where it is wanted, rather the simply removing sediment from the littoral system. RSM can reduce overall costs through
On average, USACE dredges about 214 million cubic yards of sediment per year from navigation channels nationwide. Of that, 82 million cubic yards (or 38%) is used beneficially on beaches, in wetlands, and in nearshore water each year.1 This is a good first step, but in an era of sediment shortage
–less sediment is reaching the coast than ever before due to dams, hardened riverbanks and cliff faces, and straightened channels – and rising seas, anything less than 100% beneficial usage is not enough.
One good example of RSM in practice is at the mouth of Columbia River in Oregon, where the USACE Portland District is working with partners to develop a network of nearshore placement sites for dredged sediment. The goal is to keep material in the littoral zone so that it feeds the beaches of Oregon and Washington through natural coastal processes. Placing 500,000 cubic yards of sediment in a nearshore site, with no more than five centimeters of accumulation on the seabed per disposal, has yielded $200,000 in cost savings to date, helped naturally maintain an eroding coastline, and yielded no crab mortalities (the primary environmental concern with nearshore placement in this region).
In another example of RSM, near St. Augustine, FL, the Jacksonville District has combined multiple federal projects so that timing of dredging and placement is aligned. They have also instituted inlet bypassing, so less sand accumulates in the St. Augustine Inlet and instead is distributed to a down drift shoaling area that distributes sand to eroding beaches. This resulted in a $2 million cost savings from reduced dredging and associated environmental mitigation efforts and by combining permits.
1Federal coastal navigation projects were inventoried to examine the extent to which RSM goals have been implemented across USACE at the project level. This study examined USACE navigation projects that beneficially reuse sediments dredged from Operations & Maintenance (O&M) projects nationwide. These data were derived from a comprehensive analysis of nearly 20 years of USACE dredging data at both the national and district level. The data have been quality checked, updated, and revised over the last five years through extensive interviews of USACE staff at the District, Division and HQ levels. USACE RSM, 2019. USACE Navigation Sediment Placement: An RSM Program Database
WRDA 2016 authorized a pilot program for BUDM (Sec. 1122), that was expanded in WRDA 2018 (Sec. 1216). Sec. 1122 was slow to get going: implementation guidance took a year to finalize, and after 90+ projects were submitted for the initial ten pilot projects, project selection took nearly another year. But the projects are now underway. One project, Deer Island Lagoon in MS, has been completed, and USACE has estimated the remaining nine will be in construction by FY2022, assuming current dredge timelines hold and construction funding is available.2
Local communities have widely supported the 1122 program. Washington State Department of Ecology (WADEC), the local sponsor for the “Grays Harbor South Jetty Placement” project, used this process to convene key stakeholders to plan for the beneficial use of dredge sediment to help protect shipping channel jetties, coastal beaches and nearshore habitats from erosion while avoiding and minimizing adverse impacts to environmental resources, and navigation safety. Through the development of the Grays Harbor project, WADEC identified additional opportunities for beneficial use in other parts of Washington, and developed a strategy to achieve economies of scale through coordination with local partners across the state – reducing the cost sharing challenges that many communities face. Although the Grays Harbor project is not impacting the Town of Ocean Shores, WA, Mayor Crystal Dingler has credited the 1122 process with helping her community by providing “invaluable information concerning our ongoing erosion problems. This continued engagement in our community process to address emergencies and support
USACE has not publicly determined when or how the additional ten projects authorized in WRDA 2018 Sec. 1216 will be selected, but USACE and congressional appropriations committees have each indicated they would like to see the successful completion of the first ten pilot projects before constructing the next ten.
What else is needed:
The pilot project is an important step in directing USACE districts to think more broadly about how they can use dredged sediment and how they can work with local project sponsors. But this sort of approach must be systemic across USACE projects, not limited to a handful of pilot projects, or within districts that seek innovative approaches. One way to do this is to change the understanding of the Federal Standard. As part of USACE determination of the “least cost alternative” for the disposal of dredged material, the USACE should include the economic evaluation of the sand, including ecosystem restoration benefits, storm damage reduction benefits, and other economic values and
2FY19 appropriations included an $8.5 million increase to CAP204 (BUDM) to $10 million with report language, “the Corps is directed to fund these pilots, if otherwise competitive, under the CAP Section 204 line item and the applicable additional funding line items in this account.” FY20 Energy & Water appropriations passed by the House includes $7.5 million for “BUDM Pilot Program” as well as $20 million for CAP204 (BUDM).
3Interview with Bobbak Talebi, Senior Coastal Planner, Shorelands & Environmental Assistance Program, Washington State Department of Ecology, July 2, 2019.
a)BCRs are only calculated using the economically verifiable benefits of a project’s primary purpose; and
b)Projects in wealthier communities inevitably get prioritized over projects in poorer communities, since the economic benefit of risk reduction is greater for valuable property than inexpensive property.
Using only the economically verifiable benefits of a project’s primary purpose sounds sensible, but it means projects are designed to maximize just a single benefit, rather than balancing multiple benefits. A project that is intended to reduce flood risk, such as a beach and dune system, might also have tremendous value as habitat and in supporting a
In the case of beaches, the economic value and even the direct return on investment via tax revenue can be remarkably high. Economist Dr. James Houston has calculated that beach travel and tourism generates $285 billion to the national economy and $23 billion in federal tax revenue annually.4 Additionally, beach tourism support 2.5 million jobs directly and 4.4 million jobs including direct, indirect, and induced impacts.5 While USACE is not an economic development agency, and not in business to generate revenue for the U.S. Treasury, these economic figures ought to be considered when deciding which flood risk management projects to prioritize.
Second, prioritizing flood risk management projects based on calculation of avoided economic damage means projects in areas of a high concentration of wealth have a higher BCR than less wealthy or less densely populated areas. This may be a sensible
WRDA 2018 authorized two studies to look at USACE budgeting practices, a National Academy of Science (NAS) study on USACE budgeting (Sec. 1103) and a General Accountability Office (GAO) study on
What else is needed:
4Houston, J.R. 2018. “The economic value of America’s beaches — a 2018 update.” Shore & Beach, 86 (2),
5Ibid.
While studies are helpful in clarifying specific challenges to current policy or operating procedure, as well as recommending potential solutions or steps for improvement, they don’t actually change anything. USACE’s BCR for flood risk management projects is an archaic tool that needs to be modernized. Congress needs to direct the USACE to update its BCR process – either to consider the full array of benefits, or to develop a new methodology for prioritization that incorporates a project’s secondary benefits. While this will support better projects whose primary purpose is flood risk management, it will also support better navigation projects that have multiple benefits (such as important BUDM placement sites, or ecological value in clearing channels).
Natural Infrastructure
Wide beaches, high dunes, and verdant wetlands, reefs, mangroves and seagrass beds are essential to the 40% of American who live along the coast. Properly maintained, this natural infrastructure can improve communities’ resilience and is itself resilient. Dunes and marshes can adapt to rising seas, and reefs and coastal forests regenerate after storm damage. The same can’t be said for “grey” (concrete and steel based) infrastructure. USACE has been building beaches and dunes for flood risk reduction for nearly a century and restoring aquatic ecosystems for more than half a century. It should be looking at how to fully integrate these missions in combination with its mandate to maintain coastal navigation. By doing so, USACE can more effectively restore and rebuild our nation’s natural infrastructure, in collaboration with other federal, state and tribal agencies.
USACE has many authorizations to use natural infrastructure solutions and to consider natural and nature based features in place of more traditional grey infrastructure. Recent WRDAs have clarified and built upon previous authorizations:
- WRDA 2016, Sec. 1154 authorized collaborative regional assessments on coastal resilience that prioritized natural infrastructure;
- WRDA 2016, Sec. 1184 required “natural features” to be considered in feasibility studies;
- WRDA 2018, Sec. 1149 specifically allowed “natural and nature based features” to be included in aquatic ecosystem and flood risk management projects;
- WRDA 2016 & 2018 authorized regional coastal resilience studies in the South Atlantic, Great Lakes, and coastal Texas that included natural infrastructure solutions.
None of these were wholly new authorities requiring action from USACE, so implementation has been mixed. Districts that use “natural” solutions have more leeway to do so, but ASBPA hasn’t seen a notable increase in use of natural infrastructure since 2016. ASBPA considers comprehensive coastal resilience studies to be invaluable and is pleased that the South Atlantic Coastal Study has been funded and is underway, and disappointed that the Great Lakes Coastal Resilience study has not received approval to begin as a new start and is still on hold.
What else is needed:
Rather than simply encouraging USACE to use or consider natural infrastructure in place of hard, grey infrastructure, Congress should set policy on
A final thought on the USACE’s efforts to “Revolutionize”
Many of the challenges the USACE has in modernizing to meet the needs of the 21st century – the ability to adaptively manage projects in the face of climate impacts, expediting project delivery, being reactive to the high and lows as well as delays in funding by the Administration and Congress – is not something Congress can directly fix. These challenges are procedural and cultural that will take years, if not decades, to fully address. ASBPA has been pleased with General Todd Semonite’s call to “Revolutionize” USACE, as well as Director of Civil Works James Dalton’s efforts at implementing procedures to allow USACE to operate as a
But after Gen. Semonite and Mr. Dalton leave, these efforts will need to continue. It is incumbent on Congress, and the Transportation & Infrastructure (T&I) Committee specifically, to provide oversight to ensure these procedural and cultural changes continue. USACE is an essential agency as our nation faces the biggest coastal threats in history, and it needs to be operating efficiently and effectively.
Conclusion
As the T&I Committee reviews the success of recent WRDAs and develops policies for a 2020 WRDA, ASBPA encourages the committee to consider how USACE is able to advance coastal projects that have multiple benefits. USACE has been building beaches for 100 years and wetlands for 50 years, so the concept of restoring natural infrastructure with flood risk reduction, ecological, economic and recreation benefits is not new. But the next step is for USACE to maximize each of these values for individual projects and within coastal systems. This will take systemic changes to increase the beneficial use of dredged material, budgeting changes to ensure the full value of sediment is calculated and all benefits are included in a BCR, and
Finally, the needs of our nation’s coastline are too enormous to be solved with policy changes and authorized projects in WRDA alone. Our country must make a major investment in infrastructure that includes dedicated support for coastal resilience and for waterways. From sediment management to preparing for storms and rising seas, the challenges of our coastlines and our waterways are linked and must be solved together. The policy solutions described here
Thank you for considering our testimony, and we are happy to answer any questions.
Derek Brockbank
Executive Director, American Shore and Beach Preservation Association (ASBPA)
202-827-4246
Derek.Brockbank@asbpa.org
