A Change in FEMA Policy Spells Good News for Communities, Wildlife, and Wildplaces Alike

An update to hazard mitigation grant application requirements will help make natural and nature-based projects more competitive for federal funding.

In recent years, a great deal of science has confirmed the ability of natural infrastructure—such as healthy wetlands, floodplains, forests, coral reefs, and beaches—to reduce risk to human communities and infrastructure during disasters. Often referred to as “natural or nature-based features,” natural infrastructure can be a completely natural ecosystem, or an engineered system that uses natural materials or is designed to emulate the functioning of ecosystems.

Research shows that natural infrastructure can often reduce risk to communities as well as or better than traditional “gray” infrastructure measures, like levees and seawalls, and that natural infrastructure can be more cost-effective than gray infrastructure. For instance, along the Gulf Coast, wetland and reef restoration in high risk areas is estimated to provide more than $8 in flood reduction benefits for every $1 in cost, compared with just over $1 in benefit for each dollar spent on local levees in high-risk areas. A great deal of evidence on this subject is captured in the National Wildlife Federation and Allied World’s 2020 Protective Value of Nature report.

Risk reduction is not the only benefit natural and nature-based features can confer. Natural infrastructure projects often create “co-benefits” through ecosystem services like air and water quality improvement, or recreational value. For example, oyster reefs in combination with marsh grass shorelines are called “living shorelines” and are used to abate erosion along coasts. But, these oysters simultaneously clean and protect the nearby environment; an adult oyster can also filter and purify up to 50 gallons of water per day. Moreover, natural infrastructure like living shorelines can be better for wildlife than the gray alternative. A 2016 study in North Carolina found that living shoreline sites had higher species abundance and diversity when compared with gray infrastructure such as bulkheads. Creating quality habitat for wildlife can also allow better wildlife viewing, which may bring along economic benefits for local businesses.

Double crested cormorants and a great egret sit atop the oyster reef of a living shoreline
Double crested cormorants and a great egret sit atop the oyster reef of a living shoreline. Credit: Kayla Drayton.

Though the multiple benefits of natural infrastructure are well recorded, gray infrastructure tends to be the default method used for risk reduction in the US. In recent years, policy across federal agencies has been changing to enable greater use of natural infrastructure. However, until very recently a FEMA policy for calculating project benefits for hazard mitigation grant applicants was a barrier to funding cost-effective natural infrastructure projects through FEMA programs.

When applying for Hazard Mitigation programs, grant applicants must come up with a projected “Benefit-Cost Ratio” (BCR) for a project which reflects the future risk reduction benefits compared to the project’s cost. A BCR of 1.0 or greater indicates that a project is cost-effective, and is an important qualifier to receive FEMA funding. However, as indicated above, natural infrastructure projects often provide significant benefits to communities through ecosystem services, which have not been considered “traditional risk reduction benefits” by FEMA. Prior to this month’s change in guidance, FEMA has required that a project meet a 0.75 threshold through the BCR (with only traditional risk reduction benefits compared against cost) before the benefits from ecosystem services could be considered. Through this old policy, a hypothetical nature-based project could be extremely cost-effective given the anticipated ecosystem service benefits, but would be ineligible for FEMA’s Hazard Mitigation funding if it did not quite reach a 0.75 BCR from a traditional risk reduction standpoint alone. 

A few weeks ago, FEMA eliminated the need for natural or nature-based projects to meet this threshold, allowing ecosystem service benefits to be considered regardless of BCR. FEMA has rescinded its BCR threshold policy “in recognition that the natural environment is an important component of a community’s resilience strategy,” and noted that “this update allows for easier inclusion of nature-based solutions into risk-based mitigation projects.”  With this change, natural and nature-based projects will be evaluated more fairly, and thus will be more competitive for hazard mitigation dollars. This is a big win for communities hoping to harness the protective value of natural features to mitigate flooding, hurricanes and other disaster events. Importantly, this change in policy applies to all FEMA’s Hazard Mitigation Assistance Grant programs and the Public Assistance 406 mitigation program, including the recently opened application period for the new Building Resilience Infrastructure and Communities pre-disaster grant program.

snow geese visiting marsh wetlands
Natural infrastructure can provide quality habitat for wildlife. Pictured above: snow geese visiting marsh wetlands in southern New Jersey. Credit: Steven Droter/Chesapeake Bay Program.

“With this change, FEMA is leveling the playing field in a critical way for nature-based projects that can represent a win-win for communities and wildlife. We hope communities will seize this opportunity to explore the ways that natural features can become a central part of their risk reduction toolbox.”

Jessie Ritter, Director of Water Resources and Coastal Policy

While there is still much work to be done to scale up the use of natural infrastructure to protect communities, this policy change is an exciting step in the right direction.

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