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EPA Regulatory Strategy Likely To Share Many Aspects of Failed Cap and Trade Approach

 “The Huge Mistake” In Regulatory Drag?

Science and Politics Shifting – More Ambitious Program Required

 

“Cap and trade with offsets would guarantee that we pass climate tipping points, locking in climate disasters for our children. Cap and trade benefits only Wall Street and polluters, sacrificing humanity and nature for their profits.” Dr. Jim Hansen Nov. 30, 2009

 

In light of President Obama’s State of the Union address, I thought I’d dust off prior posts on the failed cap and trade bill Obama just recommended that Congress reconsider and enact.

As expected, building on remarks on climate change in his Inaugural speech, Obama’s SOTU called on Congress to enact cap and trade legislation:

The good news is, we can make meaningful progress on this issue while driving strong economic growth. I urge this Congress to pursue a bipartisan, market-based solution to climate change, like the one John McCain and Joe Lieberman worked on together a few years ago. But if Congress won’t act soon to protect future generations, I will. I will direct my Cabinet to come up with executive actions we can take, now and in the future, to reduce pollution, prepare our communities for the consequences of climate change, and speed the transition to more sustainable sources of energy.

Surely Obama realizes that cap and trade is dead on arrival in Congress, particularly in the Tea Party Republican dominated House. So, my sense is that this was just a throw away line, to provide cover for his “executive actions”.

(for inside the beltway perspective, e.g. Obama “threat”, see WaPo:  In State of the Union, Obama threatens Congress on climate change)

Before touching on the cap and trade issues, I must note that Obama’s vague treatment of climate change emission reductions is in strark contrast to his specific proposals for more fossil energy.

Obama has retained his “all of the above” energy policy, which stresses “economic growth”, “energy security” and “low costs”, which are fundamental barriers to real reform.

Resources are finite and significant emissions reductions are required – so “all of the above” can’t work. We simply don’t have the money or the time to do everything. Energy costs much rise signifincatly to provide incentives to reduce consumption and make the revolutionary scale of required investments in renewable power profitable. Economic growth is not sustainable with finite resources and will guarantee we suffer catastrophic and irreversible climate impacts.

Building on his “all of the above” policy, in contrast to vague programmatic commitments on emissions reductions and renewables, Obama was very specific about commitments on more fossil fuel production, which will conflcit with or undermine his emsisions reductions and renewable energy goals:

After years of talking about it, we are finally poised to control our own energy future. We produce more oil at home than we have in 15 years. We have doubled the distance our cars will go on a gallon of gas, and the amount of renewable energy we generate from sources like wind and solar – with tens of thousands of good, American jobs to show for it. We produce more natural gas than ever before – and nearly everyone’s energy bill is lower because of it. And over the last four years, our emissions of the dangerous carbon pollution that threatens our planet have actually fallen. […]

In the meantime, the natural gas boom has led to cleaner power and greater energy independence. That’s why my Administration will keep cutting red tape and speeding up new oil and gas permits. But I also want to work with this Congress to encourage the research and technology that helps natural gas burn even cleaner and protects our air and water.

Nonetheless, aside from these problems that flow from Obama’s energy policy and subordination of all other policy objectives to economic growth, it still is very important that people understand the fatal flaws in cap and trade.

Most importantly, that’s because the cornerstone of the President’s “executive action” is very likely to be a complex regulatory scheme under the Clean Air Act to regulate emissions from over 500 antiquated existing coal power plants.

I’ve written about that several times and will be writing in depth about this set of issues in the near future.

But for now, I leave you with a December Report by the Natural Resources Defense Council (NRDC) (see:  Closing the Power Plant Carbon Pollution Loophole: Smart Ways the Clean Air Act Can Clean Up America’s Biggest Climate Polluters 

That NRDC Report is essentially the same politics and policy of cap and trade, in regulatory form.

Right off the bat, the NRDC Report is misleading, because it describes just one of several regulatory tools available to EPA under the Clean Air Act, Section 111(d).

But even the Bush Administration’s EPA laid out a much broader set of options, in a 2008 “Advanced Notice of Proposed Rulemaking”, which stated:

SUMMARY: This advance notice of proposed rulemaking (ANPR) presents information relevant to, and solicits public comment on, how to respond to the U.S. Supreme Court’s decision in Massachusetts v. EPA. In that case, the Supreme Court ruled that the Clean Air Act (CAA or Act) authorizes regulation of greenhouse gases (GHGs) because they meet the definition of air pollutant under the Act. In view of the potential ramifications of a decision to regulate GHGs under the Act, the notice reviews the various CAA provisions that may be applicable to regulate GHGs, examines the issues that regulating GHGs under those provisions may raise, provides information regarding potential regulatory approaches and technologies for reducing GHG emissions, and raises issues relevant to possible legislation and the potential for overlap between legislation and CAA regulation. 

NRDC fails to learn the political and policy lessons of their prior support for cap and trade and EPA’s regulatory strategy under the Clean Air Act – i.e. a modest program based on pre-movement political feasibility, limited to low cost, flexible, state autonomy, modest emissions reductions, incremental, technocratic, industry expertise/modeling driven approach.

Here’s how NRDC describes the situation:

Lots of freedom there – freedom to pollute and freedom for captured state regulators to look the other way.

And how does a 50 year old antiquated coal power plant possibly have stranded costs?

NRDC signed off on that not only politically, but actually own it via a litigation settlement agreement:

Ruling in the New York case, the D.C. Circuit Court of Appeals then ordered EPA to reconsider its refusal to curb carbon emissions from power plants. In 2011 the Supreme Court confirmed EPA’s responsibility to address carbon pollution from power plants under Section 111 in another climate change decision, American Electric Power v. Connecticut.33

In 2011 the parties reached a settlement agreement in the New York case with a schedule for EPA to act on CO2 standards for both new and existing power plants.34 Although EPA has fallen behind the settlement schedule, the agency proposed a carbon pollution standard for new plants in April 2012. This is an important step toward EPA’s meeting its statutory duties, but action is still required on the existing power plants, the largest contributor of carbon pollution in America.

In their Report, NRDC sets a very low bar for greenhouse gas emissions (power plant “reductions” are just 12.5% by the year 2025, using a 1990 baseline – see graph on page 4)

NJ’s 2007 Global Warming Response Act law is more aggressive, sestting a larger 20% emission reduction goal five years sooner (by 2020) (same 1990 baseline). NJ has already achieved that 2020 goal, based exclusively on economic factors: the economic recession and fuel switching from coal and oil to cheap natural gas.

Nationally, we assume a similar economic response to emissions, plus additional reductions from coal plants that close due to the high costs of compliance with new EPA mercury, SOx and NOx  regulations. So, it is not clear exactly whether and how much the NRDC strategy will reduce power plant emissions at all, compared with business as usual (all that complexity is conveniently buried in an industry and EPA model – which is another technical and political problem with the NRDC strategy).

The scope of what NRDC recommends as the cornerstone of the EPA regulatory strategy is also troubling. It repeats mistakes of the past as well, because power plant sector is only 40% of emissions – other sectors must be included, and it is not clear exactly how the NRDC proposed regulatory strategy and emission credits could achieve this non-power sector reductions.

The NRDC emissions reduction goal and reduction schedule is not based on science, which tells us that much deeper and faster emission reductions are required to avoid the worst and most catastrophic global warming impacts.

The NRDC modest effort comes as climate change activists are ramping up demands and movement politics, with a huge protest scheduled for Sunday, Feb, 17.

Thus, with the science suggesting the need for even more urgent and deeper cuts and the politics shifting, NRDC should have been much more ambitious and set a much higher bar.

Much more to come on this, but until I get a chance to lay out the arguments, watch this superb short video by two EPA lawyers, with over 40 years of experience. They explain exactly why cap and trade is fatally flawed.

So, until I get a chance to write more in depth,  read the NRDC Report and then

NJ Dems Blow Huge Climate Change Set Up

Democrats Playing Irresponsible Partisan Games In Effort to Undo FEMA Maps

Gov. Christie Blocks DEP & FEMA Testimony

Coastal Advocacy Groups AWOL

 

What the hell are the NJ Democrats doing?

The NJ Senate Budget & Appropriations Committee held another in their series of hearings on Sandy. Yesterday’s agenda was announced “to hear testimony from invited witnesses on issues surrounding coastal planning and rebuilding in the aftermath of Hurricane Sandy.”

The hearing comes at a time when people are finally connecting the dots betweeen climate change and extreme weather events, like Sandy.

Last week, Gov. Christie got hammered for calling climate change an “esoteric” issue that people “didn’t give a damn about”:

A day after Governor Christie dismissed questions about whether climate change fueled superstorm Sandy, scientists maintained Wednesday that global warming and sea level rise must be taken into account when rebuilding the Jersey Shore. (Rebuilding standards at Jersey Shore must reflect climate change, experts say Bergen Record 2/6/13)

Christie not only got hammered on climate change, but, due to an unfavorable comparison with NY Gov. Cuomo’s Sandy response, pledged to do more on aquisition of flood prone properties:

SEA BRIGHT — Gov. Chris Christie said today he wants the state to use a portion of the federal Sandy aid money coming to New Jersey to buy up whole neighborhoods prone to flooding. (Star Ledger 2/7/13)

But then, in another embarrassing move, Christie walked those comments back and said he was reluctant to aquire property, and would do so only if an entire neighborhood came to consensus (see: Christie says he’s reluctant to buy out flood-prone homes without neighborhood consensus (Bergen Record 2/7/13).

Meanwhile, as President Obama gears up for tonight’s State of the Union address and expectations rise about how he will flesh out his strong Inaugural remarks on climate change, [and reality pushed] Congressional Democrats are pushing to put climate change on the national agenda.

In fact, NJ Congressman Frank Pallone is playing a leading role, see House GOP Rejects Calls For Climate Hearings — But Democrats Will Keep Pressing.

A second defeated amendment, by Rep. Frank Pallone (D-N.J.), called for hearings on climate-related coastal threats including sea-level rise, more frequent and intense storms, and ocean acidification. Both proposals called for witnesses including National Academy of Sciences members.

So, going into that NJ Senate Sandy hearing, the NJ Democrats should have been riding high and focused on climate change, science, and flaws in Gov. Christie’s “Rebuild Madness” (TM).

So what did they do with this tremendously favorable setup?

They attacked the science!

They ignored climate change!

They attacked the Gov. for applying the science in a DEP Emergency Rule which adopted the FEMA Advisory Base Flood Elevation (ABFE) maps.

They did not invite any coastal, environmental, or public interest advocates to testify.

Following last week’s move by US Senators Lautenberg and Menendez, it looks like the NJ Democrats are all in in a top down political attack on FEMA and climate science to undo the ABFE maps.

This obviously is exactly the opposite of good science and public policy.

Now, let’s get back to the NJ Senate Committee hearing.

The sparsely attended hearing was one long disaster – the only relief coming at the very end of the hearing in testimony by former DEP Commissioner Mark Mauriello, not only a former Commissioner but a 30 year coastal expert.

Mauriello questioned Gov. Christie’s “neighborhood” approach to acquisition of flood prone property; supported the FEMA ABFE maps and disputed prior scientific testimony that claimed FEMA maps lacked “scientific validity”; recommended Legislative changes to eliminate the CAFRA right to rebuild provision, and provide state authority to condemn easements and consider recalcitrant easement property owners a hazard to others and public nuisance; and said DEP had failed to implement and enforce existing CAFRA public access requirements. Hello! That was a bombshell that will be ignored. It is not often that a former DEP Commissioner criticizes DEP’s failures.

But by that time, most of the Committee members and media were long gone.

Senator Bob Smith, Chairman of the Environment Committee, who is not even a member of the Budget & Appropriations Committee, was sitting in and lead this attack.

At one point, Smith suggested the need for uniform state legislation to make rebuilding “automatic”, by exempting rebuilding from local planning and zoning board reviews. That is consistent with and would go beyond DEP Commissioner Martin’s initial moves to deregulate rebuild from DEP permit reviews.

Smith laid it on thick, at one point calling the Governor’s adopton of the maps “insane”. Star Ledger:

Calling the requirements adopted last month by the Department of Environmental Protection “insane,” Sen. Bob Smith (D-Middlesex) asked scientists at a hearing in Toms River if the maps are “scientifically valid.”

At least two scientists — who testified before the Senate Budget and Appropriations Committee — declined to answer, but Stewart Farrell, director of the Coastal Research Center of the Richard Stockton College of New Jersey, said the maps are flawed when taking wave action into account.

“So why did we adopt them … if they’re not scientifically valid?” asked Smith, who has a Shore house in Lavallette that flooded during Hurricane Sandy. “Doing it on partial and preliminary information is insane.”

[Note – here is Asbury Park Press story with the same “insane” Smith quote: Senate panel meets on flood maps.

What is really going on is people with an agenda or bias are using anecdotal site specific information to smear a larger effort. The same bullshit attack has suceeded before on FEMA maps, the Builders and developers did the same thing to DEP’s Big Map project, and people are still doing it now to attempt to discredit the Highlands. Spatial data and models are never perfect or 100% ground truthed – It is easy to find mapping errors or anomalies, and use them to misrepresent the entire methodology. Shame on Smith, Sarlo, and Farrell].

While I have criticized the FEMA ABFE maps as flawed for failure to consider Sandy elevations and the effects of climate change and sea level rise as required by FEMA’s own Climate Change Adaptation Policy, I think Smith’s attack was cynical, opportunistic, and represents an insane policy of denial.

But it wasn’t only Senate Democrats who were playing partisan political games and not focusing on the science and public policy.

DEP Commissioner Martin was invited and expected to testify, but cancelled unexpectedly.

Chairman Sarlo, who again opened the hearing by repeating the subservient role he envisions for the Legislature to support the Gov. who was taking the lead on Sandy, merely said he was “disappointed” by this.

Amazingly, Gov. Christie blocked the testimony of FEMA.

I didn’t even know a Governor could do this, but in response to a harsh question by Senator O’Toole (R) asking why FEMA was not there to testify (presumably a set up to attack President Obama), Chairman Sarlo indicated that FEMA was blocked by the “NJ executive Branch”.

The US Army Corps of Engineers testified, but basically were evasive and said nothing. At times, getting a straight answer out of them was like nailing jello to a tree.

They were repeatedly asked what the best available science suggested was the most effective strategy (reply: “I can’t offer advice on that”) –  whether they had conducted a damage assessment and analysis for the entire NJ coast (“No”) – and how much it would cost to do beach replenishment and dune construction along the entire NJ coast.

All they could say was that the recent bailout legislation provide money to study those questions and the Corps will issue a report in 2 years or so. In response, Chairman Sarlo sought to dampen public expectations on dunes and beach replenishment solutions, saying they were years away.

One important thing the USACE did make clear, however, was that their project engineering designs and cost benefit analysis are very flawed. Contrary to public perception, the Corps does not design for a specific storm interval (e.g. 100 year storm); and their projects are not designed to offer a level of protection. The projects merely reduce the harm and damage that would have occurred with out them, mostly due to wave action impacts on beachfront property, not flooding and back bay or inland property. Corps projects do not prevent harms, but merely reduce harms – what the Corps called “risk uncertainty analysis”. The cost benefit analyses that justify these projects and environmental reviews are similarly flawed.

A prominent academic cheerleader for beach replenishment testified.  He not only defended that costly, ineffective, and unsustainble practice, he touted outdated structural engineering solutions. Stewart Farrell of Stockton went where other scientists would not go.  He played along with Senator Smith and used a few Cape May county back bay FEMA V Zone designations to attack the scientific credibility of the entire FEMA ABFE mapping exercise based on this handful of designations.

That view was disputed by former DEP Commissioner Mauriello, while other witnesses testified that 90% of the FEMA maps were scientifically sound and peer reviewed, all but the wave action model. So it looks like a few technically unclear V zone bay front designations are being misused to discredit the entire FEMA effort.

While criticizing FEMA for failure to fully peer review the science and modeling behind the ABFE maps, this same professor revealed that he had met behind closed doors “at the Statehouse” with DEP Commisioner Martin.

That sounds a lot more like politics than science – so much for transparency and peer review.

Another academic from Rutgers testified on climate change research. His testimony was presented with such timidity, uncertainty caveats, and refusal to engage any policy issues that it actually undermined the case for climate change.

The most critical and important point made was obscured and legislators did not understand the implications.

All our statistical analysis of historical data used to support planning, engineering, policy, and decsion-making assumes that the future will be like the past.

But with climate change, “the future will not be like the past”.  All bets are off!

When asked what was the best policy in light of this science, the Rutgers professor refused to engage any policy discussion.

I fear that Rutgers may have gagged their scientists from publicly speaking outside the science on public policy issues, perhaps in the wake of Professor Kennish’s courageous but politically controversial testimony about the “insidious ecological decline” of the Bay. Kennish explicitly criticized DEP’s science and Governor Christie’s Barnegat bay Management Plan. DEP attacked him and threatened Rutgers for that testimony.

The testimony of the final panel – the only “planners’ to testify –  was not only weak and unfocused, but basically a formality before adjourning. NJ Future testified that “some have suggested a Coastal COmmission”, but then backed away from that quickly after Senator Smith asked whether this Commission should have land use planning and regulatory powers.

Last, no public interest advocates, critics, coastal groups, or environmentalists were even invited to testify.

None even attended the hearing to monitor it.

I find this very strange, because just last Monday, Tim Dillingham  of American Littoral Society testified before the Senate Environment Committee that he was unable to even get a meeting with DEP Commisisoner Martin. This complaint prompted Senator Beck (R-Monmouth), who said she had met earlier that morning with The Rebuild Czar, to pledge to set up a meeting for Dillingham.

So, my guess is that coastal and environmental advocates were not invited to testify by the Democrats and they stayed away in a continuing sad posture of deference to the Christie Administration.

On a positive note, this was the Commttee’s first hearing – over 3 months after the storm – where serious policy issues were even broached.

But with every single issue that emerged  all going in the wrong direction, the hearing was a huge setback to efforts to cultivate a broader conversation about moving towards seriously addressing either climate change, coastal land use,  or coastal resilience.

Given these politics, I really don’t see much chance of making progress on either climate, adaptation, or coastal land use policy.

And while I do not support the Christie policy, I never thought I would have more respect for Gov. Christie and DEP Commissioner Martin’s policy – on any issue – than that of the Chairman of the Senate Environment Committee.

Senate Committee to Conduct Hearing Today on Coastal Planning and Sandy Rebuild

NJ Needs a Comprehensive Strategy for Reducing Vulnerability to Climate Change – Phase I: Sea- Level Rise and Coastal Storms

NJ Is The Only State in The Northeast With No Climate Change Plan

The Senate Budget and Appropriations Committee meets today in Toms River at 10 am to conduct a hearing – “to hear testimony from invited witnesses on issues surrounding coastal planning and rebuilding in the aftermath of Hurricane Sandy. ” You can listen live here .

We studied regional planning in Grad school, spent 13 years as an environmental planner at DEP, helped draft the Highlands Act, written many times about coastal planning issues, and in addition to strong criticism of the Christie administration, have made positive recommendations, see:

• A Path Forward on the Shore
• Coastal Commission Debate Engaged

We attended all of the Committee’s hearings, and signed up to testify at the hearing in Atlantic Highlands that was designed to take testimony from the public, but were blocked from speaking by the Chairman Sarlo, so of course we were not invited to testify today.

On Saturday, we suggested Massachusetts coastal program as a model.

So today, to supplement prior posts, below are the State of Maryland’s Coastal planning and climate change adaptation program key recommendations.

The Senate Environment Committee has looked to Maryland as a model for stormwater management and to the Chesapeake Bay Clean Water Act TMDL program as  a model for Barnegat Bay, so I thought they might want to consider Maryland’s  climate change program too, especially given the fact that NJ is the only state in the Northeast with  no climate change adaptation plan. 

We’ll attend the hearing and report what went down later today or tomorrow.

Here are Maryland’s key recommendations: 

Comprehensive Strategy for Reducing Maryland’s Vulnerability to Climate Change – Phase I: Sea- Level Rise and Coastal Storms

• Take action now to protect human habitat and infrastructure from future risks. Require the integration of coastal erosion, coastal storm, and sea-level rise adaptation and response planning strategies into existing state and local policies and programs. Develop and implement state and local adaptation policies (i.e., protect, retreat, abandon) for vulnerable public and private sector infrastructure. Strengthen building codes and construction techniques for new infrastructure and buildings in vulnerable coastal areas.

• Minimize risks and shift to sustainable economies and investments. Develop and implement long-range plans to minimize the economic impacts of sea-level rise to natural resource-based industries. Establish an independent Blue Ribbon Advisory Committee to advise the state of the risks that climate change poses to the availability and affordability of insurance. Develop a Maryland Sea-Level Rise Disclosure and Advisory Statement to inform prospective coastal property purchasers of the potential impacts that climate change and sea-level rise may pose to a particular piece of property. Recruit, foster, and promote market opportunities related to climate change adaptation and response.

• Guarantee the safety and well-being of Maryland’s citizens in times of foreseen and unforeseen risk . Strengthen coordination and management across agencies responsible for human health and safety. Conduct health impact assessments to evaluate the public health consequences of climate change and projects and/or policies related to sea-level rise. Develop a coordinated plan to assure adequacy of vector-borne surveillance and control programs.

• Retain and expand forests, wetlands, and beaches to protect us from coastal flooding. Identify high priority protection areas and strategically and cost-effectively direct protection and restoration actions. Develop and implement a package of appropriate regulations, financial incentives, and educational, outreach, and enforcement approaches to retain and expand forests and wetlands in areas suitable for long-term survival. Promote andsupport sustainable shoreline and buffer area management practices.

• Give state and local governments the right tools to anticipate and plan for sea-level rise and climate change. Strengthen federal, state, local, and regional observation systems to improve the detection of biological, physical, and chemical responses to climate change and sea-level rise. Update and maintain state-wide sea-level rise mapping, modeling, and monitoring products. Utilize new and existing educational, outreach, training and capacity building programs to disseminate information and resources related to climate change and sea-level rise.

• State and local governments must commit resources and time to assure progress. Develop state-wide sea-level rise planning guidance to advise adaptation and response planning at the local level. Develop and implement a system of performance measures to track Maryland’s success at reducing its vulnerability to climate change and sea-level rise. Pursue the development of adaptation strategies to reduce climate change vulnerability among affected sectors, including agriculture, forestry, water resources, aquatic and terrestrial ecosystems, and human health.

The Face of Corruption

Take a Look – Whose Face is That?

Political cartoonists are supposed to be bold and irreverent – to poke fun at and caricature the powerful and hold them accountable through humor. They can depict things in cartoons that more sober “objective” journalists can’t touch and even intrepid editorial writers can only suggest.

So, political cartoons play an important role and serve as a kind of barometer of our politics.

But what does it say when not even the cartoonists can tackle a politician?

Take a look at the face in that cartoon above. Is it anyone you recognize? The use of the words “aid application” even affirmatively diverts attention from the real issue, which was a no-bid contract.

And the powerful people lining up for the taxpayer money were not the little old ladies depicted in the cartoon, but a politically connected greedy corporation.

So the cartoon is not only lame, it’s misleading.

We all know that it refers to the AshBritt contract sandal. There were specific powerful people involved in and responsible for that scandal. Why the depiction of an anonymous faceless bureaucrat?

For those not paying attention, in the wake of last week’s AshBritt scandal, the faces sitting at the desk should have looked like Christie’s Rebuild Czar or the Governor himself –

By depicting an anonymous face, not only does the cartoonist fail to meet his professional and ethical obligations to target the powerful people who are responsible for the problem, but he falsely implies that other worthy agents, like FEMA Emergency Response officials, might be corrupt too.

So in case Jimmy Margulies somehow forgot what they look like, take a look at the faces responsible for the AshBritt Affair – as well as the Sandy Rebuild Madness (TM):

 

 

 

*[Note: The cartoon is used without permission of the cartoonist or the Bergen Record – I see this as a “fair use” under copyright law, as I am embellishing its meaning and using the cartoon to make a political point. I’ve had this argument with Margulies and Record lawyers in the past. I post this note in anticipation of another take down order from the Record. end]

Our Friends in Massachusetts Know That

Engineering, Sea Walls, Structural Solutions “Only as a Last resort”

 

[*update below]

I just saw the above dramatic photo in today’s New York Times’ article on Nemo, which stoked my curiosity and prompted a brief inquiry into how our friends in Massachusetts manage their highly vulnerable coast.

I can’t resist publishing my findings.

The Massachusetts folks are far more enlightened than our Rebuild Madness (TM) Governor, who continues to mislead the public about engineered solutions to coastal hazards and to deny increasing climate change vulnerabilities.

Just like NJ’s coastal experts (with the exception of a few hacks, who get all the newspaper quotes), here’s what state officials in Massachusetts’ Office of Coastal Zone Management say about sea walls and engineered “structural solutions” –

(so this is set out especially for you Gov. Christie and DEP Commissioner Martin):

ONLY AS A LAST RESORT: Flood and Erosion Control Structures

In the past, protecting coastal shorelines often meant structural projects like seawalls, groins, rip-rap, and levees. As understanding of natural shoreline function improves, there is a growing acceptance that structural solutions frequently cause more problems than they solve, and they are often not allowed under the Massachusetts Wetlands Protection Act. Structural protective measures often: