The NRDA Early Restoration Project Selection is Underway –Which Candidates Will Make the Cut?
Our natural resource trustees are drafting a restoration plan for the Gulf Coast that will be paid for by BP and the other polluters through the Natural Resources Damages Assessment (NRDA) process. Many projects have been submitted, and many are posted online by NOAA, and Florida. For Louisiana, where much of the natural resource injury from BP’s disaster has occurred, and where there is a legacy of oil damage as well as restoration, there are over 400 projects listed.
NRDA money is separate from damages to property, damages to commercial enterprises, and other injuries to individuals as a result of oil spills. NRDA money is also separate from whatever Clean Water Act fines Congress allocates towards long-term ecosystem restoration, as determined by the president’s Gulf Task Force. NRDA money is supposed to go toward projects that restore natural resources to their pre-oil spill conditions, and to compensate the public for lost ecosystem services like shoreline protection, and to restore public access to nature for recreation. The NRDA process is lengthy because it involves a thorough assessment of all the damages caused by the oil spill, and is guided by the trustees (representatives from state and federal agencies), who have the ultimate authority to decide the course of restoration efforts. Right now, the trustees are working to select “early restoration” projects – those that can be implemented before the entire NRDA injury assessment process is complete.
Cracking Open the Black Box
Federal laws set general criteria for selecting projects; and Louisiana has additional criteria due the regularity of oil spills in the state. Beyond these guidelines, the trustees have not shared the specific criteria, like the Gulf Future or Oxfam guidelines (note: link to documents), that will be used to select projects .
Our worry is that the trustees won’t explain how they are going to evaluate restoration projects, and they’ll be free to choose projects that do not accomplish restoration goals, or worse – are bad for the Gulf coast.
The goal of early restoration projects is to stop damage and restore ecosystem services as soon as possible. An acre of saline marsh built in 2011 instead of 2021 not only restores ecosystem functions and provides habitat for wildlife, but staves off further damage to wildlife and coastal marshes that only become more difficult to counteract as time passes.
For the public, early restoration projects are good news, because it means that environmental damage can be minimized, without waiting for the full injury assessment. Although BP has allocated $1 billion to early restoration efforts, this funding is only a down payment. But each project will generate offsets against BP’s future payments, so there is a possibility the early restoration projects would be the only ones ever implemented with BP’s NRDA funding.
NOAA posted some recommendations on the website of the types of projects that would be appropriate, including marsh creation, seagrass restoration, hydrologic restoration, beach renourishment, land conservation, oyster reef restoration, and improvements to recreational infrastructure. Louisiana has stated that the implementation of its “early” projects should happen within 18 months, which would exclude all Diversion projects.
Scoping the Scoping List
We at Gulf Restoration Network have scanned the project ideas (Excel file) submitted for Natural Resource Damage Assessment (NRDA) funding, and found that several of them aren’t restoration projects at all. On the NOAA site alone, there are 153 projects (64%) that in some way restore or maintain ecosystem services, 36 that will bring people into nature for “recreation,” 30 projects that are just good ideas, and 20 projects (8%) that are actually purely destructive.
On the one hand, it’s great that a full two-thirds of the projects on the NOAA site actually look like restoration—on the other, we’ve got to stop the absurdity of spending restoration monies on projects that injure the Gulf Coast.
What restoration looks like –integrated ecosystem services
Restoration should involve projects that work, that work with coastal communities, and work together to repair different kinds of injury. For example, here are examples of projects that could be implemented quickly and work to restore the Mississippi Gulf Coast:
Create a Beneficial Use Trust Fund to use dredged sediments beneficially, to build
back Barrier Islands like Deer Island and Ship Island.
Oyster reef restoration: Restore historic upthrusting reefs or place designed reefs
for habitat in Mississippi Sound.
3. Seagrass restoration: Restore to historic levels Mississippi's seagrass beds.
4. Create a Coastal Preserve Trust Fund to acquire private marshes and shorelines or to
manage public lands for preservation of their services.
What does it cost to plant a rock?
In Louisiana there are many projects that, rather than rebuilding ecosystem services themselves, “armor” the working marshes we have left with rocks and rip-rap. Although the best practices for shoreline protection build “Living Shorelines” that protect while providing habitat, carbon sequestration, and primary productivity, there are many projects that only provide the meager amount of protection that rocks give. For the tens of millions of dollars and years spent on the rock armoring of shorelines, the Trustees could build actual marshes and oyster reefs that would protect shores, provide habitat, and grow with the rising sea level, while the rocks sink.
If the trustees are scoring projects by the amount of ecosystem services they provide, a living shoreline project would rank above a rock armoring project. But we do not know the criteria for selecting projects.
Public service, but not ecosystem services
Some projects do nothing to restore ecosystem services or recreation, and even injure the natural resources further. The City of Mobile has proposed to construct a police headquarters and to rebuild fire stations. A number of projects on the list – proposals to improve drainage or to repair roads – also fall far off the mark. While these projects provide a public service, they certainly do not provide ecosystem services or clean water. If they are built in wetlands, these projects will only cause further injury.
More worrisome are the projects that seem to be restoration. One project combines a restoration project with road construction. Another in Mississippi calls for building a massive Aquarium that would intercept passing wild dolphins, temporarily detaining them for view by the visiting public. Although an aquarium would educate people about nature, it would do nothing for recreation, the footprint of the building could impair coastal wetlands, and the capture of wild dolphins will only further injure their natural population.
Without a specific statement of their evaluation criteria, the trustees are free to pick useless or even destructive projects.
The process of choosing among the hundreds of projects will be a difficult one. So it is critical that the trustees’ decisions are guided by specific criteria, and that these criteria are made available to the public. The trustees owe it to the public to make their selection process as transparent as possible, to do their best to restore the Gulf with limited NRDA funding.
Scott Eustis is the Coastal Wetland Specialist for the Gulf Restoration Network. Kara McQueen-Borden is a Healthy Waters Intern.