for Nature-Based Solutions
A Best Practices Guide
Green
Infrastructure
Federal /
Collaborative
oEPA
U.S. Department
of Transportation
Federal Highway
Administration
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Table of Contents
Introduction 1
Federal Statutes Applicable to NBS Implementation 3
Clean Water Act Section 402 3
Clean Water Act Section 404 4
Coastal Barrier Resources Act 5
Coastal Zone Management Act 6
Endangered Species Act 6
Magnuson-Stevens Fishery Conservation and Management Act 7
Marine Mammal Protection Act 7
Marine Protection Research and Sanctuaries Action Section 103 7
National Environmental Policy Act 8
National Historic Preservation Act 9
National Flood Insurance Program 10
Rivers and Harbors Act Section 10 11
Best Practices for NBS Permitting and
Environmental Reviews 12
Create Open Communication through Regional Permitting Networks 12
Dedicate Staff for Regional Permitting Programs 13
Increase NBS Knowledge for Federal Permitting and Environmental Review Staff ...13
Develop Permit Process Mapping 14
Use NEPA Categorical Exclusions 14
Regional NBS Permitting Network Examples 16
Bay Restoration Regulatory Integration Team (BRRIT) 16
Puget Sound Multi-Agency Review Team (MART) 17
Permitting and Environmental Review Case Studies 22
Beaver Restoration of Birch Creek 22
Mill River Watershed Urban Green Infrastructure 23
State Route 20 Skagit Riverbank Stabilization 24
Windy Hill Living Shoreline 25
Appendix A: NBS Permits, Reviews, Authorizations, and Consultations
Appendix B: NBS Resources and Guidance
References
Tables
Table 1. BRRIT Summary 16
Table 2. MART Summary 18
Figures
Figure 1. Example conventional permit process map. From adapted MART
diagram (2024) 19
Figure 2. Example streamlined permit process map. From adapted MART
diagram (2024) 20
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Abbreviations and Acronymns
BRRIT
Bay Restoration Regulatory Integration Team
CBRA
Coastal Barrier Resources Act
CBRS
John H. Chafee Coastal Barrier Resources System
CE
Categorical Exclusion
CEQ
Council on Environmental Quality
CGP
Construction General Permit
CLOMR
Conditional Letter of Map Revision
CWA
Clean Water Act
CZMA
Coastal Zone Management Act
DNR
Department of Natural Resources
EA
Environmental Assessment
EFH
Essential Fish Habitat
EIS
Environmental Impact Statement
EPA
United States Environmental Protection Agency
ESA
Endangered Species Act
FEMA
Federal Emergency Management Agency
GIFC
Green Infrastructure Federal Collaborative
FHWA
Federal Highway Administration
FONSI
Finding of No Significant Impact
FPRP III
Fish Passage and Restoration Programmatic
HRPP
Habitat Recovery Pilot Program
MART
Puget Sound Multi-Agency Review Team
MM PA
Marine Mammal Protection Act
MPRSA
Marine Protection Research and Sanctuaries Act
MS4
Municipal Separate Storm Sewer System
MSA
Magnuson-Stevens Fishery Conservation and Management Act
NBS
Nature-Based Solutions
NEPA
National Environmental Policy Act
NFIP
National Flood Insurance Program
NHPA
National Historic Preservation Act
NOAA
National Oceanic and Atmospheric Administration
NPDES
National Pollutant Discharge Elimination System
NWP
Nationwide Permit
PGP
Programmatic General Permit
RGP
Regional General Permit
RHA
Rivers and Harbors Act
USACE
United States Army Corps of Engineers
USFS
United States Forest Service
USFWS
United States Fish and Wildlife Service
WDFW
Washington Department of Fish and Wildlife
WSDOT
Washington State Department of Transportation
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Introduction
Nature-based solutions (NBS) are actions to protect, conserve, restore, and sustainably manage
natural or modified ecosystems. They use natural features or processes to address public health
and environmental challenges while providing multiple benefits to people and nature.1 One of the
benefits of NBS is reducing risks such as flooding, drought, wildfire, and urban heat (Warnell et
a I., 2023). NBS can also improve water and air quality while supporting biodiversity and habitat
connectivity. These benefits positively impact communities by helping them increase resiliency,
improve health, and increase access to nature.
The concept of working with nature to address
problems is not new; tribal and indigenous
communities in the United States have long
practiced NBS strategies, which are heavily
rooted in Indigenous Knowledge (CEQa, 2022).
While this guide uses the term NBS, other
organizations may use related terms such as
natural infrastructure, natural and nature-based
features, or green infrastructure.
The November 2022 White House Nature-
Based Solutions Roadmap identifies strategic
recommendations to unlock the potential of
NBS (CEQb, 2022). NBS can be implemented
as a standalone project (e.g., a living shoreline
project) or as part of a larger project (e.g.,
a bridge repair project that includes restoring a riverbank using NBS techniques). This guide
collectively refers to projects that implement NBS as "NBS projects." While there are numerous
examples of successful NBS projects, challenges may arise when implementing NBS, such as
federal environmental reviews and permitting. NBS projects may require multiple reviews and
permits from different federal agencies using different permitting and resource management
authorities, which can result in conflicting requirements and impact project schedules (Gregory
et a I., 2024; Howarth & Berkowitz, 2024). Additionally, federal permits, reviews, and processes
are often written with conventional infrastructure solutions in mind, which can add complexities
when evaluating NBS and may also slow the federal permitting and environmental review process
(Goodrich et al., 2023).
The Green Infrastructure Federal Collaborative (GIFC) is an effort that fosters engagement and
cooperations between federal agencies that actively work to promote the implementation of green
infrastructure and NBS. The GIFC developed this guide to help implement the White House Nature-
Based Solutions Roadmap by identifying ways to accelerate federal permitting and environmental
reviews for NBS projects. This document is intended to provide federal agencies involved in the
review of NBS projects with an overview of the federal permitting and environmental review
1. EPA. Clarification for types of 'actions': NBS encompass a wide range of actions that may include
the planning, design, and maintenance of engineering practices that restore, use or enhance natural
processes (e.g., green infrastructure, agricultural conservation practices, coastal restoration) and/or
protect natural features to preserve ecosystem function (e.g., wetlands, forests, riparian areas, coral
reefs).
NBS can address:
• Community resilience
• Disaster risk reduction
• Economic and social development
• Human health
• Food and water security
• Reversing environmental degradation
• Biodiversity loss
(IUCN, 2020)
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
processes related to NBS implementation; best practices
recommendations; and examples of NBS projects and
successful federal agency permitting networks that
have navigated and streamlined these reviews and
processes. Ultimately, environmental permitting and
approval is project-specific and will depend on the
unique characteristics of each project (e.g., location,
design, use of federal funding). This guide is meant to
further progress towards streamlining the process for
implementing NBS projects.
Opportunities for NBS extend across multiple
landscapes and land-use settings and range in scope
and scale. Examples of NBS projects, adapted from the
Department of Interior's NBS Roadman (Warnell et al.,
2023), are presented in the box below.
Photo Credit: Image provided by
Washington State Department of Transit
Nature-Based Solutions Examples
Coastal:
• Assisted marsh migration
• Beach nourishment
• Coastal wetland
restoration
• Coral reef restoration
• Dune restoration
• Living shoreline creation
• Mangrove restoration
• Oyster bed restoration
• Seagrass restoration
Inland Wetlands:
• Nontidal wetland
restoration
• Peatland restoration
Forest:
• Forest conservation and
restoration
• Green firebreaks
• Thinning
Grassland and Sagebrush:
• Grassland conservation
and restoration
• Sagebrush conservation
and restoration
Urban Green Infrastructure:
• Bioretention
• Bioswales
• Urban tree canopy
Riverine:
• Beaver management and
beaver dam analogs
• Floodplain reconnection
• Riparian buffer
restoration
• Riverine connectivity
restoration
• Stream restoration
Multiple Ecosystems:
• Invasive species,
nuisance pest, and
pathogen control and
removal
• Prescribed burns
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Federal Statutes Applicable to NBS Implementation
Many NBS projects require federal environmental
reviews, consultations, and permitting before they can
be implemented. NBS projects may also require similar
environmental authorizations at the state, territory, tribal,
and local levels because they either have delegated
authority from a federal statute or have implemented
their own laws and regulations that result in additional
permitting or authorization requirements. These various
layers can result in a complex approval process for NBS
projects. This section provides an overview of potentially
applicable federal statutes and highlights any permitting,
environmental reviews, or consultations required and any
approval streamlining mechanisms available under that
authority. It also demonstrates that many different federal
agencies can be involved in the environmental permitting,
consultation, and authorization of an NBS project.
Understanding the myriad of authorities that could
apply to NBS projects and the agencies that implement
them is an important step in increasing coordination and
collaboration across agencies.
Note that this section is not an exhaustive list of all federal environmental statutes. Ultimately, the
details of each specific project will determine which regulatory authorities need to be involved.
See Appendix A for additional details on specific authorities.
Clean Water Act Section 402
Implementing Federal Agency: EPA (many states and some territories are authorized to
administer the NPDES program)
Section 402 of the Clean Water Act (CWA)2 established the National Pollutant Discharge
Elimination System (NPDES) permit program. The NPDES permit program addresses water
pollution by regulating point sources that discharge pollutants into waters of the United States.
NPDES permitting authorities issue both Section 402 general permits and individual permits. An
NPDES individual permit is written to reflect site-specific conditions of a single discharger (or in
rare instances to multiple co-permittees), whereas an NPDES general permit is written to cover
multiple dischargers with similar operations and types of discharges.
An NPDES stormwater construction general permit (CGP) may be required for stormwater
discharges from construction activities associated with NBS projects if the construction involves
disturbing 1 acre or more of land. CGPs may also be required for stormwater discharges from
smaller sites that are part of a larger common plan of development or sale that disturb 1 acre or
more of land.
2. 55 u.sr.. § iMZ
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
NPDES permitting authorities also regulate discharges from some municipal separate storm sewer
systems (MS4s). NPDES MS4 permits are required to address minimum elements. In addition,
they require regulated MS4 owners or operators to develop, implement, and enforce a program to
reduce pollutants in any stormwater runoff into the MS4 from certain post-construction activities.
These permits generally require regulated MS4 owners or operators to:
• Develop and implement strategies that include a combination of structural and/or non-
structural best management practices appropriate for the community.
• Use an ordinance or other regulatory mechanism to address post-construction runoff from
new development and redevelopment projects to the extent allowable under state, tribal, or
local law.
• Ensure adequate long-term operation and maintenance of best management practices.
There may be additional local requirements, permits, or approval for certain NBS strategies.3
Clean Water Act Section 404
Implementing Federal Agencies: USAGE and EPA (Michigan and New Jersey have assumed the
Section 404 program in their states pursuant to Section 404[g] of the CWA)
Section 404 of the CWA4 establishes a program to regulate the discharge of dredged or fill
material into waters of the United States, including jurisdictional wetlands. The U.S. Army Corps
of Engineers (USACE) and the U.S. Environmental Protection Agency (EPA) jointly administer
the program. USACE implements the Section 404 program on a day-to-day basis and can
authorize activities via a general or individual permit depending on the project details and
impacts. EPA provides guidance and policy development, determines the scope of geographic
jurisdiction, reviews and comments on potential permit actions and mitigation proposals, conducts
enforcement, approves and oversees tribal and state Section 404 programs, and can prohibit,
deny, or restrict an area's use as a disposal site.
USACE general permits, which account for 94 percent of issued authorizations under Section
404, are intended to provide a faster, more streamlined approval process for defined categories
of activities with discharges that result in only minimal adverse effects to the environment. These
permits can be applicable nationally or only in certain regions or states.5 USACE general permits
include Nationwide Permits (NWPs), Regional General Permits (RGPs), and Programmatic General
Permits (PGPs). USACE divisions and districts may add regional and project-specific conditions to
NWPs, and USACE districts may develop RGPs to address state or regional laws and environmental
concerns.
3. Additionally, pursuant to Section 401 of the CWA, a federal agency may not issue a permit or license to
conduct any activity that may result in any discharge into waters of the United States unless a Section
401 water quality certification is issued or waived. States and authorized tribes where the discharge
would originate are generally responsible for issuing water quality certifications. In cases where a state
or tribe does not have authority EPA is responsible for issuing certification. Currently EPA acts as the
certifying authority in two scenarios: (1) on behalf of tribes without treatment in a similar manner as a
state for Section 401 and (2) on lands of exclusive federal jurisdiction in relevant respects.
4. 33 U.S.C. § 1344
5. 33 CFR Part 330
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Examples of potential USACE NWPs that can be utilized for NBS work include:
• NWP 13 - Bank Stabilization. Authorizes bank stabilization activities that control or prevent
erosion, among other requirements.
• NWP 27: Aquatic Habitat Restoration, Enhancement, and Establishment Activities.
Authorizes a variety of restoration activities in aquatic habitats that increase ecosystem
function, among other requirements.
• NWP 43: Stormwater Management Facilities. Authorizes discharges of dredged or fill material
for the construction of stormwater management facilities.
• NWP 54: Living Shorelines. Authorizes living shorelines up to 500 feet in length.
• NWP 59: Water Reclamation and Reuse Facilities. Authorizes discharges of dredged or fill
material for the construction, expansion, and maintenance of water reclamation and reuse
facilities, including vegetated areas enhanced to improve water infiltration and constructed
wetlands to improve water quality.
NWP 13 is an example of numerous USACE NWPs that, in some regions, have additional regional
conditions by a USACE district and/or state that require projects to use NBS techniques, unless
demonstrated to be infeasible.
Examples of Section 404 PGPs related to NBS include the New Orleans District PGP with the
Louisiana Department of Natural Resources—which authorizes oyster reefs, living shorelines, and
coastal marsh restoration projects—and the Baltimore District PGP with the Maryland Department
of the Environment (MDSPGP-6). which includes activities such as an aquatic habitat restoration
and living shorelines.6
Coastal Barrier Resources Act
Implementing Federal Agency: USFWS
The Coastal Barrier Resources Act (CBRA) established the John H. Chafee Coastal Barrier
Resources System (CBRS), a defined set of geographic units along the Atlantic, Gulf of Mexico,
Great Lakes, U.S. Virgin Islands, and Puerto Rico coasts (System Units of the CBRS). The CBRA
encourages the conservation of hurricane-prone and biologically rich coastal barriers. No
new federal expenditures or financial assistance may be made available within the System Units
of the CBRS—including for constructing or purchasing roads, structures, facilities, or related
infrastructure, and for most projects to prevent the erosion of or otherwise stabilize any inlet,
shoreline, or inshore area. However, after consultation with the U.S. Fish and Wildlife Service
(USFWS), a federal agency may make federal expenditures and financial assistance available within
System Units for activities meeting one of the exceptions under the CBRA, which include some
NBS, such as shoreline stabilization and fish and wildlife habitat enhancements. The CBRA does
not prohibit or restrict development conducted with non-federal funds, nor does it prohibit federal
agencies from issuing federal permits.
Federal agencies proposing to spend funds affecting a System Unit of the CBRS should initiate
the consultation process in the early stages of project planning. Federal agencies may request
technical assistance from the appropriate Ecological Services Field Office.
6. Refer to footnote 3.
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Coastal Zone Management Act
Implementing Federal Agency: NOAA National Ocean Service Office for Coastal Management
The Coastal Zone Management Act (CZMA)7 is administered by states subject to the National
Oceanic and Atmospheric Administration (NOAA) oversight, and it provides for the management
of the nation's costal resources. CZMA Section 307 gives states a strong voice in activities
requiring a federal license or permit, as well as federal agency activities that may affect a state's
coastal use or resources.8 Federal consistency requires that federal actions within or outside
the coastal zone, which have reasonably foreseeable effects on any coastal use (land or water)
or natural resource of the coastal zone, be consistent with the enforceable policies of a state's
federally approved coastal management program. Federal actions include federal agency
activities, license or permit activities, and financial assistance activities. NOAA oversees the CZMA,
and the various subparts of NOAA's CZMA federal regulations determine when a federal action is
subject to state CZMA federal consistency review.9 Coastal states are encouraged to develop and
implement coastal zone management plans as a basis for protecting, restoring, and establishing a
responsibility in preserving and developing the nation's coastal communities and resources.
Endangered Species Act
Implementing Federal Agencies: NOAA Fisheries and USFWS
The Endangered Species Act (ESA)10 requires consultation by federal agencies for actions they
fund, authorize, or carry out that may affect ESA-listed fish, wildlife, plants, or critical habitats. The
ESA also provides for interagency cooperation to avoid take of listed species and for conducting
consultations and providing authorizations for otherwise prohibited activities. In this context,
"take" means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect an ESA-
listed species, or attempt any of these actions against a listed species. NOAA National Marine
Fisheries Service (NOAA Fisheries) and USFWS, collectively referred to as "the Services," share
responsibility for implementing the ESA. NOAA Fisheries is responsible for protecting, conserving,
and recovering marine and anadromous species listed under the ESA. USFWS is responsible for
terrestrial and freshwater species, as well as sea birds, sea otters, manatees, and polar bears.
The two agencies share jurisdiction over species such as sea turtles, Gulf Sturgeon, and Atlantic
salmon. Interagency cooperation under ESA Section 711 provides a mechanism for federal agencies
to work with the Services to fulfill their obligation to consult. The Services can help determine
what type of consultation is necessary and what information is required for consultation with
NOAA Fisheries or USFWS.
The Services continue to develop efficiencies in the consultation process, including using
programmatic approaches, standing analyses and determination keys, and web-based delivery
for consultation aids. Section 7 programmatic consultations address a federal agency's multiple
actions on a program, geographic region, or other basis. A programmatic approach streamlines
7. 16 [J.S.C. § 1451 et sea
8. 16 [JSC § 1456
9. 15 CFR Part 950
10. 16 [J.S.C. § 15751-44
11. 16 [J.S.C. § 1556
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
the procedures and time involved in consultations for broad agency programs or multiple similar,
frequently occurring, or routine actions with predictable effects on listed species and/or critical
habitat, thus reducing the amount of time spent on individual project consultations. USFWS's
Information for Planning and Consultation web-based platform provides species information,
potential conservation measures, and in some cases consultation documents for selected activities
and species. Specific examples of programmatic consultations are provided in the Puget Sound
Multi-Agency Review Team section of this guide.
Magnuson-Stevens Fishery Conservation and Management Act
Implementing Federal Agency: NOAA Fisheries
The Magnuson-Stevens Fishery Conservation and Management Act (MSA)12 is the primary law
that governs marine fisheries management in U.S waters. MSA fosters the long-term biological
and economic sustainability of marine fisheries. It protects areas designated as Essential Fish
Habitat (EFH) and requires federal agencies to consult with NOAA Fisheries to avoid, reduce, or
compensate for any adverse effects to these habitats. NOAA Fisheries provides maps and/or other
information on the locations of EFH to help determine if a proposed action is located within or
adjacent to EFH, as well as information on ways to promote conservation of EFH and to facilitate
an EFH assessment.
Marine Mammal Protection Act
Implementing Federal Agencies: NOAA Fisheries and USFWS
The Marine Mammal Protection Act (MMPA)13 establishes a national policy to prevent marine
mammal species and population stocks from declining beyond the point where they cease to
be significant functioning elements of the ecosystems of which they are a part. MMPA has a
moratorium on taking and importing marine mammals—including parts and products—and defines
certain key federal responsibilities for conserving marine mammals. In this context, "take" means
to hunt, harass, capture, or kill any marine mammal, or attempt to do so. Sponsors of projects
that may impact marine mammals protected under the Marine Mammal Protection Act should
consult with NOAA Fisheries or USFWS, as appropriate, regarding the need for an incidental take
authorization.
Marine Protection Research and Sanctuaries Action Section 103
Implementing Federal Agencies: EPA and USAGE
The Marine Protection Research and Sanctuaries Act (MPRSA)14 regulates the transportation and
disposition of material in ocean waters and generally prohibits the disposition of material into
the ocean that would unreasonably degrade or endanger human health, welfare, or amenities, or
the marine environment, ecological systems, or economic potentialities. The MPRSA applies in
ocean waters which extend seaward of the baseline from which the territorial sea is measured and
12. 16 [J.S.C. § 1801 et sea.
13. 16 [J.S.C. § 1361 et sea.
14. 33 [J.S.C. § 1401 et sea
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
include the territorial seas, the contiguous zone, the U.S. exclusive economic zone and the high
seas extending to the exclusive economic zone of another country. The EPA and the USACE share
regulatory responsibilities under the MPRSA. Among other things, the EPA establishes criteria for
all MPRSA permits and MPRSA ocean sites and is the permitting authority for all materials other
than dredged material. MPRSA permits for ocean disposal of dredged material and federal projects
involving the disposal of dredged material are issued by USACE, subject to EPA's review and
written concurrence. Evaluations of the suitability of dredged material for ocean disposal include
evaluating alternatives to disposal, which may include dredged material use for beach nourishment
or other nature-based options.
National Environmental Policy Act
Implementing Federal Agencies: Most federal agencies
Activities with a federal nexus are subject to the National Environmental Policy Act (NEPA)15
requirements. NEPA requires federal agencies to assess the environmental effects of their
proposed actions and to coordinate and consult with other government agencies prior to making
decisions. In addition, it requires participation from the public to help inform decision-making.
NEPA is triggered by a range of federal actions, including funding and permit decision-making.
Each federal agency has its own implementing regulations and has adopted its own procedures
for NEPA. A NEPA review typically involves evaluating the environmental and related social and
economic effects of the proposed action. When NBS are implemented as part of a larger project,
such as a highway or bridge project, the NEPA review considers the project as a whole. The
White House Council on Environmental Quality's (CEQ's) NEPA implementing regulations provide
flexibility for federal agencies to eliminate duplication of efforts, adopt previous determinations
if applicable, and rely on existing information as appropriate through the NEPA process.16 As
part of a NEPA review, federal agencies may integrate other federal permitting requirements or
environmental reviews.
There are different levels of assessment for NEPA compliance, all of which require documentation:
• Categorical exclusion (CE). Normally issued within one week or up to two months after
adoption is complete, a CE is a category of actions that a federal agency has determined
in its NEPA procedures—after review by CEQ—normally does not have a significant effect
on the human environment17 and, therefore, neither an Environmental Assessment (EA) nor
an Environmental Impact Statement (EIS) is required. Agencies have the flexibility to adopt
another agency's CE by consulting with the agency that established it and then providing
public notice of the adoption. This process must be completed before the non-establishing
agency can use the CE.
• Environmental Assessment (EA). A decision document generally issued within one year,
an EA determines whether or not a federal action has the potential to cause significant
environmental effects. An EA briefly discusses the purpose and need for the proposed
action, alternatives, and their environmental effects. It also includes sufficient evidence for
determining whether or not to prepare an EIS. If the agency determines that the action
15. 4? [J.S.C. § 47,?] p.t sea.
16. 40 CFR § 1506.?. 40 CFR § 1506.5. 40 CFR § 1506.6
17. 40 CFR 150R.1fe')
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
will not have significant environmental impacts, the agency will issue a Finding of No
Significant Impact (FONSI). A FONSI is a document that presents the reasons why the agency
has concluded there are no significant environmental impacts projected to occur upon
implementing the action. If the EA determines the impacts of the proposed federal action will
be significant, an EIS is prepared.
• Environmental Impact Statement (EIS). A decision document generally issued within
two years, an EIS is required by NEPA if a proposed major federal action is determined to
significantly affect the quality of the human environment. An EIS discusses the purpose and
need of a proposed action, the range of alternatives to the proposed action, a description of
the affected environment, and the significant effects on the environment from a proposed
action to inform decisions-makers and the public. An EIS is a tool for decision-making that
helps to identify and mitigate the environmental impacts of a project.
National Historic Preservation Act
Implementing Federal Agencies: All federal agencies, SHPOs, THPOs
The National Historic Preservation Act (NHPA)18 establishes a national preservation program
and a system of procedural protections for proposed federal undertakings, which encourage the
federal government, states, and tribes to both identify and protect historic resources, including
archeological resources. NHPA Section 10619 and its implementing regulations20 were promulgated
to ensure federal agencies conduct a review of the potential effects of federally licensed, assisted,
regulated, or funded activities on historic properties listed or eligible for listing on the National
Register of Historic Places. The National Register is the official federal inventory of districts,
sites, buildings, structures, and objects significant on a national, state, or local level regarding
American history, architecture, archeology, engineering, or culture. Section 106 review requires
the federal agency, before issuing a license (i.e., permit), to identify areas of potential effect and
adopt measures—when feasible—to mitigate potential adverse effects of the licensed activity and
properties listed or eligible for listing in the National Register. Federal agencies must implement
NHPA's requirements in cooperation with state historic preservation officers (SHPOs) and tribal
historic preservation officers (THPOs). Upon notice and when appropriate, federal agencies must
also consult with the Advisory Council on Historic Preservation.
Federal agencies may develop programmatic agreements to satisfy the requirements of the NHPA
for more efficient and consistent reviews. Several NHPA nationwide programmatic agreements
currently exist, including agreements between the Advisory Council on Historic Preservation
and the U.S. Forest Service (USFS), Department of Defense, Department of the Interior, and
Department of Housing and Urban Development.
18. 54 [J.S.C. § 500101 et sea
19. 54 [J.S.C. § 506108
20. 56 CFR Part 800
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
National Flood Insurance Program
Implementing Federal Agency: FEMA
The National Flood Insurance Program (NFIP) was established with the passage of the National
Flood Insurance Act of 1968.21 Communities that participate in the NFIP and have been provided
with floodway data by the Federal Emergency Management Agency (FEMA) are required to adopt
and enforce the FEMA mapped regulatory floodways22 and corresponding floodplain management
requirements. Once a community has adopted a regulatory floodway development is restricted
in the floodway unless it has been demonstrated through hydrologic and hydraulic analyses
(performed using a FEMA-approved engineering model) that the development will not result in any
increase to the base flood elevation within the floodway. These analyses must show no increase of
base flood levels in the mapped regulatory floodway on FEMA's Flood Insurance Rate Maps.
Any project that will occur in a floodway must be reviewed to determine if it will increase flood
heights through a "no-rise" or "zero-rise" analysis before the community can issue a permit
for floodway development. The community's permit file must have a record of the results of
this analysis, which can be in the form of a "no-rise" or "zero-rise" certification from a qualified
registered professional engineer. If the project will cause an increase above the allowed flood level
in the floodway, then the permittee must assess risk to potentially affected properties and submit
a Conditional Letter of Map Revision (CLOMR) for FEMA review before the community can issue a
floodplain development permit.
It is the community's responsibility to determine the impacts of proposed development in the
regulatory floodway, whether they do the analysis in-house, contract with an engineer, or require
the applicant to submit the analysis and supporting documentation. FEMA provides some
broad, general guidance on reviewing floodway encroachment analysis. States may have specific
guidance on determining impacts and documenting the results as part of the state/local permit
process. For instance, some communities may require (as a higher standard) submission of a
CLOMR/Letter of Map Revision for all floodway development and not just encroachments that
cause an increase in flood hazards. That way, the community's map reflects current conditions
regardless of whether the development resulted in increases or decreases of the width or depth
of flooding. FEMA encourages communities to consult their State NFIP Coordinator or FEMA
Regional Office for tailored technical assistance and guidance on floodway encroachment reviews
and preparing CLOMR submittals.
NBS projects such as floodplain reconnection or restoration often cause an increase in the allowed
base flood elevation and are subject to CLOMR reviews before projects can be permitted. Several
states directly regulate all or most development in floodways and review and approve permits
for floodway development. The states may conduct the CLOMR reviews instead of FEMA. Both
a state permit and a permit from the community may be required for a floodway or floodplain
development in these states (FEMA, 2021).
21. 42 [J.S.C. § 4001 et sea.
22. Regulatory floodways are: "the channel of a river or other watercourse and the adjacent land areas that
must be reserved in order to discharge the base flood without cumulatively increasing the water surface
elevation more than a designated height" (FEMA).
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Rivers and Harbors Act Section 10
Implementing Federal Agency: USAGE
The Rivers and Harbors Act (RHA) of 189923 is the initiai authority for the USACE regulatory
permit program to protect navigable waters when developing harbors and undergoing other
construction and excavation. Section 10 of the RHA regulates actions that are part of many NBS
projects, including changes to dams or dikes in navigable waters; excavation, dredging, or disposal
in navigable waters; any actions that modify the condition, course, or location of a navigable
waterway; and discharges of dredged or fill material into waterways.24 Depending on the specific
project and location, proposed activities regulated by the RHA may be authorized by either a
USACE general permit or an individual permit. USACE individual permits are customized for
specific activities that do not qualify for a USACE general permit.
USACE general permits are intended to provide a faster,
more streamlined approval process for defined categories
of activities that result in only minimal adverse effects
to the environment. They may be applicable nationally
or only in certain regions or states.5 USACE general
permits include NWPs, RGPs, and PGPs. USACE. divisions
and districts may add regional and project-specific
conditions to NWPs, and USACE districts may develop
RGPs to address state or regional laws and environmental
concerns.
Examples of potential USACE general permits that can be
utilized for NBS work include, NWPJ3: Bank Stabilization; proWdecf
NWP 27: Aquatic Habitat Restoration, Enhancement, and
Establishment Activities; and NWP 54: Living Shorelines.
NWP 13 is example of numerous USACE NWPs that, in some regions, have additional regional
conditions by a USACE district and/or state that require projects to use NBS techniques, unless
demonstrated to be infeasible.
23. S U.S.C. § 401 fit .sen
24, 55 CFR Part 7,9.0
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Best Practices for NBS Permitting and
Environmental Reviews
This section builds on the recommendations from the White House Nature-Based Solutions
Roadmap (CEGb, 2022), discussion at the February 2024 Policy Forum on Nature-Based Solutions,
experience of the contributing agencies of the GIFC permitting implementation committee, and
the shared experiences from other federal and private NBS practitioners, regulators, and resource
managers. The best practices below are intended to be actionable within the current permitting
and environmental review landscape. They can apply to individual projects, at the regional scale,
and to decision-making within federal agencies.
Create Open Communication through Regional Permitting Networks
NBS project permit requirements are site-specific and therefore will have more similarities within
geographic regions rather than on a national scale. Regulatory agencies within a region can work
together to more efficiently implement NBS projects. Interagency coordination and collaboration
through regional permitting networks could improve efficiency as project teams navigate the
environmental permitting and review process. These networks provide a space for federal, state,
tribal, and regional regulatory authorities to collaborate on improving the overall permitting and
approval process and on permitting specific projects.
Best practices for regional permitting networks include establishing a charter, clearly identifying
roles of each agency and their authorities, meeting regularly, establishing a central workspace (e.g.,
SharePoint), collaborating on permitting problem solving, committing to continuous improvement,
and setting up an accountability mechanism for permitting agencies throughout the permitting
process.
An important step provided through regional permitting networks is early engagement, including
interagency pre-application meetings for projects. During these meetings, regulators and
applicants can work together before formally applying for a permit or entering a consultation,
which allows for potential conflicts or issues to be identified and prevents impacts to the project
schedule or changes to project designs later in the process. After this early engagement, regional
permitting networks can regularly track permitting progress with both the applicants and the
agencies and use a team approach to resolving
issues as they arise. These steps keep projects on
schedule and provide clarity and transparency about
the permitting process for the permittees.
Regional permitting networks have successfully
streamlined the NBS project permitting and approval
process in several geographic areas, as seen in the
following section. Expanding the use of regional
permitting networks is a beneficial practice that can
result in accelerated implementation of NBS projects
and their benefits to the ecosystem. This model of
communication can also be created and fostered
outside of formal regional permitting networks or on
a project-specific basis.
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Dedicate Staff for Regional Permitting Programs
Federal permitting staff with regional permitting knowledge can be a critical resource for every
phase of a project, from pre-application meetings to project decision-making, permit process
mapping, and process tracking and implementation. If an agency has the necessary funding
authority to accept outside funds, this may help facilitate strategic planning that enables policy,
guidance changes, and interagency agreements that span multiple federal, state, and local partners.
For example, some federal agencies have dedicated transportation liaisons funded by public entities.
These liaisons review projects funded by the Federal Highway Administration (FHWA) and help
build strong working relationships between transportation and resource agencies. These liaisons
facilitate early coordination, review transportation projects, and respond to state departments of
transportation priorities, which can ensure the long-term stability and continuation of permitting
efficiencies over time.
Another way to build capacity for NBS expertise is to use pre-established authorizations that allow
federal agencies to lead or support a streamlined permitting process specific to NBS projects. An
example is EPA dedicating resources for a project manager or permitting staff as part of the Puget
Sound Multi-Agency Review Team (MART). Another example includes Water Resources Development
Act funding that creates capacity for positions in agencies that are dedicated to a single organization,
such as with Snohomish County in Washington State. Interagency agreements like memoranda of
understanding can also help establish expectations or protocols between federal agencies regarding
NBS permitting and serve as a basis for building future capacity that is dedicated to NBS permitting.
Agencies can also dedicate permitting staff for NBS projects. Staff who are dedicated to performing
permitting actions for NBS projects rather than splitting time between multiple priorities will be
more successful and effective in reviewing projects, conducting consultations, and issuing permits.
Providing regional permitting programs appropriately with staff from each federal agency with NBS
expertise is an investment in the effectiveness and future sustainability of NBS projects.
Increase NBS Knowledge for Federal Permitting and Environmental
Review Staff
Permitting and environmental review staff may need training and time to develop and maintain
expertise in NBS and learn how to develop and navigate federal permitting for NBS projects. Staff
trainings can share NBS project permitting success stories, such as the case studies in this guide.
Trainings can also highlight how NBS projects differ from conventional development projects, as well
as how they can be permitted and approved under programmatic and/or streamlined authorizations
that differ from those for conventional projects. Agencies can develop policies and directives for
their permitting and staff that explain how NBS can fit into existing permits and requirements.
Interagency training may also provide valuable opportunities to share knowledge and best practices
across the federal family of regulatory and resource agencies. Training could be delivered in multiple
formats, including:
• On-demand virtual trainings such as those provided through NOAA's Office of Coastal
Management.
• Webinars offered through existing NBS-focused programs like the USACE Engineering with
Nature program or professional societies like the National Association of Wetland Managers or
Society of Wetland Scientists.
• In-person short courses for NBS-focused permitting and environmental reviews.
13
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Additionally, interactive workshops held at the local or regional scale with regulatory and resource
agencies, as well as practitioners, can enhance knowledge sharing and help develop best practices.
These workshops can also support federal agencies as they operationalize best practices.
Trainings may need to address NBS tools and methodologies to close information gaps and inform
decision-making, such as new resources to help quantity the benefits and evaluate the impacts of
NBS. Addressing data gaps may also lead to the development of new programmatic agreements for
consultation requirements and/or new expedited permitting mechanisms (e.g., new NBS-focused
general permits).
Develop Permit Process Mapping
Agency permitting staff are experts in how their own agency's permitting processes work, but
a key part of streamlining the overall process is improving interagency communication and
understanding other federal agencies' requirements related to authorizing NBS projects. The
previous section of this guide provided an overview of those requirements and serves as a
starting point for federal agencies to see how their requirements may interact with one another so
agencies can identify efficiencies.
Regional permit process mapping is a helpful tool for both regulatory agencies (federal, state, and
local) and project applicants, because permitting can often be complex. Process mapping enables
a shared understanding of each agency's role, authorities, and limitations, while also providing
a clear path to permit requirements prior to application submittal. Establishing the permitting
landscape and relative timelines increases transparency and stakeholder understanding. It also
provides an opportunity to identify and leverage available permitting and approval streamlining
mechanisms, such as programmatic consultations.
An example of this is the Federal Permitting Improvement Steering Council's (Permitting Council's)
existing permitting dashboard and timetable. The Permitting Council was established in 2015
by Title 41 of the Fixing America's Surface Transportation (FAST) Act (FAST-41) to improve the
transparency, predictability, and outcomes of the federal environmental review and authorization
process for certain large-scale critical infrastructure projects. The FAST-41 process provides
agencies with tools to efficiently coordinate federal environmental reviews and authorizations for
covered infrastructure projects across various sectors, some include renewable or conventional
energy production, surface transportation, and water resources. Their permitting dashboard
identifies and tracks interagency permitting and environmental review timelines. This highlights
how permit process mapping can bring a more unified and coordinated approach to permitting
NBS projects. Another example of permit process mapping developed by MART is presented in the
following chapter.
Use NEPA Categorical Exclusions
As discussed in the previous chapter, NEPA CEs are a category of actions that a federal agency
has determined normally do not have a significant impact on the environment and therefore do
not require an EA nor an EIS. Identifying and using CEs that apply to NBS projects could be a way
to streamline NEPA reviews for those projects. As previously noted, NEPA reviews consider the
project as whole; therefore, a CE must apply to any portion of the project with a federal nexus,
such as federal funding or a federal permit requirement.25
25. 4? [JSC Ch. 55
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Each agency has defined its own CEs, and federal agency staff conducting NEPA reviews and
those involved in authorizing NBS projects should be aware of the CEs available and how NBS
projects may fit into those CEs (see the text box below for examples). Recently Section 109 of the
2023 Fiscal Responsibility Act gave federal agencies the flexibility to adopt another agency's CE,
meaning federal agencies can adopt an existing CE without going through a notice and comment
process but must consult with the establishing agency and then provide public notice of the
adoption.26 While Congress can mandate new CEs or modify existing ones, agencies themselves
and the CEQ have administrative authority to create or adjust CEs within their regulatory purview,
and Executive Orders may also prompt CEs by directing agencies to focus on specific types of
projects or streamlined processes. To streamline NEPA reviews for NBS projects, federal agencies
could review CEs for other agencies and determine which ones they could adopt to accelerate
implementation of NBS projects. For example, if an agency often funds or conducts stream
restoration that agency may want to adopt CEs that could apply to stream restoration from other
agencies. A comprehensive list of CEs organized by federal agency and the guidance on how to
adopt another federal agency's CE are provided on CEQ's NEPA Categorical Exclusion page.
Example NBS types and example
• Assisted marsh migration (NOAA)
• Beaver management and beaver dam
analogs (USFWS)
• Floodplain reconnection (National
Resources Conservation Service)
• Forest conservation and restoration
(National Park Service)
• Grassland conservation and restoration
(USFS)
• Green firebreaks (USFS)
• Invasive species and nuisance pest and
pathogen control and removal (Federal
Bureau of Investigation)
sncies with a CE that may apply:
• Mangrove restoration (USFS)
• Nontidal wetland restoration (Tennessee
Valley Authority)
• Prescribed burns (USFWS)
• Riparian buffer restoration (Department
of Homeland Security)
• Riverine connectivity restoration (USFS)
• Sagebrush conservation and restoration
(USFS)
• Seagrass restoration (NOAA)
• Thinning (Bureau of Land Management)
• Urban green infrastructure (EPA)
26. Adoption of Categorical Exclusions Under Section 109 of the National Environmental Policy Act
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Regional NBS Permitting Network Examples
This section highlights the implementation of several best practices in this guide using two
examples of successful regional permitting networks that show the benefit of developing
interagency teams that include federal, state, and local partners. These networks create open
communication and build capacity by investing in dedicated staff for regional permitting
programs. They serve as examples for other existing regional networks and for new networks.
Bay Restoration Regulatory Integration Team (BRRIT)
BRRIT was formed to improve the permitting process for multi-benefit habitat restoration projects
and associated flood management and public access infrastructure in the San Francisco Bay and
along the shoreline of the nine Bay Area counties (excluding the Delta Primary Zone). BRRIT
assists applicants by having dedicated staff at each permitting agency available for pre-application
discussions. They provide guidance on regulatory requirements, clarification on permitting pathways,
and written responses to planning and design documents to help build trust in the permitting
process. BRRIT projects are selected by the San Francisco Bay Restoration Authority, which solicits
and evaluates proposals based on established criteria for restoration projects in the Bay Area.
Table 1. BRRIT Summary
Budget
$6 million for five years (2019-2024).
Contributing
Organizations
San Francisco Bay Restoration Authority (Measure AA), State Coastal
Conservancy, Bay Toll Authority, East Bay Regional Park District, and Santa Clara
Valley Water District.
Participating
Agencies
Federal: EPA, NOAA, USACE, USFWS.
State: San Francisco Bay Water Board, California Department of Fish and
Wildlife.
Reaional/local: San Francisco Bav Conservation and Develooment Commission.
Governance
San Francisco Bay Restoration Authority Policy and Management Committee;
representatives from all participating agencies.
Challenges
• Many agencies, many regulations.
• Differing and sometimes competing agency mandates (e.g., habitat
protection versus providing public access).
• Regulations were not developed with restoration in mind
• Sea level rise and urban infrastructure constraints.
Successes
20 projects permitted, of which two have been completed; projects include 36
permits issued or approved.
Keys to
Success
• Identification of potential conflicts before design is final, including through
pre-application meetings.
• Collaboration between agencies and applicants to resolve issues.
• Dedicated funding and resources for permit managers of BRRIT projects.
Website
httDs://www.sfbavrestore.orq/san-francisco-bav-restoration-reaulatorv-
intearation-team-brrit
Contact
BRRIT(a)waterboards.ca.qov
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
BRRIT's success is the result of many factors, one of which is continual communication both with
applicants and amongst the team. BRRIT operates in close coordination with applicants and
regulatory and resource agencies. This coordination happens early in the application process
with a pre-application meeting, and frequently throughout the permitting process. BRRIT also
provides many resources and tools on their website for permittees to refer to when planning a
restoration project. In addition, BRRIT members collaborate internally to ensure an efficient review
and approval process. Members use SharePoint to collaborate in parallel rather than individually
by agency. Satisfaction surveys and other post-permit interviews are part of the BRRIT approach
to ensure there is a feedback loop to continue to improve the services BRRIT is providing to
permittees. The Policy and Management Committee, a group of manager-level representatives
from each agency, meets monthly to work with BRRIT to identify and resolve regulatory and
policy issues limiting restoration progress that cannot be resolved at an individual project level.
Finally, BRRIT has dedicated program funding that allows time and resources to be used without
impacting current regulatory agency staffing budgets.
Puget Sound Multi-Agency Review Team (MART)
MART is a team of federal and state regulatory staff working together to streamline the
permitting process for habitat recovery projects in the Puget Sound Basin. MART uses a
facilitated, coordinated team approach to heip permit ecologically beneficial projects in both
marine and freshwater environments. Efforts focus on expediting the federal permitting process
in coordination with state and local permits. MART is informed about potential projects by
their partners and the Puget Sound recovery community. For each project, the MART facilitator
reaches out to the applicant and directs them to project-specific agency contacts and permitting
requirements. The applicant will then have a pre-application meeting with MART members
to obtain necessary information at the local, state, and federal levels before submitting their
application. These MART members hold monthly status check-ins on the project to troubieshoot
and coordinate interdependent permits. MART also practices continuous improvement by
assessing its process and implementing changes when needed.
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Table 2. MART Summary
Budget
0.10-0.20 full-time equivalent from organizations listed below.
Contributing
Organizations
EPA, USFWS, FEMA, NOAA Fisheries. Supported by the Puget Sound Federal
Leadershio Task Force and the Puaet Sound National Estuarv Program.
Participating
Agencies
Federal: EPA, USACE, USFWS, FEMA, NOAA Fisheries.
State: Washington Department of Fish and Wildlife (WDFW), Department of
Ecology, and Department of Natural Resources.
Regional/local: Puget Sound Partnership and coordination with local jurisdictions.
Governance
Facilitated and led by EPA. Representatives from all agencies listed above.
Created a governing document (or charter).
Challenges
• Many agencies, many regulations and requirements.
• Siloing of federal, state, and local agency permitting processes.
• Lack of communication and collaboration among agencies.
• Differing and sometimes competing agency mandates (e.g., habitat
protection versus providing public access).
• Unclear permit pathways and timelines for project implementers.
• Lack of consistent and available permit agency contacts.
• Regulations were not developed with restoration in mind.
• Inadequate permit agency staff capacity causes delays in permit issuance,
especially with increased project demand.
Successes
Six projects permitted out of 10 assisted by MART process; dedicated and
active federal staff.
Keys to Success
• Increase capacity of permit agency staff.
• Dedicate agency staff at USACE, NOAA, USFWS, and FEMA to work solely
on restoration project permitting.
• Develop and track emerging streamlined permitting efforts and disseminate
information to project proponents.
• Continued national and regional level support and funding for MART.
• Create an online application that can send a single application form to each
agency.
Website
httDs://www.DSD.wa.qov/MART.DhD
Contact
Diane Hennessev. EPA. Hennessev.diane(a)eDa.qov
MART brings federal, state, and local agencies together at the start of the permitting process rather
than having agencies work on review and approval one at a time. This collaboration brings a
coordinated team approach to permitting in the Puget Sound. MART works directly with the
applicant to identify which paths they should go down to streamline an otherwise unclear process.
The relevant permitting staff are involved from the beginning, which gives applicants points of
contact throughout the process. Staff also aid in navigating the federal permitting process, which
reduces permit processing time. Federal permit processing time for nearly all MART projects has
been 30 percent less than the average project.
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
One of the tools MART has used to reduce federal permit processing time is permit process mapping. MART and the Habitat
Recovery Pilot Program (HRPP) developed permit process maps for habitat restoration projects in Washington State, as shown
in Figure 1. The map below highlights the complex processes, permits, and estimated timelines that are typically required using
conventional pathways. The estimated timeline to receive all permits and authorizations required was 1 to 2.5 years.
Applicant Submittals
Non-concurrentiy (stepwise)
Land use permit
State E nvi ron m en 131 Pol icy
Act (SEPA)
Shoreline perm it application
Flood plain Habitat
Assessment (FEMA BiOpJ
Regional Road Maintenance
Program consistency {if
County)
Drainage perm it application
Grading permit application
Utilities permit a pplication
Joint Aquatic Resources
Permit Application (JARPA)
Design Pla ns
Critical Areas Assessment
Biological Assessment
Cultural Resources Analysis
Conventional Permitting Pathway Map for Habitat Restoration Projects
Washington Department of Fish and Wildlife (WDFW)
Biologist Review
Marine Shoreline
Design Guidelines
(MSDG) Design
Fill in
Online
JARPA
Hydra ul i c Project A pprova I
—~ (HPA) Permit
With Conditions/Mit'gation
Notcamjrtetc, more srrto
LOCAL JURIS DICTION
Pla rm er/Biologist Reiri ev/
Engineer Review/
SEPA
/
Not complete, marc into
Critical Areas approva I ~ Floodplain
Permit with
_ Shoreline Exemption or SDP FEMA BiOp
Determination ^ (Can use Corps
BA)
~ ShorelineCUP/Variance ~ ¥¦
Other local
permits issued
Review/ & Approval
Pla rm er/Biologist
Review
NWP
or IP?
NWP Review/
SEPA Dctcsmlnattan
Conor?
Letter of
Verification
=*• Public Notice
*
-~ 401 IP Review
Notcamptctc, mare brio
CORPS OF ENGINEERS
ESA comply
401/C2MA
Individual Permit ——
NWP Permit
Natcomittete, mare into
Estimated Permit
IssuanceTimelines from
complete application
~ 45 days
6 months to 1 year
Up to 180 days
Up to 1 year
1 to 2 years
Up to 6 months
Up to 4 months
¦* 1 or 2 years
6 months to 1 year
1 t o 4 mo nth s
BA: Biological Assessment
CUP: Conditional Use Permit
IP: Individual Permit
JPN: Apprcwed Jurisdictional
Determination
SDP: Shoreline
Development Permit
All permits issued
after application
su bmittal
1 to 2 years
Figure 1. Example conventional permit process map. From adapted MART diagram (2024).
19
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
As shown in the permitting pathway map in Figure 2, MART and HRPP streamlined the permitting for NBS projects by creating early
engagement with all agencies through a pre-application meeting, reducing redundant submittals, reducing the number of required
permits, and using programmatic permits or consultations. The streamlining reduced the estimated timeline to receive all permits
and authorizations from 1 to 2.5 years to 4 months to 1 year.
Permitting Pathway Map Habitat Restoration Projects under MART & HRPP
Applicant Submittals
to All Agenci es
concurrently
Flood plain Habitat
Assessment {FEMA BiOpf
Drainage perm it application
- possible
Joi nt Aq lb ti c Resou rces
Permit Application {JARPA}
Design Pla ns
Critical Areas Assessment
ESA Species Effects
Assessment
Cultural Resources Analysis
Department of Natural
Resources (DNR) Aquatic
Land Lease
WDFW
Fill in
Online
JARPA
Culture I Ass ess me nt
complete, state &/or fed era I
t Y«a
Biologist Review
H RPP Hydra ul i c Project
Approval (HPA)
HPA Permit
With
Conditions/
Mitigation
LOCAL JURISDICTION
Not complete, more info
ECOLOGY
Pla mer/Biologist
Review
Not complete, more info
CORPS OF ENGINEERS
Project Manager
Review
Not complete, more info
NOAA FISHERIES
&/OR USFWS
Not complete, more info
Perm it started
Planner/Biologist Review/
Engineer Review
Floodplain
Permit with
ESA
compliance
FEMA CUD MR Review
Flood plain pcfmrt
Possible
stormwater
c permit
NWP
or IP?
NWP Review
—~ Letter of
Verification
Public Notice
~
4011P Review
Biologist Rwiew
Individual
CWA Exempt
(nofed nexus}
Sect. 106 ESA com ply
Sect. 106 -j- ESA comply
11
1
401/CZMA
Exempt Letter
Ulttiytojdwwtiyallttl
Project NOTUU|fto«lv(8(t|rJtlKt
TypeT
Restoration projects (no hard at
Individual Permit
N WP Permit
likely to apply
Full consultation
Informal consultation
Programmatic permits - likely to apply
Not complete, more info
Estimated Permit Issuance
Timelines from complete
application
45 Days
6 months to 2 yea rs
4 to 6 months
2 to 4 months
6 months to 1 year
1 or 2 years
Up to 6 months
Up to 4 months
-*• 1 to 2 years
6 months to 1 year
0.5 to 4 months
IP: Individual Permit
JPN: Approved Jurisdictional
Determination
WDFW: Washington
Department of Fish and
WildRfe
All permits issued
after application
submittal
4 months
to 1 year
Figure 2. Example streamlined permit process map. From adapted MART diagram (2024).
20
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
MART also tracks applicants' progress and directs applicants to streamlined pathways for
regulatory compliance. ESA compliance can often be complex and lengthy unless a project
qualifies for a programmatic consultation instead of a consultation with NOAA Fisheries and
USFWS. When USAGE Seattle District is the lead federal permitting agency, one NOAA Fisheries
programmatic consultation that can be used for a variety of NBS projects is the Fish Passage and
Restoration Programmatic (FPRP ili) consultation established in 2017 (USAGE, 2024). FPRP III
authorizes a variety of restoration activities in aquatic habitats that benefit fish and their habitat
and increase ecosystem function, among other requirements. USAGE also collaborates with
USFWS on Fish Passage and Restoration Programmatic consultation that covers species for which
USFWS is responsible. The USFWS Fish Passage and Restoration Programmatic covers many of
the same NBS strategies covered under the NOAA Fisheries FPRP III. In Washington State, when
federal agencies other than USAGE are the lead permitting agency—such as FHWA—the USFWS
and NOAA Fisheries may consult on a variety of NBS projects under their joint Programmatic
Restoration Opinion for Joint Ecosystem Conservation by the Services, or PROJECTS (NOAA
Fisheries & USFWS, 2020).
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Permitting and Environmental Review Case Studies
The case studies below showcase permitting and environmental reviews of four different NBS projects. They
demonstrate the use of many of the best practices discussed above and how the permitting and approval
process can vary greatly depending on the NBS strategy and project location.
Beaver Restoration of Birch Creek
Project Background
In 2014, USFS, Utah State University, and a local rancher
took on a project to restore Birch Creek in Preston, Idaho.
The purpose of this project was to regenerate Birch Creek
and restore downstream habitats and creek flow by
reintroducing beavers into the watershed. Beaver dams
naturally convert flooding liabilities into groundwater assets,
which provide downstream flooding mitigation in wet
months and longer periods of flow in drier months. Prior
to this project, beaver populations in the area were being
trapped and killed, causing local watershed degradation.
This degradation impacted downstream water supplies
needed for agriculture in local communities and aquatic
habitats. The project involved closing beaver trapping
and hunting in the Birch Creek drainage area to protect
beaver populations and building beaver dam analogs on a
section of the creek. Beaver dam analogs create a deeper
water habitat to entice the beavers to stay in the area. The
Birch Creek drainage area was closed to beaver trapping
and hunting by the end of spring 2015, and all beaver dam
analogs for this project were installed by 2016.
Environmental Authorizations and Permitting Required
This project was required to obtain stream alteration
authorization from USACE and the Idaho Department of Water Resources. The proposed beaver
dam analogs were located on USFS land, so a NEPA review was required. USFS determined the
project qualified for a CE that allowed for restoring wetlands and streams by modifying water control
structures. Pre-application activities, consultations, and application submittals took place from 2014 to
2015, and the project permits were issued in 2015.
Best Practices
USFS staff had a deep understanding of beaver co-benefits and used their good working relationships
with the other regulators involved to communicate those benefits. Both USFS's and Utah State University's
experience with beaver restoration also allowed them to justify utilizing a NEPA CE in a creative way to
expedite the NEPA review timeline. Support from a local rancher involved in the project helped influence the
permitting agencies toward a positive outcome. The rancher actively advocated for beavers to return to his
ranch because he understood the environmental benefit they provide. Open communication and extensive
knowledge of this NBS allowed the permitting process to be successfully completed within one year.
Project Success
Birch Creek now flows for over 40 days longer than in previous years without the beavers. Returning
beavers to the creek enhanced fish habitat and biodiversity. Rare fish populations increased by over
1,000 percent because the beaver activity improved watershed health and created more wetland habitats
needed by hundreds of different species as well as countless migratory birds and butterflies. Lastly, this
project was estimated to cost 99 percent less than traditional stream restoration.
Project at a Glance
NBS strategy: Beaver Restoration
Location: Preston. Idaho
Agencies: USFS, USACE, Idaho Fish
and Game, Idaho Department of
Water Resources
Permitting Best Practices
• Creating open communication
• Increasing NBS knowledge
• Using NEPA Categorical Exclusions
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Mill River Watershed Urban Green Infrastructure
Project Background
In fall 2018, Connecticut nonprofit Save the Sound
began implementing two successful green infrastructure
projects in the Mill River watershed. They partnered with
a variety of other local organizations (Hamden Land
Conservation Trust, Mill River Trail Advocates, Mill River
Watershed Association, Urban Resources Initiative),
municipalities (town of Hamden, city of New Haven), and
the Yale School of Forestry and Environmental Studies to
construct a bioretention facility in the town of Hamden
and bioswales in the city of New Haven to protect the Mill
River, an impaired water body, from stormwater pollution.
The first project involved a town park in Hamden that had
no stormwater management and received a significant
amount of piped stormwater. The lack of stormwater
management caused flooding even during moderate
rainfall events and the discharge of untreated stormwater
into the Mill River. To solve these issues, a 2.5-acre
bioretention facility was constructed to provide treatment,
storage, and infiltration of the piped stormwater prior to
discharge into Mill River. The second project was in the
City of New Haven, which was also extremely susceptible
to flooding during high-intensity, short-duration rainfall
events. Part of New Haven experiences combined sewer
overflows during wet weather, which causes bacteria
pollution in the Mill River. To address these concerns,
numerous bioswales were strategically installed in areas
with flooding and stormwater pollution concerns. As of
April 2024, 286 bioswales were installed in New Haven.
Environmental Authorizations and Permitting Required
EPA awarded a Community Grant to Save the Sound to partially fund these projects. In this instance,
projects receiving federal funding from an EPA Community Grant must undergo NEPA review.
EPA determined that this project was eligible for a CE because it involved minor rehabilitation and
replacement of an existing stormwater system. No federal permitting was required for this project, but
the project was required to go through local stormwater program management review and appoval.
Best Practices
Using a CE streamlined the NEPA review timeline and allowed the projects to be completed quickly
without a lengthy environmental review process.
Project Success
These projects improved water quality in the Mill River watershed, provided green space for
communities with environmental justice concerns, and improved public health. Volunteers from New
Haven help maintain the newly installed bioswales, reducing maintenance costs. The bioretention facility
in Hamden manages over 20 million gallons of stormwater annually.
¦
Project at a Glance
NBS strategy: Urban green
infrastructure
Location: Hamden and New Haven,
Connecticut
Agencies: EPA and local municipalities
Permitting best practices:
Using NEPA Categorical Exclusions
Photo Credit: Image provided by Dawn
Henning, City of New Haven, Connecticut,
23
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State Route 20 Skagit Riverbank Stabilization
Project Background
In 2014, the Washington State Department of
Transportation (WSDOT) partnered with FHWA in Skagit
County, Washington, to protect a section of State Route
20 that passes through the Skagit River's fioodplain.
A river meander had begun to infringe on the highway
right of way, spurring WSDOT to pursue a riverbank
stabilization project spanning over 500 feet in length to
both protect the highway and benefit fish habitat. The
project installed a series of concrete dolos, jacks, and
large woody materials designed to stabilize the bank and
allow for revegetation.
Environmental Authorizations and Permitting Required
This project was required to obtain a USACE CWA Section
404 individual permit due to the project exceeding the
500-foot threshold limit for the general permit NWP-
13: Bank Stabilization. It also required ESA essential fish
habitat consultation, an NHPA Section 106 consultation,
and an FHWA Section 4(f) evaluation.
Best Practices and Lessons Learned
The permitting agencies worked together as a team
to review and coordinate on permit conditions. Open
communication and coordination among agencies were
important to the permit process for this project, which
was viewed as an innovative NBS project at the time.
Several layers of the dolo-timber structures were intentionally designed by WSDOT as deformable,
which meant the project footprint would naturally change over time. However, the CWA Section
404 permit language for this project treated these structures as static with a strict impact footprint,
resulting in one dolo-timber that shifted location over time had to be removed from the river by
WSDOT at high cost. This experience reveals an important lesson learned for permitting large NBS
installations of this type, especially in areas with high or powerful flows. If permit language provided to
the agency does not adequately reflect the adaptive nature of NBS design, costly fixes may occur in the
future to maintain permit complian.
Project Success
Federal permitting staff expanded their knowledge base by supporting this effort and learning about
the project's innovative design and multiple benefits. This project showcased that bank stabilization can
be achieved with NBS techniques and that NBS may be as dynamic as the locations in which they are
installed. Ten years later, WSDOT's design is still working as intended, and large natural woody material
and vegetation has accumulated impressively at the site. The natural accumulation of woody material
over time has proven to be very effective at lessening flows in a neighboring tide channel without
completely cutting it off, protecting both the highway, an adjacent road, and adjacent fish habitats.
WSDOT has monitored the site since the project was completed in 2014 and has found the installation
has needed little maintenance. Biological monitoring shows that there has been no adverse effect on
important fish spawning habitats in the area.
Photo Credit: Image provided by Washington
State Department of Transit
Project at a Glance
NBS strategy: Riverbank stabilization
Location: Skagit County, Washington
Agencies: FHWA, NOAA Fisheries,
USACE, USFWS, and WSDOT
Permitting best practices: Creating
open communication
24
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Windy Hill Living Shoreline
Project at a Glance
NBS strategy: Living shoreline
Location: Centreville, Maryland
Agencies: USAGE. NOAA Fisheries
and Maryland Department of the
Environment
Permitting best practices:
• Creating open communication
• Increasing NBS knowledge
Project Background
In 2010, the Maryland Department of Natural Resources
(DNR), in coordination with the Delmarva Resources
Conservation and Development Council and Underwood
& Associates, restored a stretch of eroding shoreline
along the Corsica River in Centreville, Maryland. At
the time of its construction, the project was one of
Maryland's most innovative shoreline restorations. Prior
to restoration, the site had a failing wooden bulkhead,
and stormwater flowed into the river with no stabilized
banks, which resulted in excessive sediment discharges.
The erosion was also threatening residential properties
along the shoreline. Maryland DNR took advantage of this
opportunity to implement a unique design that included a
crescent shoreform instead of straightening the shoreline,
used smooth cobblestones instead of typical large
angular rocks, incorporated woody debris from trees that
were removed during construction to enhance the shallow
water habitat, seeded the tombolos with native seeds,
and included green infrastructure upstream to slow runoff
before it reached the shoreline.
Environmental Authorizations and Permitting
Required
The project was authorized by USACE under the USACE Maryland State Programmatic General
Permit-6. The Maryland Department of the Environment also authorized the project through a joint
permit application with USACE, and NOAA Fisheries conducted an ESA consultation. Monitoring, which
can add additional complexity and expenses, was funded through an agreement with NOAA Fisheries
and the Virginia Institute of Marine Science. The consultation and permit application process ran from
winter 2008 to summer 2009, and final approvals and permits were issued in spring 2010.
Best Practices
Before beginning application and consultation activities, the project team held multiple meetings in
winter 2008 with the relevant federal, state, and local agencies. The project designer participated
in these meetings, which created open dialogue with regulatory agencies and allowed the project
team to incorporate input from the regulators into the project's design. For example, NOAA Fisheries
was concerned with the proposed amount of encroachment of the proposed living shoreline into the
channel because they wanted to protect against filling of open water. The project team presented
NOAA Fisheries with scientific literature and other project examples supporting the proposed design.
Ultimately, NOAA Fisheries approved the project based on the scientific evidence provided. The project
team ensured reviewers were informed of why projects decisions were made by maintaining open lines
of communication.
Project Success
The project was successful largely due to pre-application activities and the partnership between the
regulatory agencies and the project leads. The design was innovative at the time, and its success helped
reshape the language of the USACE Maryland State Programmatic General Permit-6 special conditions,
which now include language about incorporating woody debris into living shoreline designs.
25
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Appendix A: NBS Permits, Reviews, Authorizations, and Consultations
The information in this appendix can be used to better understand the specific environmental permits and authorizations a project
may be required to obtain and the consultations and reviews a project may be subject to in order to make the permitting and
approval process more efficient. It also describes the important pre-application steps of a pre-application meeting and community
outreach. The following is not an all-inclusive list of federal authorities that may apply to an NBS project. Applicants should
coordinate with federal agencies for project specific federal permitting requirements, as well as coordinate with state and local
authorities for other permitting needs.
1. PRE-APPLICATION
Interagency Pre-Application Meeting - Pre-application coordination between applicants and agencies is strongly encouraged. Benefits of
pre-application meetings include improved communication, better quality of applications, reduced duplication of efforts, and an open line of
communication during the review process. All these items can result in a more streamlined and efficient permitting process.
Community Outreach, Coordination, and Planning - Coordination with the community is also a crucial step depending on project location and
its impacts to the community.
2. PERMITS/AUTHORIZATIONS
Agency
Statute/Authority
Potential Permits/
Authorizations
Application Form(s)/
Process
Notes
U.S.
Environmental
Protection
Agency (EPA)
/ Authorized
State, Territory
or Tribe
Clean Water Act
(CWA) - Section 401
Water Quality Certification
Varies by Authorized State,
Territory or Tribe / EPA
CWA - Section 401
Under Section 401 of CWA, a federal
agency may not issue a license
or permit to conduct any activity
that may result in any discharge
into waters of the U.S. unless the
authorized tribe or state where
the discharge originates either
issues a Section 401 water quality
certification or waives certification.
EPA/
Authorized
State,
Territory, or
Tribe
CWA - Section 402
(National Pollutant
Discharge Elimination
System Permit
Program)
1. Construction General Permit
(CGP)
2. Section 402 Individual Permit
CWA - Section 402 (National
Pollutant Discharge
Elimination System)
EPA CGP application process
For land disturbance of at least one
acre or part of a common plan of
development of at least one acre.
A-l
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
2. PERMITS/AUTHORIZATIONS
Agency
Statute/Authority
Potential Permits/
Authorizations
Application Form(s)/
Process
Notes
EPA
Marine Protection
Research &
Sanctuaries Act
(MPRSA)
MPRSA permit - Section 102 (All
materials, other than dredged
material)
MPRSA Permits
MPRSA regulates disposition and
transportation of material in the
ocean, subject to limited exceptions.
EPA issues permits for all materials
other than dredged material.
Federal
Emergency
Management
Agency
(FEMA)
FEMA - Floodolain
Standards National
Flood Insurance
Program
Development permit
FEMA Permit for Floodolain
Develooment
A permit is required before
construction or development
begins within any Special Flood
Hazard Area.
National
Oceanic and
Atmospheric
Administration
(NOAA) /
State Agency
Coastal Zone
Management Act
Federal Coastal Consistency
Determination
Each state has a federal
consistency list which
identifies the federal agency,
federal license or permit, and
federal financial assistance
activities that are subject to
federal consistency review.
Federal consistency lists vary
bv state: see httos://coast.
noaa.QOv/czm/consistencv/
states/ for more details.
Under the CZMA, a state may review:
activities conducted by, or on behalf
of, a federal government agency
within or outside the coastal zone
that affects any land or water use
or natural resource of the coastal
zone; an application for a federal
license or permit; and any plan for
the exploration or development,
or production from, any area that
has been leased under the Outer
Continental Shelf Lands Act for
offshore minerals exploration or
development. The CZMA requires
federal agency activities to be
consistent to the maximum extent
practicable with the enforceable
policies of a state's approved coastal
zone management program.
A-2
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
2. PERMITS/AUTHORIZATIONS
Agency
Statute/Authority
Potential Permits/
Authorizations
Application Form(s)/
Process
Notes
United States
Army Corps
of Engineers
(USACE)
CWA - Section 404 -
Discharge of dredged
or fill material into
Waters of the US
River and Harbors
Act of 1899 -
Section 10 - Work
or Structures, In,
On, Over or Under
Navigable Waters of
the US
MPRSA - Section
103 - USACE and
EPA share regulatory
responsibility for
disposal of dredged
material and USACE
issues the permits.
1. General permits/Pre-
Construction Notification -
includes Nationwide
Permits (NWP), Regional
General Permit (RGP) and
Programmatic General Permit
(PGP)
a. Pertinent examples of
NWPs include, but are
not limited to:
NWP 13 (10/404) - Bank
Stabilization
NWP 27 (10/404) -
Aquatic Habitat,
Restoration,
Enhancement, and
Establishment Activities
NWP 43 (404) -
Stormwater
Management Facilities
NWP 54 (10/404) -
Living Shorelines
NWP 59 (404) - Water
Reclamation and Reuse
Facilities
RGPs
2. Individual Permit (includes
Standard Permits and
Letters of Permission)
Application Portal:
Reaulatorv Reauest Svstem
(armv.mil)
USACE Reaulatorv Program Website
Information on how to obtain an
USACE Dermit (armv.mil)
Summarv Table of 2021 Final
Nationwide Permits (oclc.ora)
A-3
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
3. FEDERAL CONSULTATIONS AND REVIEWS
Agency
Statute/Authority
Available Consultations/
Reviews
Consultant Process
Notes
Lead Federal
Agency
National
Environmental Policy
Act (NEPA)
1. Categorical Exclusion (CE)
Determination
2. Environmental Assessment
(EA) and Finding Of No
Significant Impact (FONSI)
3. 3. Environmental Impact
Statement (EIS) and Record of
Decision (ROD)
NEPA Review Process
NEPA requires federal agencies to
assess the environmental effects
of their proposed actions, and
coordinate with other government
agencies prior to making decisions.
NEPA is triggered by a range of
federal actions including funding and
permit decision-making.
NOAA
Magnuson-Stevens
Fishery Conservation
and Management Act
Federal agencies must consult
with NOAA National Marine
Fisheries Service (NOAA
Fisheries) when activities they
undertake or permit have the
potential to adversely affect
essential fish habitat (EFH).
Consultations for EFH 1
NOAA Fisheries
EFH consultation is required when:
1) a federal action has funded,
authorized, or undertaken all or part
of a proposed action and 2) The
action will "adversely" affect EFH.
An adverse effect includes direct
or indirect physical, chemical, or
biological alterations.
NOAA /
U.S. Fish
and Wildlife
Service
(USFWS)
Endangered Species
Act - Section 7
Federal agencies must consult
with NOAA Fisheries, USFWS or
both, before taking any action
that may affect an endangered
or threatened species or their
critical habitat.
Informal Consultation:
Request for Concurrence
Formal Consultation:
Biological Assessment
USFWS-Section 7
Consultation for ESA
NOAA Fisheries Section 7
Consultation for ESA
Information for Planning and
Consultation
Consultation for federal permitting/
authorizations, funding, carrying out
activities (i.e., federal actions), to
provide exemptions to the Section
9 take prohibitions of the ESA (if
necessary, formal consultation)
"Federal actions" are those that are
funded, authorized, or carried out by
a federal agency.
A-4
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
3. FEDERAL CONSULTATIONS AND REVIEWS
Agency
Statute/Authority
Available Consultations/
Reviews
Consultant Process
Notes
NOAA /
USFWS
Fish and Wildlife
Coordination Act
Any federal agency issuing
permits must consult with
USFWS and NOAA Fisheries if
the proposed activities could
potentially harm fish and/or
wildlife resources.
Wildlife Coordination Act
Consultation
Habitat Consultations
These consultations may result in
project modification and/or the
incorporation of measures to reduce
these effects.
State Historic
Preservation
Officer
(SHPO) /
Tripal Historic
Preservation
Officer
(THPO)
National Historic
Preservation Act
(NHPA) - Section 106
Any federal agency issuing a
permit to account for potential
effects of the proposed activity
on historic properties (e.g.,
shipwrecks, prehistoric sites,
cultural resources) must consult
with the SHPO and/or THPO (as
well as local governments and
other interested stakeholders).
Varies by Authorized State,
Territory or Tribe
NHPA - Section 106 review reauires
the federal agency, before issuing a
license (permit), to identify areas of
potential effect, adopt measures—
when feasible—to mitigate potential
adverse effects of the licensed
activity and properties listed or
eligible for listing in the National
Register of Historic Places.
USFWS
Coastal Barrier
Resources Act
Federal agencies must consult
with USFWS before making
federal expenditures and
financial assistance available
within System Units pursuant to
statutory exceptions in certain
relatively undeveloped coastal
areas.
Coastal Barrier Resources Act
Consultation
Coastal Barrier Resources Act
Consultations Flow Chart
A-5
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Federal Permitting and Environmental Reviews for Nature-Based Solutions
Appendix B: NBS Resources and Guidance
Building Community Resilience with Nature-Based Solutions: A Guide for Local Officials. FEMA
Building Community Resilience with Nature-Based Solutions. Strategies for Success. FEMA
Department of the Interior Nature-Based Solutions Roadmap. Department of the Interior
2024 Efficient Permitting Roadmap. A guide to the regulatory process for sediment management
on the North-central California Coast. North-Central California Coastal Sediment Coordination
Committee
Engineering with Nature, an Atlas. USACE
Engineering with Nature Program webpage. USACE
Funding Nature Not Paperwork. Policy and Programmatic Pathways to Speed Restoration
Permitting. Environmental Policy Innovation Center
Incorporation of Nature-Based Solutions in Civil Works Projects Memorandum. USACE
Green Infrastructure Federal Collaborative webpage. EPA
Nature-Based Solutions webpage. FEMA
Nature-Based Solutions Resource Guide, compendium of federal examples, guidance, resource
documents, tools, and technical assistance. White House Council on Environmental Quality, White
House Office of Domestic Climate Policy White House Office of Science and Technology Policy
Opportunities to Accelerate Nature-Based Solutions: A Roadmap for Climate Progress. Thriving
Nature Equity. & Prosperity. White House Council on Environmental Quality White House Office of
Domestic Climate Policy White House Office of Science and Technology Policy
Pav for Success and Streamlined Permitting Database. Environmental Policy Innovation Center
Permitting Dashboard Cperformance.gov). Permitting Council /FAST-41 Resources
2024 Resilience Project Funding Guide. Department of Defense Readiness And Environmental
Protection Integration Program
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References
Federal Permitting and Environmental Reviews for Nature-Based Solutions
FEMA. (2021). Guidance for flood risk analysis and mapping floodway analysis and mapping.
https://www.fema.qov/sites/default/files/documents/fema floodwav-analvsis-mappinq 112021.pdf
Goodrich, K. A., Ulibarri, N., Matthew, R., Stein, E. D., Brand, M., & Sanders, B. F. (2023). Toward
improved sediment management and coastal resilience through efficient permitting in California.
Environmental Management, 72(3), 558-567. https://doi.org/10.1007/s00267-023-01804-1
Gregory, A., Lopes, J., Powell, K., & Altman, S. (2024). Beneficial use of dredged material in the
Atlantic Intracoastal Waterway: Approaching the regulatory process. USACE Engineer Research
and Development Center, https://erdc-librarv.erdc.dren.mil/items/b1426a6b-8fd4-45ad-9dcf-
d669c89e61d0
Howarth, M., & Berkowitz, J. (2024). Perspectives on permitting and environmental review of
nature-based solutions. World Environmental & Water Resources Congress 2024.
https://ascelibrarv.orq/doi/10.1061/9780784485477.035
ICUN. (2020). IUCN Global Standard for Nature-Based Solutions: A user-friendly framework for the
verification, design and scaling up of NBS: First edition. https://doi.org/10.2305/IUCN.CH.2020.08.en
NOAA Fisheries & USFWS. (2020). Projects contractors handbook, https://www.fws.gov/sites/
default/files/documents/2020.11.19%20Contractor%20Handbook%20REVISED%20Ver1.2.pdf
Permitting Council. (2021). Federal environmental review and authorization inventory. Permitting
Dashboard Federal Infrastructure Projects, https://www.permits.performance.gov/tools/federal-
environmental-review-and-authorization-inventorv
USACE. (2024). Electronic permit guidebook: Endangered species. US Army Corps of
Engineers. https://www.nws.usace.armv.mil/Missions/Civil-Works/Regulatorv/Permit-Guidebook/
Endangered-Species/
Warnell, K., Mason, S., Siegle, A. Merritt, M. & Olander, L. (2023). Department of the Interior nature-
based solutions roadmap (Nl R 23-06). Nicholas Institute for Energy, Environment & Sustainability,
Duke University, and U.S. Department of the Interior, https://www.nicholasinstitute.duke.edu/
publications/department-interior-nature-based-solutions-roadmap
White House Council on Environmental Quality (CEQa). (2022). Memorandum for heads of
federal departments and agencies: Guidance for federal departments and agencies on indigenous
knowledge. https://www.whitehouse.gov/wp-content/uploads/2Q22/12/OSTP-CEQ-IK-Guidance.pdf
White House Council on Environmental Quality (CEQb), White House Office of Science and
Technology Policy, White House Domestic Climate Policy Office. (2022). Opportunities for
accelerating nature-based solutions: A roadmap for climate progress, thriving nature, equity, &
prosperity. Report to the National Climate Task Force, https://www.whitehouse.gov/wp-content/
uploads/2022/11/Nature-Based-Solutions-Roadmap.pdf
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