United States Government Accountability Office

GAO Report to the Honorable Wayne T.

Gilchrest, House of Representatives 

COASTAL BARRIER 

RESOURCES SYSTEM

Status of Development 

That Has Occurred 

and Financial 

Assistance Provided 

by Federal Agencies 

March 2007 

 

GAO-07-356 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2007

COASTAL BARRIER RESOURCES 

SYSTEM 

Status of Development That Has 

Occurred and Financial Assistance 

Provided by Federal Agencies 

Highlights of GAO-07-356, a report to the 

Honorable Wayne T. Gilchrest, House of 

Representatives 

In 1982, Congress enacted the

Coastal Barrier Resources Act. The

Coastal Barrier Resources Act, as

amended (CBRA), designates 585 

units of undeveloped coastal lands 

and aquatic habitat as the John H.

Chafee Coastal Barrier Resources

System (CBRS). CBRA prohibits 

most federal expenditures and 

assistance within the system that 

could encourage development, but 

it allows federal agencies to

provide some types of assistance 

and issue certain regulatory

permits. In 1992, GAO reported that 

development was occurring in the 

CBRS despite restrictions on 

federal assistance. GAO updated 

its 1992 report and reviewed the

extent to which (1) development 

has occurred in CBRS units since 

their inclusion in the system and 

(2) federal financial assistance and 

permits have been provided to 

entities in CBRS units. 

GAO electronically mapped

address data for structures within

91 randomly selected CBRS units 

and collected information on 

federal financial assistance and

permits for eight federal agencies. 

What GAO Recommends

GAO recommends, among other 

things, that the four agencies that 

provided prohibited loan

guarantees or insurance policies to 

CBRS units first verify and then 

cancel those that are in violation of

CBRA. Three agencies agreed with 

our recommendation; VA did not, 

stating that it would inflict unfair 

harm to the affected veterans. 

An estimated 84 percent of CBRS units remain undeveloped, while 16 

percent have experienced some level of development. About 13 percent of 

the developed units experienced minimal levels of development—typically 

consisting of less than 20 additional structures per unit since becoming part 

of the CBRS, and about 3 percent experienced significant development— 

consisting of 100 or more structures per unit—since becoming part of the 

CBRS. According to federal and local officials, CBRA has played little role in

the extent of development within the CBRS units that we reviewed because 

they believe that other factors have been more important in inhibiting 

development. These include (1) the lack of suitably developable land in the 

unit; (2) the lack of accessibility to the unit; (3) state laws discouraging 

development within coastal areas; and (4) ownership of land within the unit 

by groups, such as the National Audubon Society, who are seeking to 

preserve its natural state. In units that GAO reviewed where development 

had occurred, federal and local officials also identified a number of factors 

that have contributed to development despite the unit’s inclusion in the 

CBRS. These include (1) a combination of commercial interest and public 

desire to build in the unit, (2) local government support for development, 

and (3) the availability of affordable private flood insurance. 

Multiple federal agencies have provided some financial assistance to 

property owners in CBRS units that is expressly prohibited by CBRA; some 

assistance allowed under CBRA; and hundreds of permits for federally 

regulated development activities within the unit. Specifically, four 

agencies—the Department of Housing and Urban Development, the 

Department of Veterans Affairs, the Federal Emergency Management 

Agency, and the Small Business Administration—provided financial 

assistance, such as flood insurance and loan guarantees, totaling about $21 

million that is prohibited by CBRA to property owners in CBRS units. 

Although most of these agencies had processes in place to prevent such 

assistance from being provided, they cited problems with inaccurate maps as

being a key factor leading to these errors. With regard to financial assistance 

allowed by CBRA, GAO found that three federal agencies have provided 

such assistance but did not track how much assistance they provided, so the 

total extent of this assistance is unknown. With regard to permits issued in 

CBRS units for federally regulated activities, GAO identified hundreds of 

permits issued by the Army Corps of Engineers and state agencies

authorized to issue permits on behalf of the Environmental Protection 

Agency. These permits covered various activities such as the construction 

of piers, the discharge of dredged or fill material into federally regulated 

waters, and permits associated with water discharges from construction 

sites or wastewater treatment systems. 

www.gao.gov/cgi-bin/getrpt?GAO-07-356.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Anu Mittal at 

(202) 512-3841 or mittala@gao.gov. 
Contents 

Letter 1

Results in Brief 4

Background 6

CBRS Remains Largely Undeveloped 10 

The Extent to Which Federal Agencies Have Provided Financial 

Assistance and Permits to Entities in CBRS Units Varies 16 

Conclusions 26

Recommendations for Executive Action 27 

Agency Comments and Our Evaluation 27 

Appendix I Objectives, Scope, and Methodology 29 

Appendix II CBRS Units We Reviewed 35 

Appendix III Snapshots of Selected CBRS Units 40 

Massachusetts 40

Rhode Island 43 

South Carolina 47 

Florida 49

North Carolina 52 

Appendix IV Programs and Types of Federal Assistance Analyzed 57 

Appendix V Comments from the Department of Housing and Urban 

Development 60 

Appendix VI Comments from the Department of the Interior 62 

Appendix VII Comments from the Department of Veterans Affairs 64 

Page i GAO-07-356 Coastal Barrier
Appendix VIII GAO Contact and Staff Acknowledgments 66 

Tables 

Table 1: Examples of FEMA Disaster Assistance Since 1998 24 

Table 2: CBRS Units Included in Random Sample and Approximate 

Number of New Structures 35 

Table 3: CBRS Units Included in GAO’s Random Sample That Were 

Analyzed to Determine the Extent of Federal Expenditures 

and Permits 38 

Table 4: Additional CBRS Units Suggested for Review by FWS That 

Were Analyzed to Determine the Extent of Federal 

Expenditures and Permits 39 

Figures 

Figure 1: Boat Meadow CBRS Unit in Massachusetts 11 

Figure 2: CBRS Units We Visited in Massachusetts 41 

Figure 3: House and Beach on the Squaw Island, CBRS Unit in

Massachusetts 42

Figure 4: CBRS Units We Visited in Rhode Island 44 

Figure 5: Home with a Backyard in the Prudence Island, Rhode 

Island CBRS Unit 45 

Figure 6: Portion of the Prudence Island Complex CBRS Unit 46 

Figure 7: Inlet Where Proposed Dredging Project Would Occur in 

the Prudence Island CBRS Unit 47 

Figure 8: CBRS Units We Visited in South Carolina 48 

Figure 9: CBRS Units We Visited in Florida 50 

Figure 10: CBRS Units We Visited in North Carolina 53 

Figure 11: House in North Topsail CBRS Unit on the Edge of the 

Ocean 55

Page ii GAO-07-356 Coastal Barrier
Abbreviations 

CBRA Coastal Barrier Resources Act as amended 

CBRS John H. Chafee Coastal Barrier Resources System 

DHS Department of Homeland Security 

DOI Department of the Interior 

EPA Environmental Protection Agency 

FEMA Federal Emergency Management Agency 

FHWA Federal Highway Administration 

FWS Fish and Wildlife Service 

HUD Department of Housing and Urban Development 

IHP FEMA’s Individuals and Households Program 

NFIP FEMA’s National Flood Insurance Program 

NOAA National Oceanic and Atmospheric Administration

NPDES EPA’s National Pollutant Discharge Elimination System 

OPA Otherwise Protected Areas 

SBA Small Business Administration 

VA Department of Veterans Affairs 

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Page iii GAO-07-356 Coastal Barrier
United States Government Accountability Office

Washington, DC 20548 

March 19, 2007 

The Honorable Wayne T. Gilchrest 

House of Representatives 

Dear Mr. Gilchrest: 

The U.S. coasts are among the most rapidly growing and developed areas 

in the nation. From 1980 to 2003, the population in U.S coastal areas is 

estimated to have increased by 33 million people and is projected to 

increase by another 7 million people by 2008. Coastal barriers, such as 

islands and broad sandy barrier beaches, serve as the mainland’s first line 

of defense against the impacts of hurricanes and coastal storms. These 

areas are also biologically rich and provide protection for a variety of fish 

and wildlife species, including migratory birds, shellfish, and sea turtles. 

While the geological composition of coastal barriers makes them highly 

unstable areas on which to build, their desirable waterfront locations 

make them attractive for development. As development and population 

increase, the risk to human life, property, and valuable habitat increases, 

and the natural buffers that minimize storm damage are degraded. For 

example, when Hurricane Isabel made landfall along North Carolina’s 

Outer Banks in 2003, it caused widespread wind and storm surge damage 

to several piers, several thousand homes and businesses, and damaged or 

washed away sections of a highway. 

Recognizing that development in coastal barrier areas can be impacted by

the actions and programs of the federal government, Congress enacted the

Coastal Barrier Resources Act in 1982. The stated purpose of the Coastal 

Barrier Resources Act as amended (CBRA) is to minimize (1) the loss of 

human life; (2) wasteful expenditures of federal revenue; and (3) damage 

to fish, wildlife, and other natural resources associated with coastal 

barriers along the Atlantic and Gulf Coasts and the shores of the Great 

Lakes by restricting future federal expenditures and financial assistance, 

which have the effect of encouraging development of coastal barriers. 

Through CBRA, Congress designated 585 units of undeveloped coastal 

land and associated aquatic habitats comprising nearly 1.3 million acres as 

the John H. Chafee Coastal Barrier Resources System (CBRS).1

 Congress, 

 1

For the purposes of CBRA, a coastal barrier was considered undeveloped if the density of

development was less than one structure per 5 acres of land above mean high tide. 

Page 1 GAO-07-356 Coastal Barrier
through the Coastal Barrier Improvement Act of 1990, also designated an

additional 1.8 million acres already held for conservation or recreation, 

such as national wildlife refuges, national parks and seashores, and state 

and county parks, as otherwise protected areas (OPA). 

CBRA does not prohibit development in CBRS units by owners willing to 

develop their properties without the benefit of federal financial assistance, 

such as federal flood insurance, loans, grants, subsidies or other forms of 

direct or indirect federal assistance.2

 Instead, with certain exceptions, 

CBRA prohibits federal expenditures or financial assistance within CBRS 

units that might encourage development. The prohibition includes—but is 

not limited to—the issuance of flood insurance policies, home loans, loan

guarantees, and new or expanded infrastructure construction within CBRS 

units. However, the act does exempt certain federal expenditures or 

financial assistance from the general prohibition, such as emergency 

operations that are essential to saving lives, maintaining and replacing

existing publicly owned infrastructure, energy development, and activities 

related to national security. In addition, CBRA allows agencies to issue 

permits to entities within the CBRS for certain federally regulated 

activities, such as the construction of bridges and docks or the discharge 

of dredged or fill materials into waters that fall under federal jurisdiction. 

Under CBRA, no single federal agency is assigned overall responsibility for 

administering activities in the CBRS; instead, all federal agencies must 

abide by the provisions of the act and are required to certify annually that

they are in compliance with CBRA.3

 CBRA does assign the Secretary of the 

Interior responsibility for, among other things, the tasks of consulting with 

other federal agencies that propose spending funds within the CBRS, 

maintaining maps for each CBRS unit, and recommending modifications to

CBRS unit boundaries, as needed. These maps are used by property 

owners; federal, state, and local agencies; and other parties, such as 

insurance agents, to determine whether a property or planned project is 

 2

Financial assistance as defined by the act does not include general revenue sharing grants; 

deposit or account insurance for customers of financial institutions; the purchase of 

mortgages or loans by federal associations or corporations such as the Federal National 

Mortgage Association; assistance for environmental studies, planning, and other 

assessments that are required incident to the issuance of permits or other authorizations

under federal law; and assistance for programs entirely unrelated to development, such as

the federal old-age survivors or disability insurance program. 

3

Such reports and certifications shall be submitted annually to the Secretary of the Interior. 

16 U.S.C. § 3506(b). 

Page 2 GAO-07-356 Coastal Barrier
within a CBRS unit and therefore whether it is ineligible for federal 

financial assistance. Within the Department of the Interior (DOI) these 

responsibilities belong to the U.S. Fish and Wildlife Service (FWS). The 

existing maps that depict CBRS unit boundaries are outdated 

technologically and present challenges to users. In May 2006, the 

Congress directed the Secretary of the Interior to initiate a map 

modernization project for all of the units in the CBRS that is to be 

completed by 2013.4

 This effort is designed to create digital maps of all 

CBRS units that are more accurate and less time consuming for agencies 

and others to use than the maps currently available. 

In 1992, we reported that development was occurring in some CBRS units 

despite restrictions on federal assistance.5

 CBRA has been amended 

several times and the CBRS has expanded to include significantly more 

units. In this context, you asked us to update our 1992 report and review 

the extent to which (1) development has occurred in the CBRS and (2) 

federal agencies have provided financial assistance and issued permits to 

entities in CBRS units. 

To determine the extent of development that has occurred within CBRS 

units, we selected a stratified random sample of 91 units located 

throughout the system. The sample included units designated as part of 

the system in 1982 and 1990. We did not include otherwise protected areas 

in our analysis. For each unit, we obtained and electronically mapped 

address or parcel data for structures within the unit boundaries.6

Throughout this report, the percentage of units that have experienced 

development is a statistical estimate based on our analysis of the 

development in the 91 randomly selected units, which can be projected to

the entire system. The random sample was stratified by region to select an 

equal number of units in northern and southern regions. In addition, we 

conducted site visits and/or interviewed officials for a subset of 59 units in 

13 states to determine the extent of and reasons for development. To 

determine the extent of federal expenditures and financial assistance 

made to individuals and entities within CBRS units, we identified and 

 4

Coastal Barrier Resources Reauthorization Act of 2005, Pub. L. No. 109-226, § 4(a), 120 Stat 

381. 

5

GAO, Coastal Barriers: Development Occurring Despite Prohibitions Against Federal 

Assistance, GAO/RCED-92-115 (Washington, D.C.: July 17, 1992). Our 1992 report only 

covered units designated by the original 1982 act. 

6

We electronically mapped the location of the addresses using MapInfo Software. 

Page 3 GAO-07-356 Coastal Barrier
collected information on financial assistance provided in selected CBRS 

units from those federal agencies that, based on our previous report and 

our discussions with FWS, were the most likely to have provided 

assistance. These agencies include the Department of Homeland Security’s 

(DHS) Federal Emergency Management Agency (FEMA), Federal Highway 

Administration (FHWA), Small Business Administration (SBA), U.S. Army 

Corps of Engineers (the Corps), U.S. Department of Agriculture, 

Department of Housing and Urban Development (HUD), and the 

Department of Veterans Affairs (VA). We also interviewed officials with 

these agencies about the agencies’ procedures for preventing prohibited 

expenditures from being provided to individuals and entities in CBRS 

units. To determine the extent to which federal agencies issued permits for 

projects within selected CBRS units, we interviewed officials and analyzed 

data provided by the Corps, the Environmental Protection Agency (EPA), 

and state agencies authorized to administer EPA programs. The 

information we gathered on federal financial assistance and permits 

cannot be generalized to the entire universe of CBRS units. We determined 

that the agency data were sufficiently reliable for the purposes of our 

review. A more detailed description of our scope and methodology is 

presented in appendix I. We performed our work between February 2006 

and February 2007 in accordance with generally accepted government 

auditing standards. 

Most units within the CBRS remain undeveloped; however, about 3 

percent of units have experienced significant levels of development. 

Specifically, an estimated 84 percent of all CBRS units have remained 

undeveloped (no new structures were built) since they were included in 

the system, while about 13 percent have experienced minimal levels of 

development—consisting of less than 20 additional structures per unit 

since becoming part of the CBRS. An estimated 3 percent of units 

experienced significant development—consisting of 100 or more 

structures per unit—since becoming part of the CBRS. According to 

federal and local officials, CBRA has played little role in the extent of 

development within the CBRS units that we reviewed. For those units that 

have remained undeveloped, officials identified the following factors as 

being primarily responsible for inhibiting development (1) the lack of 

suitably developable land in the unit; (2) the lack of accessibility to the 

unit; (3) state laws discouraging development within coastal areas; and (4) 

ownership of land within the unit by groups, such as the National Audubon 

Society, who are seeking to preserve the natural state of the unit. For 

those units that we reviewed where development has occurred, local 

officials said that CBRA did little to discourage development and identified 

Results in Brief 

Page 4 GAO-07-356 Coastal Barrier
the following factors as being primarily responsible for contributing to 

development: (1) a combination of commercial interest and public desire 

to build in the unit, (2) local government support for development to 

improve the economic base of the area, and (3) the availability of 

affordable private flood insurance. Overall, we found that CBRS units in 

the southern region of the United States are experiencing greater 

development than units in the north. This is largely because the amount of 

developable land is greater in the south. 

Federal agencies have provided some financial assistance that is 

prohibited by CBRA, some assistance that is allowed under CBRA, and 

issued hundreds of permits for federally regulated construction projects to

property owners and other entities in CBRS units. More specifically, 

• Four agencies—FEMA, HUD, SBA, and VA—provided financial assistance 

to property owners in CBRS units that is prohibited by CBRA. For 

example, we determined that 73 FEMA flood insurance policies with total 

policy values of $20 million and 5 HUD insured loans totaling $384,000 

were made to entities in CBRS units and were active in 2006. While FEMA, 

SBA, and VA have procedures in place intended to prevent prohibited 

financial assistance from being provided to property owners in CBRS 

units, HUD does not have such procedures. FEMA officials cited the lack 

of updated CBRS maps and limitations with mapping technology as the 

primary reasons why errors were made and assistance was provided to 

entities within the CBRS. FWS has begun a congressionally directed effort

to modernize and correct CBRS unit maps. However, according to FWS 

officials, completing that effort is contingent upon receiving specific 

funding for the effort. In the meantime, FWS is working with FEMA to 

update the digital flood maps used by FEMA—an effort that should 

improve FEMA’s, insurance agents’ and other’s ability to determine if a 

property is eligible for federal flood insurance. VA and SBA officials 

acknowledged that they had provided assistance prohibited by CBRA and 

told us that they will monitor compliance with their procedures more 

carefully in the future. HUD officials told us that they have no procedures 

under their single-family mortgage insurance programs related to CBRA 

because it would be unnecessary in practical terms. For example, agency

officials believed it was unlikely that these programs would fund projects 

in the CBRS because of the high-priced homes generally found in these 

areas. In response to our findings, HUD officials said that they would be 

developing CBRA policy guidance and associated training to ensure future 

compliance.

• Three federal agencies have provided some financial assistance that is 

allowed under CBRA, but the total extent of this assistance is unknown. 

Page 5 GAO-07-356 Coastal Barrier
For example, in the past 10 years, FEMA has provided at least $5.6 million 

in disaster assistance to the unit in North Topsail, North Carolina, for 

debris removal and repairs. Similarly, FHWA has provided $1.1 million for 

road repair to the unit in Cape San Blas, Florida. However, because these 

federal agencies do not track the amount of allowable financial assistance 

they provide to CBRS units, they could not provide us with the complete 

and reliable data needed to estimate the total extent of such assistance. 

• The Corps and states authorized by the EPA have issued hundreds of 

permits allowed by CBRA to entities within the CBRS. Since 1983, in 20 

CBRS units the Corps issued at least 194 permits to allow, among other 

things, the construction of piers, mosquito control ditches, erosion control 

areas, and the raising of fish and shellfish. Similarly, since 1983, in 9 CBRS 

units EPA-authorized state agencies issued 41 permits, primarily for storm 

water runoff from construction activities and the discharge of water from 

treatment systems. 

We are recommending that FEMA, HUD, SBA, and VA obtain official 

determinations from FWS on whether the properties we identified as 

receiving federal assistance in violation of CBRA are in fact located within

a CBRS unit and cancel all inappropriate loan guarantees and insurance 

policies. We are also recommending that these agencies examine their 

policies and procedures to ensure that they are adequate to prevent 

federal assistance from being provided to entities in CBRS units. In 

addition, so that federal agencies and other parties can more accurately

determine whether a property is within CBRA and whether it is eligible for 

assistance, we recommend that FWS place a high priority on completing 

its efforts to develop digital maps that more accurately depict unit 

boundaries. In commenting on our report, DHS, DOI, and HUD generally

agreed with our recommendations. SBA had no comment on the draft 

report. VA agreed with our findings and one of our recommendations but 

did not concur with the recommendation to cancel all inappropriate loan 

guarantees, stating that it would inflict disproportionate harm on lenders 

and veterans. While we understand VA’s concerns about the adverse effect 

that this could have on the potentially affected parties, we believe that VA 

should rescind these loan guarantees because they were made in violation 

of CBRA. 

Coastal barriers are unique land forms that function as buffers, protecting 

the mainland against the destructive forces of hurricanes and other coastal 

storms. Coastal barriers also provide habitat for migratory birds and other 

wildlife; and they provide essential nesting and feeding areas for 

Background 

Page 6 GAO-07-356 Coastal Barrier
commercially and recreationally important species of fish and other 

aquatic organisms such as sea turtles. In the United States, coastal barriers 

are predominantly distributed along the Atlantic and Gulf coasts but can 

also be found in areas surrounding the Great Lakes, the Virgin Islands, and 

Puerto Rico. From the Gulf of Maine to Padre Island, Texas, coastal 

barriers form an almost unbroken chain along the coastline. Coastal 

barriers are generally unsuitable for development because the movement 

of unstable sediments undermines man-made structures. Despite this 

threat, coastal areas that include coastal barriers are among the most 

rapidly growing and developed areas in the nation, accounting for 53 

percent of the total population in the United States according to a 2004 

report by the National Oceanic and Atmospheric Administration (NOAA), 

National Ocean Service.

In 1982, Congress enacted the Coastal Barrier Resources Act to minimize 

(1) the loss of human life; (2) wasteful expenditures of federal revenue; 

and (3) damage to fish, wildlife, and other natural resources associated 

with coastal barriers along the Atlantic and Gulf coasts by restricting 

future federal expenditures and financial assistance, which have the effect

of encouraging development of coastal barriers. The act designated 186 

units, comprising about 453,000 acres along 666 miles of shoreline from 

Maine to Texas, which would later be known as the John H. Chafee 

Coastal Barrier Resources System (CBRS). 

Subsequently, the CBRS was further expanded to include additional units 

along coastal states from Maine to Texas, plus units in the Great Lakes, the 

Virgin Islands, and Puerto Rico. Currently, the CBRS includes 585 units, 

which consist of undeveloped coastal barrier lands and aquatic habitat 

that comprises nearly 1.3 million acres of land and associated aquatic

habitat. The CBRS was also expanded to include 272 OPAs that comprise 

an additional 1.8 million acres of land and associated aquatic habitat. Most 

of the land in these OPAs is publicly held for conservation or recreational 

purposes, such as national wildlife refuges, national parks and seashores, 

and state and county parks; but some OPAs may also include some private 

property that may or may not be held for conservation. 

Under CBRA, no single federal agency has overall responsibility for 

administering activities within the CBRS; instead, all federal agencies must 

abide by the provisions of the act. CBRA does assign the Secretary of the 

Interior responsibility for, among other things, maintaining maps of each

Page 7 GAO-07-356 Coastal Barrier
CBRS unit and recommending modifications to CBRS unit boundaries, as 

needed.7

 Within the Department of Interior, these responsibilities belong 

to the FWS. Both agencies and property owners can request decisions 

from FWS regarding whether specific properties are within CBRS 

boundaries. Finally, agencies must consult with FWS to determine 

whether a proposed project is within the CBRS, and if so, whether the 

project is consistent with CBRA. 

The Coastal Barrier Resources Reauthorization Act of 2000 directed the 

Secretary of the Interior to complete a Digital Mapping Pilot Project for at

least 50 but not more than 75 units in the CBRS and submit a report to the 

Congress that describes the results of the pilot project and the feasibility, 

data needs, and costs of completing digital maps for the entire CBRS.8

Currently, FWS is conducting a pilot project to create updated digital 

CBRS maps that would provide federal agencies and others with an 

enhanced tool for determining accurate boundary locations. Later, the 

Coastal Barrier Resources Reauthorization Act of 2005 directed the 

Secretary of the Interior to create digital maps by 2013 for all CBRS units 

not included in the pilot project. However, according to agency officials, 

the ability to conduct this project and the actual completion date will 

depend upon the specific funding that the agency receives for this project. 

CBRA does not prohibit development in CBRS units by owners who are 

willing to develop their properties without the benefit of federal financial

assistance. Instead, with certain exceptions, CBRA prohibits federal 

expenditures or financial assistance within CBRS units that might 

encourage development. The prohibitions include, but are not limited to 

the following: 

• the construction or purchase of any structure, facility, or related 

infrastructure; 

 7

Aside from minor exceptions, only Congress, through new legislation, can modify the

boundaries of the CBRS. To determine whether the revisions constitute appropriate 

technical corrections, FWS conducts objective reviews to examine whether or not the area 

was undeveloped when it was included in the CBRS and whether or not the boundaries on 

the map correctly follow the natural or man-made features they were intended to follow on 

the ground. When technical mapping errors are found, FWS has supported legislation to 

modify boundaries accordingly. Since the CBRS was designated in 1982, Congress has

enacted technical correction legislation to revise the boundaries of 42 CBRS units. 

8

FWS anticipates the draft maps and report will be submitted to the Congress in 2007. 

Page 8 GAO-07-356 Coastal Barrier
• the construction or purchase of any road, airport, boat landing facility, or 

other facility on, or bridge or causeway to, any CBRS unit; 

• any project to prevent the erosion of, or to otherwise stabilize, any inlet, 

shoreline, or inshore area for the purpose of encouraging development; 

and 

• the issuance of flood insurance coverage under the National Flood 

Insurance Act of 1968 for any new construction or substantially improved 

property. 

CBRA allows certain federal assistance within the CBRS for limited 

activities after consultation with FWS. However, the act does not require 

the agencies to obtain FWS’ approval before acting. Such assistance 

includes, but is not limited to the following: 

• the exploration, extraction, or transportation of energy resources that can 

be carried out only on, in, or adjacent to a coastal water area; 

• the maintenance or construction of improvements of existing Federal 

navigation channels and related structures; 

• the maintenance, replacement, reconstruction, or repair, but not the 

expansion, of publicly owned or operated roads, structures, or facilities 

that are essential links in a larger network or system; 

• military activities essential to national security; and 

• assistance for emergency operations essential to saving of lives and 

protecting property. 

CBRA has no provisions prohibiting the administration of federal 

regulatory activities, such as issuing certain permits, within the CBRS. 

Three federal agencies—the Corps, EPA, and the U.S. Coast Guard—issue 

permits that regulate, among other things, the discharge of dredged or fill 

material into federally regulated waters, including wetlands; the discharge 

of wastes into navigable waters; and the construction of bridges over 

navigable waters. Because much of the CBRS is comprised of wetlands 

and aquatic habitat, activities undertaken in these areas can require a 

permit from one or more of these agencies. Federal legislation other than 

CBRA provides the authority for issuing these permits. Among these are 

the Clean Water Act, the Rivers and Harbors Appropriation Act of 1899, 

and the Bridge Act of 1906, as amended. 

Page 9 GAO-07-356 Coastal Barrier
Despite the concentration of significant levels of development in a few 

units, most of the CBRS remains undeveloped. Specifically, we found an

estimated 84 percent of all CBRS units remain undeveloped—with no new 

structures built since the unit was included in the CBRS. We found that 

factors such as the lack of suitably developable land in the unit and state

laws discouraging development were responsible for inhibiting 

development. We also determined that an estimated 13 percent of CBRS 

units experienced minimal levels of development—consisting of less than 

20 additional structures per unit since becoming part of the CBRS—while 

3 percent of CBRS units experienced significant development—100 or 

more additional structures per unit. According to local officials, 

commercial interest and public desire to build in some units and local 

government support for development were some of the key factors 

contributing to the development in the CBRS units we reviewed. Appendix 

II lists the units in our review and the status of development in those units. 

On the basis of our analysis of a random sample of CBRS units, we 

estimate that 84 percent of the units experienced no new development 

since their inclusion in the CBRS.9

 For the units in our sample, the 

undeveloped units were generally smaller in total acreage and had less 

developable acreage than the developed units. 

Although CBRA does not appear to have been a primary factor in 

discouraging development in the units we reviewed, officials indicated 

that in those areas where CBRA prohibitions are complemented by local 

and state government objectives for development, it is unlikely that there

will be significant increases in development. Local officials cited several 

factors as being primarily responsible for inhibiting development. 

The Lack of Suitably Developable Land. This was a primary factor for the 

lack of development in a number of CBRS units that we reviewed.10 For 

example, the Boat Meadow unit in Massachusetts is comprised almost 

entirely of salt marshes with small sand bars scattered throughout shallow 

CBRS Remains 

Largely Undeveloped 

The Majority of CBRS 

Units Have Not 

Experienced Development 

 9

The random probability sample included 91 geographically dispersed CBRS units. All 

percentage estimates from the sample have margins of error of plus or minus 10 percentage

points, unless otherwise noted.

10Developable land is the number of fastland acres in each unit. Fastland is situated above 

the mean high-tide line and is generally not wetlands. FWS determined the fastland acres

for each unit within the CBRS. 

Page 10 GAO-07-356 Coastal Barrier
water, making the land unsuitable for development. Similarly, in the 

Wrightsville Beach unit in North Carolina, the sand continuously shifts, 

making the land too unstable for development. Figure 1 is an example of 

the type of terrain generally found in the Boat Meadow CBRS unit in 

Massachusetts. 

Figure 1: Boat Meadow CBRS Unit in Massachusetts

Lack of Accessibility to the Unit. A number of federal and local officials 

noted that some CBRS units are not easily accessible or are located in

remote locations that are not desirable to developers. For example, a 

number of units, such as the Bay Joe Wise Complex in Louisiana, are only 

accessible by boat. Other units, such as the Boca Chica unit in Texas, are 

in such remote locations that an official said developers are not willing to 

build there. In addition, several remote and inaccessible locations do not 

currently have the infrastructure needed to develop the unit. For example, 

an official said the lack of existing infrastructure and the high cost of 

constructing development-quality water and sewage infrastructure have

discouraged development on the North Padre Island unit in Texas. 

Source: GAO.

Page 11 GAO-07-356 Coastal Barrier
State Laws Discouraging Development. State laws were cited by a

number of officials as reasons why development had not occurred in some 

CBRS units. Some states have adopted specific restrictions to prevent 

development in coastal or wetland areas, which are often found in CBRS 

units. For example, a number of units in Massachusetts—such as Black 

Beach and Squaw Island—have not experienced development due in part 

to wetland and coastal protection laws enacted by the state.11 In addition, 

both Maine and Massachusetts do not allow state funds or grants to be 

used for projects to encourage development in barrier beaches.12 In Rhode 

Island, any coastal development project must receive a permit from the 

Rhode Island Coastal Resources Management Council, and an official 

explained that it was highly unlikely that permits would be issued for new 

development in coastal regions of the state. 

Preservation Efforts by Conservation Groups. A number of CBRS units 

include land owned by entities seeking to preserve the area in its natural 

state. In some cases, CBRS units have lands that are owned by federal,

state, or local governments, such as local parks or national forests. For 

example, the Whitefish Point unit in Michigan is part of the Hiawatha 

National Forest. In other cases, land in CBRS units is owned by 

conservation groups seeking to prevent development. For example, a 

significant portion of the Southgate Ponds unit in the U.S. Virgin Islands is 

owned by the St. Croix Environmental Association; the Fox Islands unit in

Virginia is owned by the Chesapeake Bay Foundation; and the Pine Island 

Bay unit in North Carolina is mostly owned by the National Audubon 

Society. Although these owners have sought to prevent development 

within the unit, as the land becomes more valuable, owners may 

experience pressure to sell it for development purposes. Private home 

owners have also taken actions to prevent continued development in one 

CBRS unit we reviewed. Some portions of the Prudence Island Complex 

unit in Rhode Island are located in private home owners’ backyards. Home 

 11According to Massachusetts state officials, the Wetlands Protection Act regulations 

established a “no net loss of wetlands” policy for all coastal areas and barrier beaches. 

Under the Massachusetts Coastal Wetlands Restriction Act, the Massachusetts 

Commissioner of Environmental Protection can regulate and prohibit dredging, filling, or 

otherwise altering coastal wetlands. 

12In 1980, Massachusetts Governor Edward J. King issued Executive Order No. 181 

preventing the use of state funds and grants for construction projects to encourage growth

and development in hazard prone barrier beaches. See also Me. Rev. Stat. Ann. tit. 38, §§

1901-1905. 

Page 12 GAO-07-356 Coastal Barrier
owners have voluntarily placed their land into a conservation easement to 

formally protect it from future development. 

Although the majority of CBRS units remain undeveloped, 16 percent have 

experienced some level of development. While the range of development 

varies between one additional structure for some units to over 400 new 

structures for another unit, the amount of development in most of the 

units has been small. Thirteen percent of the units have added less than 20

structures. Where there has been significant development, it has been 

concentrated in a relatively small number of units. We estimate that only 3 

percent of CBRS units have experienced the addition of 100 or more new 

structures since their inclusion in the CBRS. 

The majority of the CBRS units within our sample that have experienced 

development are located in the southern United States. Two units 

experiencing the most extensive development were the Topsail, North 

Carolina unit and the Cape San Blas, Florida unit. Several other units in 

the south, such as the Four Mile Village unit in Florida and Bird Key 

Complex in South Carolina, have plans for continued development. None 

of the units in our sample located in the northern United States had 

experienced such extensive development. One factor contributing to 

increased development in the south is the greater amount of developable 

acres; 80 percent of the developable land in the CBRS is located in 

southern units—those located south of New Jersey. 

Local officials cited several factors as being primarily responsible for the 

development that has occurred.13

Commercial Interest and Public Desire to Build in the Unit. Officials 

told us that development had occurred in several areas because the 

public’s desire to develop in the unit was stronger than the disincentive of

CBRA. For example, the Currituck Banks unit in North Carolina has 

experienced an increase of at least 400 new residential homes since its 

inclusion in the CBRS. Although this unit only has beach access for fourwheel drive vehicles, approximately 75 percent of the land south of the 

unit is currently built to capacity, and the increasing demand for 

A Small Percentage of 

Units Have Experienced 

Some Level of 

Development, but 

Significant Development 

Has Been Concentrated in 

a Few Units 

 13To determine the reasons development occurred, we interviewed local officials in a 

number of developed units in our sample as well as officials for the Cape San Blas unit in 

Florida and the Topsail unit in North Carolina. 

Page 13 GAO-07-356 Coastal Barrier
residential structures is sending developers into the adjoining CBRS unit. 

Local officials stated that the lack of federal assistance did not appear to 

have any affect on the rate of development in the area. Similarly, the Cape

San Blas unit in Florida has continued to experience increased 

development with at least 900 new structures—primarily single family 

vacation homes—being built since the unit’s inclusion in the CBRS. 

Officials in Cape San Blas believe that as other coastal locations around 

Florida became too expensive to find affordably priced ocean front homes, 

the area of Cape San Blas became a highly desirable location. Accounting 

for the significant development that has occurred in the Topsail unit in 

North Carolina, officials stated that the basic reason was simply supply 

and demand: people want to live on the coast of North Carolina, and the 

area that includes the CBRS unit had developable land available. 

Local Government Support for Development. Local officials explained that 

local governments with a pro-development attitude aided in increasing 

development in CBRS units. For example, local officials in Topsail, North 

Carolina told us that most of the 1,600 structures located in the Topsail 

CBRS unit were constructed after the unit’s inclusion in the CBRS.14 These 

officials indicated that the county government had begun development 

plans for land within the unit prior to its inclusion in CBRS. These officials 

noted that the county had targeted the area for development to promote 

tourism and increase the local tax base, and that certain infrastructure was 

built to support this increased development. As the result of these prodevelopment policies, a large portion of the unit has been developed with 

residential homes—many of which serve as vacation rentals during the 

summer months. Similarly, in the Cape San Blas unit in Florida the local 

government had development plans for the area prior to the adoption of 

CBRA. Local officials there said that the area was already subdivided into 

lots for development and that some existing infrastructure, such as roads, 

water systems, and telephone systems, was already built when the unit 

was added to the CBRS. 

Availability of Affordable Private Flood Insurance. Officials familiar with

several CBRS units told us that initially restrictions on the availability of

federal flood insurance had little impact on the development that occurred 

in some CBRS units. Lenders did not require flood insurance in order for 

 14The date structures were built in the Topsail unit was not readily available when we 

conducted this analysis, so we could not determine the exact number of structures built 

since the unit’s inclusion in the CBRS. 

Page 14 GAO-07-356 Coastal Barrier
home owners to obtain mortgage loans at the time most of the 

development occurred. According to these officials, home owners within 

CBRS units that chose to get flood insurance could readily get private 

flood insurance at rates comparable with federal flood insurance. 

However, in the past few years FEMA has updated its flood-zone maps and

has designated some CBRS areas as special flood hazard areas. This 

change in designation has made areas that once did not require owners to 

obtain flood insurance in order to receive financing into areas where 

owners are now required to have flood insurance prior to obtaining 

mortgage loans. At the same time, officials said that in several CBRS units 

the cost of private insurance has skyrocketed and is no longer comparable

to national flood insurance program rates. According to a local banker in

Cape San Blas, a $250,000 home outside the CBRS unit can obtain flood 

insurance through the National Flood Insurance Program for $470 per 

year, but private flood insurance for homes located in the CBRS unit that 

are not eligible for national flood insurance could cost between $5,070 and 

$12,500 a year, depending on the insurance company. 

The new requirements mandating flood insurance for mortgages in some 

units and the increased costs of private flood insurance may begin to 

impact development in the CBRS in the future, according to local officials. 

For example, officials in Currituck County noted that the flood zone 

determination change had significantly reduced the number of building 

permits issued for new development in the CBRS unit since 2005 and 

suggested that the unit will now experience less future development. 

Likewise, the Cape San Blas unit in Florida has also been affected by the

flood zone determination change. A local official stated that since FEMA 

adopted a special flood hazard area for the CBRS unit in 2002, property 

values in the unit have decreased by 30 percent. Because the cost of 

private flood insurance has risen dramatically in the last couple of years, a 

number of residents and officials representing areas within the CBRS, 

including Cape San Blas and Topsail, have unsuccessfully attempted to 

remove the areas from the CBRS, primarily so that residents would be 

eligible to obtain flood insurance through the National Flood Insurance 

Program. 

Our review of CBRS units did not include OPAs because FWS officials 

informed us that these areas were classified separately from system units 

and that the land was already protected from development by other 

mechanisms—such as its designation as a state or federal park. OPAs are 

not under the same limitations as CBRS units; the only restriction placed 

on federal spending within these areas is the prohibition on federal flood 

insurance. However, we found instances where land within OPAs was sold 

Page 15 GAO-07-356 Coastal Barrier
to private developers and development had increased in the area. For 

example, in the St. Andrews Complex unit in Florida, the Bahia de 

Tallaboa unit in Puerto Rico, and the Mustang Island unit in Texas, 

development has continued despite the units’ designation as an OPA. 

We found that federal agencies have provided some financial assistance 

prohibited by CBRA, some assistance allowed by CBRA, and hundreds of 

permits for federally regulated construction projects to entities within the 

CBRS units included in our review. Four agencies provided financial 

assistance expressly prohibited by CBRA to property owners in CBRS 

units. Three federal agencies also provided financial assistance to entities 

in CBRS units that is allowed under CBRA, but they do not track the 

amount of assistance they provided. As a result, we were unable to 

determine the total extent of such assistance. Finally, the Corps and EPAauthorized state agencies have issued hundreds of permits for a variety of 

federally regulated construction projects within CBRS units.

Four federal agencies—FEMA, HUD, SBA, and VA—provided some 

financial assistance that is expressly prohibited by CBRA to property 

owners in CBRS units. Our review of approximately 4,500 addresses 

uncovered 73 active FEMA flood insurance policies, 37 inappropriate 

FEMA disaster assistance payments, 5 HUD home loan guarantees, 3 SBA

disaster loans, and 11 VA home loan guarantees that should not have been 

made to property owners in CBRS units. Although three of the four 

agencies have procedures to prevent and detect assistance to property 

owners in CBRS units, agency officials cited several reasons why this 

erroneous assistance was provided in violation of CBRA, including the 

lack of updated CBRS maps, which makes determining the precise 

locations of properties and CBRS unit boundaries difficult. 

FEMA provides federally backed flood insurance for home owners, 

renters, and business owners in participating communities that are not in

the CBRS. Structures that are built or substantially improved following 

their inclusion within the CBRS are not eligible for federal flood insurance. 

However, our review of policies active as of May 2006 identified 73 

National Flood Insurance Program (NFIP) policies for properties in CBRS 

units. The flood insurance policies ranged from $26,500 to $350,000 and 

totaled approximately $20 million. Although these policies violated the 

CBRA, FEMA officials said it is unlikely that the agency would actually pay 

a claim on these policies, because before paying a claim, FEMA adjusters 

would first conduct a physical inspection of the property and determine 

The Extent to Which 

Federal Agencies 

Have Provided 

Financial Assistance 

and Permits to 

Entities in CBRS 

Units Varies 

Four Federal Agencies 

Have Provided Some 

Financial Assistance That 

Is Prohibited by CBRA 

FEMA National Flood 

Insurance Program 

Page 16 GAO-07-356 Coastal Barrier
whether it was in a CBRS unit. If a property was found to be within the 

CBRS, FEMA would deny the claim and refund the policy owner’s 

insurance premium. 

To prevent flood insurance policies from being issued for properties in 

CBRS units, FEMA’s Flood Insurance Manual requires that private 

insurance companies participating in the NFIP determine if a property is 

eligible for flood insurance. Prior to issuing a policy, the agent is required 

to review FEMA’s flood insurance maps to determine if the property is 

located within the CBRS and collect information to determine if the 

structure was built prior to the unit’s inclusion in the CBRS. However, 

according to FEMA, insurance agents have made mistakes and issued 

policies in violation of CBRA for two reasons: 

• It may be difficult to locate a property and determine whether it is in a 

CBRS unit, especially when a property is near or adjacent to a CBRS 

boundary. For example, at one location we visited, we identified homes 

adjacent to each other where one property was in the CBRS and the other 

was not. In other CBRS units, some homes had backyards that fell within 

the CBRS. Furthermore, new streets may not be depicted on existing 

maps. According to FEMA officials, the insurance agent must often make a 

judgment call when determining whether a property is within the CBRS. 

• The agent may not be familiar with CBRA prohibitions and may not follow 

procedures. According to FEMA officials and officials from a private 

insurance agency with whom we spoke, some home owners obtain flood 

insurance from insurance agents located inland, away from coastal areas,

who might not have been aware of the CBRA restrictions. 

According to FEMA officials, the agency takes a number of steps to 

identify properties that may have inappropriately received federal flood 

insurance. Since 1998, FEMA has sought to assist private companies with 

identifying flood insurance policies that potentially were ineligible for 

flood insurance coverage because the property was within the CBRS. To 

accomplish this task, FEMA uses computer mapping technology to plot 

addresses and determine whether they are potentially in a CBRS unit.15

However, the computer software FEMA relies on cannot always correctly 

 15According to FEMA officials, FEMA does this plotting for all properties in a community 

where a CBRS unit is located. Every month FEMA plots addresses of new policies or 

policies that have changed. All addresses in a community with a CBRS unit are reviewed at

least once a year. 

Page 17 GAO-07-356 Coastal Barrier
locate all addresses on the map. For example, this can occur if a street or 

address range is not included in the software, which can happen when a 

street or a range of addresses is new. Twenty of the 73 flood insurance 

policies that we determined were issued for a property that was in a CBRS 

unit could not be located on a map by FEMA’s computer software. In 

addition, computer mapping technology has inherent inaccuracies and 

may plot properties in the wrong location. For example, using our 

mapping software, we determined another 20 of the 73 flood insurance 

policies were for a property in the CBRS but were not identified as being 

in a CBRS unit by FEMA’s mapping software.16 FEMA officials said they 

recognize that their software may not always identify new addresses and 

streets in CBRS units, and so the agency obtains quarterly updates of new 

streets and addresses and rechecks insured properties against the updated 

information to identify any that might be located in CBRS units. 

When FEMA’s computer plotting reveals that a property for which a 

federal flood insurance policy has been issued may be in a CBRS unit, 

FEMA reports the error to the insurance company. Once an insurance 

company receives notification in the form of an error message that they

may have written an ineligible policy, the company may take one of four 

actions: 

1. The company can agree that the property is located in a CBRS unit and 

cancel the policy back to the inception date of coverage. 

2. The company may agree that the property is located in a CBRS unit but 

prove that the building was constructed prior to the CBRS designation. 

In these cases, the policy is deemed valid and may remain in effect. 

3. The company can disagree that the property is located in a CBRS unit 

and assume responsibility for the risk. In these cases, the policy would 

remain active, FEMA would continue to collect the premiums, but the 

insurance company would be responsible for paying any claims filed. 

Insurance companies have assumed liability for the risks associated 

with 29 of the 73 flood insurance policies that we identified had been 

issued for properties located in CBRS units. 

 16FEMA uses MapInfo software with MapMarker to plot locations. This software is updated 

more frequently than the software that we use. In these 20 instances, our software located 

properties within the CBRS boundary, but FEMA’s software did not. However, we

physically verified that 14 of these 20 properties appeared to be within CBRS boundaries

during a site visit to the unit. We did not visit the locations where the remaining 6 

properties were located. 

Page 18 GAO-07-356 Coastal Barrier
4. The company can request that FWS make an official determination 

regarding whether the property is in the CBRS. If FWS determines that 

the property is in a CBRS unit, the policy is then cancelled back to the 

inception date of coverage. However, FEMA officials expressed 

concern about the length of time FWS takes to make a property 

determination. Typically, it takes FWS a year to respond to inquiries 

for a property determination. As of January 17, 2007, FEMA was 

waiting for determinations on 544 addresses from FWS. 

According to FWS officials, the process for making property 

determinations is labor intensive because they are using CBRS maps that 

were created more than 15 years ago and are not available in digital 

format. FWS officials told us that modernized digital maps of the CBRS 

would improve the accuracy and efficiency of the property determination 

process, allowing its customers and partners, in many cases, to determine 

within minutes whether a property is located within the CBRS. In 2000, the 

Congress directed the Secretary of the Interior to create draft digital maps 

for at least 50 and not more than 75 units, or nearly 10 percent of the 

CBRS.17 FWS has created draft digital maps of 60 CBRS units that it must 

submit to the Congress for its consideration.18 In May 2006, the Congress 

also instructed the Secretary of the Interior to create maps for the rest of 

the CBRS by May 2013.19 According to FWS, digital maps would replace the 

paper maps currently being used that are (1) outdated technologically and 

(2) sometimes inaccurate and may not align precisely with the natural or 

man-made features that the Congress intended the boundaries to follow. 

FWS officials believe that modernizing the CBRS maps will address the 

inaccuracies of the existing maps. 

To implement the map modernization project, FWS officials said that they 

investigated several options for procuring data to produce the required 

draft digital maps, including federal, state, local, and private sources. In 

many cases, FWS was able to obtain data internally or from other federal 

 17The Coastal Barrier Resources Reauthorization Act of 2000, Pub. L. No. 106-514, §6, 114 

Stat. 2394, 2396, required FWS to prepare draft digital maps for a portion of the CBRS. 

18The Coastal Barrier Resources Act of 2005 directs the Secretary of the Interior to finalize 

the pilot project maps by conducting a public review of the draft maps, making adjustments

as necessary, and presenting final recommended maps to the Congress its consideration. At 

that point, the Congress could adopt the pilot project maps as the official CBRS maps 

through legislation. 

19The Coastal Barrier Resources Reauthorization Act of 2005, Pub. L. No. 109-226 § 4, 120 

Stat. 381, 382 (2006). 

Page 19 GAO-07-356 Coastal Barrier
agencies at little or no cost, including wetlands data and national wildlife

refuge boundaries from within FWS, aerial imagery from the U.S. 

Geological Survey, hydric soils data from the Department of Agriculture’s 

Natural Resources Conservation Service, and digital boundaries for many 

federally protected areas from NOAA. 

FEMA is also conducting a map modernization effort that includes 

preparing digital flood insurance maps. In 2006, FWS entered into an 

interagency agreement with FEMA whereby FWS will place current CBRS 

boundaries onto FEMA’s digital flood maps. FEMA provided FWS with 

$40,000 for an initial set of maps for some units. While the FEMA maps are 

not the “official” CBRS maps adopted by the Congress, FWS officials said

that these digital maps will allow property owners, insurance agents, and

others to have a much more accurate and precise tool for determining 

whether a property or project site is located near a CBRS area and would 

require an official determination from FWS. 

FEMA’s Individuals and Households Program (IHP)20 provides housing 

assistance and other assistance, such as medical or funeral assistance, for 

needs arising from a declared emergency or major disaster. For owners or 

renters residing in CBRS units, FEMA regulations allow providing 

temporary housing assistance (rent) but generally do not allow providing 

funds for housing repairs or construction assistance. However, we found 

that since August 26, 1998, FEMA provided 37 disaster assistance 

payments to individuals in CBRS units included in our review totaling 

$25,393. Most of the payments were for purposes labeled by FEMA as 

“Other Eligible Property Items.” According to FEMA officials, “Other 

Eligible Property Item” payments were for post-disaster purchases for 

emergency needs such as chainsaws, generators, heating fuel, 

dehumidifiers, air purifiers, and wet/dry vacuums.21 These payments were 

made under six different disaster declarations, all to individuals living in 

FEMA Individuals and 

Households Program 

 20Our study also includes data from disasters that predate IHP, from its predecessor 

program called “Disaster Housing/Individual and Family Grant Program.” 

21CBRA exempts from its general prohibition assistance for emergency actions essential to 

saving lives and the protection of property and the public health, as performed under

particular sections of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 

as amended. 16 U.S.C. § 3505(a)(6)(E). In its regulations, FEMA describes these actions to 

include, among other things, removing debris and repairing primary residences to make 

them habitable. However, for the expenditures described above as “Other Eligible Property

Items,” such as chainsaws and generators, FEMA officials said those payments were 

prohibited. 

Page 20 GAO-07-356 Coastal Barrier
CBRS units in North Carolina and Florida. The units included Coconut 

Point, Cape San Blas, Blue Hole, Ponce Inlet, and Ormond-by-the-Sea in 

Florida, and Currituck Banks and Topsail in North Carolina. In addition to

payments for “Other Eligible Property Items,” one payment of $645.95 was 

made for home repairs. FEMA procedures require officials making 

payment determinations in potential CBRS areas to document that the 

property is not in a CBRS unit prior to approving assistance for those 

types of assistance not allowed in such areas. However, according to a 

FEMA official, in these cases the procedures were not followed when 

these payments were approved.22

Through its Mortgage Insurance Homes program, HUD insures lenders 

against losses on mortgage loans used to finance the purchase of 

proposed, under construction, or existing housing, as well as to refinance 

indebtedness on existing housing as long as these properties are not 

located in the CBRS. In our review of insured home loans active as of June 

2006, we identified five HUD-insured loans for properties located in CBRS 

units. Three of the loans were for properties in the Prudence Island 

Complex unit in Rhode Island; one in the Topsail unit in North Carolina; 

and one in the Cape San Blas unit in Florida. These insured loans were 

approved by HUD between 1985 and 2000, with loan amounts ranging from

approximately $50,000 to $137,000, for a total of about $384,000. 

Despite the fact that all of HUD’s programs are subject to CBRA 

restrictions, HUD officials said that they have no procedure under their 

single family (one- to four-family property) mortgage insurance programs 

related to CBRA. HUD officials further indicated that while they could 

implement better controls for restrictions on providing single family 

mortgage insurance in the CBRS, it would be unnecessary in practical 

terms. HUD officials provided three primary reasons why it was unlikely 

that a HUD-insured loan would be provided for a property in a coastal 

area. First, HUD regulations require that flood insurance be obtained 

under the NFIP before HUD will insure single family mortgages for 

properties in FEMA-identified special flood hazard areas. HUD officials 

stated that because properties located in the CBRS would likely be in 

special flood hazard areas and the NFIP flood insurance is prohibited in 

Department of Housing and 

Urban Development 

 22We issued a report on the challenges that the IHP program experienced during Hurricanes

Katrina and Rita and recommended that FEMA address the potential for fraud and abuse 

identified in the program. GAO, Hurricanes Katrina and Rita: Unprecedented Challenges

Exposed the Individuals and Households Program to Fraud and Abuse; Actions Needed

to Reduce Such Problems in Future, GAO-06-1013 (Washington, D.C.: Sept. 27, 2006). 

Page 21 GAO-07-356 Coastal Barrier
the CBRS, HUD would not be able to insure single family mortgages for 

these properties. However, HUD’s explanation does not account for the 

fact that portions of CBRS units may not be in a special flood hazard area 

and that FEMA prohibitions are not universal as the NFIP flood insurance 

may be available to homes built before the area’s inclusion in the CBRS. 

Second, most HUD insurance for single family mortgages is for first-time 

home owners who typically are not buying homes in the higher priced 

ranges found in the CBRS. Third, property values in the CBRS are such 

that mortgage amounts would likely exceed the program limits for typical 

HUD-insured single family mortgages, as the mortgage limit for a one 

family property ranges from approximately $170,000 to $310,000, 

depending on the location. In response to our findings, HUD officials said 

that the department would be developing CBRA policy guidance and 

associated training to ensure future compliance. 

Following the issuance of a disaster declaration, SBA provides disaster 

loans to eligible home owners for repair or replacement of their primary 

residences. However, residences located in CBRS units are ineligible for 

this disaster loan assistance. During our review of the period January 1, 

1990, through May 30, 2006, we found that SBA had made three disaster 

loans for home repairs for properties in CBRS units.23 The three loans 

ranged from $5,000 to $10,000 and totaled $24,200. These loans have been

paid in full and were made to individuals in the Florida CBRS units of Blue 

Hole and Cape San Blas, and the Creek Beach unit in New York. To 

prevent disaster loans from being provided to properties within the CBRS, 

SBA procedures call for agency staff to consult FEMA’s flood maps to 

determine whether a property is within a CBRS unit before approving 

disaster loans. SBA officials acknowledge that two of these loans should 

not have been approved, but did not agree that the third loan was for a 

property within CBRS. These officials stated that it is sometimes difficult 

for agency staff to determine if a property is within the CBRS with the 

existing FEMA flood maps. SBA officials said that as a result of our review 

the agency will increase the number of quality assurance reviews 

conducted in any disaster area that includes a CBRS unit. 

VA issues home loan guarantees to help eligible recipients obtain homes or 

refinance home loans except in CBRS units. However, our review of home 

loan guarantees active as of September 2006 found that VA had provided 

Small Business Administration 

Department of Veterans Affairs 

 23SBA approved seven loans in CBRS units, however, individuals did not initiate four of

these loans and they were cancelled. 

Page 22 GAO-07-356 Coastal Barrier
11 loan guarantees for homes in a CBRS unit. Nine of these 11 loan 

guarantees were issued to home owners in the Topsail unit in North 

Carolina, while the other two were provided to home owners in the 

Ormond-by-the-Sea unit in Florida. The amount of the 11 loan guarantees 

ranged from a low of about $14,340 to a high of about $45,900 for a total 

value of $352,188. 

VA officials told us that the agency’s Lenders Handbook includes 

provisions that inform readers that properties in CBRS units are ineligible 

as security for a VA-guaranteed loan. VA appraisers are instructed during 

training sessions to reject assignments appraising such properties. Also, to 

verify that loan guarantees are provided lawfully, agency officials said that 

they or their designees (1) examine appraisal paperwork for all loan 

applications looking for anomalies; (2) inspect 10 percent of all loan 

applicant properties to verify, among other things, that they are not in 

CBRS units; (3) review paperwork for 10 percent of all closed loans; and 

(4) visit lender offices and sample VA loans for compliance. In reviewing 

the provisions included in VA’s handbook, we determined that it 

inaccurately instructs appraisers to obtain the maps for determining the 

location of a property from the U.S. Geological Survey rather than from 

FWS. 

VA officials acknowledge that agency staff should have identified the 11 

properties we discovered as located within the CBRS during their initial 

review of the appraisal paperwork. VA officials explained that as a result 

of our findings, they have (1) corrected the Lenders Handbook provisions 

to instruct staff to use maps maintained by FWS and (2) instructed 

officials at VA regional loan centers to modify their training to both 

lenders and appraisers to emphasize the procedures designed to prevent 

issuing loans to persons who reside in CBRS units. 

We found that three federal agencies had provided financial assistance 

allowable under CBRA to entities within the CBRS. We were unable to 

determine the total extent of such assistance, because these federal 

agencies do not track the amount of allowable financial assistance they 

provide to entities in CBRS units, and they could not provide us with the 

data necessary to estimate the total assistance provided. 

After a disaster, FEMA may provide disaster funding in CBRS units for 

emergency assistance such as debris removal and emergency protection 

measures. FEMA may also provide disaster funding following an 

emergency for activities like repairing roads or utilities, repairing existing 

Federal Agencies Have 

Provided Assistance That 

Is Allowable under CBRA, 

but the Extent of Such 

Assistance Is Unknown 

Federal Emergency 

Management Agency 

Page 23 GAO-07-356 Coastal Barrier
water channels, or disposing of sand. Because FEMA could not provide 

reliable data on whether this disaster assistance was within a CBRS unit 

for each project, we could not determine the full extent of the allowable 

disaster assistance provided by FEMA. However, with FEMA’s data, we 

were able to identify that some of the projects were within CBRS units. 

For example, since 1998, FEMA provided at least $5.6 million in disaster 

assistance to the Topsail unit in North Carolina to fund projects to remove 

debris, replace signs, and repair beach access crosswalks and public 

beach facilities after Hurricanes Ophelia, Floyd, Irene, and Isabel. 

Similarly, in both the Cape San Blas, Florida and Topsail, North Carolina 

CBRS units, FEMA provided funds to construct an emergency berm in 

order to protect existing development after storms destroyed protective

dunes and caused beach erosion. Table 1 provides examples of some of 

the disaster assistance FEMA has provided to CBRS units since 1998. 

Table 1: Examples of FEMA Disaster Assistance Since 1998 

Storm and year Unit Project description

Total

obligated

Floyd and Irene, 

1999 

Topsail Beach,

North Carolina

Replace traffic control 

signage 

 $13,979

Floyd and Irene, 

1999 

Topsail Beach,

North Carolina

Debris removal 1,304,417

Charley and 

Bonnie, 2004 

Ormond-by-the

Sea, Florida 

Restore an electrical 

substation 

 11,361

Ivan, 2004 Cape San Blas, 

Florida 

Construct an emergency 

berm 

 1,423,766

Frances, 2004 Ponce Inlet, Florida Restore Turtle 

Rehabilitation Laboratory at 

the Marine Science Center 

 23,666

Dennis, 2005 Dog Island, Florida Repair damaged road

surfaces 

 37,372

Dennis, 2005 Dog Island, Florida Debris removal 470,833

Ophelia, 2005 Topsail Beach,

North Carolina

Construct emergency

berms 

 $1,167,146

Source: GAO analysis of FEMA data. 

As mentioned earlier, FEMA is also allowed to provide limited disaster 

assistance to individuals through the IHP after the President declares an

emergency or major disaster in an area, including CBRS units. We found 

that since August 26, 1998, FEMA provided $8,237 to 16 individuals in 

CBRS units for emergency rental assistance. These payments were made 

to individuals in CBRS units in Florida and North Carolina. 

Page 24 GAO-07-356 Coastal Barrier
An exception to the limitations within CBRA allows FHWA to administer 

federal funding for projects on publicly owned or operated roads that are 

essential links in a larger transportation network and do not expand the 

existing transportation system. Because, as stated in agency guidance, 

FHWA determined that all roads within the federal highway system, 

including those in CBRS units, are usually “essential links” in a larger 

transportation network, most projects within CBRS units are permissible 

under CBRA after a consultation process with FWS. Although FHWA does 

not maintain data on which projects were located within CBRS units, we 

were able to identify—based on information provided by state officials—

some examples of allowable projects in CBRS units that received federal 

funds from FHWA. For example, according to data from the Florida 

Department of Transportation, federal funding totaling approximately $1.1 

million was provided to repair a road in the Cape San Blas unit after each 

of three hurricanes—Opal, Earl, and Ivan. 

An exception to the limitations within CBRA allows the Corps to provide 

assistance in CBRS units after consultation with FWS as part of its mission 

to maintain and improve existing navigation channels. We found that since 

1983, the Corps performed at least 24 such projects in CBRS units, and 

most were to dredge channels. Many of these projects occurred along the 

Atlantic Intracoastal Waterway or in channels connecting this waterway to 

the Atlantic Ocean. Of the 24 projects, two-thirds occurred in CBRS units 

in South Carolina while the others were located in North Carolina, Florida, 

and Massachusetts. However, it is difficult to calculate the value of the 

Corps’ assistance to CBRS units because nearly all of the Corps’ projects 

involve activities both inside and outside CBRS units, and the Corps does 

not breakout project costs based on CBRS boundaries. 

EPA-authorized state agencies and the Corps have issued permits to 

property owners and entities within CBRS units for a number of different 

projects.24 Since 1983, EPA-authorized state agencies issued at least 41 

permits to property owners and entities in nine different CBRS units. All of 

the permits were associated with the National Pollutant Discharge 

Elimination System (NPDES), primarily to allow storm water discharges 

from construction sites or for discharges from water or wastewater 

treatment systems. Florida, as an EPA-authorized permitting state, issued 

Federal Highway 

Administration 

Corps of Engineers 

EPA-Authorized State 

Agencies and the Corps 

Have Issued Permits for 

Federally Regulated 

Construction Projects in 

CBRS Units 

 24In most cases, permits to regulate point sources that discharge pollutants into waters of 

the United States are issued by EPA-authorized states rather than by EPA itself. 

Page 25 GAO-07-356 Coastal Barrier
38 of the 41 permits. Of the remaining three permits, two were issued by 

New York and one by the U.S. Virgin Islands, both of which are authorized 

by EPA to issue NPDES permits. 

The Corps was unable to provide a complete list of all the permits it had 

issued since CBRA was enacted. However, we have determined that since 

1983, the Corps issued at least 194 permits in 20 different CBRS units for 

purposes such as erosion control, constructing piers and mosquito control 

ditches, filling wetlands, and raising fish and shellfish. Of these 194 

permits: 

• Eighty-three were authorized under Section 10 of the Rivers and Harbors 

Appropriation Act of 1899. The act gives the Corps authority to issue 

permits to construct piers or marinas in navigable waters. 

• Eighty-seven were authorized under Section 404 of the Clean Water Act. 

Section 404 provides the Corps with the authority to issue or deny permits 

for discharges of dredged or fill material into waters under federal 

jurisdiction, including wetlands. 

• Twenty-four involved activities covered by both Section 10 of the Rivers 

and Harbors Appropriation Act and Section 404 of the Clean Water Act. 

Almost two-thirds of these permits were issued to property owners and 

entities in CBRS units in Florida; the remaining permits were issued to 

entities in units in the Carolinas and New England. 

Although CBRA has limited the amount of federal financial assistance 

provided to some CBRS units, it does not appear to have been a major 

factor in discouraging development in those CBRS units that have 

developable land, local government and public support for development, 

and access to affordable private flood insurance. Despite CBRA’s 

prohibitions on federal assistance to units in the CBRS, four federal 

agencies—FEMA, HUD, SBA, and VA—have provided such assistance. 

While the amount of assistance provided in violation of CBRA is not large, 

it does raise concerns about the ability of federal agencies to fully comply 

with the requirements of the act. Unless federal agencies follow the 

procedures they have established to prevent the provision of prohibited 

assistance and have access to up-to-date and reliable maps to ensure that 

accurate determinations are made for properties located in CBRS units, it 

is likely that some violations of CBRA may continue to occur. 

Conclusions 

Page 26 GAO-07-356 Coastal Barrier
In light of the federal financial assistance that was provided in violation of

CBRA, we are recommending that the Secretaries of DHS, HUD, and VA, 

and the Administrator of SBA direct their agencies to (1) obtain official 

determinations from the FWS on whether the properties we identified as

receiving federal assistance in violation of CBRA are in fact located within

a CBRS unit and if they are, cancel all inappropriate loan guarantees and 

insurance policies that have been made to the owners of these properties 

and (2) examine their policies and procedures to ensure that they are 

adequate to prevent federal assistance that is prohibited by CBRA from

being provided to entities in CBRS units. 

In addition, given the importance of digital maps to making accurate CBRS 

determinations, we are recommending that the Secretary of the Interior 

direct FWS to place a high priority on completing its efforts to develop 

digital maps that more accurately depict unit boundaries. 

We provided a draft of this report to the Department of Defense, DHS, 

DOI, HUD, SBA, and VA. We received comments via e-mail from the 

Department of Defense, DHS, and SBA, and we received written 

comments from the DOI, HUD, and VA. 

The Department of Defense and the SBA stated that they had no 

comments on the draft report, and DHS provided only technical comments 

and stated that it concurred with the report’s recommendations. In its 

written comments, DOI stated that it supports efforts to improve CBRS 

property determinations and ensure compliance with CBRA. DOI also 

indicated that it will consider our recommendation concerning 

prioritization of the completion of digital maps as it develops future 

budget requests. In its written comments, HUD stated that the loan 

guarantees in question have already been terminated. HUD also noted that 

it is now developing policy guidance and associated training to ensure that

no future violations of CBRA occur. In its written comments, VA stated 

that it agreed with our findings and one of our recommendations but did 

not agree with our recommendation to cancel the inappropriate loan 

guarantees that it had made in violation of CBRA. VA stated that it did not 

believe that the small number of loan guarantees that we found indicated a 

pattern of abuse of CBRA and that canceling these guarantees would 

inflict a disproportionate harm on lenders and veterans who were not 

responsible for the erroneous property determinations that the loan 

guarantees were based on. While we understand VA’s concerns for the 

adverse impacts that could affect the parties involved, we believe that 

because these loan guarantees violate CBRA they should be rescinded. 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 27 GAO-07-356 Coastal Barrier
We have also incorporated the technical comments provided by DHS and

DOI, as appropriate, throughout this report. HUD’s written comments are 

presented in appendix V, DOI’s written comments are presented in 

appendix VI, and VA’s written comments are presented in appendix VII. 

We are sending copies of this report to interested congressional 

committees as well as the Administrator, Small Business Administration; 

the Commander, U.S. Army Corps of Engineers; and the Secretaries of the 

Army, Defense, Homeland Security; Housing and Urban Development, 

Interior, and Veterans Affairs. We also will make copies available to others 

upon request. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me at (202) 512-

3841 or mittala@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

GAO staff who made major contributions to this report are listed in 

appendix V.

Sincerely yours, 

Sincerely yours, 

Anu K. Mittal 

Director, Natural Resources and Environment 

Page 28 GAO-07-356 Coastal Barrier
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 29 GAO-07-356

Appendix I: Objectives, Scope, and 

Methodology 

We were asked to address issues related to the Coastal Barrier Resources 

Act, as amended, (CBRA) by reviewing development that has occurred and 

federal funding that has been provided within the John H. Chafee Coastal

Barrier Resources System (CBRS). Specifically, we were asked to 

determine (1) the extent of development within the CBRS and (2) the 

extent of federal assistance provided to CBRS units. 

To determine the extent of development in the system, we determined the 

number of structures within each unit. We accomplished the task by 

electronically mapping addresses with MapInfo and layering electronic 

boundaries of CBRS units from the Federal Emergency Management 

Agency’s (FEMA) Q3 Digital Flood Insurance Rate Map data product with 

the mapped addresses. FEMA’s Q3 data provides the external boundaries 

for CBRS units, though it is not an exact replica of the boundaries. Our 

results are representative of the extent of development within the CBRS. 

We focused our review on a stratified random sample of 91 units drawn 

from the 584 total units in the system, excluding otherwise protected 

areas.1

 The sample was drawn so that the results from the sample would 

have a precision margin of about plus or minus 10 percentage points at the 

95 percent confidence interval. We were able to collect and analyze data

for 84 of the 91 CBRS units, representing a weighted response rate of 92 

percent.2

 Of the 84 units, 42 units are located in the north and 42 units are 

located in the south. Northern units include those located in Connecticut, 

Maine, Massachusetts, Michigan, New Jersey, New York, and Rhode 

Island. Southern units are those located in Alabama, Florida, Louisiana, 

Maryland, Mississippi, North Carolina, South Carolina, Virginia, Texas, 

Puerto Rico, and the Virgin Islands. As a result of the high response rate, 

we reweighted the sample to represent the entire population of units. 

Determining the Extent of 

Development in CBRS 

Units 

 1

According to the Fish and Wildlife Service (FWS), there are 585 units in the system. 

However, FWS considers the Waites Island Complex to be two units because portions of

the units are in North Carolina and South Carolina. We counted this as one unit for our 

analysis. We excluded OPAs from our review based on discussions with FWS officials.

According to the officials, they did not believe that OPAs were subject to the same level of 

development as full system units since they were often protected from development by 

other mechanisms. 

2

We were unable to obtain data for seven units within the sample because the local 

governments were unable to provide address data or year built for the structures in these 

areas. 

Coastal Barrier
Appendix I: Objectives, Scope, and 

Methodology 

Because we followed a probability procedure based on random selections, 

our sample is only one of a large number of samples that we might have 

drawn. Since each sample could have provided different estimates, we 

express our confidence in the precision of our particular sample’s results 

as a 95 percent confidence interval. This is the interval that would contain 

the actual population value for 95 percent of the samples we could have 

drawn. As a result, we are 95 percent confident that each of the confidence

intervals in this report will include the true values in the study population. 

All percentage estimates from the sample have margins of error of plus or 

minus 10 percentages points or less. 

To identify the number of structures within the CBRS units in our sample, 

we obtained address or parcel data from local government offices—

including tax assessor’s offices and on-line databases, geographic 

information system departments, and information technology 

departments. The exact dates for the parcel and address datasets vary by 

location—however, we requested the most recent available data. We also

collected year-built data, value, and type of structure when available. After 

determining whether the structure was within the CBRS unit, we reviewed 

the year-built data to determine how many structures were built since the 

unit’s inclusion in the CBRS. We did not independently assess the 

reliability of each address dataset provided by the local governments. 

However, for a number of address datasets we assessed the reliability of 

the data through interviews with knowledgeable local officials and 

verification of the addresses in the dataset by visual inspection during site 

visits. 

The electronic mapping was performed using roads and highways data 

provided by MapInfo’s 2002 StreetSmart program. As a result, our analysis 

would not be able to map structures located on a street not included in the 

2003 roads and highways dataset. Once the addresses were mapped, they 

were layered in MapInfo with FEMA’s Q3 data. On the basis of

conversations with FEMA and FWS officials, we believe these data are 

sufficiently reliable for the purposes of this study. Since the FEMA Q3 data 

CBRS boundaries may not be precise, the results of our analysis could 

incorrectly reflect whether a structure is within a CBRS unit. As with any 

electronic mapping technology, accuracy issues are inherent and may 

impact reliability of the results. 

We conducted site visits to 18 CBRS units in Florida, Massachusetts, North 

Carolina, Rhode Island, and South Carolina. During the site visits, we 

observed the CBRS units and interviewed local, state, and federal officials, 

home owners, realtors, insurance agents, and environmental officials to 

Page 30 GAO-07-356 Coastal Barrier
Appendix I: Objectives, Scope, and 

Methodology 

discuss the extent of development and factors encouraging or 

discouraging development in the units. 

In addition to the site visits, we conducted telephone interviews with local, 

state, or federal officials in Louisiana, Massachusetts, Maryland, Michigan, 

Rhode Island, Texas, Virginia, and Puerto Rico. Using the data collected 

during the site visits and the telephone interviews, we were able to 

determine reasons why development has or has not occurred in those 

units. 

To determine the extent of federal assistance provided to CBRS units, we 

identified eight agencies with programs that may have provided assistance 

to these areas. Appendix IV includes a complete list of these programs. We

reviewed and analyzed federal legislation and regulations that are 

applicable to federal assistance to CBRS units, including the CBRA. For 

each of the programs that provide assistance that is prohibited in a CBRS 

unit, we interviewed officials regarding their agency procedures for 

preventing assistance to CBRS units. In instances where we identified 

violations, we collected additional information about the assistance 

provided and interviewed agency officials regarding the agency’s plans to

prevent prohibited assistance from being provided in the future. 

We compiled a list of 4,472 addresses in 37 CBRS units that had at least 

one address. (See app. II for a list of CBRS units in our review.) As the 

section above details, we obtained address data from local county 

government sources and electronically mapped addresses within the 

boundaries of CBRS units. Next, we obtained data from each agency on 

program assistance provided and determined whether this assistance was 

provided within one of the CBRS units or to an address in a CBRS unit. 

We gathered additional data to determine whether civil works projects 

administered by the Corps and permits issued by the Corps or EPAauthorized state agencies were for an activity within a CBRS unit. We 

asked agency officials to provide latitude and longitude data for every 

project that occurred or permit that was issued in any of the counties that 

contained at least one of the 37 CBRS units. Then we electronically 

mapped the coordinates to determine if the activity occurred within the 

boundaries of a CBRS unit. Corps officials, however, were unable to 

provide latitude and longitude data for a large percentage of the permits 

issued. 

Determining the Extent of 

Federal Assistance 

Provided to CBRS Units 

Page 31 GAO-07-356 Coastal Barrier
Appendix I: Objectives, Scope, and 

Methodology 

For each agency program, we assessed the accuracy and reliability of the 

data system by obtaining from the agency written responses regarding (1) 

the agency’s methods of data collection and quality control reviews, (2) 

practices and controls over accuracy of data entry, and (3) any limitations 

of the data. We determined that the agencies’ data were sufficiently 

reliable for the purposes of our review unless noted below. The details of

our analysis for each agency program are provided below. 

To identify flood insurance policies in CBRS units, we obtained data from 

FEMA’s National Flood Insurance Program for all policies as of May 8, 

2006. As mentioned above, we compiled a list of 4,472 addresses in 37 

CBRS units. Because structures built prior to a CBRS unit’s inclusion in 

the system may still obtain flood insurance, we had to determine whether 

each structure was built prior to the unit’s inclusion in the CBRS. Of the 

4,472 addresses, we were able to determine that 648 structures were built 

prior to the unit’s inclusion in the CBRS, and we deleted these addresses 

from our analysis. We reviewed the addresses of all the structures built 

after the unit’s inclusion in the CBRS and addresses where we could not 

determine the year built in our flood insurance analysis. Thus, we 

reviewed 3,824 addresses in 21 units to determine if the structure had 

federal flood insurance. Structures that were built prior to the CBRS unit’s 

inclusion in the system cannot obtain federal flood insurance if the 

property has been substantially improved. We did not collect data on 

whether properties had been improved. If we identified a flood insurance 

policy among the addresses where we were unable to determine the year 

built, we reviewed the year-built data in FEMA’s database. If FEMA’s data 

revealed that the structure was built prior to the unit’s inclusion in CBRA, 

we eliminated the match from our review. 

We provided FEMA our list of addresses located in 37 CBRS units. FEMA 

compared our list of addresses with addresses for which Individuals and 

Households Program (IHP) payments had been provided from its National 

Emergency Management Information System. FEMA reviewed payments

from the system from August 26, 1998, to August 2, 2006. 

The Small Business Administration (SBA) provided loan data for business 

and disaster loans in all states with CBRS units from its Loan Accounting 

System. SBA provided us records for loans approved January 1, 1990, 

through May 30, 2006. While we did not find any matches for business 

loans, SBA officials told us that the address in the database could be a 

mailing address and not the physical address of the business. For SBA 

disaster loans, the SBA officials said that the address in the database is the 

location where the assistance was provided. 

FEMA National Flood 

Insurance Program 

FEMA IHP Program 

SBA 

Page 32 GAO-07-356 Coastal Barrier
Appendix I: Objectives, Scope, and 

Methodology 

We obtained data for 13 of the Department of Housing and Urban 

Development’s (HUD) single family and multifamily housing programs. 

(See app. IV for a list of the programs reviewed.) HUD provided data from 

its Real Estate Management System and Single Family Housing Enterprise 

Data Warehouse database for loans as of June 2006. 

The Department of Veterans Affairs (VA) provided loan guarantee data 

from its Home Loan Guaranty database. VA provided us records for active 

loan guarantees as of October 2006. 

We obtained data for 22 of the U.S. Department of Agriculture’s (USDA) 

business and industry, community facilities and single family and 

multifamily housing programs. USDA provided this information from its 

Automated Multi-Family Housing Accounting System, Guaranteed Loan

System, MortgageServ Loan Servicing System databases, and Multi-Family

Information System. The information was as of July 2006. 

For USDA’s utility programs, we used a different methodology because the 

projects are not associated with one structure as with a flood insurance 

policy or a housing loan. For USDA’s electric programs, USDA officials 

reviewed the construction work plans and the environmental reports for 

recent loans to electric service providers who provide service to selected

counties in Florida, North Carolina, and Virginia that include one or more 

of the CBRS units included in our review. USDA officials determined that 

it does not appear that they have financed projects serving a CBRS unit. 

For USDA’s water and waste programs, we requested the environmental 

assessment forms statements for the projects in the counties that included 

a CBRS unit we identified as having 100 or more structures. We then 

reviewed these records to determine if they indicated that USDA officials 

had considered whether the projects would impact a CBRS unit when 

reviewing them. 

FEMA provided data from its National Emergency Management 

Information System on disaster assistance provided to counties and 

territories in our review, including data for the U.S. Virgin Islands and 

Puerto Rico. The data were from November 1998 through July 2006. We

reviewed assistance designated by FEMA as being within a CBRS unit. 

However, we determined that this designation was not sufficiently reliable 

to identify all projects within the CBRS. We could not determine the full

extent of assistance provided to CBRS units because the CBRS 

designation in the data was not always reliable. In addition, some 

assistance was provided countywide, and we could not determine if this 

HUD Housing Programs 

VA Home Loan Guaranty 

Program 

USDA Business and Industry, 

Community Facilities, and 

Housing Programs 

USDA Utility Programs 

FEMA Public Assistance Grant 

Program 

Page 33 GAO-07-356 Coastal Barrier
Appendix I: Objectives, Scope, and 

Methodology 

assistance was provided to the unit. As a result, we provide examples of 

disaster assistance in our report. Where data were available, we 

electronically mapped the location of the assistance to verify it was within 

a CBRS unit. 

We obtained data for projects receiving federal aid that received federal

funds between January 1996 and July 2006 in counties with a CBRS unit 

that we identified as having 10 or more structures. Federal Highway 

Administration (FHWA) officials extracted the data for these projects from 

the Financial Management Information System—-a database that tracks 

projects that receive federal funding. To determine whether assistance 

was provided that is prohibited by law, we identified new construction 

projects or projects that added capacity to existing roadways. To 

determine whether these projects were within a CBRS unit, we relied upon 

interviews and location analysis provided by FHWA officials and 

Department of Transportation officials from New Jersey, North Carolina, 

Puerto Rico, Rhode Island, South Carolina, and the Virgin Islands. For 

projects in New Jersey, state officials provided aerial photographs with the 

location of federally funded projects. For North Carolina, we met with 

FHWA officials to review maps displaying the location of federally funded

projects. For Puerto Rico, FHWA and Puerto Rico Department of 

Transportation officials electronically mapped the location of projects. For 

Florida, we relied upon analysis conducted by an official at the Florida 

FHWA division office. For Rhode Island, South Carolina, and the U.S. 

Virgin Islands, Department of Transportation officials or public works 

department officials provided a paper map marked with the location of the 

projects. 

Because of the volume of projects that are allowable, we did not 

determine the number of allowable projects in every CBRS unit. However, 

we did review the allowable projects in Gulf County, Florida, and Onslow 

County, North Carolina.

Federal Highway 

Administration 

Page 34 GAO-07-356 Coastal Barrier
Appendix II: CBRS Units We Reviewed 

This appendix provides information on the CBRS units that we reviewed. 

Table 2 shows the units included within our random sample and the 

approximate number of new structures in each unit. 

Table 2: CBRS Units Included in Random Sample and Approximate Number of New Structures 

Unit 

number CBRS unit State 

No new 

structures 

1-5 New

structures 

6-10 New

structures 

11-15 New

structures 

100 or More 

new structures

Q01A Pelican Island AL X

AL-03 Skunk Bayou AL X

E03 Jordan Cove CT X

CT-13 Kelsey Island CT X

CT-01 Mason IslandaCT

E09 Norwalk Islands CT X

FL-34 Biscayne Bay FL X

FL-46 Boot Key FL X

P20 Cayo Costa FL X

P31A Four Mile Village FL X 

P05A Matanzas River FL X

P18 Sanibel Island Complex FL X

FL-99 Tom King FL X

P10 Vero Beach FL X

S01A Bay Joe Wise Complex LA X 

S05 Timbalier Islands LA X

C19 Black Beach MA X

C11A Boat Meadow MA X

C15 Centerville MA X

C00 Clark Pond MA X

C16 Dead Neck MA X

C31 Elizabeth Islands MA X

C10 Freemans Pond MA X

MA-30 Herring Brook MA X

C32 Mishaum Point MA X

MA-24 Naushon Island Complex MA X 

MA-16 Nobscusset MA X

MA-33 Phinneys Harbor MA X

C03A Rexhame MA X

C28 South Beach MA X

C14 Squaw Island MA X

Appendix II: CBRS Units We Reviewed 

Page 35 GAO-07-356 Coastal Barrier
Appendix II: CBRS Units We Reviewed 

Unit 

number CBRS unit State 

No new 

structures 

1-5 New

structures 

6-10 New

structures 

11-15 New

structures 

100 or More 

new structures

C24 Tuckernuck Island MA X

C01C West Head Beach MA X 

MD-53 Blake Creek MD X

MD-39 Drum Point MD X

MD-15 Long Point MD X

MD-56 St. Catherine Island MD X 

MD-35 Wilson Pond MD X

A03 Jasper ME X

A09 Seapoint ME X

A03B Starboard ME X

MI-59 Laughing Whitefish RiveraMI

MI-66 Lightfoot BayaMI

MI-02 Toledo Beach MI X

MI-43 Whitefish Point MI X

MS-04 Heron Bay Point MS x 

R02 Marsh Point MS X

L01 Currituck Banks NC X

L03 Hatteras Island NC X

L08 Wrightsville Beach NC X

NJ-04B Metedeconk Neck NJ X

NY-12 Centerpoint Harbor NY X

NY-41 Clam Island NY X

NY-39 Cow Neck NY X

NY-59 Fire Island NY X

NY-57 Georgica/Wainscott

Ponds 

NY 

X

NY-30 Hog Neck Bay NY X 

NY-64 The Isthmus NY X

NY-11 Lloyd Harbor NY X

NY-10 Lloyd Point NY X

NY-42 Mill CreekaNY

F10 NapeagueaNY

F05 Old Field Beach NY X 

NY-16 Stony Brook Harbor NY X 

NY-76 Walker NY X

PR-53 Bajio de Marea PR X

PR-68 Boca PrietaaPR

Page 36 GAO-07-356 Coastal Barrier
Appendix II: CBRS Units We Reviewed 

Unit 

number CBRS unit State 

No new 

structures 

1-5 New

structures 

6-10 New

structures 

11-15 New

structures 

100 or More 

new structures

PR-79 Penon Brusia PR

PR-59 Punta Ballena PR X

PR-40 Punta Tuna PR X

RI-12 East Matunick Beach RI X

RI-07 Hazards Beach RI X

RI-02A McCurry Point RI X

D02B Prudence Island Complex RI X 

M07 Bird Key Complex SC X 

M08 Captain Sams Inlet SC X

M06 Morris Island Complex SC X 

T12 Boca Chica TX X

T11 South Padre Island TX X 

TX-04 Swan Lake TX X

VI-08 Cangarden Bay VI X

VI-09 Krause Lagoon VI X

VI-17 Pond Bay VI X

VI-06 Robin Bay VI X

VI-04 Southgate Pond VI X

VI-11 Westend Saltpond VI X

VA-42 Chesapeake Beach VA X

VA-25 Fox Islands VA X

VA-45 Harveys Creek VA X

VA-46 Ingram Cove VA X

VA-16 Scarborough Neck VA X

Source: GAO analysis of CBRS units. 

Note: There was no development in any unit between 16 and 100 structures. 

a

The number of new structures is unknown for these units. 

Tables 3 and 4 show the CBRS units we included in our analysis to 

determine the extent of federal expenditures and permits made to entities 

in the CBRS. Table 3 displays the CBRS units included within our sample 

that had structures—regardless of whether the structures were built prior 

to or after the units inclusion in the CBRS. Table 4 lists the additional 

CBRS units that were suggested for inclusion in our review by FWS 

because the agency had information suggesting that development was 

occurring in these areas.

Page 37 GAO-07-356 Coastal Barrier
Appendix II: CBRS Units We Reviewed 

Table 3: CBRS Units Included in GAO’s Random Sample That Were Analyzed to 

Determine the Extent of Federal Expenditures and Permits 

Unit number CBRS unit State 

CT-13 Kelsey Island CT

CT-01 Mason Island CT

E09 Norwalk Islands CT

FL-46 Boot Key Island FL

P31A Four Mile Village FL

P05A Matanzas River FL

P18 Sanibel Island Complex FL

P10 Vero Beach FL

C19 Black Beach MA

C11A Boat Meadow MA

C00 Clark Pond MA

C16 Dead Neck MA

C31 Elizabeth Islands MA

C14 Squaw Island MA

L01 Currituck Banks NC

L08 Wrightsville Beach NC

NJ-04B Metedeconk Neck NJ

NY-59 Fire Island NY

NY-30 Hog Neck Bay NY 

NY-42 Mill Creek NY

F10 Napeague NY

NY-16 Stony Brook Harbor NY 

RI-12 East Matunick Beach RI

D02B Prudence Island Complex RI 

M07 Bird Key Complex SC 

M08 Captain Sams Inlet SC

VA-45 Harveys Creek VA

Source: GAO analysis of CBRS units. 

Page 38 GAO-07-356 Coastal Barrier
Appendix II: CBRS Units We Reviewed 

Table 4: Additional CBRS Units Suggested for Review by FWS That Were Analyzed

to Determine the Extent of Federal Expenditures and Permits 

Unit Number CBRS unit State 

P10A Blue Hole FL

P30 Cape San Blas FL

P09A Coconut Point FL

FL-94 Deer Lake Complex FL

P28 Dog Island FL

FL-92 Indian Peninsula FL

P07 Ormond-by-the-Sea FL

P08 Ponce Inlet FL

FL-98 Santa Rosa Island FL

L06 Topsail NC

Source: GAO analysis of CBRS units. 

Page 39 GAO-07-356 Coastal Barrier
Appendix III: S

Units 

napshots of Selected CBRS 

Page 40 GAO-07-356

Appendix III: Snapshots of Selected CBRS 

Units 

Within the state of Massachusetts, there are 62 CBRS units. The units 

consist of 64,076 total acres of land, with 88 percent of the land considered 

wetlands by FWS.1

 We visited six CBRS units—Black Beach, Boat 

Meadow, Centerville, Herring Brook, Sandy Neck, and Squaw Island. 

These units were primarily salt marsh or wetland areas with narrow 

coastal beach areas. Only the Boat Meadow unit had experienced any new 

development since inclusion in the CBRS. Figure 2 displays the CBRS 

units we visited during our site visit. 

Massachusetts

 1

For purposes of this appendix, wetlands include associated aquatic habitat such as 

nearshore waters and inlets. 

Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 2: CBRS Units We Visited in Massachusetts 

Source: GAO.

CBRS units

The Herring Brook and Sandy Neck units both include land used as a 

public beach destination. The Sandy Neck unit is a coastal barrier beach,

with both public and private beach areas, approximately 6 miles long 

varying in width from 200 yards to one-half mile. The unit is classified by

the local government as a conservation and recreation area. Several homes

Page 41 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

are located on the unit, but one local official noted they are all registered

by the state as historic places. 

The Centerville unit and the Squaw Island unit each have a barrier beach, 

but the beach is privately owned. The Centerville unit serves as a private 

beach and protective buffer for the homes bordering the unit. A local 

official noted the residents annually pay for a beach nourishment project 

in order to keep the protective buffer for their homes. The Squaw Island 

unit is a barrier beach and wetlands surrounding an area of developed land

that was excluded from CBRS. The excluded area consists of homes 

valued between $1.7 and $6.9 million. Figure 3 displays a portion of Squaw

Island. 

Figure 3: House and Beach on the Squaw Island, CBRS Unit in Massachusetts 

Source: GAO.

Both the Black Beach and Boat Meadow units consist primarily of salt 

marshes and wetlands. The southern portion of the Black Beach unit has 

one street of homes that were built prior to CBRA. One local official 

described the homes as “traditional Cape Cod” style houses. The Boat 

Meadow unit has several neighborhoods bordering the unit with one 

Page 42 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

neighborhood partially included in the unit. It is within this area that new

development—three single-family homes—has occurred since the unit’s 

inclusion in the CBRS. 

Within the state of Rhode Island, there are 21 CBRS units. The CBRS units 

consist of 10,320 total acres, with 83 percent considered wetlands by the 

FWS. During our site visit to Rhode Island, we focused our review on the 

Prudence Island Complex unit. The Prudence Island Complex unit 

consists of numerous separate pieces of land all included in one CBRS 

unit. The unit is located in residential neighborhoods in several counties 

around the Narragansett Bay. Although approximately 50 homes are 

located within the CBRS unit, only 8 of the homes have been built since 

inclusion within CBRS. Figure 4 shows the CBRS units that we visited in 

Rhode Island. 

Rhode Island 

Page 43 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 4: CBRS Units We Visited in Rhode Island 

Source: GAO.

CBRS units

Prudence Island

Complex CBRS unit

Several areas included in the Prudence Island Complex are backyards of 

private homes. Home owners voluntarily included the CBRS land in their 

backyards in conservation easements, limiting the right of future owners 

of the property to develop the land. Figure 5 is one of the homes with a 

backyard that falls in the CBRS unit boundaries.

Page 44 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 5: Home with a Backyard in the Prudence Island, Rhode Island CBRS Unit 

Source: GAO.

Another area included in the unit is owned by the Rhode Island Country 

Club and serves as a golf practice area. Figure 6 is the country club land 

that is included in the CBRS. 

Page 45 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 6: Portion of the Prudence Island Complex CBRS Unit 

Source: GAO.

The unit also includes a small beach and a wetland inlet located in a 

residential neighborhood. The inlet leads to the Rhode Island Country 

Club. A local official stated that the County Club has asked the U.S. Army 

Corps of Engineers to re-dredge the inlet to improve the playability of the 

golf course—which gets heavily saturated during rains. Dredging within

the CBRS unit would allow water to run off the course faster. Figure 7 

shows the area within the CBRS unit that would be dredged. 

Page 46 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 7: Inlet Where Proposed Dredging Project Would Occur in the Prudence 

Island CBRS Unit 

Source: GAO.

Within the state of South Carolina, there are 16 CBRS units. FWS officials 

determined that the units consist of 97,856 total acres, with 90 percent of 

land considered wetlands. We visited two units in South Carolina—Bird 

Key Complex and Captain Sams Inlet (see fig. 8). Each of the units has 

experienced the addition of 10 or fewer residential homes since its 

inclusion in the CBRS. The developed portions of both of these units are 

located on coastal islands—the Captain Sams Inlet homes are located on

Seabrook Island, and the Bird Key Complex homes are located on Kiawah 

Island. 

South Carolina 

Page 47 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 8: CBRS Units We Visited in South Carolina 

Source: GAO.

CBRS units

Development in the Captain Sams Inlet CBRS unit is located in the 

Seabrook Island Resort—a 2,200-acre, privately gated, beachfront 

community on Seabrook Island. According to local officials, the title to the 

land where these homes are located was in dispute for years, which 

Page 48 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

delayed its development, unlike the rest of the island. Local officials also 

stated that they believe that if the title to the land had not been in dispute,

the area would have developed at the time of the CBRS unit designations

and most likely would not have been included in the CBRS. Because of the 

CBRS inclusion, the property owners in the unit are no longer eligible for

certain types of federal assistance, in particular federal flood insurance,

which they noted is much less expensive than privately available 

insurance. Officials with whom we met on neighboring Kiawah Island 

stated that a developer has plans to build up to 50 units on a 20-acre 

portion of the Captain Sams Inlet CBRS unit that is located on Kiawah 

Island. 

Development in the Bird Key Complex CBRS unit is located on the 

northeast portion of Kiawah Island, which is also a privately gated,

beachfront community with approximately 3,000 homes. The southern 

portion of the CBRS unit includes a few homes that we identified as being 

located in the unit, an 18-hole golf course, and an area of land called 

“Cougar Island.” Kiawah officials told us that a private developer has plans 

to build 360 homes on 24 acres of Cougar Island at a future date. 

Within the state of Florida, there are 67 CBRS units. The units range 

extensively in size and composition and encompass 285,937 total acres 

along both the Atlantic and Gulf Coasts. Overall, 87 percent of the land 

within the units is considered wetlands by FWS. We visited three units—

Four Mile Village, Cape San Blas, and Deer Lake Complex (see fig. 9). All 

three units we visited had experienced some level of development. 

However, the development ranged from 11 new structures in Deer Lake 

Complex to at least 900 new structures in Cape San Blas since the units 

inclusion in the CBRS. 

Florida 

Page 49 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 9: CBRS Units We Visited in Florida 

Source: GAO.

CBRS units

Gulf of Mexico

The Four Mile Village unit in Florida has experienced an increase of at 

least 100 new residential structures since its inclusion in CBRS. This unit 

is expected to continue to experience development, as a 167-home private 

development project called Cypress Dunes is completed. The Cypress 

Dunes project consists of a 44-acre gated community and will include a 

clubhouse, pool, exercise center, dining facility, and tennis courts, all 

entirely within the CBRS unit. 

Page 50 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

The 1,637-acre Topsail Hill Preserve State Park makes up more than onehalf of the Four Mile Village CBRS unit. The preserve was purchased in 

1992 with funds from the Conservation Acquisition of Recreation Lands 

program, also known as Forever Florida. Topsail was purchased for its 

unique natural ecosystems, including freshwater coastal dune lakes, wet 

prairies, scrub, pine flatwoods, marshes, cypress domes, seepage slopes 

and 3.2 miles of sparkling white sand beaches. The park also includes 

areas to bike, walk, swim, fish, and access to the beach, plus a full-facility 

campground features a swimming pool, tennis courts, and shuffleboard 

courts. 

The Cape San Blas CBRS unit is located on a peninsula in the Florida 

panhandle. It has experienced significant development since its inclusion 

within the CBRS with the addition of at least 900 new homes. Primarily, 

the homes are single-family residences used as vacation homes and 

rentals. 

In November 2002, FEMA designated parts of Cape San Blas as a special 

flood hazard area. Mortgage lenders require home owners in these zones 

to obtain flood insurance. Because federal flood insurance is not available 

in CBRS, home owners with mortgages must obtain private flood 

insurance. At the same time, officials told us that the cost of private 

insurance has skyrocketed and is no longer comparable to national flood 

insurance program rates. According to local officials, tourism in the Cape 

San Blas area is important to the economy of the county. They told us that 

property values in the unit have decreased since FEMA adopted a special

flood hazard area for the CBRS unit. Residents and local officials have 

unsuccessfully attempted to remove Cape San Blas from the CBRS so that 

residents would be eligible to obtain flood insurance through the National

Flood Insurance Program. In the 109th Congress, legislation was 

introduced in the House of Representatives that would exempt Cape San 

Blas, along with another unit, from CBRA’s prohibitions and the 

limitations on flood insurance.2

 However, the bill never came to a vote. 

We identified some development in the Deer Lake Complex unit since its 

inclusion within the CBRS. A total of 11 new single-family homes have 

been constructed within the unit. 

 2

H.R. 3280, 109th Cong. (2005) 

Page 51 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Within the state of North Carolina, there are 10 CBRS units consisting of 

52, 215 total acres—approximately 6,809 of those are considered 

developable acres by FWS. We visited four CBRS units—Topsail, Lea 

Island, Currituck Banks, and Wrightsville Beach (see fig. 10). Both Topsail 

and Currituck have experienced significant levels of development since 

inclusion within the CBRS. In contrast, Lea Island and Wrightsville Beach 

are impractical locations for development as they are significantly affected

by erosion and shifting sands. 

North Carolina 

Page 52 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 10: CBRS Units We Visited in North Carolina 

Source: GAO.

CBRS units

The Topsail unit in North Topsail is a barrier island with low elevation 

without the protection of substantial dunes. It has a total of approximately 

1,600 structures and local officials stated that most of the structures were 

built after CBRA was enacted. The unit consists of single and multifamily 

Page 53 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

homes, a few hotels/motels, a convenience store, and the North Topsail 

Beach Town Hall. 

In recent years, the unit has been hit several times by hurricanes. For 

example, in 1996, Hurricanes Bertha and Fran caused significant damage.

The storms leveled dunes, cut new channels across the island, dumped 

tons of sand, and destroyed more than 300 buildings. The federal 

government provided funds that assisted in repairing the streets, repairing 

water and sewer lines, replacing signs, and removing substantial debris. 

Since that time, the area has been rebuilt, but other storms have continued 

to cause damage. We identified at least $5.6 million in disaster assistance 

that was provided to entities in the unit since November 1998.

Portions of the Topsail CBRS unit have experienced substantial levels of 

erosion. As the soil erodes, the ocean becomes dangerously close to the 

homes. Figure 11 pictures one of several homes in the Topsail area where

the ocean waves make contact with the home’s foundation. 

Page 54 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

Figure 11: House in North Topsail CBRS Unit on the Edge of the Ocean 

Source: GAO.

Several areas outside of the CBRS unit have approved plans for a federally 

funded Corps beach renourishment project. However, because areas 

within the CBRS unit are ineligible for federal funding for a beach 

renourishment project, local officials are pursuing other opportunities to 

fund the portion of the project that falls within the CBRS boundaries. For 

example, the Town of North Topsail Beach recently proposed a $34 

million bond package to pay for the beach renourishment project, but the 

voters rejected the proposal in November 2006. 

According to local officials, during the time when much of the 

development occurred in the Topsail unit, affordable private flood 

Page 55 GAO-07-356 Coastal Barrier
Appendix III: Snapshots of Selected CBRS 

Units 

insurance was generally available. However, in recent years the cost of 

private flood insurance has increased tremendously. Currently, these 

officials said that many residents are frustrated with CBRA’s prohibitions 

on the availability of federal flood insurance and federal funding for beach 

renourishment projects. According to these officials, residents in the 

Topsail CBRS unit are upset that they must pay significantly higher 

insurance premiums than their neighbors who own properties just outside 

of the unit who can obtain federal flood insurance. 

The Currituck Banks CBRS unit is located on the outer banks of North 

Carolina, with the northern boundary at the Virginia state line. The unit 

has also experienced significant new development, with at least 400 new 

residential homes built since inclusion in CBRS. Local officials stated that 

rapid development has occurred in the area since the late 1980s and that

as of June 2006, there were 550 single-family dwellings within the unit. 

However, officials noted this only represents 18 percent of the total 

capacity of homes that can be built in the unit. County planning staff noted 

that the area currently has 3,088 actual or planned building lots available. 

Although the Currituck Banks unit does not have any paved roads and is 

only accessible by four-wheel drive vehicle or boat, it still continues to be 

developed, partly because people on the Outer Banks are seeking the 

solitude that living in the CBRS unit can provide. Moreover, the unit has an 

extensive canal system that allows residents direct boat access to their 

homes and the mainland. 

The Lea Island CBRS unit is a tiny barrier island, accessible only by boat, 

and located south of the Figure Eight Island. The island is privately owned,

but local officials stated that conservation groups are slowly trying to buy 

more of the island. The island is approximately 60 acres long with most of 

the land less than 10 feet above sea level. The island is in a constant state 

of flux due to erosion and shifting sand. According to a local coastal 

official, 15 homes previously existed on Lea Island, but all of them—

except for one small cabin—had been destroyed by natural disasters. 

At the time CBRA was enacted, FWS determined that the Wrightsville 

Beach unit had 83 developable acres of land. However, sand continuously 

shifts within the unit. At one point, the majority of sand in the unit had 

shifted to such an extent that the entire unit was under water. According 

to local officials, to keep the unit above water, local entities must 

continually dredge an inlet adjacent to the unit to replenish the unit with 

sand. 

Page 56 GAO-07-356 Coastal Barrier
Appendix IV: Pr

Assistan

ograms and Types of Federal 

ce Analyzed 

Page 57 GAO-07-356

Appendix IV: Programs and Types of Federal 

Assistance Analyzed 

Permits - Section 404 and Section 10

Civil Works programs 

Business and Industry Programs 

Business and Industry Direct Loans 

U.S. Army Corps of 

Engineers 

U.S. Department of 

Agriculture 

Business and Industry Guaranteed Loans 

Intermediary Relending Program 

Rural Business Enterprise Grants 

Rural Business Opportunity Grants 

Rural Economic Development Loans 

Rural Economic Development Grants 

Renewable Energy and Energy Efficiency Program 

Community Facilities Programs 

Community Facilities Direct Loans 

Community Facilities Guaranteed Loans 

Community Facilities Grants 

Electric Programs 

Hardship Loans 

Municipal Loans 

Treasury Loans 

FFB Guaranteed Loans 

Single Family Housing Programs 

Rural Housing Guaranteed Loan 

Rural Housing Direct Loan 

Housing Repair and Rehabilitation Loan 

Housing Repair and Rehabilitation Grant 

Rural Housing Site Loans 

Mutual Self-Help Housing Grants 

Homes for Sale 

Multifamily Housing Programs 

Farm Labor Housing Loans and Grants 

Rural Rental Housing Loans 

Guaranteed Rental Housing 

Coastal Barrier
Appendix IV: Programs and Types of Federal 

Assistance Analyzed 

Rental Assistance Program 

Water and Waste Programs 

Water and Waste Disposal Loans 

Water and Waste Disposal Grants 

Emergency Community Water Assistance Grants

Revolving Fund Program 

Household Water Well System Program 

Federal Emergency Management Agency 

National Flood Insurance Program 

Individuals and Households Program 

Public Assistance Program (Disaster) 

Permits for bridges over navigable waters of the United States

Single Family Housing Programs

Mortgage Insurance - Section 203(b) 

Department of Homeland 

Security 

U.S. Coast Guard 

Department of Housing 

and Urban Development 

Rehabilitation Mortgage Insurance - Section 203(k) 

Mortgage Insurance for Condominium Units - Section 234(c) 

Home Equity Conversion Mortgage - Section 255

Multifamily Housing Programs 

Supportive Housing for the Elderly - Section 202 

Mortgage Insurance for Cooperative Housing - Section 213 

New Construction/Substantial Rehabilitation of Apartments with 

Nonprofit Sponsors - Section 221(d)(3) 

New Construction/Substantial Rehabilitation of Apartments with Forprofit Sponsors - Section 221(d)(4) 

Refinancing of Apartment Primary Loans - Section 223(a)(7) 

Healthcare Facilities - Section 232 

Refinancing of Healthcare Facilities - Section 232 

Supplemental Loan Insurance - Section 241(a) 

Supportive Housing for Persons with Disabilities - Section 811 

Page 58 GAO-07-356 Coastal Barrier
Appendix IV: Programs and Types of Federal 

Assistance Analyzed 

National Pollution Discharge Elimination System (NPDES) permits 

Federal Aid Highway Program 

7 (a) and 504 Loan programs 

Disaster Loan program 

Veterans Benefits Administration Home Loan Guaranty Program 

Environmental Protection 

Agency 

Federal Highway 

Administration 

Small Business 

Administration 

Department of Veterans 

Affairs 

Page 59 GAO-07-356 Coastal Barrier
Appendix V: Comments from the Department Appendix V of Housing and Urban Development : Comments from the Department 

of Housing and Urban Development 

Page 60 GAO-07-356 Coastal Barrier
Appendix V: Comments from the Department 

of Housing and Urban Development 

Page 61 GAO-07-356 Coastal Barrier
Appendix VI: Comments from the Department Appendix VI: Comments from the of the Interior 

Department of the Interior 

Page 62 GAO-07-356 Coastal Barrier
Appendix VI: Comments from the Department 

of the Interior 

Page 63 GAO-07-356 Coastal Barrier
Appendix VII: Comments from the Appendix VII: Comments from the Department of Veterans Affairs 

Department of Veterans Affairs 

Page 64 GAO-07-356 Coastal Barrier
Appendix VII: Comments from the 

Department of Veterans Affairs 

Page 65 GAO-07-356 Coastal Barrier
Appendix VIII: 

A

GAO Contact and Staff 

cknowledgments 

Page 66 GAO-07-356

Appendix VIII: GAO Contact and Staff 

Acknowledgments 

Anu K. Mittal (202) 512-3841 or mittala@gao.gov

In addition to the contact named above, Sherry McDonald, Assistant 

Director; Natalie Herzog; Stuart Ryba; Jay Spaan; Amy Ward-Meier; and 

Leigh M. White made key contributions to this report. Also contributing to 

this report were Kevin Bray, John Delicath, Nancy Hess, Gloria Saunders 

and Jay Smale. 

Coastal Barrier

GAO Contact 

Staff 

Acknowledgments 

(360666) 
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