How to Write an RFP for a Living Shoreline Feasibility Study

Since October 2008, Maryland law has made a living shoreline the default for erosion control (DNR). Under Environment Article § 16-201(c), protection must be nonstructural, such as marsh creation, unless MDE’s maps mark the shore for structural measures or the owner shows a nonstructural measure isn’t feasible (Maryland Code). The feasibility study is that showing, in either direction.

A living shoreline feasibility study tests whether marsh, sills, reefs or a hybrid can hold a specific shoreline for its design life, at what cost and through which permits. You need one before design or a construction grant application. The RFP succeeds when it pays for site data that answers the factors MDE weighs.

The permits changed this year. The Army Corps reissued Nationwide Permit 54 effective March 15, 2026 (Federal Register).

What this work should deliver

Buy a decision: a recommended alternative at concept level, with the evidence behind it, a permitting pathway, a cost per linear foot, a maintenance and monitoring plan, and the funding it can compete for. If the evidence says a living shoreline won’t hold, the study should say so plainly and document why, since that record supports a waiver.

Who this is for: counties, towns, park agencies, land trusts and community associations with eroding tidal shorelines, alone or as a program of sites. It suits public land best; Maryland DNR’s 2026 living shoreline solicitation preferred projects on public lands and required landowner commitment for private ones (DNR). A single homeowner rarely needs a formal study; MDE’s own process and a marine contractor can carry a small site.

Be clear about the problem. The statute and the permits treat a living shoreline as erosion control; NWP 54 authorizes them “to stabilize banks and shores” in low- to mid-energy settings. If your problem is flooding, ask for hybrids. Cambridge, Maryland is designing a flood barrier integrated with a living shoreline along the Choptank River with FEMA money (City of Cambridge); our Dorchester County profile follows it, and our comparison of nature-based and grey infrastructure covers the tradeoffs.

Rules and standards to cite

• The default. Environment § 16-201(c) requires nonstructural shoreline stabilization except in areas MDE maps as appropriate for structural measures or where the owner proves infeasibility. MDE’s implementing regulations took effect February 4, 2013 (MDE).
• Order of analysis. COMAR 26.24.04.01 requires an applicant to consider no action and relocating threatened structures first, and it allows breakwaters, sills, sand containment structures and beaches inside a nonstructural design. MDE keeps the structural maps under COMAR 26.24.04.01-1.
• The waiver factors. COMAR 26.24.04.01-2 lists what MDE weighs: waterway width, bottom elevation and slope at mean low water, bottom substrate, fetch, bank elevation and orientation, degree of erosion, the height and regularity of tides, other physical constraints, and nearby resources including the Critical Area buffer. The waiver must be complete before you apply for a wetlands license.
• State permit lanes. A general wetlands license covers fill no more than 35 feet channelward of mean high water and less than 500 feet long, for erosion control by tidal wetland creation, and expires in three years with no extension (COMAR 26.24.02.04). Larger projects need a Board of Public Works license.
• Critical Area. Work that disturbs the 100-foot buffer needs a draft Buffer Management Plan and a signed Buffer Notification Form in the joint permit application (Maryland Sea Grant).
• Federal permits. NWP 54 limits fill to 30 feet from mean low water and 500 feet along the bank unless the district engineer waives the limits, requires pre-construction notification and authorizes later maintenance (Federal Register, above). In Maryland, the Corps’ state programmatic general permit, MDSPGP-6, was due to expire September 30, 2026; its proposed successor would authorize living shorelines up to 500 feet long and 35 feet from mean high water, with no submerged aquatic vegetation impacts, in its Category A, which needs no separate Corps review (Baltimore District). Confirm which permit governs when you apply.
• FEMA money. FEMA’s HMA Guide, Version 2.1, lets a benefit-cost analysis count ecosystem service benefits for coastal restoration, but FEMA now discounts future benefits at 7%, up from 3.1% (FEMA), which weighs on marshes that take years to establish.
• Sea level rise. Maryland’s 2023 projections guidance treats living shorelines as high tolerance for flood risk and points them to the median projection: 1.18 feet of sea level rise above 2005 levels by 2050 at the Baltimore gauge, under the current commitments pathway.

Note the datums. The state measures reach from mean high water and NWP 54 from mean low water, so the survey has to establish both on site. A design drawn to one line can fail the other lane.

The default is still contested. A 2026 bill, SB 368, would have exempted Calvert and St. Mary’s counties from the nonstructural requirement; its record ends with a Senate hearing set for February 10 (Maryland General Assembly). On fast-eroding shores such as Calvert County’s Flag Ponds, where the county measured more than 6 feet of erosion a year (Calvert County), budget for a real test of feasibility.

Sample scope of work

Adapt the bracketed items. Task 1 carries the study; skimp there and every later task guesses.

1. Site characterization. Organize the data around MDE’s nine factors, so the record serves a design or a waiver.

The Consultant shall characterize [site] using field and desktop data: a topographic and bathymetric survey tied to mean high water and mean low water, shoreline change rates, fetch and wave climate including boat wakes, bottom substrate and geotechnical conditions, bank height and orientation, tidal range, submerged aquatic vegetation mapped in the last five years, oyster bars and leases, the Critical Area buffer, cultural resources, utilities and property ownership. The Consultant shall report findings against each factor in COMAR 26.24.04.01-2(B).

2. Alternatives. The regulation requires no action and relocation to be considered first; a good study treats them seriously.

The Consultant shall evaluate no action, relocation of threatened structures, tidal marsh creation alone, marsh with a low sill or oyster reef, offshore breakwaters, and [a hybrid with structural flood protection], scoring each on stability, habitat, permitting lane, cost, maintenance and community input in a ranking matrix.

3. Sea level rise and design life.

The Consultant shall state a design life, select a sea level rise value from Maryland’s 2023 projections using the State’s risk tolerance method and the nearest tide gauge, and show whether the proposed marsh can keep its elevation and migrate landward over that life.

4. Permitting pathway. Designing inside the general license envelope can save five to eight months of state review.

The Consultant shall identify every authorization required, state whether the preferred alternative fits the general wetlands license, NWP 54 or the state programmatic general permit, and hold a pre-application meeting with MDE and the Army Corps before concept design is final.

5. Concept design and cost. The San Francisco Bay program asked for a basis of design memo and an engineer’s estimate at 30% (RFP); copy that.

The Consultant shall prepare [30%] concept drawings, a basis of design memorandum and an engineer’s opinion of probable cost with quantities, reported per linear foot and per acre of marsh protected.

6. Benefits and funding. Our guides to FEMA grant support and resilience funding strategies cover the next steps.

The Consultant shall estimate erosion avoided and marsh acres protected over the design life, prepare a screening benefit-cost analysis if FEMA funding is contemplated, and list the funding programs the project fits, with each program’s cost and design thresholds.

7. Engagement and landowners. Our guide to stakeholder engagement plans covers the design.

The Consultant shall brief adjacent owners and the public at [two] meetings, document landowner permission and access, and identify who will own and maintain the completed project.

8. Monitoring and maintenance. Permits and funders will ask for it; DNR’s 2026 solicitation called a monitoring plan a mark of a strong proposal.

The Consultant shall propose success criteria, a five-year monitoring schedule, adaptive management triggers and an annual maintenance budget.

Deliverables to require

• Existing conditions report, with survey, bathymetry and GIS files, and a factor-by-factor table keyed to COMAR 26.24.04.01-2(B).
• Alternatives ranking matrix, including no action and relocation.
• Sea level rise memo naming the tide gauge, design life, percentile and value.
• Permitting pathway memo and pre-application meeting notes.
• Concept drawings, basis of design memo and cost opinion per linear foot and per acre protected.
• A draft Buffer Management Plan, where the buffer is disturbed.
• Benefits and funding memo, with a screening benefit-cost analysis if FEMA money is in play.
• Monitoring and maintenance plan with success criteria and costs.
• Engagement summary with landowner permissions.
• CAD and GIS files, editable and owned by you.

How to evaluate proposals

South Portland, Maine weighted approach 45%, qualifications 35% and cost 20% (City of South Portland). The San Francisco Bay program opened cost proposals only after rating the technical ones. Both are defensible; either way, make bidders price field data as its own line, since the cheapest proposal is often the one that skips it.

Feasibility and design are engineering services, so with federal money 2 CFR 200.320 allows qualifications-based selection with price negotiated afterward. Read your funder’s terms first: DNR’s 2026 solicitation required three cost estimates or an advertised competitive process for contracts over $10,000.

Timeline

Budget and cost drivers

Maryland DNR’s fiscal 2028 solicitation says living shoreline design and permitting projects typically cost $30,000 to $100,000, caps design requests at $100,000 and excludes permit fees. Multi-site work runs higher. South Portland set aside $40,000 of city money for a hardscape assessment of five sites and $288,000 from a $320,000 federal coastal resilience fund request for nature-based conditions assessments and 30% to 60% designs at two or three sites. The National Fish and Wildlife Foundation expects its 2026 site assessment and design awards to average $100,000 to $1.5 million.

Design-only money is the easier ask. In June 2026, DNR’s living shoreline awards funded one shovel-ready construction project and six designs, including Somerset County’s Franks Island (DNR).

Construction sets the stakes. DNR’s 2026 construction grants asked for less than $1,000 per linear foot and at least 2.3 acres of marsh protected per 100 feet, while three Anne Arundel County projects DNR funded in 2023 ran, by our arithmetic, from about $950 to $2,060 per linear foot in public money (DNR). At $1,000 a foot, trimming 10% from a 1,000-foot project saves $100,000, the top of DNR’s typical design budget.

What moves the price:

• Field data. Bathymetry, geotechnical borings and wave or boat wake measurement cost more than desktop work, and matter more.
• Energy. Sites with long fetch or boat traffic need wave modeling and sturdier sills.
• Shoreline length and sites. A program of sites shares mobilization but multiplies analysis.
• Permitting lane. Designs beyond the general license envelope need more documentation and agency time.
• Resources. Submerged aquatic vegetation, oyster bars, cultural resources and rare species add surveys.
• Access. Barge-only sites raise survey and construction costs.

Red flags in proposals

• A structural recommendation reached before the nine waiver factors, no action and relocation have been tested.
• A desktop-only study for an exposed site, with no bathymetry, substrate or wave data.
• A single sea level rise number with no tide gauge, percentile or design life.
• A marsh design with no elevation or sediment analysis.
• No monitoring or maintenance cost, even though permits and funders will require a plan.
• A footprint beyond the general license and NWP 54 limits with no reason given.
• Plant lists or details copied from other regions.

How we’d approach it

We would start with the people who watch the shoreline every day. In the Annapolis Maritime Resilience Initiative, where we were project manager and engagement partner for Phase I, residents named 38 sites of concern, and the 10 that advanced to preliminary concept design included living shorelines at Mariner’s Point and Georgetown Grove (Phase I report). Through Council Fire Labs we built Resilient & Ready with the Resilience Authority to rank projects like those and match them to funding. Our nature-based solutions hub collects related guides.