---
title: nbs is not natural infrastructure
canonical_url: https://ensurance.app/guide/nbs-is-not-natural-infrastructure
markdown_url: https://ensurance.app/guide/nbs-is-not-natural-infrastructure.md
subtitle: one is an action label. the other is a procurement name for a living system already doing work
category: nature-finance
---

# nbs is not natural infrastructure

*one is an action label. the other is a procurement name for a living system already doing work*

A city can restore a floodplain, file the bid as a nature-based solution, and still miss that the floodplain was already infrastructure. The argument in the room is usually about labels. The living system does not care which budget code you used.

**Nature-based solutions (NBS)** are actions. IUCN defines them as actions to protect, sustainably manage, and restore natural or modified ecosystems that address societal challenges, while providing human well-being and biodiversity benefits. **Natural infrastructure** is a procurement name — used by the U.S. Army Corps of Engineers (USACE) and watershed utilities — for wetlands, dunes, floodplains, forests, and reefs already doing flood, water, or shoreline work. One names what you do. The other names what is already on the job.

:::johnson
**nbs names the action. natural infrastructure names the object.** Use the word the room already budgets for. Then keep the living system working. The project name is not the thing.

[see what living infrastructure actually is →](/guide/what-living-infrastructure-actually-is?from=guide)
:::

## the action is not the object

If you restore a wetland to cut peak flows, that restoration is a nature-based solution. The wetland is not. It was a living system before the grant, during construction, and after the ribbon. Labeling the project NBS does not convert the marsh into a deliverable.

Natural infrastructure makes the opposite error when people treat it as a project type. USACE talks about **natural and nature-based features (NNBF)**: landscape features used for flood-risk functions. A natural feature is created by physical, biological, and chemical processes over time. A nature-based feature is designed and built to work with those processes. Either way, the feature on the civil-works sheet is not the marsh. The marsh is the living hold.

The wetland, canopy, and reef exist whether or not anyone labels a project NbS. Ensurance funds the living condition the project depends on — it is not the project name.

We already write about nature-based solutions as [financing](/guide/nature-based-solutions-proactive-financing?from=guide), as [a city stormwater system](/guide/durban-living-stormwater-system?from=guide), and as [a utility risk](/guide/nature-based-solutions-for-utilities?from=guide). Those pages keep the head term. This one is only the cut between an action label and a procurement name.

## four phrases, four jobs

Green infrastructure and living infrastructure get pulled into the same meeting. They are not synonyms for NBS, and they are not a second copy of natural infrastructure. Who says green, natural, nature-based, or living — and why the invoice never arrives — is already a [four-name map](/guide/green-natural-living-infrastructure?from=guide). This table is only the cut that matters here: action, object, stormwater dialect, qualifier.

| phrase | what it is | whose room | what it is not |
|---|---|---|---|
| **nature-based solution (NBS)** | an action: protect, manage, or restore, aimed at a societal problem | IUCN, UN Environment Assembly, FEMA, EU climate practice | the living system the action is about |
| **natural infrastructure** | a procurement name for a living system already doing flood, water, or shoreline work | USACE, Engineering With Nature, watershed utilities | the civil-works alternative that copies it |
| **green infrastructure** | in U.S. law, a stormwater practice; in city plans, often trees, parks, and corridors too | EPA, MS4 permittees, landscape architects | a synonym for NBS or for a forest |
| **living infrastructure** | a qualifier: the living part has to stay alive, which means it has a payroll | New York City Comptroller, some asset stewards | green paint on a pipe |

Same ecology can sit in every row. The budget code cannot.

Picture a county restoring a floodplain to drop a ten-year peak. The grant calls it NBS. The Corps feasibility study lists the floodplain as a natural infrastructure alternative. Public works calls the overflow swale green infrastructure because it keeps runoff out of the municipal stormwater system. Parks asks who is monitoring invasives and keeping cattle off the new plantings — that is the living part. Four correct sentences. One ecology. Three of the four sentences do not pay the fourth.

## what a nature-based solution names

Start with the searcher's phrase, in the dialect the standard uses.

IUCN (2016): NBS are "actions to protect, sustainably manage, and restore natural or modified ecosystems, that address societal challenges effectively and adaptively, simultaneously providing human well-being and biodiversity benefits."

The UN Environment Assembly agreed a cousin wording in 2022 (Resolution 5/5). FEMA and EU climate practice use the umbrella. The point is the verb: protect, manage, restore. A nature-based solution is something you do to a living system, for a problem a treasury can name — flood, heat, water, food, disaster risk.

That is why a wetland is not an NBS. A forest is not an NBS. You can restore either as an NBS. You can fail to fund either after you do. The IUCN Global Standard is a process for qualifying the action. A process is not a payor. That cut belongs to a [sibling post](/guide/an-nbs-standard-is-not-a-funded-acre?from=guide).

If you needed the category definition first — what NBS actually is, against the standard — start with [what nature-based solutions actually are](/guide/what-nature-based-solutions-actually-are?from=guide). This page assumes you can already hear "action" and still need the infrastructure names pulled apart.

## what natural infrastructure names

USACE did not invent living systems. It named a way to put them on a civil-works sheet.

When the Corps says natural infrastructure, it usually means existing or restored wetlands, dunes, floodplains, forests, and islands performing flood, coast, water, or navigation functions — often next to gray works, not instead of a mission. **Engineering With Nature (EWN)** is the method: align natural and engineering processes. NNBF is the feature language inside that method. A feature can be natural (the reef that grew) or nature-based (the reef you built). Neither line item is the living system.

Congress has told USACE to consider natural infrastructure alternatives alongside traditional ones when they are practicable. That is useful. It is also how a planner can think the alternative *is* the marsh. A project that copies a floodplain is still a project. The floodplain is already doing the work.

Development banks sometimes say **nature-based infrastructure** when they need NBS to enter an appraisal spreadsheet. That dialect already has a [home](/guide/natural-infrastructure-consensus-trap?from=guide). It is not a fifth asset class, and it is not this page's keyword.

Canada and New Zealand have funds and plans that use the same two words. Those are program names. If you came here looking for a named fund, you are in the category, not the brand. The category is a living system doing work.

If you need the object defined on its own terms — USACE dialect, without the NBS comparison — read [what natural infrastructure actually is](/guide/what-natural-infrastructure-actually-is?from=guide). If you already know which landscape is doing the work and the failure is the handoff between vision, budget, and ownership, use [how to implement natural infrastructure](/guide/how-to-implement-natural-infrastructure?from=guide). That how-to already owns the head term. Do not start from a blank page, and do not treat this post as a second implementation guide.

## green infrastructure is a stormwater dialect

**Green infrastructure** is the only phrase in the table with a U.S. statutory definition. The Clean Water Act defines it as measures that use plants, soils, permeable surfaces, harvest and reuse, or landscaping to store, infiltrate, or evapotranspirate stormwater and keep it out of sewers and surface waters (33 U.S.C. § 1362(27)). In an MS4 shop — a city that holds a municipal stormwater permit — that is the buying term.

City plans use the same two words for trees, parks, wetlands, and corridors. The wide meaning wins the slide. The narrow meaning wins the permit. Pitch on the wide definition, fund through the narrow one, and you get money for the basin and nothing for the canopy.

Is green infrastructure an NBS? Sometimes the action qualifies. A green stormwater project can be a nature-based solution if it protects or restores a living system and addresses a societal challenge with a real biodiversity benefit. The statute does not require that. A permeable parking lot is green infrastructure. It is not a wetland. It is not natural infrastructure in the USACE sense.

The cobenefit argument — corridors that work twice — already has a [home](/guide/green-infrastructure-works-twice?from=guide). This page will not retell it.

## living is the qualifier

**Living infrastructure** is not a fifth product. It is the qualifier that tells you the operating model.

Gray depreciates on a schedule. A living system can renew its function, but only while the conditions that keep it alive are protected. Planting is capital. Care is a payroll. New York City's Comptroller used the phrase as a report title because the city's trees were already doing stormwater and cooling work, and the operating line was not keeping up with the capital line.

That is why living is not a synonym for green, natural, or nature-based. Those names get the project into a room. Living names what happens if you only fund the ribbon. The definition lives on [living infrastructure is not green paint on a pipe](/guide/what-living-infrastructure-actually-is?from=guide). The taxonomy, the gray contrast, and the payor map sit next to it. One link. No recap.

## frequently asked questions

### what is the difference between nbs and natural infrastructure?

A nature-based solution is an action aimed at a societal problem. Natural infrastructure is a procurement name for a living system already doing flood, water, or shoreline work. You can restore a floodplain as an NBS. The floodplain, doing that work, is natural infrastructure. The restoration contract is not the floodplain.

### is green infrastructure an nbs?

Not automatically. In U.S. law, green infrastructure is a stormwater practice. Some of those practices — and many of the wider city-plan uses — can qualify as nature-based solutions. A permeable lot does not become an NBS by being called green. Check the action, the living system, and the societal problem. Then check whether the biodiversity benefit is real or a slide.

### is living infrastructure the same thing?

No. Living infrastructure is a qualifier: the system's performance depends on it staying alive, which means someone pays for condition after the ribbon. NBS is the action. Natural infrastructure is the object in a civil-works dialect. Living is the operating model those other names often forget.

### which phrase should a city use?

Use the word the room already budgets for.

- Qualifying an IUCN or UNEA action, or talking to FEMA and EU climate practice: **nature-based solution**.
- USACE alternative analysis, watershed utility, flood and navigation functions: **natural infrastructure**.
- MS4 permit, consent decree, EPA stormwater grant: **green infrastructure**.
- Arguing for care, monitoring, and the operating line: **living infrastructure**.

Then protect the living system behind the label. Four dialects. One unpaid ecology. The glossary for [who says which](/guide/green-natural-living-infrastructure?from=guide) is already on the shelf. Pick the door that opens the budget. Do not invent a fifth product because the first meeting used a different noun.

## next

You now have the cut. NBS is not natural infrastructure. Green is a stormwater dialect. Living is the qualifier.

Read the object next if Corps language is the door you actually walk through. Read the how-to if the living system is already named and the failure is the handoff. Read the living-infrastructure pillar if the fight in your budget is capital versus care.

[what natural infrastructure actually is →](/guide/what-natural-infrastructure-actually-is?from=guide)

[how to implement natural infrastructure →](/guide/how-to-implement-natural-infrastructure?from=guide)

[what living infrastructure actually is →](/guide/what-living-infrastructure-actually-is?from=guide)

If you still need the category in IUCN's words first:

[what nature-based solutions actually are →](/guide/what-nature-based-solutions-actually-are?from=guide)

## sources

[IUCN — NbS definition](https://inbs.iucn.org/understand/nbs-definition/) — 2016 World Conservation Congress definition used above

[UNEA Resolution 5/5](https://www.informea.org/en/decision/nature-based-solutions-supporting-sustainable-development) — 2022 multilateral wording of nature-based solutions

[USACE Engineering With Nature — Natural & Nature-Based Features](https://ewn.erdc.dren.mil/natural-nature-based-features/) — NNBF as landscape features used for flood-risk functions; natural vs nature-based distinction

[USACE — About Engineering With Nature](https://ewn.erdc.dren.mil/about/) — EWN as a method; natural infrastructure as wetlands, dunes, and islands doing flood and navigation work

[33 U.S.C. § 1362(27)](https://www.law.cornell.edu/uscode/text/33/1362) — Clean Water Act definition of green infrastructure

[FEMA — Nature-Based Solutions](https://www.fema.gov/emergency-managers/risk-management/building-science/nature-based-solutions) — U.S. hazard-mitigation use of the NBS dialect

[New York City Comptroller — Living Infrastructure](https://comptroller.nyc.gov/reports/new-york-citys-living-infrastructure-funding-and-managing-nycs-urban-forest-and-tree-canopy/) — official use of living infrastructure as cared-for urban canopy, not a planting ceremony

## the series

This is post 4 of 5 on what nature-based solutions actually are.

1. [what nature-based solutions actually are](/guide/what-nature-based-solutions-actually-are?from=guide)
2. [an nbs is not the asset](/guide/an-nbs-is-not-the-asset?from=guide)
3. [an nbs standard is not a funded acre](/guide/an-nbs-standard-is-not-a-funded-acre?from=guide)
4. nbs is not natural infrastructure (this page)
5. [who pays after the nbs ribbon](/guide/who-pays-after-the-nbs-ribbon?from=guide)