Demand the Army Corps take a comprehensive, localized approach to flood protection

Climate change has made New York vulnerable to an increasing number of severe storms and the flooding that often follows. This will only get worse in the coming decades, climate projections show. Following Hurricane Sandy, the Army Corps of Engineers commenced a study to evaluate these flood risks in the area surrounding the New York-New Jersey Harbor and Estuary and along the east coast. The Army Corps proposed a plan for addressing some of these risks late last year, which would cost $52.6 billion and would not be completed until 2044. This tentatively selected plan, 3B, relies almost entirely on “grey infrastructure” being built – flood walls and similar barriers - while largely ignoring solutions made in conjunction with nature. The plan fails to adequately value social impacts to our region, such as those on environmental justice communities. The plan also fails to use this opportunity to address multiple flood threats, such as day-to-day sea-level rise and inland flooding from rain storms.

The Army Corps’ proposed plan delays consideration of nature-based solutions, uses insufficient sea-level rise estimates, and fails to value our diverse communities. Join us in calling on the Army Corps of Engineers to reconsider their plan, and work with communities to develop a local alternative, in light of these shortcomings!

UPDATE: the comment deadline has been extended to March 31st. Send your comments today!

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Army Corps needs to take a comprehensive, localized approach to flood protection

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Dear Mr. Wisemiller and Ms. Alkemeyer, I want to express my sincere appreciation to the Army Corps and the non-federal sponsors and partners for the continued commitment and work on protecting New York and New Jersey’s natural areas and communities from storm surge. However, I cannot support and would like to express my opposition to the currently proposed tentatively selected plan, 3B, as well as many aspects of the plan creation and selection process as part of the New York New Jersey Harbor and Tributaries Study (HATS). There are several main shortcomings to the HATS delivery that ignore the unique environmental and social context of our region and surrounding areas. In light of this, I hope you reconsider the current plan and work with communities in the near future to build off of the great technical work already undertaken and come up with a more appropriate, localized plan. My main concerns are listed below: 1. The postponement of including natural and nature-based solutions in the plan until later phases is unconscionable and against the sound science that is laid out in the Army Corps own guidance from Engineering With Nature, not to mention countless other scientific examples. New York City is so vulnerable to water-related risks in part because natural systems that can soak up water have been removed. While we cannot completely undo the development that has taken place, including along the waterfront, it is crucial that we do not continue the mistake of damaging nature and attempting to solve climate crisis-induced changes to storms and sea levels with more grey measures alone. If these are used, it should be in conjunction with natural features, which would be prioritized first. The Corps must consider nature-based solutions as a first resort. 2. The 2022 Water Resources Development Act indicates that the Army Corps must consider comprehensive flood risks when devising plans. Taking into account only storm surge, even when exacerbated by sea-level rise, is not sufficient or appropriate for our location and will leave the city vulnerable. Not accounting for this in the plan not only represents a missed opportunity, but is negligent, as proposed hardscape flood barriers will impact inland flooding (e.g. trapping in pollutants) and be impacted by sea-level rise (e.g. requiring gates to be closed more often). The Corps must consider comprehensive flood risks. 3. Using the Army Corps’ outdated methodology for assessing sea-level rise may result in plans that are insufficient for the risk at hand, which would serve as a waste of funds and time that are precious when the need for protection is so great in our communities. It may also lead to underestimates in the amount of time that gates will be open or closed, impacting key ecosystems. As per the first point above, these types of barriers should be a last resort, rather than front and center as they currently are, as hardscapes have the inability to adapt with climate threats over time, as opposed to integrated living features. The Corps must use the most recent, localized, and sound science for planning. 4. The Army Corps’ tentatively selected plan is chosen largely based on property values, which puts low-income and environmental justice communities at a disadvantage and ignores other social costs and benefits, such as those to public spaces and infrastructure. Using this benefit-cost analysis approach is not appropriate for a dense place with public services like New York City, which will see many of the protection measures. The Corps should work with local partners to develop a local plan, building off of the work done by the Army Corps already, using a more holistic accounting measure to devise, plan and select neighborhoods for interventions. Thank you for allowing me the opportunity to comment.