Regional Plan Association (RPA) thanks the US Army Corps of Engineers (USACE) for the opportunity to review and submit public comments on the Draft Integrated Feasibility Report and Tier 1 Environmental Impact Statement for the New York-New Jersey Harbor and Tributaries Coastal Storm Risk Management Feasibility Study. For over 100 years RPA has used its position as a research, planning, and advocacy organization to conceive of and help to advance long-range plans that promote the health, equity, sustainability, and prosperity of the Tri-State region. Our work transcends municipal and state boundaries, and political timelines. So the work being carried out by USACE on a plan to help the communities in our region adapt to the worsening climate impact of flooding is critical. This Study is the only one of its kind being carried out in our region, as it is considering the entirety of the New York-New Jersey Harbor Estuary, including all of the waterways, and human and natural systems of which it is comprised, and how to reduce the risk of flooding to communities and infrastructure within.
The Study anticipates the investment of many tens of billions of taxpayer dollars across multiple geographies that include urban centers and suburban communities, as well as the region’s port, airports, transportation networks, and other infrastructure that keeps this region, and the nation, thriving. As the impacts of climate change continue to worsen, threatening the viability of the region, there is perhaps no more important study being carried out, and no greater need than to get the final approach right. In that spirit, we offer the following comments on the Tentatively Selected Plan, with the goal of making necessary improvements to meet the challenges we face.
Video from cnbc.com.
Key Recomendations
RPA suggests the following recommendations to address the study’s underlying flaws:
- Use a more aggressive estimate for sea level rise, guided by regional projections
RPA calls on USACE to re-evaluate its proposed measures using more aggressive, regional projections for sea level rise in the jurisdictions for which those projections have been developed. Such refinements are authorized through the Water Resources Development Act of 2020 and 2022 (WRDA) and should be heeded. - Factor in multiple climate hazards in addition to coastal storm surge
RPA suggests that USACE re-evaluate the proposed interventions in Alternative 3B and decipher which projects address multiple hazards and which simply address coastal storm surge, and which hazards are left unaddressed, in order to present an alternative approach within 3B. Another way to phrase this is, if the study had considered addressing multiple hazards at once, how would this alternative look different? - Reconsider the emphasis on and assumptions about surge barriers
RPA recommends that USACE propose an alternative approach within 3B that demonstrates what this would look like, particularly in areas behind the surge barriers that close off Northern New Jersey and Jamaica Bay. - Expand the Emphasis on Environmental Justice and Social Vulnerability
RPA joins other advocates in encouraging USACE to place greater emphasis on ensuring that communities with less accumulated wealth, and who have been marginalized and victims of systemic racism, be better accounted for in the benefit-cost ratio and screens like Economic and Regional Economic Development, which fail to adequately capture the value of protecting and advancing justice for these communities.
RPA also suggests the following recommendations to expand flood risk reduction tools and proceed thoughtfully in close collaboration with partners and communities:
- Better Understand Opportunities for Nature-Based Features
RPA suggests that USACE take the opportunity this study affords and fully and clearly model what level of flood risk reduction that nature-based features could afford, and where these approaches would work best. - Embrace Acquisitions (Buyouts) as a Tool for Flood Risk Reduction
RPA recommends that USACE should work closely with both states and New York City to identify those areas most prone to repetitive loss to consider buyouts as a viable alternative to shore-based measures. - Alter the Scale of the Study for Further Engagement and Implementation
Moving forward, RPA recommends that USACE should consider breaking the study into smaller sections - perhaps the same 64 reaches, or a more reasonable number - for future engagement and project design. RPA suggests that USACE should work closely with the Congressional Delegation to seek the necessary time and resources to get this study done effectively. - Empower New York, New Jersey, and New York City as Partners in Planning and Engagement
RPA suggests that a more formal partnership with clear responsibilities be reached between USACE, the states and New York City to develop a plan that best represents each entity’s vision for their residents.
If the changes recommended above cannot be carried out through the next phase of Alternative 3B, RPA would recommend studying and pursuing a new alternative, with leadership from New York, New Jersey, and New York City, and in close collaboration with the residents and stakeholders of this region.
Reviewing the Feasibility Report and Tier 1 Environmental Impact Statement, it is very clear that an abundance of time and resources has been spent developing an understanding of the New York-New Jersey Harbor and Tributaries system. Engineering, economic, and environmental analyses have led USACE to land on Alternative 3B as their Tentatively Selected Plan. But within those analyses are a series of underlying flaws that need to be addressed before moving forward with design, let alone implementation.
![HATS map](https://img.imageboss.me/general/width/300/quality:80/latest/HATS-map.png?bossToken=27f568fec860824de940a8a4640a1a5667fb8b25cde55fc55ada542e2c86d923 171w, https://img.imageboss.me/general/width/600/quality:80/latest/HATS-map.png?bossToken=7c6386404641bc277633d2d579012b91ae2ca3d1fc2742bfb37d3fbfac3f9025 343w, https://img.imageboss.me/general/width/900/quality:80/latest/HATS-map.png?bossToken=33d34fc6aa8b08ee4861cbc3b29ecca06913b8c6cc603c27fbbcac634ed5ff60 514w, https://img.imageboss.me/general/width/1200/quality:80/latest/HATS-map.png?bossToken=7ae4a12eabc0f3ec35329556273352e8886857c36f819f8f32e86703ea30a842 686w, https://img.imageboss.me/general/width/1500/quality:80/latest/HATS-map.png?bossToken=f4c03c19f3504af33e7a6d6d1149afe358b2fea9931e13f8515b07118f25e67b 857w, https://img.imageboss.me/general/width/1800/quality:80/latest/HATS-map.png?bossToken=abdf17a5efb21dc6f8ead44d4dca46a2ca9006f5de42a1ca834ba1885f3ca85d 1029w, https://img.imageboss.me/general/width/2100/quality:80/latest/HATS-map.png?bossToken=1f765ed1049e23ffebab7088e6958cb642da4b36fbca0ea420612728b1c92d85 1200w, https://img.imageboss.me/general/width/2400/quality:80/latest/HATS-map.png?bossToken=fe8e9b8a577d24f015bbd3ea5fa46ac0b1b4e52c676e7db868c085bfa5de7d61 1371w, https://img.imageboss.me/general/width/2700/quality:80/latest/HATS-map.png?bossToken=bbb5490f2b88d52dea4a14dcc3325d2e57a25b0bf6bf7b741841b60ae7560217 1543w)
Map of Alternative 3B features from USACE Draft Integrated Feasibility Report.
1. Use a more aggressive estimate for sea level rise, guided by regional projections
![HATS Sea Level Rise](https://img.imageboss.me/general/width/300/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=2d8b3ab9ff14f574c3fe5d6b56b0e22a322d4abfcf4b3c26b3ebb8936a2cadf6 171w, https://img.imageboss.me/general/width/600/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=cfcec5f401d6bc2696d94a59629618fd000bb074274239eb00780d6e8eaeb0af 343w, https://img.imageboss.me/general/width/900/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=8f889df1c0815477feef410f5aac1c867f313838031950686bce8ba78cc8f233 514w, https://img.imageboss.me/general/width/1200/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=d4a927a067e4c7d7022d6365bf2a4fa71856477fe943dbe9fce7147efe46ea81 686w, https://img.imageboss.me/general/width/1500/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=7e46f5195645dfeb6143e14ed62edd2697e89a0394b0ba7b6c437a8ae97038e1 857w, https://img.imageboss.me/general/width/1800/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=323ef97de5ed334657e1d69eefa3200b2e3fd9851a31371cfd886385b7d964b0 1029w, https://img.imageboss.me/general/width/2100/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=deb6a13d0cb58ae57e1ea7c5874d6ca26af3a2ea36e75d03cd430620bf550aa0 1200w, https://img.imageboss.me/general/width/2400/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=c56649c218844f282f70661b585c29f982c5e07fcb6efa50907604d17035e048 1371w, https://img.imageboss.me/general/width/2700/quality:80/work/Reports/2023-reports/HATS-study/HATS-Sea-Level-Rise.png?bossToken=b713f07662f5ff6d15d88526347a4e83c80abadb674c0d4f06e2f12f36ac5ccd 1543w)
Projected Sea Level Rise for the Region
Source: RPA
2. Factor in multiple climate hazards in addition to coastal storm surge
![Map 5 Multiple Flood Hazards](https://img.imageboss.me/general/width/300/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=10b43514f85f50b93e43b05d16095cc9205e2b74ca55c2f297a4723bae796afa 171w, https://img.imageboss.me/general/width/600/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=e4f31c311b7aa7b4f30742f8c2abd69b6945ce056642c8492402caa81a9cb71b 343w, https://img.imageboss.me/general/width/900/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=5254f7032f9408e6edb971bcaabfcc7e9af238f2da7a0b63a9b7fc6fe7274f4c 514w, https://img.imageboss.me/general/width/1200/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=c351d34c288d3bb3b564c7b445cd5b1c068fb2fe664306d462ca0fb05fff6758 686w, https://img.imageboss.me/general/width/1500/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=9873d8b3f33835985c8d4299c3cb2735e57ce1350e5e661c5c732ef2adeabb9c 857w, https://img.imageboss.me/general/width/1800/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=f4c4122c39fbd694c52179d79590571d922eecd1b9f7e5edae61cdbe9d6f3710 1029w, https://img.imageboss.me/general/width/2100/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=5da12915fa6d958245aa05c242687e08d19d961fd5e36356cd6ca8e346b18338 1200w, https://img.imageboss.me/general/width/2400/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=d5fbe2f10014ce15986d80a8a486b561318700f1ae7cd89fa18366a199661b76 1371w, https://img.imageboss.me/general/width/2700/quality:80/work/Reports/2023-reports/HATS-study/Map-5-Multiple-Flood-Hazards.png?bossToken=17472cbe11676414ad4c5797c84b72388ca4bec8fa041bb5bace5f38040ae404 1543w)
Projected flood risk in 2050 and NYC Stormwater Flooding projections
Sources: RPA, NYC DEP
3. Reconsider the emphasis on and assumptions about surge barriers.
The majority of the alternatives put forward by USACE included some level of surge barrier projects as part of the overall solution. This is understandable, as surge barriers are an engineered solution that directly address the primary hazard studied, coastal storm surge. As described above, RPA urges USACE to factor in multiple, overlapping climate hazards, which may change the calculus on the reliance on surge barriers.
There are also important issues that USACE, state and local governments, and residents and stakeholders need to address or have addressed before giving a green light to surge barriers.
RPA recommends that USACE address the following issues in particular:
- Failure rate: While offering a sense of security to communities behind them, surge barriers that fail to close properly could be devastating to communities that have not otherwise invested in surge protection. How often and under what conditions could barriers as proposed fail to function properly, and what would be the impact if one or more did? What entity is liable in the case of failure?
- Frequency of closure. The effectiveness, costs, and impacts of a surge barrier will depend on how frequently it is closed, for both storms and maintenance. Frequent closings would raise maintenance costs and cause greater ecological impacts, but public or political pressure could lead to closing it even when there is only minimal risk of flooding. Infrequent closings could raise damage risks, and bring into question the ecological, political, and financial costs of building a surge barrier that is seldom used. Additionally, if sea level rise projections are found to be inadequate, there will be a need to close the barriers more frequently than modeled. What impact would this have?
- Decision-making in an engineered system. With multiple surge barriers proposed in Alternative 3B, New York-New Jersey Harbor and its tributaries will be transformed into more of an engineered system with newly created flood basins. In order for the measures to effectively reduce the risk of flooding from storm surge, each barrier will need to be closed at the right time, and in the right sequence. With footprints in New York State/New York City and New Jersey, whose decision will it be to close the barriers? What if there are disagreements between entities on whether a particular storm justifies a closing? What level of government makes the ultimate decision? Can a Governor override a Mayor if there is disagreement? Agreement on a protocol should be reached before proceeding with design and implementation.
- Lifespan. What is the feasible lifespan of a well-maintained surge barrier, and what is the process to dismantle or otherwise adapt the structure when it has reached the end of its useful life.
- Alternatives. What shore-based measures would be required to provide the same level of protection to at-risk areas absent surge barriers? How much would they cost?
![Map 6 Social Vulnerability](https://img.imageboss.me/general/width/300/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=9d2df07ec859a4782a49989f55f79e2b21df26983cfed5b2197cd05c1bab89ff 171w, https://img.imageboss.me/general/width/600/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=4a87f09d3535481aab00f9f77afb9c536ca872f30cc5ba2481b84a8f958f2330 343w, https://img.imageboss.me/general/width/900/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=5a711c8e38752de0c1c73c1c7a4dc3c18030a4a1513690776fe3b42e1f56ac24 514w, https://img.imageboss.me/general/width/1200/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=7eea3c60b604a8c11e60da5cff11335e9ecfa9535c8afb32df46cb2bce5c51fb 686w, https://img.imageboss.me/general/width/1500/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=d76c526516e4d0dc5a7eb77d15a6737e3eea3ba288c6c96cc818e10efc0489a2 857w, https://img.imageboss.me/general/width/1800/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=949be540683e67f8e263adba1fc5f21c426f63612a866d49e9727d9f0dd8e298 1029w, https://img.imageboss.me/general/width/2100/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=948a4e82e240dc84c80276123848647f0720238d6f66fced7b713b629d9d16a0 1200w, https://img.imageboss.me/general/width/2400/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=537a7e11cea4c211c6743a327d72ece3262f03a58c4c723045023c2841872592 1371w, https://img.imageboss.me/general/width/2700/quality:80/work/Reports/2023-reports/HATS-study/Map-6-Social-Vulnerability.png?bossToken=639114848d40986cfba2a67906c53b76012e782e65a4043c35b53e8c399c82e7 1543w)
Social Vulnerability in the Region’s Coastal Communities
Sources: RPA, US Census Bureau
Reflecting some of the comments provided above, Alternative 3B, like most of the other alternatives, relies heavily on hard, “shore-based measures” including surge barriers, tide/navigable gates, seawalls, floodwalls, levees, and other engineered structures, some 84 miles in total of hard structures. Some of these features would permanently change the Harbor Estuary as we know it, further developing it into a more engineered system, with less public access and community connections to the coast. This is perhaps the cost of protecting places that have been historically developed in floodplains and on filled-in wetlands and waterways. But there is also an opportunity to consider re-balancing the approach toward more nature-based and non-structural solutions.
1. Better Understand Opportunities for Nature-Based Features.
2. Embrace Acquisitions (Buyouts) as a Tool for Flood Risk Reduction.
Undertaking such a large and critical effort across a complicated geography is unprecedented for USACE. Held to a strict timeline, budget, and mission limits the scope of what is required, for many of the reasons listed above. Yet, this is the only study of its kind and plan of its scale for climate adaptation in our region. With it comes the likely promise of federal funds to implement what is sorely needed, protection from the impacts of climate change. How USACE proceeds from this point will determine if our region gets the plan and investments that best serve us, or a glaring example of the regrettable limits of bureaucratic planning with limited flexibility in approach. In order to avoid an expensive and regrettable lesson, USACE - working with Congress - should consider a modified approach moving forward that better involves the non-federal partners and improvements in engagement.
Alter the Scale of the Study for Further Engagement and Implementation
Empower New York, New Jersey, and New York City as Partners in Planning and Engagement
The New York Metropolitan Region is at significant risk from the impacts of climate change, including flooding, and is largely without a comprehensive plan to ensure its viability. This study, in combination with various efforts at specific locations, represents the best opportunity to reach consensus on how taxpayer dollars should be invested to make our communities, infrastructure, and ecosystems resilient to the changes that have begun, and will intensify. Working closely with fellow organizations, as well as drawing on our own research and interest in this area, RPA has provided comments above that we feel need to be considered before proceeding with Alternative 3B as it is presented. If the changes recommended above cannot be carried out through the next phase of Alternative 3B, RPA would recommend studying and pursuing a new alternative, with leadership from New York, New Jersey, and New York City, and in close collaboration with the residents and stakeholders of this region.