This fall, RPA submitted comments to the US Army Corps of Engineers (Army Corps) to help guide their New York New Jersey Harbor and Tributaries feasibility study, which has been underway since 2016 and evaluates six alternatives to address severe coastal storm risks for New York and New Jersey communities in and around the Harbor and throughout the greater harbor estuary.

The public comment period – which was opened this past summer for just six weeks, but later extended to November 5 in response to overwhelming stakeholder, elected official and public demand – is intended to gather input on the alternatives and their locations in an effort to narrow them down for further study. As Army Corps studies typically do, one desired alternative will ultimately be chosen and become eligible for federal funds to implement it.

Our comments provided both general recommendations for the overall process of the study as well as specific advice for the alternatives being considered.

In short, RPA recommended the following:

• Fully fund and complete an expanded study. Most Army Corps studies have a three-year timeline and cost $3 million. Given the complexity and importance of this study, RPA supports an expanded budget ($19.4 million) and extended timeframe (6 years).
• Be fully transparent. We called on the Army Corps to share all of the results of its study with the public, not just those for the chosen alternative. As the region moves into a more uncertain future driven by climate change, the results of these analyses can help to drive policy decisions and investments now and into the future.
• Account for accelerating sea level rise. The focus of this study’s alternatives is on coastal protection during storms and only uses a moderate forecast of sea level rise. We encourage that the Army Corps consider both intermediate and high projections of sea level rise and consider the ability to protect against daily inundation from sea level rise flooding as it weighs the costs and benefits of each alternative.
• Don’t simply commit to one alternative. While antithetical to typical Army Corps procedure, we recommend a more flexible approach to this study that supports the study of the six alternatives, but encourages the Army Corps to be open to new information and changing conditions across the study timeline, and adjusting the study accordingly. Such factors include faster rates of climate change, new ecological research and policy shifts around flood-zone development and insurance, amongst others.
• Invest in non-traditional approaches. While some of the alternatives include nature-based approaches, we encourage the Army Corps to consider expanded or additional alternatives that invest in buy-outs for particularly at-risk geographies, as well as helping to finance adaptation projects in the planning or implementation phases (such as New York City’s Big U), that aren’t fully funded.
• Study the effectiveness, ecology, social/political and fiscal/economic implications of the six alternatives. Each of the alternatives presented by the Army Corps present the potential for benefit, but also significant costs. The most widely discussed alternative – a regional surge barrier – has been debated for decades, with very little middle ground between pro and con. This study can help to answer some of the most vexing questions about the surge barrier approach - questions we put forward in the Fourth Plan - while extending the same considerations to the other alternatives.

Following this public comment period, the Army Corps plans to release a public interim report sometime in early 2019 with further detail of the six alternatives as well as an early analysis of costs and benefits, opening up another window of opportunity for public comment. They then plan to release a Draft Feasibility Report/Tier 1 Environmental Impact Statement in Spring 2020, which will focus on their tentatively selected plan. The final steps include a ​“Chief’s Report” in summer 2022, followed by a recommendation to Congress which could authorize funding and advance the project to design. As these comment periods open, RPA will continue to be engaged and advocate for the best approach to make our region resilient in balance with the natural systems that sustain us.