Dear Ms. Alkemeyer and Ms. McClanahan,

We, the undersigned 27 members of the Rise to Resilience Coalition, appreciate the U.S. Army Corps of Engineers’ (“Corps”) efforts to reduce coastal storm risk in the New York–New Jersey Harbor region as part of the New York-New Jersey Harbor and Tributaries Study (“NYNJHATS”). We support the intention to move forward with ​“Actionable Elements” in the Harlem River, East Riser, and Oakwood Beach. These sites represent critical opportunities to protect vulnerable communities and essential infrastructure. To be effective, these projects must go beyond short-term protection and align with a broader, equitable, and comprehensive climate-resilient regional strategy.

The Rise to Resilience Coalition represents over 100 organizations, including residents, community leaders, scientists, environmental advocates, and design professionals, collectively dedicated to making climate resilience an urgent policy and planning priority across the nation and in the New York-New Jersey region. We write to provide comments on the Draft Integrated Interim Response Feasibility Report and Environmental Assessment for Actionable Elements of the NYNJHATS released in July 2025.

Our Coalition has been at the forefront of advocating for the NYNJHATS. We played a crucial role in securing the reauthorization of funding for this study in the Water Resources Development Act (“WRDA”) of 2020, ensuring a stronger focus on equity, nature, and comprehensive flood risks. Additionally, we successfully led the advocacy campaign to invoke Section 8106 of WRDA 2022, which mandates the Corps to consider multiple climate hazards, including sea-level rise and increased rainfall, in Coastal Storm Risk Management (“CSRM”) projects, a first-in-the-nation request made by the non-federal sponsors of the NYNJHATS.

Starting broadly, we encourage the Corps to review Appendix B of the Rise to Resilience Coalition March 2023 Comment Letter (page 15), documenting the ​“Guiding Principles of Climate Adaptation Infrastructure” developed by more than 55 organizations across New York and New Jersey.

As of August 2025, we have built on these Guiding Principles and developed a set of shared goals. As the Corps focuses on implementable, community-scale projects in the near-term, we are advocating for an approach and projects that holistically:

1. Address the multiple flood hazards communities face, informed by the best available science.
2. Prioritize people over property value, protecting at-risk frontline communities that have borne the burden of environmental injustice and historic underinvestment.
3. Protect critical infrastructure that communities depend on today and into the future.
4. Meaningfully engage communities in an iterative planning process that aligns with other city and state resilience investments.
5. Maximize nature, protecting ecosystem health, safeguarding water resources, and advancing public access and connection.
6. Keep it comprehensive, ensuring that individual projects add up to a region-wide plan to adapt the NY-NJ Harbor and its tributaries to flooding impacts.

To achieve these goals, we encourage the Corps to take the following specific steps as you plan for and invest in projects, and build partnerships to implement them:

Project Planning

• Avoid Induced Flooding: Ensure that any proposed project - in part or in total - does not cause induced flooding anywhere else.
• Think Regionally, Act Locally: Break out sub-watersheds within each planning area of HATS to better understand how local flooding - tidal, rivers/streams, stormwater, groundwater - and drainage interact within a greater, regional context.
• Multihazard Flood Protection Pilot: Demonstrate the feasibility of multi-hazard flood protection planning under WRDA Section 8106, beginning with a pilot developed collaboratively with non-federal sponsors, NGOs, academia and other stakeholders.
• New Benefit Cost Analysis: Pilot a new benefit-cost analysis approach using the new 3-part benefit model (ie, environmental and social factors to be considered, as well as national economic development goals).
• Protect People with Nature: Prioritize protecting people and critical infrastructure and seek to utilize nature to reduce flooding wherever feasible.
• Project Monitoring: Advance monitoring of projects to help inform the design of future projects.
• Solicit Feedback in Spring 2027: Share for feedback - with adequate lead time - any additional projects being considered for the WRDA 2028 cycle (~Spring 2027) with our Coalition and HATS working group.

Project Cost

• Flood Programs: Allow investments in non-federal sponsors’ flood risk reduction programs (like NYC’s cloudburst program, or Resilient NJ) to contribute toward non-federal cost share.
• Emergency Management: Allow investments in non-federal sponsors’ coastal storm and flood emergency management programs to contribute towards non-federal cost share.
• Community Organizing: Allow investments from non-federal sponsors to community-based organizations for grassroots organizing that informs HATS project proposals to contribute toward non-federal cost share.

Partnerships

• Engineering with Nature: Work closely with ACE’s Engineering with Nature program to formulate alternatives for specific projects and the comprehensive regional plan.
• Academia and HATS Working Group: Strengthen collaborations with our working group and academic partners (MACH) to inform multi-flood hazard modeling and project performance, including workshops.
• Grassroots Organizations: Collaborate with grassroots partners to solicit early feedback, specifically identifying planned, existing or ongoing projects that may impact the Corps’ proposal in their neighborhood.
• Monitoring and Stewardship: Leverage grassroots partnerships for long-term monitoring and stewardship of projects once they are built.

More specifically, the region needs a comprehensive flood risk management approach that addresses not only coastal storm surge, but also tidal flooding, extreme rainfall, groundwater rise, and compound flood hazards. We urge the Corps to fully implement WRDA Section 8106’s multi-hazard planning mandate, and to apply WRDA 2024 Section 1343’s requirement to maximize ecological and societal benefits—at each project site. As outlined in our March 2023 Coalition comment letter, we strongly recommend that public safety, infrastructure resilience, and environmental health should be prioritized over property value alone. The Rise to Resilience Coalition supports the advancement of the Oakwood Beach and East Riser Actionable Elements, as these elements align with congressional mandates to maximize net public benefits, including ecological and societal benefits, and to incorporate natural and nature-based features. The Oakwood Beach Actionable Element is a nature-based solution focused on wetland enhancement, contributing significantly to environmental quality, while the East Riser Actionable Element addresses comprehensive flood risks from both coastal and riverine drivers, reflecting our Coalition’s advocacy for a holistic approach to flood management. While these are relatively small-scale projects, we recommend scaling this approach for future Actionable Elements.

Similarly, as detailed in our March 2023 Coalition comment letter, we continue to urge that natural and nature-based features (NNBFs) be central to the project designs, not secondary. Elements such as living shorelines, oyster reefs, and wetland buffers are essential to long-term resilience, offering ecological, water quality, and recreational benefits. These features must be included in preliminary design and cost-benefit calculations, not deferred to future environmental analysis or described hypothetically.

The Corps must also integrate stormwater and sewer management into the proposed Actionable Element projects. Risks from combined sewer overflows, stormwater runoff, and ​“bathtub” flooding behind walls demand detailed mitigation plans. To that end, projects should align with New York City’s Unified Stormwater Rule and prioritize green infrastructure wherever feasible.

These projects must also protect navigation, habitat, and water quality. To address these areas of concern, the Corps must provide transparent modeling early in the design process. Each project must be designed to minimize environmental impacts and degradation and ensure safe navigation in and around New York City.

In addition, the Corps must use these projects to protect and expand public access to waterfront areas. Access to the waterfront is a key public benefit that must be prioritized. The Corps must avoid conflicts with ongoing efforts, like the Manhattan Greenway, and explore dual-use design options, such as floodwalls that support promenades or greenways. In neighborhoods with communities who have long been cut off from the shoreline, this is a chance to reconnect communities to their waterfronts.

As one example, the Harlem River project must avoid narrowing the navigation channel and degrading water quality. It must include engineered NNBFs, address local stormwater and CSO challenges, and support public access improvements. Done right, this project could serve as a model for multi-benefit, community-aligned coastal resilience. The longer timeline associated with the Harlem River project provides a crucial opportunity to enhance the project’s design. Key data gaps, such as detailed subsurface exploration, stormwater infrastructure mapping, record drawings of MTA tunnels, and refined coastal hydrodynamic modeling for wave characteristics, must be thoroughly addressed. The Harlem River project must incorporate rainfall and tidal flooding, as the NYNJHATS study is designed to protect from a broad set of climate hazards. This means actively exploring how NNBFs can improve stormwater management and mitigate CSO, rather than maintain existing conditions. We recommend connecting with the NYC Department of Environmental Protection’s (DEP) existing Green Infrastructure Program and Long-Term Control Plans. It is also critical to confirm and/or address induced flooding that will occur on the Bronx side of the Harlem River as a result of the proposed Actionable Element.

We commend the use of NNBFs in the East Riser and Oakwood Beach proposals and encourage the Corps to apply similar practices across all HATS projects. By designing with nature, listening to communities, and planning across hazards, the Corps can deliver projects that protect life, strengthen neighborhoods, and create a healthier harbor for the future.

Robust and frequent community engagement must guide all project phases. Early, continuous, and meaningful involvement from frontline residents and local organizations is essential. The Corps should coordinate with New York City, New York State, New Jersey, and local community groups to align with existing plans and identify synergies that support local priorities.

We urge the Corps to clearly outline a phased implementation strategy that delivers near-term benefits to the most at-risk communities. We also request a public update by Spring 2027, well in advance of the WRDA 2028 cycle, to assess progress, share lessons, and guide next steps. The Corps has committed to working with our Coalition partners and academia partners on workshops to support the selection of future actionable elements. We look forward to productive workshops and discussions between now and the next WRDA cycle. The Corps should proactively seek out and formalize existing community-led plans, visions, and projects as these offer the most effective way for communities to clearly express what they want and how to address climate threats.

We commend the use of NNBFs in the East Riser and Oakwood Beach proposals and encourage the Corps to apply similar practices across all HATS projects. By designing with nature, listening to communities, and planning across hazards, the Corps can deliver projects that protect life, strengthen neighborhoods, and create a healthier harbor for the future.

The 27 undersigned members of the Rise to Resilience Coalition appreciate the opportunity to provide feedback on the Draft Integrated Interim Response Feasibility Report and Environmental Assessment for Actionable Elements of the NYNJHATS. We look forward to your response and thank you for your consideration.