Regional Plan Association public comments related to the scoping of the Financial District and Seaport Fortifying our Resilient Growth and Economy (FiDi FORGE) project

To the members of the FiDi FORGE Project Team from the New York City Economic Development Corporation (EDC), the US Army Corps of Engineers (Corps), and their consultants, Regional Plan Association (RPA) would like to thank you for the opportunity to provide written comments on the scoping of the FiDi FORGE project as it moves into EIS analyses and the preparation of a Draft Integrated Interim Report. These comments build on those shared in the public forum on July 16, 2026.

RPA is a 100-year-old organization dedicated to improving the quality of life, environmental resiliency, and economic health of the New York metropolitan region. We weigh in on projects and issues when they: significantly advance our four core values of health, equity, prosperity, and sustainability; are in line with our regional plan recommendations; lead to long term, region-shaping outcomes, leverage short-term opportunities; and have support from key partners and decision-makers. The FiDi Forge project meets every one of these criteria and is an essential project to move forward and get right.

Project Need & Urgency

First, we are thrilled to see an assessment of this project advance, as it represents the final link on the chain of protection for Lower Manhattan, a critical and highly vulnerable area of New York City that was devastated by Superstorm Sandy, and is an essential employment, transportation, and neighborhood hub with assets that link all the way back to the City’s modern origins. Much work has been and is being done to protect Lower Manhattan, but this project needs to move ahead as quickly as possible, to protect the area at risk, and to support the full efficacy of the resilience projects around it. We have been fortunate that no storm since Sandy has wrought such devastation, but every year without protection is a year of increasing risk in a worsening climate crisis. But project need and the need for urgency must not justify cutting corners on project features or process, including community feedback.

Deliver on a New Model Partnership for Resilience

We are also pleased that EDC and the Army Corps are partnering on this effort through Section 203 of the Water Resources Development Act of 1986, bringing the best of local knowledge together with efficient federal resources and expertise to get the job done. It is essential that this partnership serve as more than the sum of its parts. We see this approach as an opportunity for a new model of resilience planning that draws from the best of each partner and we encourage clear communication, respect for processes that have led to

this point, and openness to possibilities in project design that innovates beyond the bare minimum. We hope that the process’s successes and shortcomings will be documented to ensure improvements going forward.

Specific Recommendations

As the project moves into review, we are seeking assurances on a few key issues given the shift from a city-led effort to a joint effort with the Corps. In that light, we also strongly encourage that key features of the City’s plan remain in the alternatives being assessed.

1. Clarify the differences between proposed alternatives and FiDi Seaport Climate Resilience Master Plan

First, we ask that EDC and the Army Corps make clear that the alternatives being studied stem directly from the meaningful public process and deep technical analysis that resulted in the FiDI Seaport Climate Resilience Master Plan. Alternatives 4 and 4a seem to track most closely to that vision but given the years of engagement and ultimate community buy-in for that plan, it will be essential to understand what is different and what remains the same.

2. Provide additional information about the process to choose alternatives in the scoping phase

Given potential changes in approach between the vision from the FiDi Seaport Climate Resilience Master Plan and the alternatives chosen to be assessed through an EIS, we hope to understand more about how those alternatives were evaluated and selected, including the following:

• Screening Approaches

The scoping document provides a brief summary of the process to screen and ultimately choose which alternatives will be analyzed in the EIS. While this information is helpful, we seek greater detail, including the criteria, methodology, assumptions used to analyze, compare, and identify the chosen alternatives, and, to establish a proposed scope for the evaluation of the project’s environmental impacts. Gaining a deeper understanding of what was learned and how that knowledge was used to choose/screen out alternatives, will help us better understand the particular strengths and weaknesses of a given alternative - whether it was chosen or screened out - and for those projects moving to the EIS, will serve as baseline information to better evaluate and provide comments on determinations in the Draft Integrated Interim Report.

• Cost-effectiveness and environmental impacts

We are also interested to learn more about the cost/cost-effectiveness differences between each alternative and any initial environmental analyses for each alternative that were used to screen them out. In particular, for Alternatives 4 and 4a, we are seeking any information on assumptions around environmental impact, including any additional information about the volume of fill assumed for each, the degree of habitat loss, and any potential mitigation, understanding that a full EIS will study these questions in greater detail.

• Maritime uses

Given the importance of preserving maritime uses in the study area, we are interested to learn any additional detail about those uses, which are to be preserved and how much each contributes to NYC’s economy. RPA supports the continued use of the waterfront for maritime uses and encourages approaches that integrate resilience and maritime uses.

3. Ensure that the alternatives studied include hybrid engineered-natural features

The alternatives ultimately selected in scoping appear to have no overlap with each other, resulting in basic, inflexible options (on shore, versus in-water; engineered versus nature) that largely serve one purpose. This is a mistake. Most resilience projects in NYC and around the world are made-up of a diversity of approaches that combine a hybrid of engineered and nature-based approaches. These systems balance the need to manage flooding, with ecology, and human use. We strongly encourage the team to break out of simple, uncreative approaches that are easier to study but result in projects that are rejected by the public.

More specifically, in terms of design, we strongly encourage that the thoughtful features of the Master Plan are included in the assessment of Alternatives 4 and 4a. What made the Master Plan vision so attractive was the innovation in design, sensitivity to ecology and incorporation of nature-based features, as well as the attention to public access and connection to the waterfront.

Understanding that final design considerations often follow the assessment of function, we want to stress that the review must incorporate or - at a minimum - does NOT make assumptions that would preclude the following objectives:

• Minimizing impact to existing aquatic ecosystems;

• Enhancing or supporting habitat through structural features, areas for penetration of light, protection from wave action, creation of new, nature-based spaces, and restoration and stewardship opportunities;

• Ensuring public space, public access, and connection to the waterfront;

• Innovations in design that provide multiple layers of protection from different flood risks, including an esplanade built to withstand periodic flooding and aspects that address stormwater flooding behind protective coastal layers; and

• The preservation and enhancement of maritime uses and infrastructure.

These objectives reflect what the community has indicated they seek and should be factored into the analyses being performed.

4. Be responsible to the public, engaging widely and sharing critical information

There has already been significant community engagement that resulted in the Master Plan for the FiDI/Seaport area. As the effort now shifts into a different phase, ongoing meaningful engagement with the community is essential. There are too many neighborhoods in NYC bearing the scars of changed projects after robust community engagement. This effort must do better. Some of our recommendations above speak to this concern, and there is more that can be done. As information is learned, (including around the differences between the current alternatives and the Master Plan vision) the community should be kept apprised through both formal and informal means, in between major milestones along the timeline.

Conclusion

We understand the urgency and need to move forward in assessing alternatives, and the opportunity that collaborating with the Army Corps presents. We do, however, want to ensure that the project that is assessed and eventually moves forward is supported by an informed public, and incorporates a mix of the best possible combination of flood risk reduction, ecological protection and enhancement through nature-based features and ecological design, and robust public access, not simply just the least that could be invested to yield the greatest potential protection. Resilience infrastructure must also be community-building infrastructure.

Thank you for considering our comments and we look forward to continued engagement going forward.

Sincerely,
Robert Freudenberg
Vice President, Energy & Environment