Thanks for the opportunity to offer this testimony. My name is Rob Freudenberg, and I am the Vice President for Energy & Environment at Regional Plan Association, an organization that for nearly a century has sought to advance and advocate for research-based solutions to long term problems.

As a highly developed, dense waterfront city with 520 miles of shoreline, New York City is centered directly in the crosshairs of the climate crisis. In addition to the other climate impacts of heat and increased precipitation, the slow, steady, and accelerating, rise of sea levels threatens to permanently inundate neighborhoods and infrastructure, while deepening the reach and destruction of more frequent and intense coastal storms.

Put another way, New York City faces a challenging and dubious future: uncomfortable at best, wholly uncertain at worst.

Faced with these worsening impacts, the City must make critical decisions around existing and future development in flood hazard areas, if it is to continue to thrive while safeguarding its residents.

In RPA’s own Fourth Regional Plan, we called for a combination of resiliency strategies – including zoning changes, investments in engineered and nature-based solutions, and strategic buyouts, among others – to adequately adapt to our changing coastline.

In that spirit, we join you today to offer our support for the action to amend the Zoning Resolution of the City of New York, to modify its flood resiliency provisions with the proposed Zoning for Coastal Flood Resiliency.

This amendment comes at a tenuous moment: standing in the long wake of Hurricane Sandy and our continued recovery from it, while facing a future of rapidly rising seas and increased flooding, it is clear the City must take action to become more resilient and face the impacts of climate change head-on.

Achieving resiliency means having the ability to look in two directions at once: backward to the disaster we are recovering from, making sure to learn from the difficult lessons it brought; and forward toward future catastrophic impacts – which can look very different from those in the past – doing everything possible to anticipate and reduce risk.

I’m pleased to say that the amendment before you succeeds in doing that, incorporating the lessons learned from Sandy’s devastation to bolster support for post-disaster recovery; while also promoting long-term resiliency by allowing precautionary standards and resiliency features for buildings in the current and future flood zone as well as zoning and design rules that factor in sea level rise. Further, prohibiting the construction of new nursing homes in high flood risk areas represents a small but important leap, with strong overtures for future development restrictions.

These are common sense updates that acknowledge the reality that there will be more disasters to recover from across a wider area, and that we must take additional and meaningful steps today to prepare for the worsening impacts that are to come.

While this amendment will help to reduce risk for many, it will fully eliminate long-term risk for none. And in order to have its greatest impact, it will need to be paired with tools that help building owners and developers pay for the modifications it allows. Still, it is a very good, well-thought out and tested next step that should be approved.

Yet, there is still much to be done.

So, while we enthusiastically urge the Planning Commission to adopt this amendment, we also encourage you to advance beyond these measures. Stated simply, there are an awful lot of people in areas that are at high risk of flooding, far too many of whom are particularly vulnerable because of their race, age, or limited wealth. This amendment can help, but we must also acknowledge that there are just some areas for which design solutions have a much shorter shelf life.

The tools of planning and zoning, can be used to do even more, and they must. Adopting this amendment helps to buy some additional time. Let’s use that time wisely and advance important, necessary and honest conversations – across City agencies and in City neighborhoods – to plan for the difficult road ahead, using, refining and improving all of the adaptation tools we have at hand.