Testimony March 31, 2023

Public Comment: U.S. Army Corps NY & NJ Harbors and Tributaries Study (HATS) Tentatively Selected Plan

Thank you to the U.S. Army Corps of Engineers for its study to protect New York City from future flood risks. I am writing on behalf of the 5BORO Institute, a think tank committed to advancing innovative ideas to improve New York City’s future. 5BORO is informed by a board of directors with decades of experience cultivating change in NYC and globally across a number of sectors — including climate experts and leaders from government, business, tech, real estate, healthcare, journalism, academia, non-profits, labor unions, and more.

We are writing to reiterate the critical importance of increasing flooding protections for New York City and the surrounding region. We are in strong support of the Army Corps advancing without delay a plan to increase New York City’s resilience to coastal storm surge. As the Army Corps selects, designs, and develops its proposal, we urge you to incorporate throughout the life of the project our recommended principles, detailed below. We urge the Army Corps to commit to more robustly integrate these principles over the coming decades as the project is developed — delivering a solution that meets the many needs of New Yorkers, while maintaining a schedule we cannot afford to delay.

New Yorkers have unfortunately grown increasingly familiar with the dangers of flooding over the past decade, underscoring the critical need for this project. Hurricane Sandy was the worst natural disaster to ever hit New York City. During the storm, 44 New Yorkers lost their lives, nearly 70,000 homes were damaged, and millions of residents lost power for up to two weeks. Even after the storm subsided, it left devastating impacts in its wake. Thousands of New Yorkers were displaced from their homes, critical public and private infrastructure was damaged, and entire communities were upended. In total, Hurricane Sandy inflicted an estimated $19 billion in damages and lost economic activity across the city. And it showed us just how vulnerable our city is in the face of climate change.

These risks are only growing. Sea levels in the city have already risen by a foot over the last century, and the rapid acceleration of sea level rise over the coming decades means our coastal flooding will only get more frequent and intense. Temperatures are also rising. Intense rainfall events like Hurricane Ida are becoming more common. And the City projected in 2013 that by the 2050s, a Sandy-like storm could cause $90 billion in damage and economic loss – nearly five times Sandy’s impact.

That’s why the Army Corps’ work is so important as one piece of a comprehensive set of preparations for our growing climate risks. This project presents a once-in-a-lifetime opportunity to install resiliency infrastructure of this scale, which is critical to protect our city against our growing climate risks. As New Yorkers, we urge the Army Corps to commit to improving its design over the coming years to incorporate our principles. These commitments must be made without adding delays to the process, since every year without flood protections is another year New York City remains at risk of extreme climate impacts.

Over the coming years as the Army Corps selects and designs the infrastructure, it must ensure that it is designed smartly to meet multiple needs, address multiple risks, use the latest science, and be developed in close collaboration with local communities. Any project of this scale and in the densest and most complex city in the nation must serve more than just one function to maximize the benefits. We request that the Army Corps commit to incorporating the following improvements to the design and process without adding significant delays to the installation of these vital protections.

Community engagement: In order for this project to be successful, the design process must be community-centered. The Army Corps must meaningfully and thoughtfully engage local and historically underserved communities in impacted neighborhoods. This may include utilizing engagement strategies that go beyond what is standard procedure for federal public engagement processes, such as holding events during non-traditional business hours, providing childcare, offering sessions in different languages, or seeking input in locations where communities already meet. 

Environmental justice: The Army Corps must also prioritize environmental justice by ensuring that historically underserved communities are meaningfully involved, valued, and protected. Environmental justice is too-often devalued in federal cost-benefit analyses, but President Biden’s Justice40 demands a renewed commitment to environmental justice as we confront our climate crisis. 

Public amenities: These flood protection measures must be integrated into the fabric of our city and enhance our public spaces along the waterfront. For example, seawalls can also incorporate an elevated promenade with green space, so that New Yorkers have waterfront access and new public spaces to enjoy. We have already seen other climate resiliency efforts incorporate features and amenities like these for communities to enjoy, such as with the Rockaway Boardwalk and the East Side Coastal Resiliency project.

Nature-based solutions: The designs must not only protect us from storms, but should also clean our water, enhance biodiversity, and guard against sunny-day tidal flooding caused by sea level rise by maximizing the use of nature-based solutions. Green infrastructure such as wetlands and oyster reefs are a critical part of a holistic and smart resiliency strategy, and its use must be prioritized.

Buy-outs: As part of an integrated plan, the Corps must consider the benefits, costs, and long-term viability of buying out properties at risk of flooding. With a new, dedicated source of flood buy-out funding from the New York Bond Act of 2022, as well as federal funding sources for that purpose, it could be a potential long-term solution to permanently move people from areas that are going to be inundated or otherwise at risk.

Latest science: The Army Corps must also commit to incorporating the latest scientific projections for the New York City region. This includes not only relying on the latest National Oceanic and Atmospheric Administration projections, but also local projections developed by the New York City Panel on Climate Change.

Flexibility: The project must also be designed and constructed in a way that is flexible, iterative, and phased. It is imperative that we have the ability to update the design at key points of its development to incorporate the latest science and technological innovations. This will help ensure the infrastructure functions optimally and reduce risks of maladaptation. 

Environmentally sound: The project must be constructed to mitigate potentially harmful environmental impacts. As a dense city, it is even more imperative that the construction and operations do not disturb contaminants in Superfund sites or reduce air or water quality. We must also not disrupt the wildlife that live in or travel through our waters. This includes providing passageways and corridors for access through our waters and mitigating noise, vibrations, and sediment disruption.

Future planning: The plan must better account for other risks New York City faces, including tidal flooding and overland flooding from precipitation, as well as increased sewer overflows and stormwater runoff pollution as a result of increased precipitation. The project must also be developed in close collaboration with the State, City, utilities, and others doing work or planning in our waterways. With new technologies, such as offshore wind, being developed or transmitted across our waters, we must ensure that the proposed project is not in conflict with infrastructure that will be built in the future or concurrently.

This proposal is an unprecedented opportunity to bring together communities and federal, state, and local governments to invest in the future of New York City. An improved plan must be advanced and developed — without delaying the critically-needed protections that this project could bring. We urge the Army Corps to incorporate the above principles throughout the design process to ensure that the final project meets New Yorkers’ needs and guards our city against growing climate risks. The future of our city depends on it.