March 23, 2023
The following is Metro Flood Defense Co-President Sam Jackson's public comment submitted to the US Army Corps of Engineers in response to their "Tentatively Selected Plan" Alternative 3B in the NY NJ Harbor and Tributaries Study (HATS). Please reach out to sam@metroflooddefense.org with any questions or comments.
NYNJ HATS TSP Comment:
Sam Jackson
Co-President and Co-Founder
Metro Flood Defense
Mar 23, 2023
My name is Sam Jackson, I am co-president of Metro Flood Defense (MFD) and a member of the LI-NY-NJ Storm Surge Working Group (SSWG). I will start by saying that my colleagues and I have the utmost respect for the Army Corps of Engineers New York District and we recognize the difficulty and complexity of protecting New York Harbor. We also stand with the environmental conservation and social justice advocates who demand comprehensive protection for ALL communities in the region, not just some.
Over the past year, I have attended dozens of City Council hearings, Community Board meetings, seminars put on by environmental organizations, Army Corps public information meetings and coastal resiliency conferences. It will come as no surprise to you, the representatives from the Corps who are reviewing this comment, that most people in the community do not like Alternative 3B. Some, like Community Board 4 on the West side of Manhattan, will never accept or allow concrete walls (as seen in the Corps renderings of Christopher Street) to cut them off from Hudson River Park. Others, like Newtown Creek Alliance, will never allow a single basin barrier to be built across the opening to their estuary. If the Corps attempts to move forward with 3B, these communities will fight it and many of the proposed projects in the TSP will be stymied by legal battles and fierce community protests that will serve to diminish the Corps’ reputation, all while the clock is ticking and our entire region remains vulnerable.
So, there is general consensus among stakeholders that 3B is not the solution we want. And, there is general consensus that we need a solution that protects everyone, including all vulnerable Environmental Justice communities, such as Hunt’s Point and the South Bronx and Red Hook to name a few. This is where we believe SSWG and MFD can help the Corps. Our scientists, led by Professor Malcolm Bowman of Stony Brook University, have been studying this issue for decades and they know that there is no way to protect everyone without in-water perimeter barriers. Based on the major disparities in percentages of at-risk areas protected in the HATS Alternatives, the Corps knows this too. Alternative 5, with no in-water structures, will only protect 3.3% of at-risk area, compared with 96% for Alternative 2, 87.1% for Alternative 3A, and 63% for Alternative 3B. Bryce Weismeller has a habit of describing the alternatives by saying they range from “farther out in the estuary to farther in” as you go from Alternative 2 to Alternative 5, but a more relevant way to say it is that the alternatives go “from protecting a large percentage of communities to protecting a small percentage of communities” as you go from Alternative 2 to Alternative 5.
At a seminar in February 2023, Riverkeeper and the NY NJ Urban Tributaries Working Group made a claim that sums up the difficult task that the Corps has ahead of it. The two organizations opposed 3B and they demanded a “locally preferred plan” that focuses on nature and nature based solutions AND protects everyone in the region from all types of flooding, especially all Environmental Justice communities. Metro Flood Defense and the Storm Surge Working Group support nature and nature based solutions (NNBS) and we believe that green systems like oyster beds are a key element contributing to the flood defense of New York Harbor. But we, like the Corps, know that NNBS can only protect against small storms, not extreme events like Superstorm Sandy. To protect our region from extreme storms and rising sea levels, the so-called gray and green communities (engineers and conservationists) will need to work together much more closely. That means convincing groups like Riverkeeper that there are gray solutions that can protect everyone without sacrificing the vitality of our waterways.
When it comes to protecting our region from extreme storm surges, we believe there is one solution that far outweighs the rest. That solution takes advantage of the natural geographic setting of New York City and its Harbor. All 500-plus miles of NYC coastline flood through two openings adding up to only six miles in width (Lower Bay/Verrazano Narrows and Throgs Neck, western Long Island Sound). And that’s not to mention hundreds more miles in NJ and up the Hudson River that also flood through those same openings. Taking advantage of this geography and blocking storm surge from even entering the harbor is the only cost effective and non-destructive solution for the next 100 years that will actually protect everyone. In order to ensure that the outer seagate system would only need to close in the event of a major storm, there must be interior layers of defenses, as outlined below, We firmly believe a layered defense will not only prevent the next storm from the scale of catastrophic destruction to our region caused by Sandy, but will provide robust protection from smaller events and will satisfy the needs of communities that want to be protected, but don’t want concrete walls on their perimeter or single-basin barriers obstructing their tributaries. Metro Flood Defense and the Storm Surge Working Group call for a system of “layered defense” that takes advantage of these natural topographic features and is designed to protect virtually the entire metro region for the next century and beyond from storm surges and sea level rise. We call this plan the Sandy Seagate System Alternative. This proposal is based in part on the experience of numerous flood barrier systems built in the U.S. (Stamford CT, Providence RI, New Bedford MA, New Orleans LA) and overseas (London UK, The Netherlands, Venice Italy, St Petersburg Russia), and input from experienced Dutch engineers who enjoy the world’s longest track record of protecting major population centers from storm surges and sea level rise.
This layered defense alternative’s four main components include:
Offshore movable sea gates that take advantage of the unique geography of the metropolitan area and allow for the Dutch principle of “shortening the coastline.” protecting several hundreds of miles of shoreline with only a few miles of moveable offshore barriers —either a six-mile Outer Harbor Barrier stretching from Breezy Point to Sandy Hook or a shorter barrier stretching from Coney Island to Staten Island, combined with a one-mile long movable barrier near the Throgs Neck Bridge.
Low onshore levees or dunes of a few feet in height to protect against routine flooding and slow sea level rise.
Green systems —Natural defenses, including rehabilitated wetlands and oyster beds to dampen wave action while also improving water quality and estuarine ecosystems.
Network of Onshore Detention Basins, Swales, Green Roofs and Other Measures to protect inland areas from intense rainfall events.
We invite the Corps to work with us to develop this Regional Layered Flood Defense Strategy.
Thank you,
Sam Jackson
Co-President, Metro Flood Defense
508.330.2445
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