Five months after the close of a public comment period, New Yorkers are awaiting a response from the Army Corps of Engineers on whether it will forge ahead with a $61.5 billion plan to protect the New York and New Jersey Harbor region from coastal storms. 

For many, the biggest worry is whether the corps will heed appeals to rethink—or significantly elaborate on—the proposed construction of storm-surge barriers. The current plan includes a network of floodwalls, seawalls, elevated promenades, deployable flood barriers and 12 permanent storm gates that would be built along tidal straits and rivers in New York and New Jersey. 

The plan has even raised hackles at another federal agency, the National Oceanic and Atmospheric Administration. NOAA, its National Marine Fisheries Service and a phalanx of environmental advocates argue that such barriers, whether placed miles from the coast or close by, could imperil fish habitats and broader ecosystems and that more study is needed on potential impacts.

A range of stakeholders have also pleaded for a greater emphasis on nature-based solutions and on responses to climate hazards beyond major storms, like the inexorable rise of sea levels linked to climate change. 

“This project is very focused on the 100-year storm surge,” said Sahana Rao, a staff attorney at the Natural Resources Defense Council, which weighed in during the public comment period that ended on March 31. “But more flooding will happen even without storms just because of sea level rise, and storm-surge barriers by themselves are not going to account for that.” 

A decision from the Army Corps on whether to stick with its recommended strategy, known as Alternative 3B, is expected by the end of the summer.

Dominating the debate is the memory of Hurricane Sandy, which roared ashore in October 2012 and inundated the region, killing 44 New Yorkers and destroying vital infrastructure, homes and businesses. The devastation awakened the federal government to the need for vastly improved defenses against storm surges up and down the Atlantic coast, resulting in an Army Corps study to identify the most critical locations for flood-risk management. 

The New York-New Jersey Harbor area vaulted to the top of the list in 2015, prompting the Army Corps to map out five potential construction solutions for managing future coastal flooding there. Eventually the agency settled on one, Alternative 3B, and a draft report on that recommendation was issued last September. Thousands of individuals and organizations weighed in. 

The design remains a preliminary concept of a recommendation to be proposed to Congress. After the Army Corps announces whether it will continue with its chosen plan, it will use the public feedback to prepare a Chief of Engineer’s report due for release in June 2024.

Tyler Taba, the senior manager for climate policy at the New York-based Waterfront Alliance, said the corps indicated that it would prioritize the concerns that were expressed most frequently during the comment period, which led the alliance to push for as much input as possible. In April, the Waterfront Alliance organized a joint response from 45 organizations under the umbrella of the Rise to Resilience Coalition. 

The coalition appealed to the Army Corps to focus on improving how it communicates with communities at the frontlines of the massive infrastructure project. Taba contends that a public comment period with a cutoff point was less than ideal. “This should be a more two-way conversation between the Army Corps and the communities that will be affected for generations over the course of the project,” he said. 

And on Wednesday, more than 25 organizations in New York and New Jersey, including the Rise to Resilience Coalition, announced a set of shared demands for an overhaul of the plan.

The themes of prioritizing more nature-based features and addressing climate risks beyond coastal storm-surge flooding have been echoed in comments submitted by the New York mayor’s Office of Climate & Environmental Justice, the New York State Department of Environmental Conservation and the New Jersey Department of Environmental Protection.

The Regional Plan Association, the Environmental Defense Fund and the Natural Resources Defense Council underlined those concerns as well in letters during the public comment period, and urged the Army Corps to research any pollution or other problems that might arise from the plan’s static storm-surge barriers. They also asked the corps to use a more aggressive estimate for sea level rise.

NOAA Sees “Significant Deficiencies”

NOAA said it could not support the tentatively selected plan as it is currently described. It noted the scope of the project, which would cover 2,150 square miles and 25 counties in New Jersey and New York, and complained that the corps had not factored in the range of impacts on coastal ecosystems.

“Significant deficiencies exist in the document and in the coordination process used in its development,” NOAA said in its letter to the Army Corps. “As a result, at this time we cannot support carrying forward the TSP [tentatively selected plan] as it is currently described.”

NOAA ticked off the 12 area basins that would be affected by floodwalls, gates and other construction: Jamaica Bay, Arthur Kill, Kill Van Kull, the Gowanus Canal, Newtown Creek, Flushing Creek, Sheepshead Bay, Gerritsen Creek, the Hackensack River, Head of Bay, Old Howard Beach East and Old Howard Beach West. Storm-surge barriers across 12 basins could have “significant negative consequences” on federally managed species, it warned. 

The National Marine Fisheries Service added comments stating that it was unable to determine whether the project would harm essential fish habitats because of significant gaps in the report’s description of the proposed barriers. 

NOAA urged the Army Corps to develop a revised plan that minimized adverse impacts on ecosystems and prioritized the use of nonstructural land use management options and nature-based solutions. Those might include buyouts to move infrastructure farther from the shore to create room for new wetland habitats and “living shorelines” made of natural components like plants and sand that can absorb the impact of storm surges before they reach the city. 

Estuarine ecologists are also concerned about the lack of scientific research into how the storm-surge barriers will affect ecosystems, even when the barriers are not activated in anticipation of a major storm. Some scientists predict that even when open, they will block sediment from reaching the ecosystems where it is needed. 

Researchers at the Woods Hole Oceanographic Institute created a model based on an early design of a storm-surge barrier that the Army Corps released in 2019. They found that a barrier at the Narrows tidal strait separating Staten Island from Brooklyn would constrict tidal flow and could alter conditions both near the barrier and farther inside the estuary, according to a study published in February in the journal Estuaries and Coasts. 

The Narrows strait is the primary channel through which the Hudson River empties into the Atlantic Ocean. An obstruction of that flow would create changes in tidal velocities, the researchers reported. The estuaries would then experience a decrease in sediment accumulation as high tidal velocities sent the minerals out to sea, they said, potentially affecting the ability of local marshes to keep pace with a rise in sea levels. 

The tentative Army Corps plan calls for one storm gate to be constructed at the entrance to Jamaica Bay, an estuary that meets with the Atlantic Ocean through the Rockaway Inlet and hosts a wildlife refuge accessible from Queens and Brooklyn. Judith Weis, an estuarine ecologist at Rutgers University who was not involved in the Woods Hole modeling study, is concerned that such a gate would further starve the tidal marsh of needed sediment and put the estuary at risk.

“The marshes in Jamaica Bay, as in many other places around here, are not growing in elevation anywhere near as high as they need to keep up with sea level rise,” Weis said. 

Other gates are proposed around Staten Island and at the entrances to Flushing Creek, Newtown Creek, the Gowanus Canal, Sheepshead Bay, Gerritsen Creek, Shellbank Basin,  Hawtree Basin and the Hackensack River in New Jersey. The plan also includes a proposed tidal gate for the middle of Coney Island Creek in Brooklyn.

Closed Sea Gates as a New Normal?

Some activists are concerned that as tidal flooding accelerates, the storm-surge gates will be deployed more frequently. Willis Elkins, the executive director of the Newtown Creek Alliance, a community nonprofit that advocates the restoration of the historic estuary bordering Brooklyn and Queens, said he feared that over time, the authorities would use a barrier built into Newtown Creek more heavily for high-tide flooding.

“Our concern with the gate in general is that any sort of strangulation at the mouth of the creek is going to mean reduced exchange with the East River and reduced flow of the creek, which would lead to severe water quality impairment,” Elkins said.

Others have raised concerns about equity, as some waterways are notably missing from the 3B Alternative. 

Along the Bronx Kill Strait, which connects the Harlem River to the East River, a land-based seawall is proposed rather than an in-water storm surge barrier. Arif Ullah, the executive director of the neighborhood advocacy group South Bronx Unite, said he worried that the borough’s Mott Haven and Port Morris sections were not receiving the same attention or protection as other waterfront communities in the Army Corps’ plan. 

Ullah wants to see flood protection in the form of a public waterfront. “We believe that a nature-based and green infrastructure-rooted waterfront plan could be as effective as an onland seawall,” he said. “The Army Corps has proposed those types of infrastructure for other communities, raised promenades and such, and we want equity in their planning.”

In its letter to the Army Corps, NOAA said that the project was not consistent with rebuilding principles developed by the agency and the corps a decade ago in response to Hurricane Sandy. Those tenets emphasized an approach that incorporates natural, social and built systems as a whole, the agency wrote. 

The National Marine Fisheries Service argued in its comments that the draft report of the project “appears to be fundamentally biased towards structural elements.” It pointed out that the construction of storm-surge barriers could induce flooding in new areas, depending on how a coastal storm arrives.

Modeling has shown that the proposed barriers to protect critical infrastructure in Newark Bay could cause more flooding from the Kill Van Kull and Arthur Kill channels around Staten Island, for example, according to Kate Boicourt, the director of climate-resilient coasts and watersheds in the New York-New Jersey region for the Environmental Defense Fund.

Educating Locals on Coasts and Nature

The Regional Plan Association’s comments call on the Army Corps to explain why nature-based solutions would or would not work at every place in the study where artificial barriers are proposed. Robert Freudenberg, the vice president for energy and environment at the association, said he saw the study as an opportunity to educate the region about what nature-based solutions might be possible. 

“We’re considering some significant changes to our estuary system,” he added. “We should have the conversation about what nature-based solutions would look like.”

The Waterfront Alliance says it is not opposed outright to in-water structures. “We want to see nature-based solutions looked at with equal weight as structural solutions, and maybe even as a priority over them in places where you can,” Taba said.

Freudenberg suggests that Army Corps planners ask questions like, how much land is needed to make nature-based features work? Would the government have to pursue significant buyouts to get rid of development in certain places to incorporate these features? 

The Environmental Defense Fund’s letter points to precedents that might allow the Army Corps to take more aggressive steps in response to the public feedback, given the project’s vast scale and importance. Boicourt said EDF had pressed the Army Corps to issue a supplemental environmental impact statement that would more accurately address a project of this size. 

“We would really love to see a couple of iterations because we feel like there’s a lot more to be addressed,” Boicourt said. “I think that’s been reflected, as they’ll find, in the thousands of comments they’ve received. And we’d like to see those responded to meaningfully.”

While Hurricane Sandy drove home that the New York and Jersey coasts are unprepared for ferocious storms, many community members are concerned that a strict focus on storm flooding will detract from the broader protective nature of the project. 

“Storm surge was really the primary driver of the study,” said Taba of the Waterfront Alliance, echoing others. “If they looked at this from a really holistic, multihazard approach, then you might see a different tentatively selected plan or different measures put forward.”

A Plea: It’s Not Just Megastorms

The storm surges will continue to increase in magnitude as the sea level rises. Yet a warmer planet also brings generally increased precipitation, which will cause flooding to happen more often. Flooding isn’t limited to heavy rains, however. Inundation from high tides in U.S. coastal communities is now twice as frequent as it was 20 years ago.

The permanent in-water storm-surge barriers will not protect coastal communities from those increasingly common forms of flooding. So many want to know what the Army Corps could propose instead. 

For now, a number of activists are hoping that a follow-up environmental impact statement will emerge that addresses what is missing from Alternative 3B. With this week’s announcement of a new campaign to demand a rethinking, the pressure remains intense. 

“We want to know more about surge barriers before we use them as a linchpin for our resilience efforts,” Freudenberg said, “What’s the typical failure rate of surge barriers? What does it take to make sure they don’t fail? And who is liable if it does fail?”

Again and again, the lack of details in the tentative plan have been cited by organizations providing feedback. “The Army Corps is, rightly I think, trying to phase the project so that at first they are dealing with the general idea of what this will look like and then drilling down on details,” said Rao of the NRDC. 

“The problem is we do need some details in order to be able to say whether or not we think this is a good idea.”