This is a critical time to become informed and speak out about the U.S. Army Corps of Engineers’ proposal to build a $52 billion suite of flood protection projects throughout New York-New Jersey Harbor from 2030 to 2044. The proposed investment of federal funds for regional resiliency is sorely needed. But the plan, as proposed, has critical flaws that would omit crucial flood protections for some communities while unnecessarily impairing water and aquatic habitats. Public discussions are ongoing, and communities throughout New York City, northern New Jersey and the Hudson Valley all have a stake.

Key to the Corps’ “tentatively selected plan” is the construction of 12 storm surge barriers across the mouths of waterways such as Jamaica Bay, Newtown Creek, Flushing Creek and the Gowanus Canal, where they flow into the harbor. (Read more about the plan in our previous post.) Such barriers are made up of various kinds of moveable gates, supported by giant structures built in and around the water. Larger systems – such as a barrier envisioned at the entrance to Jamaica Bay – would include artificial islands, sills and other permanent structures built into the water.

These structures – even when the gates are open – threaten to choke off the tidal flow, impede fish migration, and trap contaminants in waters already burdened by pollution and degradation. As a flood-control measure, they are at best a partial, short-term solution in a world of rising water. Designed to close only during rare storms, these solutions focus narrowly on flooding from storm surge, and fail to protect against the long term certainty of increased flooding from sea level rise, heavy downpours and rising groundwater.

Riverkeeper and our partners support specialized, locally-driven solutions that provide more holistic protection, and that work with nature, address pollution, and protect the life in our waters. Certainly there are areas, such as Lower Manhattan, where hard shoreline walls and raised promenades will be necessary to protect infrastructure and neighborhoods from storm surge risk. And there are areas where a carefully managed “retreat” is the only realistic scenario in response to sea level rise. But throughout New York City – an archipelago with a multitude of waterways and coastal habitats – there are opportunities to design berms and other shoreline measures that allow rivers to flow, provide public access to the water, incorporate green stormwater infrastructure, enhance natural habitat, and protect neighborhoods from the full combination of storm surges, rainfall and rising waters.

To prioritize these modern solutions, and to invest federal dollars wisely, we need much better coordination between the Corps and state and city agencies. We need to tap the Corps’ own expertise in “engineering with nature” now, not later. The current proposal is too narrowly focused on storm surge barriers and fails to factor in the value of rivers, wetlands, shallows and creeks, and the creatures that rely on them. We need to ensure that the waters of New York and New Jersey are healthy and life-sustaining, especially as we face the extremes of a changing climate. We all rely on these waters.

Following are Riverkeeper’s specific recommendations to the Corps and its "non-federal study partners," New York and New Jersey States, as well as New York City.

Shift to a locally-led flood protection planning process. New York City, New York State and New Jersey need to take co-leadership roles in the study, in partnership with the Corps, to identify the most critical federal investments necessary for flood protection for our communities. While increased local government leadership is not a substitute for deep engagement with community members, state and city governments are in a better position to respond to local voices than the Corps, and their mandates are much broader to protect the public from all types of flooding, in contrast to the Corps’ focus on storm surge. Moreover, the non-federal partners’ expertise in local planning, water and sewer infrastructure and existing resiliency projects should be shaping the plans.

Protect living rivers: No storm surge barriers across our waterways. Each of the 12 barriers in the Corps’ “tentatively selected plan” are much smaller in size than in the more drastic plans envisioning gates across the Hudson where it meets the ocean, but their potential negative impacts are similar. They would interfere with tidal energy, reduce sediment transport, and slow the flushing of pollutants, for example. Waters affected by the proposed storm barriers include Flushing, Newtown, Coney Island, and Gerritsen Creeks; Gowanus Canal; Jamaica and Sheepshead Bays; Shellbank and Hawtree Basins; the Arthur Kill and Kill Van Kull; and the Hackensack and Passaic rivers in New Jersey.

Protect essential fish habitat. The Army Corps’ cost-benefit analysis fails to put a value on rivers and their life, including our endangered species like the Atlantic sturgeon. Scientists have noted that marine life has been stopped by storm surge barriers elsewhere. Marine habitats will be permanently altered by the proposed gates, in ways that are difficult to predict. The structures, and the faster currents they would cause, would likely restrict the movement of numerous small species around the barriers. Smaller creatures would be unable to effectively maneuver through the turbulent waters, and would be more vulnerable to predators at these locations. Some structures would require a large sill along the bottom of the waterway to support the weight of the barriers and would act like a dam, impeding fish and invertebrates. And what little habitat remains in New York Harbor – marshes, sea grass, oysters – would be imperiled.

Eliminate pollution – don’t worsen it. Storm surge barriers would worsen problems in urban waterways already suffering from industrial and sewage pollution, as well as channelization and overdevelopment. Even when open, they would significantly narrow the channel width at the mouths of these waterways. When closed, which would occur more and more frequently as sea levels rise, they would acutely trap contaminants and exacerbate pollution. Two of the waterways are among the nation’s worst-polluted waters, Gowanus Canal and Newtown Creek, and are in need of extensive cleanup over the coming decades.

Prioritize environmental justice – don’t worsen inequities. The proposed investment of federal funds throughout the region is sorely needed. But the plan relies on a benefit-cost analysis solely based on real estate and infrastructure values, ignoring the protection of human life, health, and the environment and perpetuating historic inequities caused by redlining and other racist policies. The cost-benefit analysis should factor in the demographics of those protected or otherwise impacted by its plan, among many other considerations. New York City, New York State and New Jersey must work with communities and the Corps on additional strategies, including the potential benefits of prohibiting or minimizing new development in floodplains and/or implementing flood buyout programs.

Plan for all types of flooding combined – not just storm surges. Because of the Corps’ narrow focus on storm surge, the tentatively selected plan overlooks other risks from other types of flooding, such as rising groundwaters, tidal flooding, and precipitation-related flooding like what New York saw during Hurricane Ida. In fact, the Army Corps has stated that stormwater flooding is outside the scope of its study. Its plan, therefore, is fatally flawed and irrationally skewed in favor of in-water storm barriers.

Use realistic scenarios for sea level rise. The Army Corps is relying on outdated climate projections – less change in sea level than predicted by the New York City Panel on Climate Change and the National Oceanic and Atmospheric Administration. Riverkeeper calls on the Corps to amend its estimates to reflect the best science and most recent modeling to better inform the study, protect communities, and extend the useful life of any infrastructure developed as part of the plan.

Learn more: Riverkeeper.org/barriers