RPA comments on the NY-NJ Harbor and Tributaries Coastal Storm Risk Management Feasibility Study

As the New York Metropolitan Region marks the sixth anniversary of Superstorm Sandy and its aftermath, residents can rightly ask themselves if they are safer now than when the storm struck in 2012. After spending billions of dollars on rebuilding, recovery and adaptation projects, we are in some ways better prepared to endure another storm like Sandy, but by no means “Sandy-proof.” At the same time, sea level continues to rise, expanding the reach of storm flooding and increasing the risk of permanent flooding in the many low-lying areas of the region. It’s critical that we continue to study, plan and invest in actions to reduce our region’s risk from coastal storms while preparing for the permanent flooding that sea level rise will bring.

The US Army Corps of Engineers (Army Corps) New York – New Jersey Harbor and Tributaries Coastal Storm Risk Management Feasibility Study is the most significant study underway in our region focused on determining federal actions to reduce risk from coastal storms in and around New York Harbor. Launched as a “3x3x3” ($3 million, three year, three concurrent levels of review) study in 2016 by the Army Corps along with New York and New Jersey and other partners, the project’s budget and timeline were already estimated to exceed the three year, $3 million limits with a $19.4 million budget estimated over six years, given the complexity of the project and the importance of its outcomes.

As the only comprehensive study considering multiple approaches to minimizing the risk of coastal storms, Regional Plan Association (RPA) supports full funding and completion of the expanded study and scope. While the study is limited to potential federal investments into largely engineered solutions, the results of both benefit-cost ratios and any environmental impact studies would shed significant light on a handful of tools in the toolbox of options to minimize coastal flooding risk in the region.

To that end, RPA requests that the Army Corps of Engineers publicly release the complete results of the evaluation stage of alternatives, including project screenings, comparison of damage reduction, environmental impacts and the benefit-to-cost ratios, including for those alternatives not ultimately selected as preferred. As the region moves into a more uncertain future driven by climate change, the results of these analyses can help to drive policy decisions and investments now and into the future.   

General Approach

Overall, RPA would like to see the following general principles adhered to across the study’s scope and timeline:

  • Account for accelerating sea level rise. Sea level rise of around one foot since 1900 has already been documented in the study area, and projections show that it is accelerating. The Army Corps intends to use their own intermediate projections for sea level rise, which track considerably lower than their high projections. Given the significant difference between the two, the quickly changing climatic conditions and the considerable additional damage that would be caused at higher levels, the study should test the alternatives at both intermediate and high projections. Additionally, the benefit-to-cost-ratio should consider that sea level rise will ultimately result in daily or permanent flooding in an increasing number of low-lying areas of the region outside the context of a storm, and that higher sea levels will add require additional maintenance and may shorten the lifetime of measures being studied.
  • Ensure the study is iterative and doesn’t commit to one fixed alternative. Should the study successfully be carried out over a timeline of six years, there is much that can change over this period. Rather than lock us into a path of investing in a single alternative, this study needs to be a flexible process in an uncertain future. For example: which alternative would be best if, say, NFIP was completely reformed? What if sea levels rise considerably faster than models are showing? What if states became more aggressive with buyout programs?  What if new research around the NY-NJ Harbor estuarine system were to emerge? The feasibility study should find ways to factor in relevant changes. And as new information or different approaches emerge, the Army Corps should be willing to abandon or change the preferred alternative if such information warrants it.
  • Seriously consider additional “out-of-the-box” approaches, such as funding buyouts and bolstering funding for projects already underway. The Army Corps of Engineers – in this feasibility study and in the North Atlantic Coast Comprehensive Study – has demonstrated openness to non- or less-engineered approaches, including natural and nature-based features.  That openness should be extended to the consideration of buyouts as a risk reduction strategy funded by the Army Corps of Engineers. The Army Corps between 1977 - 1983 spent over $8 million to acquire over 8,000 acres of wetlands as part of the Charles River Natural Valley Storage Area project in the greater Boston Region. That strategy ensured flood protection by retaining the natural flood storage features of wetlands in the Charles River floodplain. The New York region’s most at-risk, low-lying areas, including Jamaica Bay, the Hackensack Meadowlands and the Passaic River valley, are home to hundreds of thousands of residents at significant risk to damaging flooding from storm surge and sea level rise. Taking a page from their approach in the Charles River floodplain, the Army Corps of Engineers could establish a fund to be used to facilitate buyouts of homeowners in the most at-risk places. The land would be returned to nature and form a natural buffer to flooding. Such an approach should either be added to one of the alternatives or considered as a new alternative.

Additionally, the “No Action” alternative includes a comprehensive list of projects planned or already underway that aim to protect some of the most vulnerable areas in the region, largely through perimeter-only solutions. Given the degree of planning, design, public input and interagency collaboration, and the number of bureaucratic hurdles already cleared, it is imperative that projects that are in the final stages of planning or already underway be fully funded and completed. One option would be to expand include these projects in each of the alternatives, and make them eligible for additional federal funds as part of a Tentatively Selected Plan. 

The Five Alternatives

There are no simple solutions to the complex problems of coastal adaptation. None of the five alternatives put forward for consideration can by itself eliminate the risk of coastal storm damage, and most of them do little to address the permanent flooding that will come about from additional sea level rise. All of them need to be considered for their impacts and their benefits. Additionally, these alternatives should be viewed in the context of all of the other actions – policy, planning and engineering – being carried out in the region.

Preliminary analyses of all of the alternatives will be critical to understanding how each scenario protects the region differently, and the degree of costs (construction and maintenance), risk of failure and environmental and social impacts associated with them. Such an increased body of knowledge about engineered approaches will be critical to dialogue and future decision-making as climate impacts worsen.     

Of all of the alternatives, it is Alternative 2 that has received the greatest attention and has been the source of significant debates for decades. Given the degree of funding that would be required to construct and operate the system, the significant number of communities and infrastructure it stands to protect (and conversely, the number of communities and infrastructure left vulnerable if it were to fail), and the potential for estuary wide ecological impact, we offer the following detailed statements concerning this alternative as well as for Alternative 5, which would implement lower-cost, local solutions. 


Consideration of a region-wide barrier system has been discussed now for decades. This study represents the clearest and best opportunity to consider what the impacts of such a system would be and what design could be implemented that would minimize these effects. As recommended in our Fourth Plan, RPA urges that this approach be comprehensively studied.

Particular emphasis should be placed on the following topic areas and considerations:

1.       Effectiveness

  • Failure rate and lifespan: Determine how often and under what conditions the barrier could fail, as well as the lifespan of an effective barrier, and ability to adapt it to changing conditions.
  • Sea-level rise: Because surge barriers do not protect against permanent flooding from sea-level rise or the inland flooding caused by stormwater, investments will still need to be made to protect or move populations and infrastructure. The rate of sea-level rise must also be factored in when determining the design, scope, and estimated completion date of any potential new surge barrier.
  • Frequency of closure: The effectiveness, costs, and impacts of a surge barrier will depend on how frequently it is closed, for storms and maintenance. Frequent closings would raise maintenance costs and cause greater ecological impacts, but public or political pressure could lead to closing it even when there is only minimal risk of flooding. Infrequent closings could raise damage risks, and bring into question the ecological, political, and financial costs of building a surge barrier that is seldom used.
  • False sense of security: Even areas protected by a surge barrier could end up needing additional protection against inland flooding, sea-level rise, and high winds—as well as storms that could occur before a barrier is built. The decision to proceed with a barrier may create a false sense of security that could lead to delays in improving site-level resilience or transitioning away from high-risk locations—or cause them to be canceled altogether.

2.       Ecology

The New York –New Jersey harbor estuary is complex, comprising more than 30 rivers and streams; over a dozen tidal straits and nearly 40 bays, inlets, and coves. These comprise tens of thousands of acres of wetlands, parks, beaches, and piers, support maritime and recreation industries that include the East Coast’s busiest port, and are a critical habitat for numerous species that are essential to the region’s ecosystem. It is essential that we build on preliminary studies and determine the potential impacts on this integrated system, including:

  • Salinity/tidal area: Barriers have been shown to alter the circulation of water in and out of the system, regardless of whether they are open or closed. Estuaries—where freshwater and saltwater meet and the fish and wildlife therein depend on a given range of salinities—can be particularly affected.
  • Water quality: When closed during a storm, a barrier will contain all of the water that normally flows out of the system naturally, as well as any accumulated stormwater and CSO effluent, potentially concentrating pollutants and nutrients in the system.
  • Sediment: Sediment distribution, which is necessary for wetland survival, could be altered or impeded by a barrier. Additionally, the bottom substrate in sites like the Hackensack, Passaic, and Hudson rivers has been found to contain industrial pollutants that could be affected by changes in the system from a barrier.
  • Anadromous fish and wildlife migration: The estuary is home to a number of fish and wildlife that migrate in and out of the system over their life cycle (including shad, striped bass, bluefish, blue crabs, and young eels). It should be determined what level of interruptions to access would be harmful to migrating species.
  • Resident fish and wildlife habitat: Resident fish and wildlife in the estuary find their niche on the bottom of the system based on a variety of factors ranging from substrate type, surrounding vegetation, water depth, etc. Any changes to the dynamics of the system could make portions of the estuary uninhabitable to resident species, such as the Shortnose Sturgeon, which lives in the Hudson River and is considered endangered. This designation ensures that any potential impacts on their habitat must be taken into account before any changes to the system are made.
  • Potential greenhouse gas emissions: Changes to the salinity of an estuary system that is rich in nitrogen could lead to a chemical reaction wherein the potent greenhouse gas nitrous oxide is created.

3.       Social/Political

While outside the scope of an EIS, the social and political dimensions must be considered in evaluating the feasibility of this project.

Constituents inside/constituents outside: As it is impossible to build a system that can protect the entire region from storm surges, many of the region’s residents would still be left without protection should a barrier be built, and there are questions about the impact of additional flooding in communities adjacent to such structures. Debates over this dynamic could make the project complicated to design and approve.

Resilience funding: There is a risk that a surge barrier could divert funding from other needed projects. For example, many adaptation projects, including large resilience investments being made in places like New York City’s Lower East Side and Hoboken in New Jersey, do not yet have full funding. Additionally, other infrastructure, including transit, wastewater, and energy systems face significant shortfalls in funding designated for maintenance.

Two states + New York City: Responsibility for the barrier, including who would determine when it should be closed and opened and who is responsible for maintaining it, will need to be considered.

4. Fiscal/Economic

Estimates for constructing a barrier range from $10 billion to as much as $140 billion, with annual maintenance costs estimated between $100 million and $2.5 billion, depending on factors including design and frequency of closure. Currently, the region’s planned adaptation projects are not yet fully funded, nor are upgrades to our transportation, water and wastewater, energy, and other critical pieces of infrastructure. While federal funding may cover the costs of building a barrier should it be warranted, it is critical that funding streams for maintenance be determined. Such funding streams must be designed to successfully work in concert with other adaptation costs, at the community and regional infrastructural levels.

Alternative 5: Perimeter Only Solutions

Unlike Alternative 2 or any of the other “action” alternatives, this approach introduces the least number of potentially disruptive changes to the Harbor estuary system, focusing primarily on solutions on the perimeter of some of the most at-risk places. Understanding the difference in damage reduction, environmental impact and benefit-to-cost ratio for this alternative compared to #2 and the “No Action” alternative would offer the greatest range of potential options for federal funding (in addition to the general recommendations provided above). The approach in the Meadowlands in this alternative raises questions about impact on that system, however, and the potential for increased flooding in adjacent communities not protected by the intervention.  

Additionally, a number of the topic areas described for Alternative 2 above are also relevant for this alternative. In particular:

1.       Effectiveness

  • Failure rate and lifespan: It is important to understand the lifespan of these projects and their potential failure rate.
  • Sea-level rise: Any study should determine whether these projects help to safeguard against permanent flooding from sea level rise, and up to what level. These projects have the potential to protect against both surge and sea level rise, which should be factored in as a benefit.
  • False sense of security: Like a regional system, local projects could also facilitate a false sense of security and the tendency to continue to develop in risky areas. This should be considered.

2.       Ecology

While more localized than a regional barrier system, the projects evaluated as part of Alternative 5 are likely to have local ecological impacts that need to be considered. Most concerning is the strategy presented for the Meadowlands, which could set back ecological gains made in this important eco-region.

3.       Social/Political

As with Alternative 2, while outside the scope of an EIS, the social and political dimensions must be considered in evaluating the feasibility of this approach. In particular:

  • Constituents protected/unprotected: Given that projects in this alternative would be in select locations, many more of the region’s residents would be left without protection compared with a regional barrier. Explanation for how project sites were chosen will be necessary to justify investments in some places over others.
  • Resilience funding: As described above, given the localized and dispersed nature of these projects, we recommend that the Army Corps consider including incompletely funded projects already underway in this Alternative.

 4. Fiscal/Economic

Ongoing maintenance costs for all local projects should be factored into estimates.


Alternative 3A/B + Alternative 4

These alternatives present multiple engineered solutions in different locations throughout the Harbor and the greater estuary. Like Alternatives 2 and 5, these should be assessed according to the same categories of effectiveness, ecology, social/political and fiscal/economic considerations. 



In summary, RPA supports the effort to fully study resilience alternatives for the New York – New Jersey Harbor and its Tributaries and promotes full transparency of all phases of the study’s results. In addition, RPA has recommended additional considerations for the US Army Corps of Engineers to consider as it undertakes the study and has highlighted particular areas of concern that we hope will be addressed in the study.




Robert Freudenberg

VP, Energy & Environment


[email protected]