Updates since close of comment period

11/15/23 press release from office of Congressman Dan Goldman:

 In short: the NYS Department of Environmental Conservation (DEC) invoked the agency’s role as formal non-federal sponsor of HATS. NYS DEC’s letter to USACE triggers a federal requirement that HATS include comprehensive flood protection (not just protection for storm surge/harbor seawater overriding the shoreline.)

STATEMENT FROM CONGRESSMAN DAN GOLDMAN ON NEW YORK STATE REQUIREMENTS FOR COMPREHENSIVE APPROACH TO US ARMY CORPS OF ENGINEERS FLOOD PROTECTION PLAN   

Washington, D.C. – Congressman Dan Goldman (NY-10) today issued the following statement after the New York State Department of Environmental Conservation (NYSDEC) sent a letter requiring the US Army Corps of Engineers (USACE) to revise their $52.6 billion New York and New Jersey Harbor and Tributaries Study (HATS) storm surge protection plan to include a comprehensive approach to address a multitude of flooding risks. This announcement comes after Congressman Dan Goldman and Congresswoman Nydia Velázquez led twelve Members of Congress from New York and New Jersey in sending a bipartisan letter to the USACE expressing concern that the Corps plan to address flood risk insufficiently protects New York and New Jersey against multiple varieties of flooding.   

“I am thrilled that the New York State DEC formally requested that USACE revise their flood protection plan to include a comprehensive approach to flood risks across the New York and New Jersey harbor and tributaries.   

“While the initial proposal failed to sufficiently address the flooding risks faced by our communities, I am encouraged at the hope for a revised plan that will protect New York and New Jersey’s coastal communities.   

“Our states face a multitude of flooding risks, including not only storm surge but tidal and river flooding, heavy rainfall, groundwater emergence, erosion, and sea level rise. To ignore these flooding threats that endanger our region would be an irresponsible use of taxpayer dollars.  

“I am pleased to see that the New York State DEC has heeded the calls to ensure our communities receive comprehensive flood protection in accordance with federal laws. With this important letter from DEC, I expect USACE to promptly issue comprehensive implementation guidance and not delay compliance with the Water Resources Development Acts any longer. This must include a period of public review and comment to ensure that this revised plan adequately addresses community concerns.  

“Disadvantaged communities across our region must receive proper protection from all forms of flooding, and they must be included in reviewing and considering these plans. I look forward to working with all stakeholders to ensure that the new plan is comprehensive and has the best interest of New Yorkers at its core.” 

9/13/23 excerpt from press release from office of Congressman Dan Goldman:

CONGRESSMAN DAN GOLDMAN AND CONGRESSWOMAN NYDIA VELÁZQUEZ LEAD MEMBERS OF CONGRESS IN DEMANDING COMPREHENSIVE FLOOD PROTECTION FOR NEW YORK AND NEW JERSEY  

Upcoming U.S. Army Corps of Engineers Flood Protection Plan Only Protects Against Storm Surge, Neglects Tidal and River Flooding, Heavy Rainfall, Erosion, and Sea Level Rise Threats  

Members Urging U.S. Army Corps of Engineers to Update Protection Plan, Bring into Compliance with Water Resources Development Act and Justice40 Initiative  

Read the Letter Here 

Brooklyn, NY – Congressman Dan Goldman (NY-10) and Congresswoman Nydia M. Velázquez (NY-13) today led twelve Members of Congress from New York and New Jersey in sending a bi-partisan letter to the United States Army Corps of Engineers (USACE) expressing concern that the Corps plan to address flood risk insufficiently protects New York and New Jersey against multiple varieties of flooding. The upcoming plan fails to address tidal and river flooding, heavy rainfall, groundwater emergence, erosion, and sea level rise. Their plan also does not comply with the Water Resources Development Acts (WRDA) of 2020 and 2022 or President Biden’s Justice40 Initiative (J40).  

“With the passage of WRDA, Congress directed the Army Corps to formulate a plan that protects the region from tidal and river flooding, heavy rainfall, groundwater emergence, erosion, sea level rise and storm surge,” wrote the Lawmakers. “However, after seven years of planning, the Army Corps is proposing to spend $52.6 billion to protect our constituents from only one kind of flooding - storm surge. Members of Congress worked diligently to pass WRDA on behalf of our constituents in communities that remain vulnerable to multiple flood threats, and we urge HATS to comply. To ignore the more frequent flooding threats that plague our region is an irresponsible use of taxpayer dollars.”  

In the letter, the Members list actions that they would like USACE to take to better protect millions of residents in the New York-New Jersey metropolitan area from flooding:    

1. Promptly issue implementation guidance on applicable directives in 2020 and 2022 WRDA legislation; 
2. Factor that guidance into the current draft environmental impact study (DEIS) to conduct additional analyses and develop additional alternatives; 
3. Ensure that disadvantaged communities are properly protected; and 
4. Issue a Supplemental Draft Environmental Impact Statement (DEIS) for public review and comment before reaching the Agency Decision Milestone.  

The New York-New Jersey Harbor and Tributaries Focus Area Feasibility Study (HATS), and its upcoming Agency Decision Milestone (ADM), tentatively scheduled for release this summer, does not comply with the Water Resources Development Acts (WRDA) of 2020 and 2022 or President Biden’s Justice40 Initiative (J40).  

In addition to Velázquez and Goldman, this letter was signed by Representatives Yvette Clarke (NY-09), Adriano Espaillat (NY-13), Hakeem Jefferies (NY-08), Michael Lawler (NY-17), Greogory Meeks (NY-05), Grace Meng (NY-06), Jerrold Nadler (NY-12), Alexandria Ocasio-Cortez (NY-14), Donald Payne (NJ-10), Patrick Ryan (NY-18), Paul Tonko (NY-20), and Ritchie Torres (NY-15).  

The comment period closed. Below is our work until that deadline

PortSide’s comment is here. We continued working on this after posting a draft comment here on 3/29.

The deadline for comments is 3/31/23. If you don’t speak up, you can’t be heard! Please submit comments. See the tips for making comments below. You don’t need to be an expert. Express concerns if you have them, suggestions if you have them.

PortSide Zoom - learn more about alternatives to USACE HATS plan:

Don’t like The Big Grey Wall proposed by USACE HATS?
Learn about alternatives!
The recording, chat and transcription for the Zoom on 3/20/23 are in Dropbox at the same link used to register www.bit.ly/ALTresiliency. Download the one-page PDF in there; it’s a handy intro to all this.

• Presentation by Belgian firm Aggeres of their surge-powered flood barriers (SCFB)
• Presentation of landscape architecture resiliency by Walter Meyer and Tom Asbery from LOCAL
• Screening 9-minute segment of this TEDx presentation about “Red Hook Island” – a barrier island proposal by Red Hook resident Alex Washburn

3/7/23 BREAKING NEWS! The deadline for comments has been extended to 3/31/23.

• Recording and presentation and Zoom chat are here.

• Issues we raised at that Town Hall are here. We have yet to write a final comment.

• Brooklyn Paper article about that Town Hall is here.

March 31, 2023 is the newly extended deadline for comments on a MASSIVE $52 billion plan for flood protection by the US Army Corps of Engineers (USACE) called HATS, short for Harbor and Tributaries Focus Area Feasibility Study. 

The catch? The thing is 569 pages long, and it’s webpage has additional documents, videos, and interactive pages! In total, it is 4,000 pages.
Send comments to nynjharbor.tribstudy@usace.army.mil
The website is here.
The 569 page plan is here.
What they call the Readers Guide is contents, a description of which document (website link) contains what. Since some of those links have no description in the name, this is key to finding stuff.
The interactive NYNJHAT Study StoryMap is here.
Their glossary of acronyms is here.
Pg 7 of Sub-appendix B1: Shore-Based Measures  has a map showing the different kind of structures “measures” proposed to protect Red Hook and their locations.

At right, that big grey wall is what they are proposing for much of Red Hook. A flood gate would go at the mouth of the Gowanus Canal.

This “Floodwall Concept for Coffey Street and Ferris Street” shows they need to make a 25’ wide trench and have to drive piles 75’ deep to support these walls. Red Hook buildings have cracked during recent pile driving for new construction. These flood barriers look to involve driving a LOT of steel H-piles. Would vibrations from installing piles this deep damage buildings? One negative impact looks certain, such a deep, wide, long installation along Beard Street would cause traffic gridlock in Red Hook due to how it would likely reroute and delay the last mile trucks using the two Amazon facilities on Beard Street, plus IKEA shoppers.

For years, PortSide has asked if surge-powered flood barriers such as the Aggeres SCFB in the video below could work in NYC. In the video, incoming flood waters push the flood barrier up! We’d like the SCFB and other non-permanent barriers assessed, so we had Aggeres present during our 3/20/23 Zoom, linked above.

A 2/22/23 email from Aggeres says “We engineered the SCFB barrier up to 3m high (which is feasible). In theory the barrier could even be higher, but then many other factors must be taken into account (foundation, very large concrete basins, etc). We have installed barriers up to 2m protection height.” Here is an engineering animation of how the SCFB works.

The plan the USACE has tentatively selected, called Alternative 3B, proposes a 14-year construction project with 12 storm surge gates around waterways of the NYC region such as the Gowanus Canal, Newtown Creek and near the Verrazano Bridge). It would also create barriers along 41+ miles of NYC’s shoreline, including seawalls and floodwalls in Red Hook and elsewhere in south Brooklyn, Lower Manhattan, East Harlem, and all of the Rockaway Peninsula 

You can see 3B, the Tentatively Selected Plan (TSP), running through Red Hook below. This is from Pg 7 of Sub-appendix B1: Shore-Based Measures. The circles in the colored lines are the only places they have planned an opening in the barrier wall.

PortSide has focused on resiliency topics for the decade since Sandy; but we do NOT have time right now to digest and summarize 569 pages for you – we have to deal with our campaign #rethinkEDC, and work on our own Sandy recovery since FEMA gave us a deadline of 7/31/23 to finish the project. So… here’s what we’re offering you:

1.       Honesty about our limitations on this as per above.

2.       The info above and below. Request for comments to the blogpost that we can incorporate to improve this resource.

+ Excerpts from the 569 page HATS document

We did word searches. Red Hook is mentioned 18 times. Sunset Park, our neighbors across Gowanus Bay and part of our City Council district D38, only got mentioned 2 times (both about rail yards). Gowanus is mentioned 25 times. See page 13.

NYCHA is mentioned only once ☹ and for something in Manhattan.

Page 6 is overview map of the whole thing.

Page 8 Project Cost includes item Cultural Resource Preservation.

Page 220 shows RH map and barrier locations.

Here’s a one pager showing a Red Hook flood wall section at Ferris and Coffey Street next to Valentino Park.

Pg 160 summary of Red Hook’s resiliency projects – this does not mention the HUGE resiliency project underway to protect the NYCHA properties (Red Hook Houses East and Red Hook Houses West)
“Red Hook, Brooklyn, NY The City of New York is expected to complete the design phase of the Red Hook Coastal Resiliency Project (RHCR) by the end of 2022. RHCR is an integrated coastal protection system for more frequent, lower intensity coastal storm surges and tidal flooding. Community engagement is a key component for project development since the earliest stages of project feasibility. The project has also aimed to maintain access to the waterfront, and create improved public spaces in response to six years of community engagement. The Red Hook Coastal Resiliency Project will be a critical step toward ensuring a more resilient Red Hook community in the face of future extreme weather and a changing climate.”

Pg 219 “The Gowanus Canal storm surge barrier would provide coastal storm risk management in the neighborhoods of Gowanus, Red Hook, and Park Slope, Brooklyn (Figure 49). The storm surge barrier would include a navigable miter gate. It would span approximately 200 feet from shore to shore and would have one gated navigable passage 100 feet wide, with a sill elevation at -21 feet NAVD88. The proposed structure crest elevation is +16 feet NAVD88. On the east side of the storm surge barrier, shore-based measures such as deployable flood barriers and floodwalls tie into higher ground. On the west side of this storm surge barrier, shore-based measures are proposed to provide flood risk reduction for the Red Hook neighborhood and are placed in proximity to, or at the coastal edge. These shore-based measures may potentially include seawalls, levees, floodwalls, and deployable flood barriers.”

Pg 248 & 241 show that one concern/motive of theirs is to keep water from getting in the Battery Tunnel and BQE trench near here: “major vehicular tunnels in the Study Area would also be increasingly exposed to coastal flood risk in the future without-project condition”
Surface Roads: “For example, the proposed alignment of shore-based measures in the Red Hook neighborhood in Brooklyn includes several vehicular gates that, when deployed, would block vehicular, bicycle, and pedestrian traffic.”

Pg 482 Summary of Construction Footprint and Operations and Maintenance Impacts Associated with the TSP (Alternative 3B) on Roads, Bridges, and Tunnels. For example, the proposed alignment of shore-based measures in the Red Hook neighborhood in Brooklyn includes several vehicular gates that, when deployed, would block vehicular, bicycle, and pedestrian traffic.

Pg 520 Impacts Associated with the Alternative 3B on Schools “There are four public schools in the storm surge barrier managed risk area of Red Hook, Brooklyn.” Do public schools only count?! How about the 3 other schools (2 charter, 1 private), and we count 3 public schools not 4.

Pg 524 Summary of Historic Properties. We note that the list does NOT include a category for National Register ships! Red Hook has two, our MARY A. WHALEN and the LEHIGH VALLEY 79 of the Waterfront Museum. We note low income communities like ours DO have historic properties but that listing them doesn’t happen much in our kinds of neighborhoods, plus the local NYC preservation process, the Landmarks Preservation Commission (LPC), has NOT been receptive to Red Hook efforts to landmark buildings (Todd Pump House, Todd Graving Dock, Bowne Storehouse, Lidgerwood), and many historic structures were leveled to make space for last mile centers. However, we do still have historic properties listed (the Parks Rec Center) and unlisted (brick and stone warehouses by the water in particular). In short, privileged communities get preservation; low-income communities of color don’t. Does the Justice40 Initiative of the White House come into play here?

+ Info from Public Meeting Webinars

Monday 3/6/23, 7pm, at a meeting co-hosted by CB6 and Congressman Dan Goldman’s office, the Army Corps (USACE) presented at a Zoom Town Hall:
• Recording and presentation and Zoom chat are here.
• Issues PortSide raised at that Town Hall are here. We have yet to write a final comment.
• Brooklyn Paper article about that Town Hall is here.

Rebuild by Design has a webpage with 8 videos

Webinar (1 hour and 15 minutes) recorded February 22, 2023 with Gowanus Canal Conservancy on the panel along with Hudson Riverkeeper, Newtown Creek Alliance, Baykeeper, Miami Waterkeeper.

+ Info on Other & Prior Resiliency Plans in Red Hook

See PortSide’s history in Red Hook WaterStories here.

+ White House Environmental Justice Initiative: Justice40

See the USACE one-pager on their EJ position and Justice40 here. It says “If there is a localized concern regarding the plan that might impact a disadvantaged portion of your community, we want to know! Comments Please! Send comments with subject line EJ to  nynjharbor.tribstudy@usace.army.mil

+ What Environmental Groups are Saying

There is opposition to HATS from environmental groups. We share this Gothamist article without endorsement (as we said up top, we have not had time to drill down on this).