Army Corps' NY/NJ Storm Surge Barrier Project Must Protect Communities on Their Terms

The U.S. Army Corps of Engineers’ updated proposal to protect New York City and northern New Jersey from coastal flooding using large offshore storm surge barriers continues to fall short on protecting vulnerable communities and addressing comprehensive flood risk in our region. In the wake of Hurricane Sandy, Congress tasked the U.S. Army Corps of Engineers with formulating a plan to protect the New York City metropolitan area from coastal flooding. With climate change increasing the frequency and severity of coastal storms, and sea level rise leading to more intense storm surges, taking adaptive and protective action is critical. Last September, the Army Corps released the latest iteration of its feasibility study and tentative proposal to construct storm surge barriers in New York Harbor and Long Island Sound. NRDC and many others submitted comments to this proposal, which needs significant work to fully protect coastal communities from flooding.

The proposal rightly states the importance of protecting vulnerable coastal communities, but it fails to fully examine the harms the project could impose on vulnerable communities—and it does not meaningfully involve these communities in the planning process. It is crucial to note that low-income communities and communities of color are significantly more vulnerable when storms hit because they have been pushed out to live in low-lying areas that are more susceptible to flooding. 

Though the Army Corps is trying to make its public participation process more robust by increasing accessibility and accommodations at public meetings, it still misses the crucial point that the decision-making process requires meaningful partnership with community members from the outset. NRDC joins many other environmental and community advocates in the call for an Environmental Justice and Community Working Group through which community members could obtain necessary information and provide ongoing input to the Army Corps on the proposed alternatives.

Further, the Army Corps has not provided enough specific information for frontline community members to understand how their homes and neighborhoods will be impacted. For example, New York City and northern New Jersey are heavily industrialized areas, and stormwater runoff picks up historic contaminants as it flows over land and ultimately into surrounding waters. In addition, New York City and several northern New Jersey municipalities rely on combined sewers that overflow during storms, discharging untreated wastewater and raw sewage into the surrounding waters. But storm surge barriers interrupt the natural flow and dispersal of these waters, and they can trap polluted water with high concentrations of contaminants near the shoreline. The proposal does not sufficiently explain what health and environmental harms coastal communities would be exposed to as a result, nor how the Corps plans to mitigate these particular risks.

The proposed measures are also too narrow to address the full scope of climate-related coastal flood risk that threatens the New York-New Jersey region. The proposal addresses storms of the size and severity that could occur every 100 years, but fails to address many other climate impacts, like “sunny day” tidal flooding and flooding from rainstorms. Not only will this project take years to construct, but it will also not prevent harm from coastal flooding until the threat rises to its most extreme. The need for more comprehensive measures has long been recognized, and Congress recently acknowledged that coastal flood risk cannot be addressed in a vacuum.

The Army Corps also needs to incorporate more natural and nature-based measures into its plan. Nature-based measures have many environmental and public health co-benefits and are much more cost-effective with public tax dollars. For example, increasing tree cover and green space in coastal communities can not only help adapt to greater flood risk, but also contribute to improving air quality, protecting against extreme heat, and boosting physical and mental health.

Coastal flooding is one of the largest-scale threats facing our region, and it is tempting to settle on a silver bullet solution like storm surge barriers. But a one-size-fits-all approach will inevitably leave some people less protected than others, and we have seen historically how our most socioeconomically vulnerable communities are almost always the ones left behind. We need a robust public process to better understand the proposed plan so that certain communities don’t become “sacrifice zones,” and we need the proposed plan to take a comprehensive approach to adaptation that uses all the tools at our disposal.

The comment deadline may have passed, but it will not be the last—and you can still tell the Army Corps what you think of the plan! Click here to let them know you want a comprehensive and community-centered coastal flood risk adaptation plan for New York City and northern New Jersey.

This blog provides general information, not legal advice. If you need legal help, please consult a lawyer in your state.