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Public Comments Received

Received November 14, 2010

Douglas Hill, Eng.Sc.D., P.E. - Protection vs. Adaptation: A Way Out:

What is sad is that all the talent and energy that went into preparing this report has produced only another salvo - this one obviously intended to be Big Bertha - in the endless war between those who favor building structures to protect the waterfront, and those who would let nature take its course, when some sort of reconciliation could have been proposed. It is clear that the charge by the state legislature merely to protect coastal ecosystems and natural habitats, and to increase the resilience of coastal communities, not protect them, could only produce a report that favors non-structural coastal measures. What took three years?

What is worrisome is that New York State policy might actually be determined not by what is needed to protect people but what is needed to protect ecosystems, not by what is needed to protect communities but what can merely make them resilient.

The concept of "resilience" is at odds with protecting public safety. Resilience is defined as "the ability to return to original form" and "the ability to recover readily." It implies that the damage has already been done. Resilience as a criterion implies that that damage is acceptable. Resilience may be important for the interim or as a back-up. What is needed most, however, is surely protection.

At the heart of this report is the statement: "Non-structural solutions can reduce or eliminate the long-term threat of flooding at a much lower long-term cost with fewer impacts to natural systems." Is this a self-evident truth? Is it the result of research? Or is it simply ideology?

"Regional planning is critical to ensure sound decision-making to reduce risk along the coast," according to the report. With its ideological tunnel vision, however, the Task Force not only misses, but dismisses, a regional innovation that in much of the State could transcend the endless disagreement between coastal protection and adaptation: namely, storm surge barriers in the waterways surrounding New York City. Since storm surge barriers are structures, the authors apparently assume that they must be no better than levees, seawalls and dikes. That they present a qualitatively different way to protect against the consequences of sea level rise has apparently not occurred to the authors.

"Large-scale engineered fortifications may not be the best way to protect large cities and densely populated urban areas such as New York City from coastal storm impacts and inundation," opines the report, offering no alternative. Reference is made to the findings of the National Academy of Engineering and the National Research Council (twice) that "... the risks of inundation and flooding never can be fully eliminated by protective measures no matter how large or sturdy those structures may be." Better then to have no protection at all?

At a March 2009 conference sponsored by sections of the American Society of Civil Engineers and the New York Academy of Sciences1, the hydrologic feasibility of protecting much of the metropolitan New York - New Jersey metropolitan region with storm surge barriers was demonstrated by the results of modeling studies at Stony Brook University and HydroQual, Inc. The technical feasibility of barriers was established with conceptual designs by four major engineering firms - Arcadis, Camp Dresser & McKee, Halcrow, and Parsons Brinckerhoff - and geotechnical studies by Mueser Rutledge.

Against this substantive body of work supporting the concept, the Task Force report presents a single opinionated, condescending, undocumented and misinformed2 paragraph dismissing storm surge barriers.

In addition to serving to block storm surges from hurricanes or nor'easters, the barriers could also be operated as tide gates to limit the elevation of high tide as sea level continues to rise by being closed daily at the level of present high water. This would prevent all the problems of chronic inundation described in the Task Force report, not only in the New York City environs but up the Hudson River to Troy. It would work until sea level rises to the point where present low water reaches the level of present high water. By the most pessimistic of sea level rise projections, that is more than a century away.

The Rising Waters scenario planning project for the Hudson Valley conducted by the Nature Conservancy offered participants a choice between "environmentally benign approaches to adaptation" or "big, hard engineered flood management infrastructure along the main stem," the latter of which it rightly charges would cause additional flooding downstream. Not surprisingly, participants may have reached a consensus on recommendations for adaptation, as reported by the Task Force, but they were not aware of the full slate of options. Storm surge barriers also operated as tide gates would avoid both of these unnecessary alternatives.

This concept needs to be verified with the hydrologic models that exist for the Hudson River. The Task Force could make a useful contribution by recommending that such a study be given priority. Instead, we have the judgment that "Holding back the rising sea on a large scale is not practical or even possible." Too bad that the Dutch didn't know that when they started building dikes in the 9th Century.

With the draft report to the legislature apparently in final form, and only three weeks between the close of this comment period and the presentation of the report to the state legislature, it appears unlikely that any of these comments will make a difference. If the Task Force cannot present an informed constructive appraisal of the potential of storm surge barriers, however, it can at least delete the unfortunate paragraph on the subject on page 50.

Footnotes:

1. D. Hill and J.S. Khinda (eds.). Against the Deluge: Storm Surge Barriers to Protect New York City. American Society of Civil Engineers (in press).

2. Extensive systems of levees would not be required to accompany barriers to protect inner New York City. At three locations for which conceptual designs have been prepared, there is high ground, 8 meters in elevation, nearby on the adjacent shores. Pump facilities are needed at only one of the several barriers around the world: Providence, RI, where there is a very small reservoir inside the barrier. The broad Hudson presents no such problem.

Received November 24, 2010

Steve Calvin

"With important natural habitats and coastal ecosystems, and more than 60% of New Yorkers living in homes on or near waterfront areas, the New York Sea Level Rise (SLR) Task Force has been developing a statewide framework to address the risks posed by climate changes on sea level rise and coastal storms."

You're kidding me right? You really want to initiate some sort of action to protect the rich people who've lived on the coast and now are afraid because the seas are rising?!? You have to be kidding me. Who cares. Let 'em fall into the sea. I mean really, what did they think was going to happen when they built in their ritzy neighborhoods and blocked others out? If the government bails them out there will be an uprising. That's like feeling sorry for the upper crust whose homes are lost in the California mud slides? HELLO?!? You built on a cliff overlooking the ocean, idiot. And this surprises you?!? Idiots... And we're supposed to bail the poor babies out? How ridiculous.

That said, protection of the WILDLIFE and their areas I'm all behind and yes that should be funded by a general fund.

And yes, the possibility of waste contamination needs to be addressed BUT should be paid for by the richie-rich who've lived on the shore and enjoyed it while they have successfully kept normal people out. The government (read as us commoners) shouldn't foot the bill for that either.

I'll be watching this and will pass it to people I know so that they're aware and can watch what happens here as well.

You can be sure I'll also send this to my representatives once all are sworn in.

Received December 6, 2010

Crystal M. Lake
Long Beach, New York

Re: Sea Level Rise Comments from North Park an Environmental Justice Community

For decades the North Park Residential Community which is located in the City of Long Beach New York, have endured severe flooding due to our close proximity to Reynolds Channel. Reynolds Channel is a Federal Navigation Channel with aging infrastructure, lack of bulk heading, other engineering controls coupled with many environmental and health concerns from prior, current, future commercial and industrial facilities. Such as Power Plants, Incinerator sites, potential residential development/local waterfront or zoning plan, waste water facility and waste water sewer lines which are adjacent to Reynolds Channel in the North Park Area. Severe flooding mostly occurs on Park Place/Pine St. to Pine St/Long Beach Rd and Riverside Blvd/Pine St. to Riverside/Fulton St.

"The Tidal influence on Reynolds Channel causes a mean tide range of approximately 3.9 feet and a spring max range of 4.7 feet. Higher tides caused by nor'easter storms". Along Reynolds Channel bay front area from the Long Island Rail Road east to the Long Beach Bridge consist only of rip-rap no bulk heading. Outfalls located at Long Beach Road (County Owned) and Riverside Blvd are without Tide Flex Valves. Also, Reynolds Channel is listed on the Final New York State 2006 section 303(d) List of Impaired Waters. Pathogens from Urban/Storm runoff are identified as the cause and source of pollution in Reynolds Channel.

From 2006 to the present, requests for engineering controls and/or solutions to these reduce or eliminate flooding issues fall upon death ears. Our quality of life is greatly diminished. Our children forced to stand in and tread deep water to attend school and/or daycare. Our seniors forced to stay in their homes. Tragically they are unable to keep necessary doctor's appointments, fill prescriptions, run errands and attend their house of worship.

The Presidential Executive Order 12898 Environmental Justice was signed into law on February 11, 1994 to provide meaningful involvement and fair treatment for all persons regardless of race or income for numerous quality of life concerns with respect to development, implementation and enforcement of environmental laws, regulations and policies. Furthermore, Citizen Participation, Citizen Participation inclusive of Commissioner Policy CP 29, our input, should be a crucial component for Community Resilience; Sea Level Rise Adaptation and Smart Growth Development for all residents to have better places to live work and play.

Recommendations are as follows:

1. Part II: Funding for measures to reduce risk. Pages 57-59:

Full implementation should be 2-5 years Not Full implementation within 10-15 years

2. 6. Develop maps and other tools to assist decision makers in preparing for, and responding to, sea level rise. Pages 59- 60:

Full implementation should be 2 - 5 years Not Full implementation 10 - 15 years

3. Long Island South Shore Estuary Reserve Act (Article 46) Page 67:

Full implementation should be 2 - 5 years Not Full implementation of all regulatory recommendations within 10 -15 years

May 9, 2010

Gregory Smith
Stony Brook University '12

I am writing to you in regard to the New York State Sea Level Rise Task Force and the necessity of physical barriers as prevention mechanisms against large storm surges. In the course of the Task Force's review of rising sea Level-Is and its effects on New York State, it is important to keep in mind the effects of storm surges stemming from more powerful storms. As sea levels increase, potentially now at a much higher rate, due to climate change, the effects of storm surges with be vastly more powerful, with huge consequences.

New York State, with specific focus on New York City, is the financial epicenter of the world. We have seen the impacts in the last few years of what happens globally when financial giants like Lehman Brothers collapse. Major disruptions in New York City affect the global economy with such force that underestimating them would have far reaching consequences.

There is no question that New York City will be hit with a massive storm in the foreseeable future, one that will have immense consequences on the city's infrastructure and economic stability. The storm surge from such a storm will inundate parts of Brooklyn, Queens, and Lower Manhattan. Salt water will shut down the subways, while flooding with easily close the region's airports. This has happened in the past, and will again in the future with greater impact due to sea level rise. Storm surges in the future will be significantly more powerful and further reaching.

New York needs to prepare now. We know larger storms will come, and the way to prevent devastation from storm surge is to build physical barriers. Large-scale construction, like that seen on the Thames River, England and in the Netherlands is needed to ensure the ongoing success of New York City.

"Disclaimer: the views expressed in this letter are mine alone and do not necessarily reflect those
of Stony Brook University or its employees"

Received December 9, 2010

Wanda Brooks
Long Beach, New York

I would like to thank you for taking the time to look at the North Park flooding issues in Long Beach. East Pine Street has flooded for decades caused by high sea levels. I remember once as a youngster the water being waist level. At that time I was 11 or 12 years old.

I now have a grandchild 13 years old and Pine Street still floods. I hope with the attention brought to this issue that the problem will finally be rectified. Instead of being ignored for another decade.

Please help our community with this issue.

Received December 10, 2010

Mike Cruz
Executive Director, Long Beach Latino Civic Association, Inc.
Long Beach, New York

The City of Beach, sits on a barrier island off the southern coast of Nassau County. According the U.S. Census figures, Long Beach has an estimated population of 35,000, with a growing Latino population of 15.1% and African American 13.3%. Currently, the average annual family income is between $72,715 and $ 77,000. with a poverty level of between 9 and 10%.

For over 30 years the North Park Residential Community has endured sever flooding due to our close proximity to the Reynolds Channel. Reynolds has been a Federal Navigation Channel with an infrastructure that is in desperate need of repair, the lack of bulk heading, a 60 year old sewer treatment plant, coupled with many environmental and health concerns from prior commercial and industrial facilities, such as a former incinerator site, power plants, gun range, which are adjacent to Reynolds channel in the North Park area. Severe flooding continues to occur on Park Place/ E. Pines street and Riverside Blvd/E.Pine .to Riverside Blvd /E. Fulton street.

Along the Reynolds Channel bay front area from the Long Island Railroad east to the Long Beach bridge consist of rip-rap and no bulk heading. Outfalls located at the Long Beach Road (County owned) and Riverside Blvd are without Tide Flex Valves, also Reynolds Channel is listed on the Final New York State 2006 section 303 B List of impaired waters. Pathogens from Urban storm runoff are identified as the cause and source of pollution in Reynolds Channel.

From 2006 to the present, request for engineering advise and or solutions to reduce or eliminate flooding issues have falling upon deaf ears. The quality of life continues to greatly diminish. Children are forced to stand in and tread deep water to attend school
and or day care, as are seniors forced to stay home due to flooding conditions.

The Presidential Executive order 12898 Environmental Justice was signed into law February 11, 1994 to provide meaningful involvement and fair treatment for all persons regardless of race or income for numerous quality of life concerns and enforcement of environmental laws, regulations and policies.

Recommendations should include,

The development of maps and other tools to assist decision makers in preparing for and responding to sea level rise.

Funding for measures to improve the existing conditions and reduce risk

Full implementation should be two to five years and not within 10- 15 years

Development of partnerships with other communities that have been successful in the implementation of projects that have or will attempt to address similar conditions.

Received December 10, 2010

Randolph S. Price, Vice President, Environment, Health and Safety
Consolidated Edison Company of New York, Inc.
New York, New York

Con Edison Comments relating to the Sea Level Rise Task Force Draft Report - 212 KB PDF

Received December 10, 2010

Isaac R. Melton, Jr., Pastor
Christian Light Missionary Baptist Church
Long Beach, New York

Sea Level Rise Comments from North Park an Environmental Justice Community - 305 KB PDF
(35 copies of this letter were received, each signed by a different individual)

Received December 10, 2010

Myrnissa A. Stone, Executive Director
Long Beach MLK Center, Inc.
Long Beach, New York

Sea Level Rise Comments from North Park an Environmental Justice Community - 173 KB PDF

Received December 10, 2010

R. Darryl Banks
Deputy Director of Conservation Strategy and External Affairs
The Nature Conservancy
Albany, New York

The Nature Conservancy Comments relating to the Sea Level Rise Task Force Draft Report - 235 KB PDF

Received December 10, 2010

Robert Zerrillo
Acting Director, Policy and Planning Division
NYS Department of Transportation
Albany, New York

NYS Department of Transportation Comments relating to the Sea Level Rise Task Force Draft Report - 170 KB PDF

Received December 10, 2010

Anthony J. Aloisio, Director
Department of Planning and Environment
Town of Huntington
Huntington, New York

Town of Huntington Comments relating to the Sea Level Rise Task Force Draft Report - 1.26 MB PDF

Received December 10, 2010

Christopher R. Zeppie
Director, Office of Environmental and Energy Programs
Port Authority Of New York and New Jersey
New York, New York

Port Authority Of New York and New Jersey Comments relating to the Sea Level Rise Task Force Draft Report - 139.52 KB PDF

Received December 10, 2010

Neal Lewis, Executive Director
The Sustainability Institute
Molloy College
East Farmingdale, New York

The Sustainability Institute Comments relating to the Sea Level Rise Task Force Draft Report - 98.88 KB PDF

Received December 12, 2010

Lawrence Levine, Senior Attorney
Kim Knowlton, DrPH Senior Scientist, Health and Environment Program
Natural Resources Defense Council
New York, New York

Natural Resources Defense Council Comments relating to the Sea Level Rise Task Force Draft Report - 134.4 KB PDF

Received December 12, 2010

New York State Senator Thomas K. Duane and
New York State Assembly Member Richard N. Gottfried

Comments by New York State Senator Thomas K. Duane and New York State Assembly Member Richard N. Gottfried Regarding the New York State Sea Level Rise Task Force Draft Report to the New York State Legislature - 84.2 KB PDF

Received December 12, 2010

Emory Breiner, Deputy Chair
Shelter Island Planning Board

Over the years, as a Town Official, I have attended numerous workshops hosted by The Nature Conservancy on Planning for Sea Level Rise and Coastal hazards. The worst case scenarios were used to generate the highest possible rise in sea level

Suffolk County has a large shoreline and the mapping depicting the various scenarios on sea level rise redline large swarths of property. Being familiar with the towns used in the demonstrations and the actual streets I found it most troubling that the property owners affected have no idea their property was under discussion. From the first meetings, years ago now, I asked who represents these people? Where are they?

The Nature Conservancy considers stakeholders to be only town officials or other people who have the ability to adopt or influence local code. The Nature Conservancy had no interest in the thousands of stakeholders who own the property that is now to be subject to additional regulation.

The presenters pointing to actual houses I have lived in, made extreme statements, "These houses shouldn't be there. Nobody should buy these houses." In many cases these expensive properties are the revenue generators for the towns. When I asked where the money is coming from to buy these properties I was told the people may donate them to get out of the sea's way.

We performed an absurd exercise to move all the people from West Hampton Beach and relocate them
inland by the airport, of all places. TNC meant this seriously.

The theme was simple, in seventy years you may be underwater, so we want it now. The Nature
Conservancy appears to greet sea level rise with glee. I am concerned they are using the threat to confiscate by regulation more and more of the shoreline.

I would hope those who do represent these property owners, both developed and undeveloped, would be protective of them.

Received December 12, 2010

Sacha Spector, PhD
Director of Conservation Science
Scenic Hudson, Inc.
Poughkeepsie, New York

Scenic Hudson, Inc. Comments relating to the Sea Level Rise Task Force Draft Report - 153.04 KB PDF

Received December 12, 2010

Carolyn Spilman
Long Island Bird Conservation Coordinator
Audubon New York
Albany, New York

Audubon New York Comments relating to the Sea Level Rise Task Force Draft Report - 70.33 KB PDF

Received December 12, 2010

Emilie Hauser
Kingston, New York

Emilie Hauser Comments relating to the Sea Level Rise Task Force Draft Report - 126.02 KB PDF

Received December 12, 2010

Udo Drescher
New York

Udo Drescher Comments relating to the Sea Level Rise Task Force Draft Report - 31.09 KB PDF

Received December 13, 2010

Danielle Schreiber Legal Intern
PACE Environmental Litigation Clinic, Inc.
PACE University Sshool OF Law
White Plains, New York

Daniel E. Estrin, Esq. Comments on behalf of Riverkeeper, Inc. ("Riverkeeper") relating to the Sea Level Rise Task Force Draft Report - 101.94 KB PDF

Received December 13, 2010

Sarah Lansdale
Executive Director
Sustainable Long Island
Bethpage,New York

Sustainable Long Island Comments relating to the Sea Level Rise Task Force Draft Report - 64.51 KB PDF

Received, December 13, 2010

Lillian Ball
Southold, New York

The enormous effort that went into preparing this report is undoubtedly appreciated by the natural ecosystems still remaining in NY State. They cannot speak for themselves. The human communities, however, can and should be made more aware of these issues and the proposed reconciliations. Hopefully the NYS legislature and state agencies will take the positive steps needed to make this possible. There fore I wholeheartedly endorse the point that "state policy should engage communities as active participants in achieving climate goals". Having observed several of the SLRTF meetings in NYC, I am impressed by the even-handed way the Task Force looked at the overwhelming issues. Green infrastructure methods and low impact development, in addition to renewable energy technologies appear again and again to be the most cost effective measures at this point in time. As a member of the Southold Town Land Preservation Committee, I realize the enormous efforts necessary to protect our coastal communities. There is simply not enough funding to purchase the most vulnerable wetland areas for future migration upland given the high cost of shoreline properties . I would suggest that permitting procedures be streamlined whenever possible to expedite green infrastructure stormwater remediations. The substance of the point below cannot be emphasized enough. B. Stormwater management techniques and approaches should be incorporated wherever possible into existing contributors and across all sectors- private, commercial, municipal, etc. Greater stormwater runoff control is necessary to reduce pressures, especially on urban drainage systems. Stormwater is currently regulated for new projects, but contributions from existing, unmanaged sources will continue to increase unless those sources can be retrofitted to reduce runoff. This effort should include an assessment of opportunities to create or maintain open spaces with permeable surfaces, to lessen the degree that storm surges will sweep toxic substances inland.

Received December 14, 2010

Frank Santomauro, Chief
Planning Division
Department of the Army
New York District, Corps of Engineers
New York, New York

Department of the Army Corps of Engineers Comments relating to the Sea Level Rise Task Force Draft Report - 102.04 KB PDF

Received December 16, 2010

Vernon G. Rail, Esq., Assistant Regional Attorney
New York State Department of Environmental Conservation, Region 1
Stony Brook, New York

New York State Department of Environmental Conservation, Region 1 relating to the Sea Level Rise Task Force Draft Report - 20.22 KB PDF

Received December 16, 2010

Beryl A. Thurman, Executive Director/President
The North Shore Waterfront Conservancy of Staten Island, Inc.
Staten Island, New York

NSWC's response for draft Sea Level Rise Task Force Report - 50.30 KB PDF

Received December 17, 2010

Adam Freed, Deputy Director
New York City Mayor's Office of Long-Term Planning and Sustainability
New York, New York

The City of New York's Comments on NYS Sea Level Rise Task Force Report Draft for Public Comment - 109.67 KB PDF

Received December 20, 2010

American Society of Civil Engineers ASCE
Metropolitan Section
New York, New York

ASCE Metropolitan Section Comments and Recommendations on Draft NYS Sea Level Rise Task Force Report 120KB PDF

Received January 20, 2011

Gerard Stoddard
Fire Island Association, Inc.
Ocean Beach, New York

Fire Island Association's Comments on the Report of New York State Sea Level Rise Task Force - 755 KB PDF


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