Letter – Army Corps Removes Environmental and Public Input from Resiliency Projects


The Army Corps of Engineers (ACOE) has decided to withdraw its intent to prepare a Draft Environmental Impact Statement (EIS) for resiliency projects on the Hudson River and Meadowlands. We are very concerned with this decision because we believe the proposed resiliency projects will cause environmental harm and the review process should not be withdrawn. We believe the resiliency project to protect Hoboken, Weehawken and Jersey City as well as the Meadowlands area will put surrounding towns at risk. These proposals includes hard infrastructure which will not only fail during a storm, but will cause additional flooding, pollution, and stormwater runoff. They also fail to address climate impacts like sea level rise. The public deserves to comment and review the Environmental Impact Statement for these proposals.


“It is not only troubling, but it is potentially very dangerous that the Army Corps is allowing these resiliency projects to go forward without environmental reviews. Many of these projects will fill in wetlands, block access to the waterfront, even put seawalls right through communities and parks that will cause a lot of environmental problems. By building dikes and hard structures, these projects will allow more development in flood-prone areas. This will not only put people and properties in harm’s way, but give people a false sense of hope. Without looking at sea level rise and climate impacts, we are concerned that these projects may fail anyway,” said Jeff Tittel, Director of the New Jersey Sierra Club. “The Army Corps says they want to fast-track these projects, but this is just an excuse to avoid looking at the environmental impacts. They are doing this because the Corps, developers, and others want to get rid of public oversight and review.This is outrageous because they want to spend hundreds of millions of taxpayer dollars so the public deserves to be involved in the oversight.”


The Meadowlands resiliency project includes hard infrastructure with soft landscaping to control stormwater runoff like water pumps. Instead of creating flood storage areas, stopping basement apartments in vulnerable areas, the plan is town-by-town and project-by-project that fails to take a holistic and regional approach. The communities included in the resiliency project are Carlstadt, East Rutherford, Hackensack, Hasbrouck Heights, Little Ferry, Moonachie, Rutherford, South Hackensack, Teterboro and Wood-Ridge. However, we are concerned that all these walls and structures will be overcome by future storms, which will push more flooding, stormwater, and pollution into neighboring communities.


“If the Corps are trying to make things more resilient, they must be looking at resiliency that allows the most environmentally protective options. If you ignore environmental impacts, than these projects cannot be more resilient.Without a proper review, there will be no analysis of whether or not these dikes and seawalls will work or what environmental impacts they will cause. We are also concerned that there will be no analysis to see if these projects will even work and do the job they are supposed to do,” said Jeff Tittel. “In the densely populated Hudson County there is no open space so this water will ultimately cause flooding in Hoboken. The public needs to come out against this proposal because main purpose of building the flood wall is so developers can build more high rises along the water front and rail yards. It is not about protecting the people of Hoboken it is just a rationalization for more development.”


The Hoboken Resiliency project includes the construction of a flood resistance structure stretching from 19th Street in Weehawken and extending south into Hoboken, slightly inland from the river. An additional flood-resistance structure will be constructed along the southern end of Hoboken.


“We desperately need proper environmental review on the proposed resiliency projects because these plans do not deal with climate change or proper science. Seawalls and hardening structures and other programs that will not work will actually make things worse, giving people a false hope that will be washed away in the next storm. What is even more dangerous is that the wall would raise the water level with the water going around the walls or being pushed into neighboring cities,” said Jeff Tittel. “We not only need to look at Jersey City and Weehawken, but the whole New York Harbor. We believe mechanisms to reduce flooding like green roofs and flood storage are good, but we also need buyouts to put people out of harm’s way. Instead of rebuilding our state in a more resilient way, they are instead putting more people at risk and wasting important federal funds. Without considering adaptation and mitigation from climate effects, this money will just be washed out to sea.”


Along with the Christie Administration’s rollback of environmental protections, we believe these resiliency projects are a disaster.  The DEP’s recent changes to the CAFRA and Coastal Zone Management rules will add more loopholes and waivers and weakening coastal protections.  The rules do not strengthen protections, encourage more regional planning, address climate change or sea level rise, and they do not include programs for adaptation or mitigation of sea level rise, resiliency, or natural systems restoration. This will add more development in hazard areas and put people and property in harm’s way.  They have also proposed to weaken the Flood Hazard rules and the Water Quality Management Planning rules, which will increase flooding and development in environmentally sensitive areas.


“Instead of addressing climate change, Administration wants to perpetuate failed programs of the past, including sea walls, hardening our coast, and other things that have failed.  The DEP is allowing for more development and loopholes in coastal areas putting more people and harm’s way. The state has not only failed to protect us from future storms, but has not taken into consideration sea level rise or completed suitable FEMA mapping after Hurricane Sandy. We also do not have proper projections are for sea level rise. Without climate change data and projections, we cannot properly build to protect our shores from the results of climate change like sea level rise and storm surges,” said Jeff Tittel. 


While Christie has been in office we have seen 22 major weather events and we are the worst state in the nation for flooding damage. Rutgers predicts that the coast will see a 1 ft. increase in sea level by 2050 and that is up to 3 ft. with ebb and flow. The DEP expects to formalize the projects design in 2017. Construction is expected to begin in 2019 and take about three years to complete.


“These projects cannot be resilient if there is no input and oversight. With all the people of New Jersey that have been devastated by the recent storms, ignoring climate change is outrageous, dangerous, and puts people at risk. The federal monies coming in for rebuilding should be going towards adaptation and mitigation, restoring natural systems and requiring green buildings and energy efficiency so that New Jersey will have a fighting chance,” said Jeff Tittel, Director of the New Jersey Sierra Club. “The Army Corps of Engineers must allow a proper review of these resiliency projects. We need to be able to comment against these proposals because if we do not deal with climate change as we rebuild we will be wasting millions of dollars and putting people in harm’s way.”


The ACOE notice can be found below:


The U.S. Army Corps of Engineers, New York District (NY

District), is withdrawing its intent to prepare a Draft Environmental

Impact Statement (EIS) for the Study. The Notice of Intent to prepare

the Draft EIS was published in the Tuesday, December 28, 2004 issue of

the Federal Register (69 FR 77744).

The U.S. Army Corps of Engineers, NY

District published a notice of intent to prepare a Draft Environmental

Impact Statement in the December 28, 2004 issue of the Federal Register

(FR Doc. 2004-28331). In an effort to streamline work in early 2015,

the U.S. Army Corps of Engineers, New York District, consolidated

multiple parallel USACE ecosystem restoration feasibility studies into

the Hudson Raritan Estuary Ecosystem Restoration Feasibility Study

(HRE) Study.

    This streamlining is consistent with the Civil Works Transformation

Initiative and Specific, Measurable, Attainable, Risk Informed, Timely

(SMART) Planning principles, and maximizes efficiencies, resources and

benefits. The other feasibility studies include:

     HRE–Lower Passaic River Ecosystem Restoration Feasibility


     HRE–Hackensack Meadowlands Ecosystem Restoration

Feasibility Study;

     Flushing Creek and Bay Ecosystem Restoration Feasibility


     Bronx River Basin Ecosystem Restoration Feasibility Study;

     Jamaica Bay, Marine Park, Plumb Beach Ecosystem

Restoration Feasibility Study.

    As such, a Draft EIS is no longer necessary. Each Feasibility Study

was at a different stage prior to the decision to consolidate into the

HRE Feasibility Report/Environmental Assessment (FR/EA). The planning

was conducted independently with their non-federal sponsor and resulted

in the selection of specific recommendations within each watershed.

These combined efforts resulted in the recommendations included in the

broader HRE FR/EA. The HRE FR/EA will be prepared and circulated for

review by agencies and the public. The New York District invites

participation and consultation of agencies and individuals that have

special expertise, legal jurisdiction, or interest in the preparation

of the draft environmental assessment. Comments received, including the

names and addresses of those who comment, will be considered part of

the public record for this proposal. As a result of the process, if it

is determined that the project may have significant impacts, the EIS

process will be reinitiated and a NOI published.