Hunters Point Parks Conservancy (HPPC) thanks the U.S. Army Corps of Engineers for the opportunity to comment on the New York New Jersey Harbor and Tributaries Feasibility Study (NYNJHATS) and Draft Tier 1 Environmental Impact Statement (EIS). HPPC is a community-based non-profit that was founded in 1998 to enhance and advocate for the green spaces and waterfront of Hunters Point, Long Island City, Queens, and to ensure the parks remain an indispensable asset to the community. We work with the New York State Office of Parks, Recreation and Historic Preservation and with the New York City Parks Department to advocate for Hunter’s Point South Park and Gantry Plaza State Park, two green spaces that are heavily affected by the Tentatively Selected Plan (TSP), Alternative 3B.
This letter will provide our response to the overall approach seen in the TSP and our concerns about the types of choices being made followed by comments on the specific design features being proposed for the neighborhood.
Guiding Principles
Hunters Point was heavily affected by Hurricane Sandy, and HPPC welcomes federal investment in resilience planning for the neighborhood and larger region. We recognize the significant costs associated with protecting our neighborhoods from future storm surges, and that those costs likely exceed existing City and State resources. However, much has already been invested throughout NYC, and particularly in Long Island City, in addressing these challenges through green infrastructure projects. Given the anticipated cost of the TSP, we believe that it would be better to account for the work already done throughout NYC, and in Long Island City in particular, to address some of these concerns so that new work can be additive rather than in competition with existing models of resilience.
Hunter’s Point South Park is often held up as a model of climate resilient design. The park was built to absorb and release water during flood events and to support the surrounding ecosystems. It was designed to both mitigate storm surge flooding through the use of riprap, berms, a restored wetland, and a 600 gallon reservoir that can capture floodwaters before they reach the neighborhood. We acknowledge that these features alone are not enough to protect the neighborhood from a 100 year storm surge event, but the TSP undermines or destroys these features rather than enhancing them.
HPPC feels strongly that any proposal to address climate change must prioritize Natural and Nature Based Solutions (NNBS) and only resort to gray infrastructure where absolutely necessary. Where possible, parks and green spaces should be designed to absorb water from both rain and storm surge flooding, with gray infrastructure being used to supplement these designs. NYC is facing challenges related to sea level rise, inland flooding, and increasing temperatures exacerbated by the heat island effect in addition to the threat of storm surges, and NNBS can help mitigate all three, often more effectively than proposals that increase the amount of impermeable and concrete structures in a neighborhood.
Crucially, the TSP seems to undermine decades of work done throughout the city to invest in waterfront access, parks, and connectivity on the basis of increasing equity of access to the city’s waterfronts. Even before Hurricane Sandy, NYC developed Comprehensive Waterfront Plans to address waterfront access, resilience, and equity to start undoing the disconnect between citizens and the waterways that surround their neighborhoods. The most recent 10 year plan, released in December 2021 (accessible at www.waterfrontplan.nyc) highlights how important waterfront parks were during the pandemic in supporting people’s mental and physical health, and how waterfront access can support environmental justice and equity goals.
We feel it is essential that any major infrastructure project not recreate past urban planning missteps that NYC communities have been working to redress for decades. There is broad consensus that parks and waterfront access are essential for healthy communities, and that the historic tendency to make city planning decisions that limited access to these features resulted in a less equitable city. The efforts of so many communities to preserve and develop park and waterfront access should not be discarded, and a plan that prioritizes “cheaper” alternatives at the cost of community access is a plan that is merely requiring the next generation to refight many old battles.
We feel that deployable flood barriers provide potentially the best model for gray infrastructure in Long Island City and similar communities where Natural and Nature Based Solutions alone are insufficient and require an additional layer of protection. The Shore-Based Measures Sub-Appendix to NYNJHATS describes flip-up barriers as an option to be used in areas where “the need to preserve viewsheds and maintain level and unimpeded access to the waterfront is essential.” Despite this, the majority of those barriers seem to be located in Manhattan.
Public parks are essential to all communities. We acknowledge that these barriers are likely more expensive than seawalls and floodwalls, but they would potentially preserve waterfront viewsheds and prevent the parks and surrounding neighborhoods from feeling walled-in and unwelcoming, and may integrate better into the existing park environmental and resilience features.
Storm surges are unfortunately not the only source of flooding affecting NYC neighborhoods, and any plan that seeks to help protect the region must also take into account the effects of sea level rise, sunny day flooding, and upland flooding during increasingly common heavy rainstorms. We are particularly concerned about the plan to limit water flow in Newtown Creek and the potential for increased flooding and water pollution as a result of the change.
As a superfund site undergoing an extremely slow clean up process, we feel any plan must address the potential for chemical contamination and show that the proposal will not affect or further delay remediation efforts. The creek also has a large number of Combined Sewage Overflow points, and changes that restrict waterflow may increase the number of pathogens present in the water. We are concerned that as the sea level rises and heavy rain events increase, the challenges facing the creek will only grow. By restricting water flow, the proposed gate may lead to an increase in upland flooding in both Queens and Northern Brooklyn, potentially exposing residents to both harmful chemicals and pathogens from the untreated sewage dumped from the CSOs. The current trend of very rapid development and a transition from industrial to residential and commercial uses in both Long Island City and Greenpoint is likely to result in much of the inland creek area becoming increasingly populated, leading to an increase in the negative effects every time the creek floods.
Overall, HPPC would like to see a plan that builds on the existing work done in NYC to protect our waterfront while providing equitable access to the space, that prioritizes Natural and Nature Based Solutions and integrates them into gray infrastructure designs in a way that promotes the larger environment, and that acknowledges and protects the role of the waterfront and waterfront access as a public good.
Specific Features
HPPC has concerns with several of the proposed features included in the TSP for Hunter’s Point South Park and Gantry Plaza State Park. Working north from the proposed gate in Newtown Creek (discussed above) the design features:
A seawall that removes access to a boat launch that allows people to recreate on the water that will limit people’s ability for recreational boating on Newtown Creek and in the East River.
Waterfront recreation access is important, and if this wall’s location cannot be moved we would like to see a proposal for an alternative access point to the water, especially as the proposal for Gantry Plaza State Park seems to significantly limit access to the piers there.
A levee that is located to completely remove the park’s restored salt water marsh, causing a negative impact to the birds and insects that depend on that habitat and reducing the park’s ability to absorb water during multiple types of flood events.
Please note, there is a berm immediately inland from the proposed levee location. HPPC would prefer to see alternatives that propose enhancements to the existing berm design that do not require the destruction of the wetlands, or the use of deployable flood barriers more inland to protect the wetland and the neighborhood.
We understand that the USACE is performing an environmental impact study, but want to highlight the incredibly important role wetlands play for local and migratory species and how few wetland areas remain in the city. Any proposal that destroys these marshes would have an outsized impact on the larger ecological systems of the surrounding areas.
A seawall that cuts off the remainder of the wetlands and a public art project on a man-made peninsula.
The entire park was designed to absorb water in the extent of major flooding from storm surges, and in fact the portion of the park under construction during Hurricane Sandy took no damage from flooding. Hunter’s Point South Park should be used as a model for how to build green spaces that can survive storm surges without taking extensive damage.
This location highlights the need for further consideration of options for more inland flood prevention features that would allow the public to still access the waterfront during non-flood conditions. For example, the use of deployable flood barriers along the walkway inland of this peninsula, or along the roadway next to the park, could potentially allow access to the waterfront while still protecting the neighborhood during serious flooding.
A deployable flood barrier that allows access to the current NYC Ferry dock.
This is the only deployable flood barrier in the plans for either Hunter’s Point South Park or Gantry Plaza State Park, despite the fact that there is a second ferry terminal in Gantry Plaza State Park that would be cut off by a floodwall.
As discussed above, we feel that deployable flood barriers provide potentially the best model for flood walls in Long Island City and similar communities.
USACE should note that this ferry location will be moved in the very near future as the current location is ending the end of its useful life and construction at that location is not viable because of existing infrastructure challenges.
An elevated promenade
HPPC agrees that this portion of the park does provide some of the best views along the waterfront, and appreciates the inclusion of at least one area in the park where the views of the Manhattan skyline can be preserved. However, we would like to see more information about the accessibility features planned for this promenade, and believe that the park would likely be better suited by the use of deployable flood barriers located inland of the large oval immediately behind this space, which includes a 600,000 gallon reservoir designed to absorb flood waters.
A large levee along the 4 piers in Gantry Plaza State Park
We would like to see plans for how this levee would impact access to the piers, which are used extensively for recreational purposes including fishing, boating, and environmental education.
A floodwall along the entire boardwalk in Gantry Plaza State Park.
We are very concerned about the suggestion of walling in this entire walkway. We acknowledge that the location of the buildings adjacent to this part of the park make some other options potentially less viable, but this is an extremely popular boardwalk with extensive seating options that sees a large amount of use throughout the year. Deployable flood barriers, or at the very least an elevated promenade along the boardwalk would significantly lessen the impact of the loss of waterfront access for the majority of this park.
This plan does not appear to provide access to the NYC Ferry terminal in Gantry Plaza State Park.
In conclusion, Hunters Point Parks Conservancy feels that the Army Corps of Engineers should recognize the important role played by parks and waterfronts for the wellbeing of all New Yorkers, continue to explore Natural and Nature Based Solutions, build on the extensive work already completed and being planned by the City and State when considering waterfront design options, address the existing environmental conditions and future challenges posed by climate change, and continue to incorporate feedback from the impacted communities. We are grateful for the opportunity to share our concerns on this proposal and appreciate the Army Corps’ willingness to engage with our communities to help design a resilient waterfront.
