Comments on the Draft Scope for the FiDi FORGE Environmental Impact Statement and Feasibility Report

Source: NYCEDC, US Army Corps of Engineers (USACE)

Dear FiDi FORGE Study Team:

The City Club of New York appreciates the opportunity to comment on the

Draft Scope of Work for the Environmental Impact Statement (EIS) and

Integrated Interim Feasibility Report for the Financial District and Seaport

Fortifying Our Resilient Growth and Economy (FiDi FORGE) Coastal Storm

Risk Management Project.

The City Club recognizes that sea level rise, coastal flooding, and increasingly frequent and intense storms present growing challenges throughout New York City. Addressing these risks will require thoughtful planning, sound science, significant public investment, and careful consideration of priorities across the City’s waterfront.

As one of the largest and most consequential climate adaptation and public infrastructure projects proposed in New York City, FiDi FORGE has the potential to shape Lower Manhattan for generations and to influence future resilience planning throughout the region. Because of its scale, cost, and long-term implications, the Environmental Impact Statement should provide a comprehensive, transparent, and objective evaluation of the project’s alternatives, environmental impacts, costs, benefits, and tradeoffs.

The Draft Scope of Work provides a thoughtful framework for environmental review and identifies many of the issues that warrant detailed analysis. Given the scale and long-term significance of FiDi FORGE, however, the Environmental Impact Statement should do more than identify environmental impacts and mitigation measures. It should clearly explain how alternatives were developed and evaluated, identify the assumptions, methodologies, and decision criteria used throughout the planning process, and provide suficient information for decision-makers and the public to understand the tradeoffs among competing approaches.

The Financial District and Seaport Climate Resilience Master Plan (FDSCRMP) was developed through years of technical analysis, interagency coordination, and public engagement, and established three overarching goals: protecting Lower Manhattan from tidal flooding and coastal storms; integrating climate resilience infrastructure into the city; and enhancing the public waterfront through new open space and community-serving uses. The Environmental Impact Statement should evaluate the extent to which the proposed alternatives advance—or depart from—these planning objectives and explain the reasons for those differences.

The City Club offers the following recommendations to strengthen the Final Scope of Work and help ensure that the subsequent Draft EIS provides a comprehensive, transparent, and technically rigorous evaluation of the proposed project and its alternatives.

1. Plan FiDi FORGE as Part of an Integrated Lower Manhattan Resilience System

The Draft Scope appropriately describes the evolution of climate resilience planning in Lower Manhattan, including the Lower Manhattan Climate Resiliency Study, the Financial District and Seaport Climate Resilience Master Plan, and adjacent resilience initiatives. However, the environmental review itself is largely confined to the FiDi FORGE project area. The Draft Scope also states that the Seaport Coastal Resilience Project will not be included because it has not yet been approved.

While this approach may simplify the environmental review, it risks overlooking how individual resilience investments function as parts of a larger system. Flood protection, transportation, ecological restoration, waterfront access, emergency response, and stormwater management do not stop at project boundaries. Decisions made within FiDi FORGE will influence the effectiveness of adjacent resilience projects, just as those projects will influence the long-term success of FiDi FORGE.

Accordingly, the City Club recommends that the Final Scope of Work expand its cumulative analysis to evaluate how FiDi FORGE integrates with surrounding resilience initiatives, including the Seaport Coastal Resilience Project, Battery Park City Resiliency, The Battery Coastal Resilience Project, the Brooklyn Bridge–Montgomery Coastal Resilience Project, and the broader New York and New Jersey Harbor and Tributaries Study (HATS). In particular, the scoping should address how the different alternatives would affect the cost/benefit analysis of each existing HATS alternative including but not limited to the Tentatively Selected Plan.

The EIS should explain whether FiDi FORGE is intended to function as an independent project, an initial phase of HATS implementation, or a complementary project whose design assumptions will influence future HATS recommendations. The scoping process should examine how the alternatives affect the HATS study and explain how FiDi FORGE has been coordinated with the HATS planning process.

The analysis should also explore opportunities to leverage existing infrastructure—including the FDR Drive corridor —to improve flood protection while minimizing environmental impacts and maximizing public benefit.

The Final Scope should require a continuous line-of-protection plan and a segment-by-segment design-basis table for FiDi FORGE and each adjoining project. For every segment and tie-in, the report should disclose the vertical datum, design event, planning year, sea-level-rise assumption, passive and structural protection elevations, freeboard, deployable elements, closure points, residual risk, and adaptation provision. The EIS should test mismatched design standards, incomplete or delayed adjoining projects, inland and sewer pathways, temporary construction conditions, gate or pump failure, power loss, and exceedance events; map every route by which water could enter behind completed protection; and identify the entity responsible at each interface. The report should also state how FiDi FORGE shares data, assumptions, dependencies, and residual-risk responsibilities with HATS without treating the two studies as the same project.

The EIS should also evaluate how the various Lower Manhattan coastal resilience projects function together as an integrated flood protection system. In particular, it should assess whether differences in design flood elevations (DFE), alignments, or project sequencing could allow floodwater to bypass higher levels of protection by entering protected areas from adjacent or inland segments. The EIS should explain how the individual projects are designed to work together to prevent flooding from behind completed flood protection systems and identify any measures needed to avoid unintended vulnerabilities at the interfaces between projects.

Providing a transparent explanation of these design standards will help the public understand how the individual projects function together as components of a coordinated Lower Manhattan coastal resilience system.

2. Develop Integrated Resilience Strategies

The Draft Scope proposes evaluating five thematic approaches and advances the Structural on Land and Structural in Water approaches for detailed study while screening out the standalone Engineering with Nature approach.

The City Club appreciates the rationale for comparing different approaches during plan formulation. However, the alternatives as currently framed do not fully reflect how successful climate resilience projects are designed and implemented.

Contemporary waterfront resilience relies on layered systems that integrate structural protection, nature-based features, interior drainage, green infrastructure, transportation improvements, and high-quality public space. These strategies are complementary rather than competing. Treating Engineering with Nature as a separate alternative, rather than integrating nature-based solutions into the structural alternatives, risks overlooking opportunities to improve ecological function, reduce environmental impacts, and enhance the public realm.

The Final Scope of Work should evaluate whether integrated resilience strategies combining structural and nature-based approaches could better achieve the projectʼs stated objectives while reducing environmental impacts, construction costs, implementation timelines, or other tradeoffs. In particular, the EIS should explain how Engineering with Nature measures will be incorporated into the structural alternatives; evaluate opportunities to reduce unnecessary encroachment into the East River while maintaining flood protection objectives; enhancing rainfall absorption, and storage, maximize publicly accessible waterfront and open space; and identify opportunities for habitat restoration, biodiversity, and ecological enhancement consistent with the goals of the FDSCRMP.

The planning horizon should extend beyond the currently proposed 50-year timeframe. Major public infrastructure investments made today should be expected to serve the city for a century or more. Accordingly, the EIS and project design should evaluate conditions at 100- and 150-year horizons to ensure that todayʼs investments remain resilient, adaptable, and cost-effective under accelerating sea level rise and changing climate conditions.

For every measure and alternative, the Integrated Interim Report should publish the screening criteria, definitions, underlying data, ratings or scores, thresholds, weights, cost basis, uncertainty, and reason for advancement or elimination. It should identify the nonstructural, Engineering with Nature, drainage, transportation, and public-realm components included in each structural alternative and test whether reasonable changes in assumptions would change the final array or Tentatively Selected Plan. The report should distinguish the formal 50-year economic period from the longer service life of major structures, test performance at least through 2100 and over each componentʼs expected life, and identify the cost, feasibility, lead time, and trigger for future adaptation. Designs that foreclose later options or transfer risk should be identified explicitly.

3. Measure Project Performance, Not Simply Environmental Impacts

The Draft Scope appropriately emphasizes identifying environmental impacts and mitigation measures across a broad range of resource categories. While this analysis is fundamental to NEPA review, FiDi FORGE is intended to accomplish far more than avoiding adverse impacts.

The environmental review should also evaluate how effectively each alternative achieves the projectʼs stated objectives and the broader goals established in the Financial District and Seaport Climate Resilience Master Plan. Including measurable performance criteria would provide a more transparent basis for comparing alternatives and understanding the tradeoffs among them.

The EIS should also clearly identify the design standards, climate assumptions, and sea level rise scenarios used to evaluate project performance and explain how the proposed system can be adapted over time as climate science and flood risks evolve.

4. Strengthen the Transportation Analysis

The Draft Scope identifies maintaining transportation connectivity as one of the projectʼs principal objectives and includes transportation among the technical analyses proposed for the EIS.

The Final Scope should require an operating-performance analysis for ferries, subways, buses, roads, pedestrians, bicycles, freight, emergency vehicles, and maritime services. The analysis should disclose current and future service, passenger and freight volumes, berth and terminal capacity, accessible routes, transfer patterns, and network dependencies. Alternatives should be compared using a bounded set of measures: passenger throughput, berth availability, accessible transfer time, street and greenway continuity, service-interruption duration, emergency and evacuation capacity, and time to restore operation. Hydrodynamic and navigation analysis should quantify changes in currents, maneuvering conditions, and access to maritime facilities during construction

and operation.

Included in the analysis should be studies of how proposed changes to the shoreline will impact the currents of the East River and how changes in currents will impact maritime navigation.

The analysis should include options to increase connectivity with the existing street grid to enhance pedestrian access and visual and physical continuity, taking into account the NYC landmarked Street Plan of New Amsterdam and Colonial New York.

5. Strengthen the Analysis of Stormwater Management, Interior Retention and Drainage, and Emergency Response

The Draft Scope appropriately includes Water Quality and Stormwater Management as a technical resource category. However, the proposed methodology focuses primarily on potential impacts to existing infrastructure rather than evaluating how each alternative improves stormwater management and interior drainage capacity.

The Final Scope should require a defined compound-flooding test matrix pairing rainfall, tide, coastal surge, sea-level rise, and groundwater conditions, with the timing relationship among those hazards stated explicitly. The EIS should state whether collection, sewer conveyance, storage, gates, pumping, outfalls, and operating controls are unified, coordinated but separate, or independent by project area. The Integrated Interim Report should disclose model boundaries, calibration and validation, rainfall distributions, wastewater inputs, boundary conditions, assumptions about adjacent projects and interceptor gates, and uncertainty. It should test blocked outfalls, gate nondeployment, power loss, pump outage, and conveyance failure and report flood depth, extent, duration, sewer surcharge, combined-sewer-overflow volume, and recovery time. Pump analysis should identify capacity, redundancy, backup power, discharge constraints, maintenance access, and operating responsibility.

Similarly, the Draft Scope references emergency access as one of the projectʼs objectives but provides relatively little discussion of how the alternatives will support emergency response and evacuation. The EIS should evaluate how each alternative affects emergency vehicle access, maritime evacuation, ferry operations during emergencies, and the resilience of critical transportation infrastructure.

6. Establish a Framework for Long-Term Governance, Monitoring, Adaptive Management, and Financial Sustainability

The Final Scope should require an asset-responsibility matrix identifying the owner, operator, maintainer, emergency decision-maker, and funding source for each floodwall, gate, pump, conveyance element, outfall, ferry facility, public space, and project tie-in. The report should state activation thresholds, command and communications protocols, inspection and testing requirements, backup-power arrangements, replacement schedules, and the process for modifying interfaces as adjoining projects or climate conditions change. Lifecycle comparison should include capital cost, contingency, operations, energy, major renewal, adaptation, and the fiscal consequences of delayed or incomplete funding. Public monitoring should be limited to the performance measures used to justify the selected plan.

The EIS should evaluate each alternative using lifecycle financial analysis rather than initial construction cost alone. Capital costs, operating costs, maintenance obligations, long-term repair needs, anticipated funding sources, remaining funding gaps, and long-term financial responsibilities should all be compared as part of the alternatives analysis. Given the scale of the proposed investment, the analysis should also identify the long-term fiscal implications for the City and discuss how funding commitments to this project may affect the Cityʼs ability to address resilience needs in other vulnerable neighborhoods.

Finally, the Final Scope should establish a long-term monitoring framework with publicly available performance measures for flood protection, ecological conditions, infrastructure performance (including CSO discharges, public access, and public use) so that project effectiveness can be evaluated over time and management strategies refined as conditions change.

7. Maximize Public Benefits

Throughout the Draft Scope, the methodologies emphasize identifying adverse impacts and mitigation measures. The City Club encourages the Final Scope to give equal attention to evaluating the public benefits each alternative is intended to deliver.

The EIS should assess how each alternative expands publicly accessible waterfront, improves the quality and usability of public open space, strengthens ecological systems, restores habitat, supports community programming, preserves historic resources and their character-defining elements, preserves significant views, improves accessibility for people of all ages and abilities, and contributes to the long-term vitality of Lower Manhattan.

Finally, because construction is anticipated to extend over approximately a decade, the EIS should include a consolidated analysis of cumulative construction impacts on neighborhoods, businesses, schools, transportation systems, cultural institutions, public health, and waterfront access, together with clear mitigation measures that minimize disruption throughout the construction period.

The analysis should also evaluate construction sequencing and identify opportunities to phase work in ways that preserve neighborhood access, support local businesses, maintain maritime and emergency response capabilities, minimize disruption to existing public spaces and waterfront activities, and reduce cumulative impacts over the duration of construction.

Conclusion

The City Club appreciates the significant effort that has gone into developing the Draft Scope of Work and recognizes the importance of carefully evaluating strategies to address increasing coastal flood risks in Lower Manhattan. Because FiDi FORGE represents one of the largest and most consequential public infrastructure investments proposed for New York City, the Environmental Impact Statement should provide a transparent, comprehensive, and objective evaluation of the projectʼs alternatives, impacts, costs, benefits, and long-term implications.

A robust EIS will enable decision-makers and the public to better understand the tradeoffs among alternatives and help ensure that any future investment is well-founded, environmentally responsible, and in the public interest.

Thank you for your consideration of these comments.

Sincerely,

The City Club of New York Waterfront Committee Co-Chairs

Tom Fox John Shapiro

Trustee Vice President