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  NEW YORK STATE SEA LEVEL RISE TASK FORCE REPORT

                                    FIA RESPONSE

 

The New York State Sea Level Rise Task Force was created by an act of the New York State Legislature (Chapter 613 of the Laws of New York ) in August 2007.  The  New York State Department of Environmental Conservation (DEC) was charged with creating a task force to prepare a report on the impact of projected rises of sea level on NYS.  Attached is that report.

Below is the Fire Island Association's comment on the report.   They assert that the process which created the report was deeply flawed, and that the conclusions are not scientifically valid.  The next step in the process is unclear.

                                                                                                                         December 30, 2010

 

Mark D. Lowery

Office of Climate Change

New York Department of Environmental Conservation

677 Broadway, Eighth Floor

Albany NY 12233-1030

 

 

                                                            Comment on the Report of the New York State Sea Level Rise Task Force

Dear Mr. Lowery:

            The Fire Island Association (FIA) represents the interests of the 3550 households in the 17 communities located within the boundaries of the Fire Island National Seashore. Fire Island is the barrier island that protects the south shore of Long Island, from Babylon to the Moriches, from the Atlantic Ocean . The following is FIA’s comment on the draft report on sea level rise issued by New York State Sea Level Rise Task Force.

            The conclusions and recommendations of the Task Force do not seem the considered opinion of qualified coastal scientists and engineers, a group notably under-represented on the task force body. The public is entitled to the benefits of expert knowledge in such reports. This report is apparently the product of an environmental organization with its own agenda; namely, The Nature Conservancy (TNC). In fact, it appears the Coastal Program Division of TNC’s Long Island Chapter seems to have provided staff assistance in formulating and writing the Task Force report. 

            We recognize that DEC has been forced to eliminate hundreds of positions through layoffs and early retirement programs because of the state’s fiscal problems. That is not a reason to turn over preparation of a “task force report” to an interest group with its own agenda. Citizens whose homes and property have been in the crosshairs of TNC and other “pro-environment” groups are especially entitled to full details about the extent of TNC’s participation in the Task Force process, including contribution of staff time, in the formulation or writing of the report. There should be no mistake that this report is part of an on-going effort by TNC and other environmental organizations to roll back development in New York ’s coastal communities.

            Readers of the report should also be aware of other background on this issue. The public should know, for example, that for several decades, damage from coastal storms, damage compounded by failure to mitigate the effects of inlets on shoreline erosion, caused the U.S. Army Corps of Engineers to urge implementation of a Fire Island Inlet to Montauk Point shoreline protection project (FIMP). In 2010, the Corps was seeking opinions of members of the public on the results of a $25 million study designed to lead to that project’s reformulation. Although the project would provide protection to Fire Island communities, and to other easterly Long Island coastal communities all the way to Montauk Point , it has been strongly opposed by TNC and other non-government environmental groups on the theory that protecting the coastline encourages its development. The task force report on sea level rise is the latest manifestation of ongoing opposition to protecting New York ’s developed coastal areas.

            In New York , protecting the coast against storms and, lately, sea level rise, is not a recent problem, and neither are the most effective means of addressing it. More than fifteen years ago, a committee of the National Research Council stated, “Beach nourishment is a viable engineering alternative for shore protection and is the principal technique for beach restoration; …”.[1] When the beach at Coney Island was restored in the 1920s, the nation’s first major beach fill project, Long Island became the leader in beach preservation. Decades later, the rise of the environmental movement gave opponents of beach nourishment reasons to fight to prevent it. Lately, the movement has seized on sea level rise as a reason for doing so. As a result, New York State-Federal cooperation at preserving beaches and coastal communities has all but ended.

            This is borne out in the introduction to the Task Force Report that refers to a 2007 monograph from New York Sea Grant.[2] The Report quotes New York Sea Grant’s Jay Tansky to the effect that “Sea level along New York ’s coast has been rising at the rate of almost one foot per century for at least 100 years.” The report, however, makes no mention of Mr. Tansky’s additional assertion that sea level rise “is of secondary importance compared to other factors operating on shorter, decadal time scales.” The other factors include storms and poor inlet management, which cause beach erosion. Tansky continues, “However, over planning time frames of 30 to 60 years (emphasis added), even increased sea level rise would not significantly change the actual observed rates of shoreline change in those areas experiencing the most severe erosion. On these time scales, sea level rise is of secondary importance compared to other factors in controlling what happens on the coast.”[3] 

            In other words, the Task Force report invokes the words of experts in talking about sea level rise, but makes little effort to place the ideas in the context the experts intended.                   

 

            Well before sea level rise became a new excuse for failure to protect beach communities from storms and erosion, after the severe storms of 1992-93, Governor Mario Cuomo established a Coastal Erosion Task Force. Staffed by experts from a wide array of disciplines, that task force produced a comprehensive and detailed two-volume report that recommended emergency and long-term protective actions needed to protect Long Island’s Atlantic Ocean coastline. Included was an endorsement by the Task Force of the Fire Island Interim Project (FIIP), basically the Fire Island portion of the FIMP. Coastal engineers, employees of the state DEC, were the primary authors of the Coastal Erosion Task Force Report. It remains a common-sense blueprint for using Long Island ’s vast supplies of readily available sand to protect the island’s south shore coastal resources. Those interested in a practical approach to erosion and sea level rise need look no further.

            The Coastal Resources Division of New York ’s Department of State (DOS), nominally co-author of the 1994 Task Force Report, refused to endorse the FIIP, one of its key recommendations, six years later. This may have been because Governor Cuomo had come to rethink the arrangement he had put in place in 1975 when, as Secretary of State, he created the Division of Coastal Resources as part of DOS rather than DEC, the agency in charge of New York ’s shorelines since 1945. The new unit qualified New York for funding under the federal Coastal Zone Management Act of 1972, which continued to provide virtually all of DOS Coastal Resources’ funding for the first decade and more of its existence. But in late 1994, Governor Cuomo’s draft 1995 budget was seeking funds to study whether the DOS Coastal Resources Division might function better as a part of DEC.

            As it happened, the Governor’s draft budget never saw the light of day and his Coastal Erosion Task Force recommendations were not published until October 1994, a few weeks prior to his defeat at the polls by George Pataki. And during his 12 years in office Governor Pataki was in no position to offend organized independent voters, of which environmental groups were and are a leading example. This meant the Interim Plan for Fire Island, and the later reformulated version, extending to Montauk, has had little support in Albany , even though either of those plans would have been two-thirds paid for by the federal government.

            Nevertheless, DEC engineers continued to work with their counterparts from the Army Corps on a plan to protect the south shore. By late 1999, DEC had signed off on a proposed project to implement the Interim Plan and public hearings were scheduled for January 2000.

            Enter TNC. At the hearing at Dowling College on January 12, TNC’s then LI Director of Coastal Programs organized environmental group opposition to the proposed project. While some 70 statements favored the proposal, fewer than 10, from environmental groups, opposed it. Under New York ’s rules, however, DOS is required to find that proposed coastal projects are “consistent” with its policies. When that determination was withheld, without benefit of any formal statement by DOS, the Interim Project was dead, and with it any hope for a rational coastal management program in New York .

            The public has a right to know how sophisticated environmental groups make policy decisions that the public must live with. In the present case, it appears TNC has done so by deciding the issue to be addressed, arranging for creation of a task force, getting involved in the manning of the task force, helping to write its report, and then announcing that “a Task Force” has spoken.  But the TNC position on shoreline management is not supported either by science or experience, and we can hope Legislators are wise enough to send the report back to the drawing board or, better yet, the shredder.

 

Sincerely,                                                                                                                                            

Gerard Stoddard
President - Fire Island Association

---

[1] Beach Nourishment and Protection, National Research Council, National Academy Press, 1995, p. 3.

[2] Long Island’s Dynamic South Shore – A Primer on the Forces and Trends Shaping Our Coast, Jay Tansky, New York Sea Grant, 2007, p. 13.

[3] Ibid.

SEA LEVEL RISE TASK FORCE FINAL REPORT

FIA Directors

The representative of the Mayor's Office who is a member of the Task Force, has sent in a comment, printed by the Task Force, that raises some of the same criticisms that are in our letter and others; namely, poor science. The following appears in the first paragraph of the letter from Adam Freed, Deputy Director of the Mayor's long-term planning office, to Peter Iwanowicz, Acting Commissioner of DEC: "As articulated throughout this process, however, the City has a number of concerns about the recommendations in the draft report, many of which are not supported by thorough scientific, environmental, or cost-benefit analysis or do not recognize the differences between undeveloped areas and densely populated cities." The latest version of the Task Force Report, attached, has the five page letter as an addendum to the Report, at about p. 98.

I have not received any objections to sending the previously distributed FIA letter, and intend to put it in the mail tomorrow.

GS

________________
Gerard Stoddard
LICA/FIA
263 West 20th Street
New York NY 10011
212-929-6415
FI 631-583-7291

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