Introduction 

The Atlantic Coast of New York is fronted by an effective Federal coastal storm risk management (CSRM) program. However, the Nassau County back bay region currently lacks a comprehensive CSRM program. The Nassau County Back Bays (NCBB) feasibility study investigates CSRM problems and solutions to reduce damages from coastal flooding that affect population, critical infrastructure, critical facilities, property and ecosystems. The purpose of the NCBB CSRM feasibility study is to identify a plan for implementation of comprehensive CSRM strategies to increase resilience and to reduce risk from future storms and compounding impacts of sea level change. The NCBB is one of nine focus areas identified in the North Atlantic Coast Comprehensive Study.

Comment Letter 

October 8, 2021

U.S. Army Corps of Engineers

USACE Philadelphia District, Planning Division, 100 Penn Square E.

Philadelphia, PA 19107

This email address is being protected from spambots. You need JavaScript enabled to view it.

Re: Nassau County Back Bays Coastal Storm Risk Management Draft Integrated Feasibility Report and Environmental Impact Statement

To Whom It May Concern:

Environmental Review, Inc. has reviewed the document and has the following comments:

Comments

1.      The NCBB Environmental Impact Statement contains erroneous wording on the final sentence of page 10. The sentence states Figure ES-4 shows structures to be elevated (red dots) and flood proofed (yellow dots). Figure ES-4, however, does not match the description and only depicts before and after photographs of elevated residential building renderings. The sentence is likely referring to Figure ES-2, which contains the yellow and red dots described. The sentence is erroneous and should be changed from “Figure ES-4” to “Figure ES-2”.

2.      When discussing the impacts of the TSP plan on climate change in Section 5.1, titled Climate Change, the greenhouse gas emission potential of the TSP plan during its construction phase should be included. Section 2.4.4.1, titled Greenhouse Gasses, highlights the substantial impact carbon dioxide emissions have on climate change. Given the TSP plan involves the construction of elevating 14,183 residential structures and the dry flood proofing of 2,667 industrial and commercial structures, which will require extensive construction and transportation of materials, the estimated carbon emission of this plan, or otherwise the acknowledgement of the existence of carbon dioxide emission, should be included in Section 5.1 to provide a more complete analysis of the impact on climate change.

3.     A) Table 3 in Section 2.2.1, titled Critical Infrastructure, contains a numeric error. The Structure Value for the row titled Total, has an incorrect value of $2,189,000. The actual value of the row’s average is $2,188,000. Thus, the value of the total in this row should be changed from $2,189,000 to $2,188,000.

B) Table 3 in Section 2.2.1, titled Critical Infrastructure, contains a numeric error. The Total Value for the row titled Total, has an incorrect value of $3,417,000. The actual value of the row’s average is $3,416,000. Thus, the value of the total in this row should be changed from $3,417,000 to $3,416,000

4.     Table 21 in Section 2.10, titled Navigation, contains a numeric error. The Average for the row titled Number of Unique Vessels, has an incorrect value of 20. The actual value of the row’s average is 20.25. Thus, the value of the average in this row should be changed from 20 to 20.3, rounding to the nearest tenth.

5.     Table 33 in Section 6.5.1, titled Ecosystems and Habitat, contains a numeric error. The Total Impact of Column 3 titled, Unvegetated Estuarine Subtidal Benthic Habitat (LZ), has an incorrect value of 2.97. The actual value of Column 3 is equal to 2.95. The total impact value of this column should be changed from 2.97 to 2.95.

6.     Section ES-3 #3 and 4 page 5: In relation to building walls in front of the critical areas, what

are the hydrologic impacts of the water infiltrating around the walls and the resulting sand and

soil losses?

7.     Table of Contents Lists: The use of a dashes, colons, and periods are inconsistent within these

Lists, consider choosing one and continuing that throughout.

8.     Introduction, 1.8 paragraph 6: The following link is blocked: https://www.longbeachny.gov/bulkhead.

9.     Section 3.4.2 – Water Resources: This section is stating that there will be a rise in ocean

salinity. However, if the ice caps are melting, releasing fresh water into the oceans, wouldn’t

that cause the salinity to decrease? (Rising Sea Level | UCAR Center for Science Education).

When responses to these comments are available, please email those to us at This email address is being protected from spambots. You need JavaScript enabled to view it. and This email address is being protected from spambots. You need JavaScript enabled to view it..

Sincerely,

Kobe Ramirez (Associate in California)
Environmental Reviewer 

Environmental Review Workshop

(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Organization)

1792 Rogers Ave, San Jose, CA  95112

Laura Macklin (Associate in Arizona)
Environmental Review Coordinator

Environmental Review Workshop

(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Organization)

1792 Rogers Ave, San Jose, CA  95112