Mr. Dennis Reinknecht, Program Manager
New Jersey Department of Environmental Protection (NJDEP)
Bureau of Flood Resilience
501 East State Street, Mail Code 501-01A
P.O. Box 420
Trenton, NJ 08625-0420
Dear Mr. Reinknecht:
Environmental Review, Inc. has reviewed the New Jersey Department of Environmental Protection (NJDEP) Final Environmental Impact Statement for the Rebuild by Design, Hudson River Project, dated June 2017, and has the following comments:
1) Chapter 4.0 Development of Alternatives: The Final EIS compares three alternatives that address both storm surge and rainfall flooding in the project area. The alternatives differ in the alignment and general nature of the storm surge barrier but have the same approach to addressing rainfall flooding and combined sewer/stormwater overflow.
The funds allotted to the project are inadequate to implement the preferred alternative and the proposed project will proceed by implementing only the storm surge barrier. The response to public comments (Appendix C; page C-2) recognizes that the remainder of the preferred alternative will be implemented over the next 50 years.
Given that the available funds are only adequate to implement either the storm surge barrier or the inland drainage upgrades, the alternative analysis should really compare the storm surge barrier to the drainage upgrades. If the time horizon for constructing the preferred alternative is about 50 years, the project area is likely to experience 5 to 10 inland flooding events (given they occur during a five to ten year rainstorm) but may not experience storm surge flooding, given its relatively infrequent occurrence.
It would seem that the greater benefit for the long time horizon for implementation is to address the more frequent flooding event. This is particularly true when the lower cost and water quality benefits from improving the combined stormwater/sewer system are considered.
2) Chapter 3.1 Goals and Objectives: Goal: Contributing to On-going Community Efforts to Reduce FEMA Flood Insurance Rates: The proposed project will construct a storm surge barrier but will not address inland rainfall flooding (internal drainage). The FEIS does not demonstrate a reduction in the FEMA flood hazard areas from construction of the storm surge barrier and, as a result, it does not support claims that the project, as will be constructed, contributes to reduced rates.
Given that storm surge and other calculations have been completed, this section would benefit from an analysis of the expected benefits, showing the areas where reduced insurance rates might apply, and the time frame before the reductions occur seems to be required. Given the very long time frame before implementation of the other components of the package, it is difficult to see any actual benefit.
Sincerely yours, Ken Rood – Environmental Reviewer, Environmental Review, Inc. P.O. Box 2756, Berkeley, CA 94702