Comments from The Nature Conservancy on How To Protect Long Island’s South Shore
We’re urging the Army Corps of Engineers to work with nature’s dynamic systems to protect people and nature.
As so many of us find solace on beaches and in forests, The Nature Conservancy is also thinking about how best to preserve them for the long term. Our comments to the Army Corps of Engineers on how to protect Long Island’s South Shore highlight the importance to people and nature of working with nature’s dynamic systems, rather than against them.
A portion of comments by Stuart F. Gruskin, Chief Conservation and External Affairs Officer for The Nature Conservancy in New York, is included below; the full version can be found here.
Thank you for the opportunity to provide comments on the Fire Island to Montauk Point Reformulation Study (FIMP) and the associated Final Environmental Impact Statement (FEIS). The Nature Conservancy is a global environmental nonprofit organization working to create a world where people and nature can thrive. We thank the Army Corps of Engineers for the investments you have made and committed to assist the south shore of Long Island to cope with coastal storms and offer the following suggestions for ways that the FIMP plan can ensure that both people and nature will thrive long into the future in this changing world.
Examination of the Alternatives:
- The Nature Conservancy commends the Army Corps of Engineers on excluding levees, floodwalls, and seawalls from the final plan because they are not economically viable, due to the mainland site constraints, and generally not supported by sponsors and stakeholders since they have limited effectiveness against non- storm flooding and potential for negative impacts to nature and quality of life.
- Table 2-5. Summary Comparison of the Alternatives: The description of impacts on wetlands is not scientifically accurate. Dynamic coastal habitats such as tidal wetlands require the tides to come in and the tides to go out. They also need to experience episodic storm events. These are part of the natural way that coastal habitats respond to changes in the environment and maintain themselves. The summary describes the “risk of coastal storms to wetlands” and a “net positive impact to estuarine and forested wetlands by reducing barrier island breaching and overwash,” however these systems function and remain viable into the future is exactly the reverse. Coastal habitats require the sediment dynamics provided by these natural processes, like barrier island breaching and overwash and even episodic storm events, to respond to future sea level rise and future storms superimposed on top of those higher base sea levels. As such, muting or reducing these natural dynamic events is a net negative, not positive, impact.
- Discussions of impacts to vegetation don’t take a long enough view to be meaningful. The text suggests that overwash and barrier breaches damage vegetation. While this might be true in the immediate aftermath of a breach or overwash, the long-term trajectory of these systems is improved if the sediment moved with those events allows the vegetation to recolonize on a higher elevation plane.
- After several years of experience monitoring and studying the breach in the Wilderness Area of Fire Island, all projections of minimal negative impacts and improved water quality have been proven correct. There is accordingly no reason to continue to hold open the possibility that it should be intentionally closed during the study period for this plan. Fundamentally, in the interest of protecting development, this plan disrupts the natural barrier island evolution throughout the island; at a minimum the natural processes should be left alone to achieve their natural functions in the undeveloped wilderness area.
- The overall breach policy must be based on science, and not arbitrary measurements or even more arbitrary waiting periods. The barrier islands of the south shore of Long Island have been studied for many years. We already have good information about where breaches are most likely to happen (for example
see the USGS Coastal Change Hazards Portal). The time between now and the next catastrophic event should be spent studying the potential impacts of new breaches, in the high likelihood locations, on factors such as water level, sediment transport, and water quality. This will provide the information necessary to make evidence-based decisions about new breaches that occur in the future.
- Additionally, it makes absolutely no sense for this static plan to be the definitive word on breach management for 30-50 years into the future – we can be certain that given an environmental response plan with that timeline will fail. Consistent with good adaptive management principles, the breach management plan should be revisited periodically, and the management of these events must be guided by science that holistically weighs the costs and benefits of barrier island evolution and further coastal process manipulation. Significantly, New York State is better suited to manage this evolving process, consider local needs and new information, and mobilize important scientific investigations when necessary.
The Nature Conservancy is a global conservation organization dedicated to conserving the lands and waters on which all life depends. Guided by science, we create innovative, on-the-ground solutions to our world's toughest challenges so that nature and people can thrive together. We are tackling climate change, conserving lands, waters and oceans at an unprecedented scale, providing food and water sustainably and helping make cities more sustainable. Working in 79 countries and territories, we use a collaborative approach that engages local communities, governments, the private sector, and other partners. To learn more, visit www.nature.org or follow @nature_press on Twitter.