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Bloomberg Mayor, City of New York City Hall New York, NY 10007 Dear Mayor Bloomberg: Given the unprecedented impact of Hurricane Sandy, it is clearer than ever before that we need to carefully consider how and what we build along our waterfront. The unexpected flood levels experienced during Sandy combined with the anticipated rise in sea levels only makes these challenges more severe. Abiding by the strictest definition, Hurricane Sandy was technically not a true hurricane. The sustained wind speeds recorded by the time the storm made landfall in New York were below that of a traditional category 1 hurricane. Hurricane Flood Zone A, which we previously understood to be the designated perimeter for likely flooding during such storms, was unexpectedly overrun by a storm that was, in some ways, less powerful than a traditional category 1 hurricane. The affects of Sandy overwhelmed our understanding of traditional hurricanes and therefore undermines the system by which we estimate the likely impacts of such storms. It is now apparent that our conventional understanding and therefore our expectations of such storms are no longer accurate. We cannot continue to believe with confidence that we are able to accurately predict and classify flood zones of our waterfront in anticipation of future storms. Among the many concerns this raises for the City is our need to carefully rethink how and what we build along our waterfront. The new reality of storm behavior in NYC brings into question some of the City’s planned construction projects along our waterfront, including the East 91st St. Marine Transfer Station (MTS). Situated on the East River, in the middle of Hurricane Flood Zone A, the already long list of concerns raised by this project has lengthened and become more pressing than ever before. The location’s viability in relation to potential storm damage, which we have questioned in the past, is now is an even more urgent concern. The surrounding community near East 91st St. as well as the larger collection of communities potentially serviced by the MTS, would be well
served to gain a better understanding of how the City plans to address the additional concerns brought to light in recent weeks. In addition, following Sandy, the Coast Guard closed New York Harbor to fuel tankers, partially out of fear that floating debris (storage containers etc.) presented a hazard to such vessels. This is considered a major contributor to the gas crisis following the storm. It is not unimaginable that such massive objects adrift in the harbor and rivers could pose a future threat to river and harbor activity. This fact raises additional questions about a potential MTS in a flood/surge area on the east river. Our expectations of flood damage were exceeded during Sandy. Given this information, it is safe to assume we no longer have a full understanding of potential flooding in the future. Based on these concerns, I am requesting a response to the following questions regarding the safety of the MTS in tropical storm or hurricane conditions: Could the proposed MTS be at risk of damage from large drifting objects as the Coast Guard deemed dangerous for large vessels post-Sandy? Could garbage containers from the MTS be knocked into the river during a storm, causing hazardous conditions for vessels? Have plans for the MTS taken into account such possibilities? In the event that storms similar to or more severe than Sandy were to strike NYC and cause damage to the East 91st St. MTS, how would the City handle/respond to the following possibilities? Would flooding of the MTS cause garbage contaminated water entering basements and first floor homes to be more harmful than the flooding endured during Sandy? Why or why not? Please review the attached photo’s of the site during Sandy flooding. Would additional preparation be necessary in the event of evacuation and relocation of displaced residents in anticipation of waste contaminated flooding? How would DSNY handle garbage removal and transport in the event that the MTS suffered debilitating damage during a storm or was out of commission for an extended period of time? Would such methods be more or less expensive than projected utilization of the MTS or our current system? Does the City anticipate any design alterations, following Sandy and the lessons we’ve learned? Would these alterations change the cost of the project? Does the MTS need to be built higher or stronger?
What will be done to prevent containers from breaking lose in the event of high flood waters? If the City does not anticipate any changes: What evidence exists to suggest that alterations are not necessary? Has the City conducted a study to better understand additional risks presented by Sandy? If the City has studied these contingencies already: What alterations are needed to insure that the MTS is safe from floods exceeding Hurricane Flood Zone A? What alterations are being considered and what financial implications do they have on the overall project? Do any of the alterations require additional permits or renewal of previously issued permits? Considering that flooding went beyond Hurricane Flood Zone A during Sandy, will the project be built to address flooding of the Marine transfer station in situation where storms impact Hurricane Flood Zones B or C? Given the new realities of storm behavior identified by Sandy, I am urging your office to consider the many pressing concerns I have outlined in this letter. Please feel free to follow up with Patrick Madigan in my office with any questions you may have prior to responding. Thank you in advance for your time an attention on this matter. Sincerely,
Liz Krueger State Senator Cc: Mr. John J. Doherty, Commissioner DSNY Mr. Marc Ricks, Advisor to the Mayor on Infrastructure