Tell the Army Corps: Protect Boston’s Communities and Salt Marshes
Boston’s flood protection plan could shape the future of its neighborhoods—and its salt marshes. Learn what’s being proposed, why nature-based solutions belong in the plan, and how you can make your voice heard before the September 18 comment deadline.
We’ve made it easy to take action! Use NepRWA’s sample comment letter to send your message to the Army Corps. Go to sample comment letter.
The U.S. Army Corps of Engineers (USACE) has released a draft Boston Coastal Storm Risk Management Feasibility Report, which outlines proposed projects to help protect Boston neighborhoods, infrastructure, and natural resources from coastal flooding and sea level rise.
The report does not recommend a specific action plan, and the USACE is seeking public feedback. Now is the time to make your voice heard about the future of your neighborhood!
Today, areas along Boston’s coast already experience flooding during high tide and coastal storms. Sea level rise and increasingly intense coastal storms will raise flood levels, disrupt roads and transit, and threaten residential and commercial properties.
The USACE and the City of Boston have been working together over the last four years to address these anticipated risks.
The report looked specifically at five neighborhoods across Boston that were identified in the Climate Ready Boston reports as being highly vulnerable to coastal storm risk:
- East Boston
- Charlestown
- Downtown/North End
- South Boston
- Dorchester
The report identifies several potential actions for the Neponset/Dorchester area, including:
The recently released draft report includes three scenarios, or “action plans,” including:
- a no-action scenario (Action Plan 1)
- a comprehensive plan (Action Plan 2)
- an incremental levee early actions plan (Action Plan 3).
Only the first design (DOR1) — a floodwall and levee behind Day Boulevard following Moakley Park — is included in Action Plan 3, “Early Action,” and has a completed design.
Due to the study limitations, more design work will be needed to develop the other alternatives.
A key part of this study is the fact that the cost to implement these proposals would be shared between Boston, the state, and the federal government.
Therefore, it is critically important that the draft plan fully reflects the needs of residents and those impacted by Boston’s coastal flooding risks.
The Draft Plan Falls Short on Protecting the Neponset Estuary’s Salt Marshes
The nearly 400 acres of salt marsh help reduce the flood risk to homes, businesses, and transit routes by buffering floodwaters and reducing wave intensity.
The marshes provide habitat for more than 200 species of birds and wildlife, including the Saltmarsh Sparrow, a Species of Special Concern.
Current protections for ACECs require that projects consider the impacts to the environment and minimize any negative impact to these natural resources.
The proposed plans, by creating levees and berms that disconnect the marshes from the upland areas, will limit marsh migration and ultimately doom the marshes to being drowned by rising sea levels and converted to mudflats.
By failing to include nature-based solutions in the future planning for Boston, the Army Corps risks locking us into a future where our salt marshes will be lost, and the many natural benefits they provide for climate resilience will need to be replaced by infrastructure that is expensive to create and maintain.
State of the Neponset Estuary
NepRWA recently completed a two-year study on the current state of the Estuary and how the salt marshes can be part of a climate solution for the region. Read the report.
Take Action!
NepRWA has submitted its own comment letter to the Army Corps outlining our concerns and recommendations. Read NepRWA’s comment letter.
Want to submit your own comment? Use NepRWA’s sample comment letter below as a starting point, adapt it to share your own experiences and concerns, or simply echo the points that matter most to you.
Submit comments through the online comment form here or via email to boston-csfrm@usace.army.mil.
Questions: Email NepRWA River Restoration Director Sean McCanty at mccanty@neponset.org
Sample Comment Letter
[Date]
Mr. Todd Randall
U.S. Army Corps of Engineers, New England District
ATTN: COB CSRM Project Team
696 Virginia Road
Concord, MA 01742-2751
Re: USACE Study for City of Boston Coastal Storm Risk Management (CSRM) Feasibility Study
Dear Mr. Randall,
[I/We] appreciate the opportunity to comment on the City of Boston’s Coastal Storm Risk Management Feasibility Study. The planning conducted through this collaboration between the City, state, and federal governments is critically important to prioritize action areas and minimize the financial and human impacts that future flooding will bring.
[Add a sentence or two about how you are connected to Boston or the Neponset Estuary and why coastal flooding concerns you. For example: “I am a Boston resident in the Lower Mills Neighborhood of Dorchester and am very concerned about increased coastal flooding affecting my property, commute, and/or place of business.”]
This draft plan has many benefits, including addressing known flood pathways and building on work previously done by the City and state. In particular, the proposed action areas of Tenean Beach (Conley St.) and Neponset Circle (MBTA Red Line Bridge to Pope John Paul II Park) are critical to reducing inland flooding that interrupts roadways, the Neponset Greenway multi-use trail, as well as residences and businesses.
However, the draft plan does not do enough to incorporate natural solutions into Boston’s flood strategy. While the plan evaluates several potential nature-based opportunities, it does not carry them forward into the design work. Despite claims that these opportunities could be pursued in parallel, designing only for hard/gray infrastructure could limit or prevent their implementation in future projects.
[I am/We are] concerned about the following factors:
- Excluding nature-based solutions from the design work now may make them ineligible for federal cost sharing in the future. This will place an undue burden on Boston and Massachusetts to cover their cost and make it less likely that salt marsh restoration or living shorelines will be implemented in the future.
- Designing for hard infrastructure alone will restrict the available space for nature-based solutions in the future, limiting future marsh migration potential. This would ultimately doom the salt marshes to eventual drowning and conversion to mudflats in the future.
- The Neponset Estuary is a state-recognized Area of Critical Environmental Concern. This requires that projects within this area minimize damage to the environment. By restricting salt marsh migration, this project will necessarily cause damage to the future extent of salt marshes, which provide wildlife habitat in addition to flood risk reduction. Notably, the Saltmarsh Sparrow, a state Species-of-Concern, is known to breed in the Neponset Estuary and is dependent on healthy saltmarsh habitat.
The Neponset River Watershed Association (NepRWA) has recently completed a two-year study of the Neponset Estuary, including the current conditions of the marsh habitat and modeling of future coastal storm surge and sea level rise. This study has found that restoring and protecting the existing salt marshes can improve flood outcomes for annual storms and monthly tidal flooding. Using the existing salt marsh habitat is an important way to provide resilience to coastal flooding and preserve important ecological habitat.
[I/We] strongly urge you to work closely with the Neponset River Watershed Association to integrate their recent modeling work on how salt marshes can reduce flood risk within the Neponset Estuary section of Dorchester.
Sincerely,
[Your Name, Address]
