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PUBLIC TESTIMONY
Testimony by Em Ruby, Advocacy and Policy Coordinator at Riverkeeper
2:29:48
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3 min
Em Ruby from Riverkeeper testifies on nature-based solutions for climate resiliency, expressing support for expanding such solutions but raising concerns about two proposed bills. Riverkeeper opposes Intro 1254, arguing it could undermine efforts to reduce Combined Sewer Overflows (CSOs) in polluted waters and fail to drive meaningful flood mitigation in MS4 areas.
- Riverkeeper supports nature-based solutions for climate resiliency but opposes Intro 1254 due to concerns about its implementation and potential negative effects.
- The testimony highlights the difference between green infrastructure for CSO control and flood risk reduction, emphasizing that the proposed "greened acre" target in MS4 areas may not effectively address either issue.
- Ruby suggests that more thoughtful, coordinated approaches like the Cloudburst and Blue Belt programs are needed for effective flood reduction and pollution control in MS4 areas.
Em Ruby
2:29:48
Good afternoon council member.
2:29:50
I'm Em Ruby, the advocacy and policy coordinator at Riverkeeper.
2:29:54
Thank you chairperson Gennaro and members of the committee for your leadership to promote nature based solutions for climate resiliency.
2:30:01
And I appreciate the opportunity to testify today.
2:30:05
Nature based solutions for climate resiliency are absolutely critical for New York City's adaptation to climate change.
2:30:10
Riverkeeper strongly supports efforts by the council and DEP to expand the use of nature based solutions to address climate threats citywide.
2:30:18
However, we do have some concerns regarding the two bills being introduced today and how they propose to do so.
2:30:24
We oppose intro twelve fifty four.
2:30:27
Riverkeeper appreciates the council's intent to ensure development of green infrastructure in the MS 4 area, and that is a goal which we have supported through the inclusion of GI in the MS4 area in the CSO Consent Order Modification of 2023.
2:30:41
We supported that modification.
2:30:44
However, we oppose this bill as the Greened target goal we believe would undermine DEP's efforts to reduce CSOs in the most polluted waters in the city while failing to drive meaningful flood mitigation and other key benefits to communities within the MS4 areas.
2:31:00
A greened acre is a unit that was created to measure the volume reduction of CSO and is a key target to ensure DEP is meeting its CSO reduction requirements to help remediate the impairments of most New York City waters.
2:31:12
A greened acre of green infrastructure is specific to CSO control for water quality improvement and cannot be used for flood risk reduction, which I believe this bill is attempting to do so.
2:31:23
I know that Deputy Commissioner Lacotta also spoke to this.
2:31:30
Setting a greened acre target in the MS 4 area would result in widely dispersed and poorly planned green infrastructure assets having little benefit either in reducing pollution to waterways or to reducing street flooding.
2:31:42
By setting a mandatory target of 2,400 green acres over ten years in the MS4 area, this legislation will also place a significant burden on DEP.
2:31:50
Currently DEP does not have the resources to meet this target and would have to take funding from the CSO program to do so.
2:31:57
As a result, there is a one to one trade off in which every dollar spent in the MS4 areas decreases the funding for green infrastructure in the CSO areas which could risk DEP falling out of compliance with the CSO consent order.
2:32:11
In order to achieve effective flood reduction and pollution control, green infrastructure in MS4 areas must be thoughtfully deployed in conjunction with gray infrastructure and other assets.
2:32:20
For New York City neighborhoods to use green infrastructure well to significantly reduce street flooding, strategies like the Cloudburst program and the Blue Belt program which we're spoken about today are needed that coordinate resilience on a neighborhood scale.
2:32:33
Installing green infrastructure rain gardens and bioswales will not have the kind of intended flood reduction effect.
2:32:39
While we appreciate the intent of this bill, as written we believe that it would have a significant negative effect including by diverting resources from the city's very successful green infrastructure program in CSO areas while not significantly reducing storm water pollution or street flooding in the MS4 areas.
2:32:55
And we would like to work further with the committee and the chair to find a more effective solution?