Save Battery Park City's Trees

Dear BPCA Board and Leadership, I am a Battery Park City resident. I support the North/West Resilience Project — but I am asking BPCA to pause all tree removal until the following three steps are completed. The current plan removes 435 mature trees — nearly 40% of every tree in the project area. These are 40-year-old trees that provide shade, absorb stormwater, and define the neighborhood. Of those 435, only 17 are being considered for transplanting — less than 4%. The rest will be cut down. BPCA has never classified which trees are genuinely in the path of the wall and which could be preserved. Without that analysis, there is no basis for concluding that every removal is necessary. Three steps would establish that basis: 1. File a USACE Vegetation Variance Request. The federal guidelines BPCA cites include a formal process for preserving trees near flood infrastructure. BPCA has never applied — and has never even contacted the USACE New York District about a variance. The Draft EIS committed to exploring the variance process; that commitment was struck from the Final EIS without explanation. Let the Army Corps' own specialists determine which trees can safely remain. 2. Publish a tree-by-tree removal classification. For each of the 435 trees marked for removal, disclose whether it is: (A) in the floodwall footprint, (B) within the 15-foot zone — a variance candidate, (C) in a temporary construction area — a transplant candidate, or (D) being removed for other reasons. Without this breakdown, the public has no way to evaluate which trees could be saved. 3. Submit the classification to independent review. Have the tree-by-tree assessment reviewed by qualified arborists and flood engineers who are not employed by BPCA's design-build contractor — professionals with no financial stake in the current plan. When the Wagner Park community hired the park's original designers, they proved a tree-preserving alternative was feasible. Residents deserve the same transparency here. The variance process is not theoretical. In Sacramento, the USACE approved a vegetation variance covering 42 miles of levees — one of the first ever granted — allowing trees to remain alongside flood infrastructure. In Idaho, the same 15-foot rule BPCA cites was challenged on a levee lined with mature pines; only dead trees were removed and every healthy tree was preserved. The 15-foot rule itself was reversed nationally in 2014 after Congress found it lacked site-specific engineering justification. BPCA has not even attempted this established pathway. We are not asking BPCA to stop the resilience project. We are asking BPCA to stop cutting trees until it has proven — tree by tree, with independent verification — that every removal is necessary and every alternative has been exhausted. Floodwall construction can proceed in sections that don't require tree removal while this assessment is completed. Thank you, [Your Name] [Your Address in Battery Park City]

Good afternoon resident, Thank you for writing, and for your support of the North/West Battery Park City Resiliency Project (NWBPCR). The vital work now underway will protect our neighborhood against the threat of storm surge and flooding resulting from heavy rains and sea level rise. Nearly 14 years since Superstorm Sandy claimed 44 lives, including one here in Lower Manhattan, and after five years of community input on project design across dozens of public engagement sessions, we’re glad to be delivering a more resilient downtown with our part of New York City’s overall Lower Manhattan Coastal Resiliency Project. As to your specific concerns here, we’re glad to note that NWBPCR will result in a net increase in the number of trees in Battery Park City. Battery Park City has more than 1,700 total trees across its 92-acre site. As we have articulated over the course of our public engagement, it is, unfortunately, necessary to remove some of these trees to effectuate building of the NWBPCR flood barrier system (FBS). Additionally – and unrelated to the Authority’s resiliency work – a number of trees require removal due to poor health. The project team has worked diligently to minimize tree removals to the greatest extent possible, and our approach for the planting of new ones will prioritize diversity in species, age, and size to cultivate a more sustainable urban tree canopy. More detailed information regarding tree removal is reflected in the bullets below. Following that are some more specific answers to your questions. The NWBPCR Final Environmental Impact Statement (FEIS) contemplated a net increase in the number of trees pre vs. post construction – a total of 435 existing trees to be removed and 450 new trees to be planted – a +15 net increase. 40 of these tree removals are “conditions” removals – meaning trees in poor health that would have required removal even without any resiliency work occurring. In its post-FEIS Technical Memorandum (December 2025), the Authority noted an increase in the estimated number of trees requiring removal with a corresponding increase in the estimated number of new trees to be planted. The result was a greater net increase in new trees planted – a total of 500 existing trees removed (+65 from FEIS) with 525 new trees planted (+75 from FEIS) – a +25 net increase. The majority of the increase of removals that were noted in the 12/25 Tech Memo – 50 of 65 trees – are located outside Battery Park City, along the Route 9A median. The balance, mostly in Reach 6 (South Esplanade), are required to be removed to accommodate a combination of FDNY ambulance access, hydrant removal/installation, utilities conflicts, or grading/draining requirements. The Tech Memo also noted that in the South Cove area of the project, where construction work recently began, five fewer trees (30) would require removal than the 35 contemplated in the FEIS. Has each tree been individually assessed? How many of the 435 actually fall within the required clearance zone? Which could remain with modified wall alignments? Each tree in the project area was assessed for removal, protection, or transplantation. What design alternatives were evaluated for tree-adjacent sections? The project already uses deployable barriers at multiple locations — were similar approaches considered where they could preserve mature trees? The alternatives analyzed are set forth in the Alternatives Chapter of the FEIS. NWBPCR has been designed to minimize tree clearing to the extent possible. As a general matter, trees have been designated for removal due to construction either because they are located within the limits of work or because they are sufficiently close to such areas that the root zones of the trees would be impacted. It is instructive to note here that, in comparison to typical wall construction, the flood barrier system (FBS) includes substantial underground elements, including drilled pile foundations and seepage barriers that extend below the surface. To protect the structural integrity and function of the FBS from detrimental effects of vegetation (for example, root intrusion, falling limbs or trees, or blocking inspection and maintenance access) all trees must be kept at a minimum distance from the system’s wall and gates. This distance is determined through careful analysis of the system’s vulnerability such as the type of foundation used, proximity to operable/deployable elements, exposure to wave impact, and elevation at each site – as well as the species and size of the proposed trees, their growth habits, and their tolerance to flooding, wind, and salt exposure. This analysis will also be part of the overall process for flood protection certification. Has BPCA explored the USACE Vegetation Variance Request process? Federal guidelines include a formal mechanism for preserving vegetation when site-specific analysis supports it. Has this been pursued? If not, why not? The US Army Corps of Engineers Guidelines are not directly applicable to NWBPCR because it is not a USACE project, so no variance has been or needs to be sought. As discussed in the FEIS, 60 replacement trees will be planted within the 15-foot USACE “buffer” zone as part of the project. Has BPCA considered transplanting trees that must be removed during construction and returning them afterward? Other US cities have done this successfully — Phoenix's Central Station redevelopment relocated 20 mature trees during construction, and Stanford's Packard Children's Hospital boxed and stored 12 protected oaks and redwoods for replanting. If transplanting has not been evaluated, why not? Tree transplantation has been considered, and a total of 7 trees within the project site identified will be transplanted. Considerations that impact tree suitability for transplant include: Species, Size (smaller is better, larger trees are harder and more expensive to transplant and are less likely to survive the process), Overall tree health, Suitable location to be transplanted to. How does removing 40-year-old canopy — and replacing it with saplings that won’t match its stormwater, cooling, and carbon benefits for decades — serve a project whose purpose is resilience? NWBPCR will provide for a diversity in tree age at the time of planting. Approximately one-third of the trees proposed to be replanted along the Esplanade and throughout Battery Park City will range from 4- to 8-in trunk caliper, which means that these trees will be several years old at the time of planting (i.e., not young saplings). The balance will be 3-in caliper or are multitrunk species and thus are not measured by trunk diameter, but rather by height, which is anticipated to be 8ft to 14ft at time of planting. Tree purchases will be timed to allow for uninterrupted growth in nurseries before planting occurs. Thank you again for writing, and for your support of our coastal resiliency work. For regular updates please subscribe to our biweekly construction newsletter, and please send any project-related questions to: nwbpcrinfo@bpca.ny.gov or (917) 436-6739. Sincerely, Michael Michael Ryan Community Construction Liaison