Trees are already being cut down. BPCA has never even applied for the federal variance that could save them.
Trees in south Battery Park near 3rd Place are already gone — and this is just the beginning. Send an email demanding a pause until every alternative has been evaluated.
Or scroll down to copy the email text and send from your email account manually.
What's happening?
BPCA is removing 435 mature trees[1] (~40 years old) and planting 450 new saplings.[1]Cutting has already started — trees in south Battery Park near 3rd Place are already gone.[13] BPCA classified this as "no significant adverse impact"[2] because the replacement count is slightly higher.
That's 37% of every tree in the project area destroyed.[2] Of those 435, BPCA is considering transplanting just 17 — less than 4%.[1] The remaining 418 will be cut down, in a project with a $1.6 billion budget.
BPCA can save these trees.
The same Army Corps regulations they cite include a built-in process — the Vegetation Variance Request — that allows trees to be preserved when site-specific analysis supports it.[4]BPCA never filed one.[6] Their own Draft EIS committed to exploring the variance process — but that language was struck from the Final EIS.[7]
BPCA lumps all 395 healthy tree removals into one category: "project construction."[1] But not all removals are the same. Some trees are in the wall footprint. Some are in the 15-foot zone. Some are in temporary staging areas. Some are being cut because building around them costs more. BPCA has never disclosed which trees fall into which category — making it impossible to identify which ones could be saved.
A mature canopy tree intercepts 1,000+ gallons of stormwater per year, provides cooling, carbon capture, and habitat. A sapling won't match that for 20-30 years. Removing mature trees in a resilience project is a step backwards.
Communities have stopped this before
Sacramento, 2025 — Army Corps planned to cut 700+ trees for levee work. A federal judge blocked all cutting after the community proved alternatives weren't explored.
San Antonio, 2022 — City planned to remove 105 trees for park renovation. Community pressure cut it to fewer than 50 — more than half saved.
Nationwide, 2014 — The Army Corps had a policy requiring tree removal within 15 feet of levees — the same rule BPCA is citing now. It was reversed after communities and environmental groups pushed back.
Coeur d'Alene, 2012 — Army Corps ordered 1,000+ mature pines removed from a levee. The community fought back, and only dead trees were removed. The rest were saved.
Virginia, 2024 — The National Park Service was already cutting trees when the community caught it and mobilized. All removal was halted. It's not too late.
Full email text
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]
Subject:Pause Tree Removal Pending Assessment — North/West Resilience Project
Also contact these officials
These leaders have direct influence over BPCA or the federal rules it cites — but only accept messages through their websites. Take 2 minutes to send each one a note asking them to intervene.
BPCA Final EIS — Response to Comments (May 2025) — Table 10-1: 435 trees removed, 450 planted, per-reach breakdown; ~395 due to construction, ~40 due to health; deployable barrier locations; USACE vegetation policy discussion
BPCA Final EIS — Executive Summary (May 2025) — ES-17/18: tree removal and replacement summary; DEIS commitment to explore FEMA variance process struck from Final EIS (visible in strikethrough text)
BPCA — Tree Impacts and Planting (July 2024) — per-reach tree impact maps showing each tree marked for removal, transplanting, or retention; before/after renderings at 5 and 10-15 years