City of Boston USACE Comment Letter

Read the City of Boston public comment letter on the U.S. Army Corps of Engineers (USACE) Draft Integrated Feasibility Report and Programmatic Environmental Assessment. 

The City sent a letter that explains three main things:

1. Where we agree with the U.S. Army Corps of Engineers (USACE) Draft Feasibility Report.
2. Where we want our partnership with USACE to go next.
3. Where we think federal policies and practices need to improve as we work toward building the projects in USACE’s Action Plans.

No action is not an option

We agree that Boston needs action and federal investment. We support USACE’s findings on coastal flood risk, including their estimate of at least 42 inches of sea level rise. We also agree with the economic findings showing Boston could face at least $54 billion in damages by 2090 if we do nothing. With a return of $4 for every $1 spent, the case for federal investment is strong. Because of this, we agree that Action Plan 1 - No Action is not an option for Boston.

Boston is already taking action

Over the past 10 years, Boston has built $48 million in coastal resilience projects and is currently building $32 million more. We also have $59 million in projects planned for the next five years. We know the non‑federal share of the full plan—at least $3.5 billion—would be our biggest investment ever, and we are exploring every possible funding source. The Boston Green Ribbon Commission is creating a Coastal Resilience Financing Blueprint to inform how the non-federal share can be funded. We are also working with state agencies to coordinate plans and funding. Our goal is to keep protecting our neighborhoods, infrastructure, and economy while improving our waterfront for future generations.

We Need Both Action Plan 2 and Action Plan 3

We agree that Moakley Park (Action Plan 3) is an Early Action Project and cannot wait for federal funding. But Moakley Park alone does not protect the whole city. It only protects one neighborhood from one flood pathway. A Comprehensive Plan (Action Plan 2) is needed to close major flood gaps across Boston’s 47‑mile coastline. We ask USACE to commit to a process and timeline to move the rest of Action Plan 2 projects beyond 10% design and toward future federal approval and funding.

Detailed Feedback on Action Plan 2

All Neighborhoods

We need more information about how to support areas that would still face flood risk even with USACE’s recommended projects built. Across Charlestown, East Boston, Dorchester, and South Boston, about $13 billion in damages from “residual risk” remain.

Charlestown

We prefer CH3A instead of CH3. CH3A protects the full perimeter from the Navy Yard to Little Mystic Channel and should be extended to protect the Charlestown Community Center. CH3 leaves out hundreds of properties and puts Chelsea Street—an important evacuation route—at risk of flooding.

Dorchester

We agree with DOR1, DOR2, DOR3, DOR4, and DOR6. These match the City’s Coastal Resilient Solutions Dorchester plan and community input.

Downtown/North End

We prefer DT3, not DT3A. DT3A would close Commercial Street at Sargent’s Wharf, blocking a key evacuation route. DT3 keeps emergency access open by continuing the line of protection along the waterfront.

East Boston

We prefer EB2, not EB2A. EB2A would put a floodwall in the middle of Route 1A, causing traffic bottlenecks and doubling evacuation times. EB2 protects the full coastline and all lanes of Route 1A.

We support EB3A, with changes. We request a fully waterside alignment along Border Street and New Street, matching the City’s Resilient Border Street Waterfront Project. We recommend removing the interior floodwall and using the City’s waterside design.

South Boston

We prefer SB3, not SB2. SB2 does not include the City’s resilience plans for the Raymond L. Flynn Marine Park. SB3 provides full perimeter protection for this important industrial and maritime area and has a strong Benefit‑Cost Ratio of 1.5.

We also need early coordination on planning for the Fort Point Channel Storm Surge Barrier. We need USACE’s help to connect ongoing projects—like the Boston Children’s Museum’s improvements and the City’s interim deployable barriers—to long‑term plans.

Overall Partnership Needs

Streamlined Funding

We are committed to exploring all funding options—federal, state, local, and regional partnerships—to support USACE‑compatible design and construction. We also intend to soon begin discussions about long‑term operations and maintenance, which are essential for protecting our shared investment.

Hybrid Infrastructure

Our goal is to be a global leader in hybrid infrastructure that blends built structures with natural systems. The current plan focuses mostly on stone and concrete. We want clearer guidance on how wetlands, living shorelines, and stormwater improvements will be incorporated into the proposed infrastructure. We also request more pilot projects that use natural and nature‑based features.

Integration with Stormwater

We will continue to advocate for more federal funding for drainage projects. Coastal flooding and stormwater flooding are connected problems, and we believe federal policy should support solutions that address both together.

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