DISTRICT OFFICE

2015 STILLWELL AVENUE

BROOKLYN, NEW YORK 11223
(718) 307-7151
FAX: (718) 996-1300
CITY HALL OFFICE
250 BROADWAY
SUITE 1776
NEW YORK, NY 10007
(212) 788-7045
FAX: (212) 788-7769

mtreyger@council.nyc.gov

CHAIR
RECOVERY AND RESILIENCY

COMMITTEES
AGING
EDUCATION

THE COUNCIL
OF
THE CITY OF NEW

LAND USE
PARKS AND RECREATION
LAND USE

YORK

MARK TREYGER

SUB-COMMITTEES
PLANNING, DISPOSITIONS, AND CONCESSIONS

COUNCIL MEMBER, 47TH DISTRICT

BROOKLYN

January 16, 2015

Hon. Mitchell Silver
Commissioner
Department of Parks and Recreation
830 Fifth Avenue
New York, NY 10065
Dear Commissioner Silver,
The community strongly feels you are ignoring public safety concerns that have arisen
after Hurricane Sandy by proceeding with a Bloomberg-era, post Hurricane Sandy plan to convert
the historic Riegelmann Boardwalk into a concrete roadway. This despite our repeated requests
for the city to perform an Environmental Impact Statement so that safety can be assured.
You have allowed construction to begin despite our repeated requests not to proceed
without a proper environmental review. That is unacceptable and irresponsible. As we have
repeatedly stated, there have been no engineering or scientific reviews to determine if concrete
slab construction will exacerbate storm surge impacts to residences and businesses that are
adjacent to the boardwalk.
Furthermore at the December 30th meeting you were asked if the Parks Department was
going to stop construction to allow the safety report to which you responded "no," stating that you
were not legally required to. This was extremely disconcerting.
The Department of Parks and Recreation (DPR) has a history of ignoring this community
and dismissing their concerns. The community alerted your department to extensive beach
erosion, including the likelihood of severe storm surge flooding, prior to Hurricane Sandy
(documentation provided upon request) and nothing was ever done. Now the DPR is continuing
to dismiss eyewitness accounts of storm surge problems, thus jeopardizing public safety. This is
irresponsible. We also believe that you have either not been provided with all of the information
pertaining to this issue or have been misled.
Disregard for this community has now reached epic proportions: A stakeholders meeting
was to be held prior to the start of construction. Yet even that simple promise has been broken as
demolition of the wood boardwalk had already begun. We are scratching our heads trying to
figure out the purpose of the so called stakeholders meeting convened on December 30th while
simultaneously destroying the board for this ill-conceived $ 10 million dollar boardwalk-toconcrete sidewalk renovation project.

It was painfully obvious you had no intention of listening to the community. This was a
fait accompli.
Not only is this a slap in the face to the community but a direct contradiction of Mayor de
Blasio's stated promise of enabling communities to determine their own fate. Community-based
planning and consultation were supposed to be the major difference between the prior
administrations and the current one.
It was also a slap in the face to learn at the meeting that a deal had been made with
Assemblyman Stephen Cymbrowitz to allow the funds to be released, this after repeatedly saying
he would block them after December 31st. As you are fully aware the deal allows the city to
proceed with its concrete plan without any restrictions.
Our concerns remain unaddressed.
Regarding the pre-cast concrete that was already on the boardwalk and survived the
storm, the question of whether or not it exacerbated storm surge damage has never been
answered. You deride anecdotal evidence that storm surge damage may have been greater in
areas a concrete boardwalk was in place, however, the PlaNYC Report A Stronger, More
Resilient New York documents that a breach occurred at exactly the spot where this pre-cast
concrete section had been installed. The Report documents that as a result of this breach, the
storm surge penetrated 1.6 miles inland.
You mention that aerial imagery showed no difference in areas of inundation near wood
as opposed to concrete sections. Aerial imagery only shows the area that was inundated with
sand, it does not show the depth of sand in these areas. And that is where the difference was
profound. Near the pre-cast concrete section at Ocean Parkway, approximately six feet of sand,
with higher depths, covered local streets, while at adjacent areas with wooden boardwalks, mere
inches of sand covered the ground.
The finding that concrete is more resilient simply disregards reality: Although it has
been in place for only a few years, the concrete section at Ocean Parkway is already riddled with
cracks, large chunks are missing from the sides of the slabs and hockey puck shaped pieces have
disappeared from numerous places. In winter, it quickly ices over while wooden sections remain
dry. Also, there used to be a concrete walkway called The Esplanade that ran between Brighton
Beach and Manhattan Beach. It was destroyed by Hurricane Donna in the 1960s and never
repaired. During Hurricane Sandy, some of the remaining slabs lifted up and punched holes in a
nearby apartment building (documentation provided upon request). This is a perfect illustration of
how solid slabs become projectiles in a storm surge. Therefore, the resiliency claim is an arbitrary
statement, made without any examination of the unique conditions that occur in coastal areas.
Regarding the Rockaway boardwalk, in areas where groins or jetties were present on the
beach, boardwalks, whether wood or concrete survived relatively unscathed. After Hurricane
Sandy, a major design flaw was discovered. The wooden boardwalks were never fastened to the
underlying concrete supports, not a single one! So of course they failed and lifted up. Engineers
relied solely on the massive weight of the wooden beams being fastened to each other to keep
them in place, which clearly did not work, as we saw during Sandy.
Furthermore, and very importantly, in Rockaway, for the most part, the boardwalk is
separated from residential buildings by parkland and a multi-lane roadway. In Brooklyn,
residential and commercial buildings have no such buffers. Therefore, there is an urgent need to

know for sure that storm surge wave action will not be exacerbated by concrete slab construction.
This is basic planning.
Regarding alternatives to tropical hardwoods, to our knowledge, DPR has not adequately
addressed a processed wood called Kebony, even though it was successfully used at Hunters
Point South Park in Queens. DPR also appears unaware that there are different types of Kebony
some of which have properties very similar to tropical hardwoods. Furthermore, DPR is insisting
that black locust wood is not suitable, even though it was used in Brooklyn Bridge Park. Over the
past few years, several nurseries have offered to grow black locust wood to meet DPR
specifications, but DPR just ignored them.
The Boardwalk is in terrible shape because it has been neglected and abused for decades,
in large part caused by the Citys refusing to allocate the proper resources to maintain it. The
claim that there is a need to create a concrete vehicular highway on the Boardwalk is just
ludicrous. On days when it is crowded and there are now more such days than ever before
Parks and Police Department vehicles have no problem driving on the sand, at considerable
speeds. Previous administrations had the sense to begin using lighter vehicles if it was necessary
for them to drive on the Boardwalk. Quite frankly, the most egregious abusers of the Boardwalk
are Parks Department workers and contractors who use it as a delivery route and parking lot.
We appreciate your response to our November 17th letter but our concerns remain
unaddressed.
Given the complexities of this issue and the significant impacts that local residents
experienced firsthand, we ask that you halt this project immediately until public safety can be
assured.

Sincerely,

Mark Treyger
Council Member, 47th District

Chaim Deutsch
Council Member, 48th District