1. United States
2. N.Y.
3. Letter

Battery Park City Authority is removing 500 mature trees for the North/West Battery Park City Resiliency Project — more than 40% of every tree in the project area, and roughly 80% on the South Esplanade alone. This is a state authority's project on state-owned land. In a May 2026 written response to community inquiries, BPCA confirmed that none of the seven reaches in the project's Final EIS Alternatives Chapter was designed around tree retention. Only one reach contains a tree-count comparison across alternatives. The other six contain none. SEQRA's "hard look" standard, applied through 6 NYCRR 617.9(a)(7), requires the agency to genuinely examine alternatives that could mitigate significant environmental impacts. Removing 40% of a public park's mature trees is a significant impact. Yet no reach was designed with retention as a primary objective — meaning the single most consequential mitigation alternative was never seriously studied. I am writing as a constituent of Battery Park City to ask that BPCA be required, before any further removals, to: Publish per-tree justification — for each of the 500 trees, the specific design constraint that made retention impossible, and where that constraint is itself a design choice, the alternative considered and the basis for rejecting it. Develop retention-first design alternatives by reach. Not variations on the current plan — designs built from the premise that tree retention is a primary objective. Submit both analyses for independent review by qualified arborists, flood engineers, and landscape architects with no financial relationship to the design-build contractor, with findings published on the public record. A pause while this work is done would cost the project very little. Cutting more than 40% of the waterfront's mature trees — and 80% in some neighborhoods — cannot be undone.