Reply to the National Wildlife Federation NWF and Others

NWF Plays Fast and Loose With Facts About the Shore By Gerard Stoddard
The National Wildlife Federation (NWF) recently published on the internet (see nwf.org) a list of 25 Civil Works projects that NWF feels symbolizes the inherently anti-environment nature of the U.S. Army Corps of Engineers. Project No. 10 on NWF's list of "Top Twenty-five Environmentally Harmful and Financially Wasteful Corps Projects" is the Fire Island Interim Project. Called FIIP for short, this is a project with which the present writer is familiar enough to be able to point out unfair or inaccurate statements in the NWF analysis. People involved with the other Corps projects listed could probably provide similar comment. The page devoted to Project 10 is entitled, "Fire Island, New York to Montauk Point, New York: Long Island Beach Replenishment -- Corps Building Before Comprehensive Study is Done." Here is some background: Following a series of hurricanes and nor'easters in the 1950s, Congress authorized the Fire Island Inlet to Montauk Point Storm Damage Reduction and Hurricane Protection Project in 1960. The project area being fully 83 miles in length, the Corps, logically enough, broke it into five discrete reaches that shared similar coastal characteristics and problems. Of relevance here are Reach 1, which extends east from Fire Island Inlet to Moriches Inlet along the 32-mile barrier island known as Fire Island, and Reach 2, which extends east from Moriches Inlet to Shinnecock Inlet. Most of the construction involved in the overall project was planned to occur in Fire Island (beach fill only), Westhampton Beach and in the area of Shinnecock Inlet. The work at Westhampton Beach has been concluded, save for annual maintenance. At the time the original project was authorized, residents of Fire Island (Reach 1) were actively urging the creation of what became the Fire Island National Seashore. The struggle pitted the residents against New York master builder Robert Moses. Having constructed Jones Beach State Park, the world's premier bathing beach, on Jones Island, the barrier segment next to the west of Fire Island, Mr. Moses was intent on extending his concept to the east. He proposed that Ocean Parkway, a four-lane, divided highway running the length of Jones Island, be extended through Fire Island and Westhampton Beach, eventually to reach Bridgehampton. While no one can fail to be impressed by this vision, and the extent to which it was realized, the vision did not sit well with Fire Island property owners. To them the fate of the residents of Jones Island to the west and Westhampton Beach was an object less. Most on Jones Island saw their property condemned and their houses razed, while the helter-skelter development of Westhampton Beach was an equally unattractive alternative. Compared to the rest of Long Island, development on Fire Island was slow to occur. The island was not connected to the mainland by bridges until the late 1950s, so large areas of the barrier's thirty-two mile length had remained relatively undisturbed. The residents proposed to keep it that way. They urged creation of a national seashore with existing communities allowed to continue under special zoning rules. Not only did Mr. Moses oppose this, so did the National Park Service, which considered the area too small and too urbanized to be successful as part of the park system. Nevertheless, the new National Seashore was created in September 1964. Given the unsettled state of affairs at Fire Island, and in response to pressure from landowners to the east whose property had been battered by the 1962 Ash Wednesday nor'easter, the Corps began the approved project in Reach 2, in the form of the now infamous Westhampton groinfield. It is generally agreed that when a series of groins is built as part of an overall design, it is best to begin at the downdrift terminus of the groinfield and work toward the updrift terminus. If the project must be built in reverse order, it is essential that each groin compartment be filled with sand before the next is constructed. For whatever reason, the Westhampton groinfield was built ignoring these precepts, and the result was increasingly severe erosion as each new groin was completed. In 1975, Suffolk County, the local sponsor, withdrew from the project, apparently in an effort to end the lawsuits that were being filed each time a new groin was constructed. This turned out to be a poor decision for the County. Over time, two breaches in the Westhampton segment of the barrier had to be repaired, the owners of more than a hundred homes compensated and local infrastructure replaced, among other things. The beach was finally restored and a plan for maintaining it approved in 1994. While this took care of the problem in Reach 2, it did little for Fire Island, the Shinnecock area, or points east. The same severe coastal storms in 1992-93 that caused the second breach at Westhampton also ravaged the length of Fire Island, causing the damage or destruction of more than 100 buildings and extensive flooding over large areas of the mainland. In the wake of the storms, Governor Cuomo named a Coastal Erosion Task Force. After numerous studies and reports, the Task Force called for modifying the Westhampton groinfield, a fill project on Fire Island, sand bypassing at all south shore inlets, and a quicker response to breaches that occurred in the barrier island system. These recommendations amounted to a repudiation of the retreat policy, which had been the preferred approach of the agency in charge of coastal policy (the Department of State) but not the agency in charge of coastal erosion regulations (the Department of Environmental Conservation). In the coastal context a retreat policy means that, instead of assuring that logical steps are taken to protect beaches and coastal areas from erosion, houses and other infrastructure that are in the path of erosion are moved back or abandoned. This policy serves the objectives of those who believe that it is unnatural and anti-social for beaches to be developed in any way, save as recreation areas and wildlife preserves. Environmental organizations are strong advocates of retreat as a solution to erosion problems. Not only can the retreat policy be set up as environmentally friendly but its opponents (generally those from whose property the retreat will occur) provide a good excuse for not doing anything about coastal erosion. By characterizing beach house owners as enemies of the environment, project opponents take advantage of the class rivalries that sometimes masquerade as concern for the environment. Political rivalries, too: only Republican Congressmen and Senators are criticized in the NWF report, and only Democrats praised as being anti- or pro-environment respectively. Though the argument is made that beach nourishment best emulates natural processes in restoring an eroding beach, environment groups meet two objectives by opposing it. It is a blow in favor of establishing "retreat" as the more environmentally sound policy, and it helps to "feed the beast," by providing members and potential recruits with an issue calculated to engage their irritation With that background the criticism of Project 10 is better understood. NWF begins its critique by invoking what has become a truism in the environmentalist approach to shore protection: "natural" is good; hard structures are bad. Thus, the very first sentence of the critique invokes the fear that the barrier island beaches will be "stabilized with groins," despite the fact that groins are nowhere contemplated in the proposed interim project. In fact, while the 1963 plan called for "the use of up to 50 groins as needed" [emphasis added], Westhampton Beach was scheduled to receive 23 of these, with only 15 actually installed. As it is well known that no groins have been placed anywhere in the project area since 1972, it seems clear that the truism is invoked simply for shock value, and without regard for truth. Had the Westhampton project been completed, of course, it is safe to say that the breaches of 1981 and 1992 would not have occurred. That would have saved the taxpayer some $30 million in emergency breach closure expense, flood insurance claims on over 100 homes would not have been necessary and the erosion of Fire Island would have been far less extensive. In another sentence, the NWF writes, "The Corps is able to build [interim projects] without first evaluating their cumulative impact on the affected coastal ecosystem." But the Environmental Protection Agency, perhaps unlike NWF, actually reviewed the Corps' draft decision document and environmental impact statement and found no environmental impact sufficient to support an objection to the project. Thus, neither the agency entrusted by Congress with the protection of America's shorelines, nor the agency in charge of protecting the environment found anything wrong with the project. Various commenting agencies have raised concerns, which the Corps has painstakingly addressed over the past four years. Most believe those still unresolved (ongoing studies needing completion, for example) can be addressed in the EIS for the reformulation of the longer-term project, due in 2002. In contrast, NWF and other non-government organizations would simply scrap the project. The Corps asserts the 6-year project is reversible, should experience show it caused environmental harm. Indeed, interim projects must have this attribute under guidelines issued by the Council on Environmental Quality. This is not good enough for project critics. NWF states that it "is unlikely" that the Corps would recommend abandonment of the project even if its own EIS concluded that it should be. No support for this allegation is suggested; it seems it is put out on the internet simply to inflame those unfamiliar with the NEPA process. NWF writes that the Corps "alleges" that breaches in the barrier lead to mainland flooding, as if this were open to question. The Corps is the expert agency charged by Congress with making such determinations. As the nation's coastal protection experts since the 1930s, the Corps has become the pre-eminent coastal engineering organization in the world. Its assessment that the barrier is subject to a 20 percent chance of breach in any given year deserves respect. "Currently the Corps fills breaches as they occur," NWF notes. True, but no one knows where a breach will happen. Near the Fire Island Lighthouse, for example, a swift-running channel 25 feet deep is just offshore in the bay. No one knows if a breach in that location could be closed or what its impacts would be on three state parks, the Robert Moses Causeway or Ocean Parkway, not to mention the Lindenhurst to Islip bay front. The Corps has concluded it is better to reduce the chances of such a breach occurring than to try to repair it after it occurs. NWF disagrees, based on no information whatever, and would place the Long Island bayfront at risk if its judgment is erroneous. Next NWF asserts that the project would "induce more development on and in front of the primary dune." But development in this area is strictly regulated by the state's Coastal Erosion Hazard Areas Act, which, as an incident to the project, now applies to Fire Island. The writers obviously hope that bashing beach house owners as potential developers will appeal to some elements of the public. NWF writes, "Experts predict the projects may require renourishment at least every five years over their life. Coastal geologists warn interfering with natural beach processes may actually increase flood risks." Juxtaposing these two sentences is, at least, a disingenuous attempt to mislead the public. The clear implication is that renourishment is "interference with natural processes." It is not. Renourishment is an attempt to augment natural processes by replacing sand blocked from Fire Island by the groins and inlet jetties to the east. Those structures, not renourishment, are the interference with "natural beach processes." And then we're told that "Extensive development is threatening ecologically sensitive areas on Fire Island." This statement is utterly false. Development that did threaten Fire Island was effectively curbed by the creation, primarily at the insistence of the property owners there, of the Fire Island National Seashore. Since September 1964, fully 80 percent of the upland areas of the 32-mile barrier and 100 percent of its beaches have been in public hands. There has been no development outside the boundaries set up by Congress for almost four decades. The present project will not occur in beaches adjacent to the Federal Wilderness Area east of Watch Hill, nor in other large federal areas. NWF writes that "Mining offshore sand … and dumping it on beaches smothers tidal wildlife." This statement is totally unsupported by the known science. Adding sand to a dynamic sandy shoreline in no way "fundamentally alters the barrier island ecosystem." It simply replaces the sand that would have been there had it not been blocked by manmade structures to the east. The National Research Council concluded that "Beach nourishment is a viable engineering alternative for shore protection and is the principal technique for beach restoration; its application is suitable for some, but not all, locations where erosion is occurring." (Beach Nourishment and Protection, Marine Board of the National Research Council, National Academy Press, Washington, 1995) It is clear that the writers are primarily opposed to the existence of beach houses on the private lands that still exist on Fire Island. The NWF critique is an attempt to enlist the support of the public for an assertion that these homes somehow damage the island. Not only is no harm is done to Fire Island by the homes that exist there, much economic benefit is derived from them. But organizations such as those of the authors of the NWF critique continue to attract members and dues by railing against "a privileged minority": the beach house owner. It is little short of shameful to suggest to gullible members of the public that an evil (incidentally, one perpetrated by "rich New Yorkers" and "special interests") can be confronted by sending money to the environmental organizations listed. The only way to restore "natural rebuilding of the barrier islands" is to implement bypassing around all manmade structures to the east of Fire Island. Not only was this a key recommendation of Governor Cuomo's Coastal Erosion Task Force in 1994, but the Task Force also recognized that the island first had to be restored to something like the condition it would have been in had the sand flow not been interrupted. That means a beach fill project, exactly as the Corps of Engineers and NYS DEC has recommended. The NWF writers say that the Fire Island Association supports the project for the benefit of "the owners of expensive beachfront homes." For the record, there are 3,850 homes on Fire Island, some expensive, some not. But thousands of Long Islanders help support their families by providing services to those homes, and 7 million people visited Fire Island in 1997. That 32 miles of Atlantic Ocean beach, fully open to the public, is available within 50 miles of Times Square is a fact curiously absent from the NWF analysis. Incidentally, the relatively few Fire Island homes that exist under the agreement that created the National Seashore are by law exempt from condemnation by the Secretary of the Interior so long as they comply with a zoning code that he has approved. NWF goes on, "This interest group [FIA] has wielded its influence to secure a deal in which homeowners would pay less than 7 percent of project's construction cost." A "deal?" Fire Island property owners know that a project could be perceived as providing a special benefit to those who own property on the barrier. For this reason they agreed to pay half the local costs of the project, simply to be able to dispel the notion that they were getting a "special deal." Much good it has done. FIA is also accused of having "hired Tom Downey, former Congressman of the district, to lobby the Council on Environmental Quality for approval of the full-scale project." Mr. Downey has said publicly that he was not hired by FIA; that he continues to support the project in private life even as he did when he supported it as Congressman. This is playing fast and loose with the facts in an obvious effort to inflame the public. The writers hold that a moratorium on new beach building would solve the problem. They cite as "promising" the Town of East Hampton "encouraging retreat from the shore and restricting erosion control structures that often lead to erosion on adjacent beaches." But court decisions have consistently found that a moratorium in place long enough for authorities to come up with a permanent solution to erosion problems would itself be unconstitutional. (FIA's environment counsel's legal memo on this point is available on request.) In any case, a long-term moratorium, if adopted, could result in the endangerment or destruction of the houses that pay a disproportionate share of area property taxes. Worse, to the extent such a policy is a substitute for beach nourishment, it would assure that public beaches would be narrower and more dangerous than they have to be. When it comes to recommendations, the writers believe that no beach replenishment projects should go forward until costs are "reevaluated." As the Corps has amply demonstrated the positive benefit to cost ratio that supports the project, it is clear that the writers simply do not agree with the Corps numbers. They offer no contradictory numbers, however, because they cannot. Not surprisingly, the NWF concludes by calling for "strategic retreat from hazardous coastal development." We assume "retreat from coastal hazards" is meant, but it amounts to the same thing: do not protect America's shorelines because some might get to enjoy them more than others. They find this a policy worth following even if it puts the back bay and mainland areas at extreme risk from coastal flooding, most of it preventable. In the interests of informed debate, it is essential to respond to deliberately provocative and erroneous assertions whenever they are made. Society's objective should be to maintain a beach wide enough for the public to enjoy between private property and the water's edge. In all but the completely sand-starved beach, that should be within the abilities of today's coastal engineering fraternity. Ongoing beach nourishment is costly, but it has been shown cost effective at the federal and regional level. Locally, the coastal community, and especially the first row property owner, should be expected to foot a fair share of the non-federal, non-state cost. Over time, the result will be wide, protective beaches, a healthy barrier island system and reduction of the risk of catastrophic flooding of the mainland. If a federal-state project has the incidental benefit of protection of private property on the barrier (protection that the owners are seen as paying for in special taxes) that should be an additional argument in favor of the project; not an argument against it.

NWF Plays Fast and Loose With Facts About the Shore

By Gerard Stoddard

The National Wildlife Federation (NWF) recently published on the internet (see nwf.org) a list of 25 Civil Works projects that NWF feels symbolizes the inherently anti-environment nature of the U.S. Army Corps of Engineers. Project No. 10 on NWF's list of "Top Twenty-five Environmentally Harmful and Financially Wasteful Corps Projects" is the Fire Island Interim Project. Called FIIP for short, this is a project with which the present writer is familiar enough to be able to point out unfair or inaccurate statements in the NWF analysis. People involved with the other Corps projects listed could probably provide similar comment.

The page devoted to Project 10 is entitled, "Fire Island, New York to Montauk Point, New York: Long Island Beach Replenishment -- Corps Building Before Comprehensive Study is Done." Here is some background:

Following a series of hurricanes and nor'easters in the 1950s, Congress authorized the Fire Island Inlet to Montauk Point Storm Damage Reduction and Hurricane Protection Project in 1960. The project area being fully 83 miles in length, the Corps, logically enough, broke it into five discrete reaches that shared similar coastal characteristics and problems. Of relevance here are Reach 1, which extends east from Fire Island Inlet to Moriches Inlet along the 32-mile barrier island known as Fire Island, and Reach 2, which extends east from Moriches Inlet to Shinnecock Inlet. Most of the construction involved in the overall project was planned to occur in Fire Island (beach fill only), Westhampton Beach and in the area of Shinnecock Inlet. The work at Westhampton Beach has been concluded, save for annual maintenance.

At the time the original project was authorized, residents of Fire Island (Reach 1) were actively urging the creation of what became the Fire Island National Seashore. The struggle pitted the residents against New York master builder Robert Moses. Having constructed Jones Beach State Park, the world's premier bathing beach, on Jones Island, the barrier segment next to the west of Fire Island, Mr. Moses was intent on extending his concept to the east. He proposed that Ocean Parkway, a four-lane, divided highway running the length of Jones Island, be extended through Fire Island and Westhampton Beach, eventually to reach Bridgehampton. While no one can fail to be impressed by this vision, and the extent to which it was realized, the vision did not sit well with Fire Island property owners. To them the fate of the residents of Jones Island to the west and Westhampton Beach was an object less. Most on Jones Island saw their property condemned and their houses razed, while the helter-skelter development of Westhampton Beach was an equally unattractive alternative.

Compared to the rest of Long Island, development on Fire Island was slow to occur. The island was not connected to the mainland by bridges until the late 1950s, so large areas of the barrier's thirty-two mile length had remained relatively undisturbed. The residents proposed to keep it that way. They urged creation of a national seashore with existing communities allowed to continue under special zoning rules. Not only did Mr. Moses oppose this, so did the National Park Service, which considered the area too small and too urbanized to be successful as part of the park system. Nevertheless, the new National Seashore was created in September 1964.

Given the unsettled state of affairs at Fire Island, and in response to pressure from landowners to the east whose property had been battered by the 1962 Ash Wednesday nor'easter, the Corps began the approved project in Reach 2, in the form of the now infamous Westhampton groinfield. It is generally agreed that when a series of groins is built as part of an overall design, it is best to begin at the downdrift terminus of the groinfield and work toward the updrift terminus. If the project must be built in reverse order, it is essential that each groin compartment be filled with sand before the next is constructed. For whatever reason, the Westhampton groinfield was built ignoring these precepts, and the result was increasingly severe erosion as each new groin was completed. In 1975, Suffolk County, the local sponsor, withdrew from the project, apparently in an effort to end the lawsuits that were being filed each time a new groin was constructed.

This turned out to be a poor decision for the County. Over time, two breaches in the Westhampton segment of the barrier had to be repaired, the owners of more than a hundred homes compensated and local infrastructure replaced, among other things. The beach was finally restored and a plan for maintaining it approved in 1994. While this took care of the problem in Reach 2, it did little for Fire Island, the Shinnecock area, or points east.

The same severe coastal storms in 1992-93 that caused the second breach at Westhampton also ravaged the length of Fire Island, causing the damage or destruction of more than 100 buildings and extensive flooding over large areas of the mainland.

In the wake of the storms, Governor Cuomo named a Coastal Erosion Task Force. After numerous studies and reports, the Task Force called for modifying the Westhampton groinfield, a fill project on Fire Island, sand bypassing at all south shore inlets, and a quicker response to breaches that occurred in the barrier island system. These recommendations amounted to a repudiation of the retreat policy, which had been the preferred approach of the agency in charge of coastal policy (the Department of State) but not the agency in charge of coastal erosion regulations (the Department of Environmental Conservation). In the coastal context a retreat policy means that, instead of assuring that logical steps are taken to protect beaches and coastal areas from erosion, houses and other infrastructure that are in the path of erosion are moved back or abandoned. This policy serves the objectives of those who believe that it is unnatural and anti-social for beaches to be developed in any way, save as recreation areas and wildlife preserves.

Environmental organizations are strong advocates of retreat as a solution to erosion problems. Not only can the retreat policy be set up as environmentally friendly but its opponents (generally those from whose property the retreat will occur) provide a good excuse for not doing anything about coastal erosion. By characterizing beach house owners as enemies of the environment, project opponents take advantage of the class rivalries that sometimes masquerade as concern for the environment. Political rivalries, too: only Republican Congressmen and Senators are criticized in the NWF report, and only Democrats praised as being anti- or pro-environment respectively. Though the argument is made that beach nourishment best emulates natural processes in restoring an eroding beach, environment groups meet two objectives by opposing it. It is a blow in favor of establishing "retreat" as the more environmentally sound policy, and it helps to "feed the beast," by providing members and potential recruits with an issue calculated to engage their irritation

With that background the criticism of Project 10 is better understood. NWF begins its critique by invoking what has become a truism in the environmentalist approach to shore protection: "natural" is good; hard structures are bad. Thus, the very first sentence of the critique invokes the fear that the barrier island beaches will be "stabilized with groins," despite the fact that groins are nowhere contemplated in the proposed interim project. In fact, while the 1963 plan called for "the use of up to 50 groins as needed" [emphasis added], Westhampton Beach was scheduled to receive 23 of these, with only 15 actually installed. As it is well known that no groins have been placed anywhere in the project area since 1972, it seems clear that the truism is invoked simply for shock value, and without regard for truth. Had the Westhampton project been completed, of course, it is safe to say that the breaches of 1981 and 1992 would not have occurred. That would have saved the taxpayer some $30 million in emergency breach closure expense, flood insurance claims on over 100 homes would not have been necessary and the erosion of Fire Island would have been far less extensive.

In another sentence, the NWF writes, "The Corps is able to build [interim projects] without first evaluating their cumulative impact on the affected coastal ecosystem." But the Environmental Protection Agency, perhaps unlike NWF, actually reviewed the Corps' draft decision document and environmental impact statement and found no environmental impact sufficient to support an objection to the project. Thus, neither the agency entrusted by Congress with the protection of America's shorelines, nor the agency in charge of protecting the environment found anything wrong with the project. Various commenting agencies have raised concerns, which the Corps has painstakingly addressed over the past four years. Most believe those still unresolved (ongoing studies needing completion, for example) can be addressed in the EIS for the reformulation of the longer-term project, due in 2002. In contrast, NWF and other non-government organizations would simply scrap the project.

The Corps asserts the 6-year project is reversible, should experience show it caused environmental harm. Indeed, interim projects must have this attribute under guidelines issued by the Council on Environmental Quality. This is not good enough for project critics. NWF states that it "is unlikely" that the Corps would recommend abandonment of the project even if its own EIS concluded that it should be. No support for this allegation is suggested; it seems it is put out on the internet simply to inflame those unfamiliar with the NEPA process.

NWF writes that the Corps "alleges" that breaches in the barrier lead to mainland flooding, as if this were open to question. The Corps is the expert agency charged by Congress with making such determinations. As the nation's coastal protection experts since the 1930s, the Corps has become the pre-eminent coastal engineering organization in the world. Its assessment that the barrier is subject to a 20 percent chance of breach in any given year deserves respect.

"Currently the Corps fills breaches as they occur," NWF notes. True, but no one knows where a breach will happen. Near the Fire Island Lighthouse, for example, a swift-running channel 25 feet deep is just offshore in the bay. No one knows if a breach in that location could be closed or what its impacts would be on three state parks, the Robert Moses Causeway or Ocean Parkway, not to mention the Lindenhurst to Islip bay front. The Corps has concluded it is better to reduce the chances of such a breach occurring than to try to repair it after it occurs. NWF disagrees, based on no information whatever, and would place the Long Island bayfront at risk if its judgment is erroneous.

Next NWF asserts that the project would "induce more development on and in front of the primary dune." But development in this area is strictly regulated by the state's Coastal Erosion Hazard Areas Act, which, as an incident to the project, now applies to Fire Island. The writers obviously hope that bashing beach house owners as potential developers will appeal to some elements of the public.

NWF writes, "Experts predict the projects may require renourishment at least every five years over their life. Coastal geologists warn interfering with natural beach processes may actually increase flood risks." Juxtaposing these two sentences is, at least, a disingenuous attempt to mislead the public. The clear implication is that renourishment is "interference with natural processes." It is not. Renourishment is an attempt to augment natural processes by replacing sand blocked from Fire Island by the groins and inlet jetties to the east. Those structures, not renourishment, are the interference with "natural beach processes."

And then we're told that "Extensive development is threatening ecologically sensitive areas on Fire Island." This statement is utterly false. Development that did threaten Fire Island was effectively curbed by the creation, primarily at the insistence of the property owners there, of the Fire Island National Seashore. Since September 1964, fully 80 percent of the upland areas of the 32-mile barrier and 100 percent of its beaches have been in public hands. There has been no development outside the boundaries set up by Congress for almost four decades. The present project will not occur in beaches adjacent to the Federal Wilderness Area east of Watch Hill, nor in other large federal areas.

NWF writes that "Mining offshore sand … and dumping it on beaches smothers tidal wildlife." This statement is totally unsupported by the known science. Adding sand to a dynamic sandy shoreline in no way "fundamentally alters the barrier island ecosystem." It simply replaces the sand that would have been there had it not been blocked by manmade structures to the east. The National Research Council concluded that "Beach nourishment is a viable engineering alternative for shore protection and is the principal technique for beach restoration; its application is suitable for some, but not all, locations where erosion is occurring." (Beach Nourishment and Protection, Marine Board of the National Research Council, National Academy Press, Washington, 1995)

It is clear that the writers are primarily opposed to the existence of beach houses on the private lands that still exist on Fire Island. The NWF critique is an attempt to enlist the support of the public for an assertion that these homes somehow damage the island. Not only is no harm is done to Fire Island by the homes that exist there, much economic benefit is derived from them. But organizations such as those of the authors of the NWF critique continue to attract members and dues by railing against "a privileged minority": the beach house owner. It is little short of shameful to suggest to gullible members of the public that an evil (incidentally, one perpetrated by "rich New Yorkers" and "special interests") can be confronted by sending money to the environmental organizations listed.

The only way to restore "natural rebuilding of the barrier islands" is to implement bypassing around all manmade structures to the east of Fire Island. Not only was this a key recommendation of Governor Cuomo's Coastal Erosion Task Force in 1994, but the Task Force also recognized that the island first had to be restored to something like the condition it would have been in had the sand flow not been interrupted. That means a beach fill project, exactly as the Corps of Engineers and NYS DEC has recommended.

The NWF writers say that the Fire Island Association supports the project for the benefit of "the owners of expensive beachfront homes." For the record, there are 3,850 homes on Fire Island, some expensive, some not. But thousands of Long Islanders help support their families by providing services to those homes, and 7 million people visited Fire Island in 1997. That 32 miles of Atlantic Ocean beach, fully open to the public, is available within 50 miles of Times Square is a fact curiously absent from the NWF analysis. Incidentally, the relatively few Fire Island homes that exist under the agreement that created the National Seashore are by law exempt from condemnation by the Secretary of the Interior so long as they comply with a zoning code that he has approved.

NWF goes on, "This interest group [FIA] has wielded its influence to secure a deal in which homeowners would pay less than 7 percent of project's construction cost." A "deal?" Fire Island property owners know that a project could be perceived as providing a special benefit to those who own property on the barrier. For this reason they agreed to pay half the local costs of the project, simply to be able to dispel the notion that they were getting a "special deal." Much good it has done.

FIA is also accused of having "hired Tom Downey, former Congressman of the district, to lobby the Council on Environmental Quality for approval of the full-scale project." Mr. Downey has said publicly that he was not hired by FIA; that he continues to support the project in private life even as he did when he supported it as Congressman. This is playing fast and loose with the facts in an obvious effort to inflame the public.

The writers hold that a moratorium on new beach building would solve the problem. They cite as "promising" the Town of East Hampton "encouraging retreat from the shore and restricting erosion control structures that often lead to erosion on adjacent beaches." But court decisions have consistently found that a moratorium in place long enough for authorities to come up with a permanent solution to erosion problems would itself be unconstitutional. (FIA's environment counsel's legal memo on this point is available on request.) In any case, a long-term moratorium, if adopted, could result in the endangerment or destruction of the houses that pay a disproportionate share of area property taxes. Worse, to the extent such a policy is a substitute for beach nourishment, it would assure that public beaches would be narrower and more dangerous than they have to be.

When it comes to recommendations, the writers believe that no beach replenishment projects should go forward until costs are "reevaluated." As the Corps has amply demonstrated the positive benefit to cost ratio that supports the project, it is clear that the writers simply do not agree with the Corps numbers. They offer no contradictory numbers, however, because they cannot.

Not surprisingly, the NWF concludes by calling for "strategic retreat from hazardous coastal development." We assume "retreat from coastal hazards" is meant, but it amounts to the same thing: do not protect America's shorelines because some might get to enjoy them more than others. They find this a policy worth following even if it puts the back bay and mainland areas at extreme risk from coastal flooding, most of it preventable.

In the interests of informed debate, it is essential to respond to deliberately provocative and erroneous assertions whenever they are made. Society's objective should be to maintain a beach wide enough for the public to enjoy between private property and the water's edge. In all but the completely sand-starved beach, that should be within the abilities of today's coastal engineering fraternity. Ongoing beach nourishment is costly, but it has been shown cost effective at the federal and regional level. Locally, the coastal community, and especially the first row property owner, should be expected to foot a fair share of the non-federal, non-state cost.

Over time, the result will be wide, protective beaches, a healthy barrier island system and reduction of the risk of catastrophic flooding of the mainland. If a federal-state project has the incidental benefit of protection of private property on the barrier (protection that the owners are seen as paying for in special taxes) that should be an additional argument in favor of the project; not an argument against it.