The Real Estate Board of New York on the Fortifying our Resilient Growth and Economy (FiDi FORGE) Environmental Impact Statement

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The Real Estate Board of New York (REBNY) is the City’s leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY appreciates the opportunity to comment on the Environmental Impact Statement (EIS) for the Fortifying Our Resilient Growth and Economy (FiDi FORGE) project. REBNY strongly supports advancing this critical resiliency initiative and urges the City, State, and federal partners to continue moving the project forward expeditiously.

Lower Manhattan is one of the nation's most important economic and commercial districts. In 2024, the neighborhood generated an estimated $134.4 billion in economic output, accounting for 9.8% of New York City's GDP and 6.53% of New York State's GDP. In Fiscal Year 2025, Lower Manhattan generated $4.9 billion in tax revenue, representing approximately 6% of all City tax revenue. The district is home to approximately 233,000 private-sector employees, 70,000 residents, welcomes 17.7 million visitors annually, and serves approximately 417,000 daily subway, PATH, and ferry riders. Beyond its economic significance, the South Street Seaport is one of the nation's most historic waterfront districts, whose maritime heritage helped establish New York as America's leading port and financial center.

There is a clear need for infrastructure investment to reduce the long-term economic costs to the government as modelled by the no-action scenario. Hurricane Sandy caused an estimated $19 billion in citywide damages and lost economic activity, demonstrating the significant consequences of more frequent severe storm events and coastal flooding for residents, businesses, and critical infrastructure. Sea levels in New York Harbor have already risen approximately one foot since 1900 and are projected to rise by as much as five feet by the end of the century. Without additional flood protection, repetitive flooding is projected to result in as much as $20.3 billion in cumulative losses to the project area by 2100. These estimates do not fully capture the broader impacts associated with disruptions to the region's transportation, electrical, and stormwater infrastructure, which would have cascading effects throughout the city, state and national economy.

The FiDi FORGE project represents a critical investment in protecting Lower Manhattan's residents, businesses, and infrastructure from increasingly frequent and severe coastal flooding. In addition to reducing future economic losses, the project will help preserve and strengthen property values, provide greater certainty for continued investment, and reinforce Lower Manhattan's role as a global business district within the United States. A resilient waterfront is essential to maintaining the area's long-term economic competitiveness and encouraging continued public and private investment.

REBNY also recognizes that this project will complement other resiliency investments throughout Lower Manhattan and help close remaining gaps in the city's coastal flood protection network. Given the scale of infrastructure work necessary to protect this nationally historically and economically significant geography for the nation’s future prosperity, it is imperative that planning, environmental review, funding, and implementation continue without unnecessary delay. Thank you for the opportunity to comment.

CONTACTS:
Maddie DeCerbo
Director of Urban Planning
Real Estate Board of New York
Mdecerbo@rebny.com

Basha Gerhards
Executive Vice President of Public Policy
Real Estate Board of New York
Bgerhards@rebny.com