NEWRA splits vote on Richmond Street proposal building code

At the September 10 monthly meeting, the North End/Waterfront Residents’ Association (NEWRA) voted to support and oppose plans for 139-145 Richmond Street.

The owner is seeking building code and zoning relief for interior changes to increase the number of residential apartments from 17 to 20 units and add a common roof deck to the six-story building.

While NEWRA supported the additional units by a vote of 16-2 they opposed the common roof deck of the proposal by a vote of 7-10.

Old North Illuminated has received a grant to research when the North End was a Jewish community made up of synagogues, schools, homes, businesses and other things that make up a community, was discussed at the meeting by Jessica Dello Russo, historian and researcher.

The grant will be used to document and identify historic marker sites for the City of Boston’s Historic Markers Program.

Jessica noted the project is seeking photos and community participation.

Interested email dellorusso@gmail.com or tours@oldnorth.com

Derek Anderson, ARUA and engineer for the North End Waterfront Climate Control Alliance reviewed the US Army Corp report and response by NEWRA and NEWCCA.

Letters are listed below

September 17, 2026

Mr. Todd Randall

U.S. Army Corps of Engineers, New England District

ATTN: COB CSRM Project Team

696 Virginia Road Concord, MA 01742-2751

via email: boston-csfrm@usace.army.mil

Subject: Public Comments on the USACE Boston CSRM Study Draft Integrated Feasibility Report and Programmatic Environmental Assessment (IFR/EA)

The North End Waterfront Climate Alliance (NEWCA) is a climate-focused task force consisting of a collaboration of North End residents, business owners, environmental experts, engineering firm Arup, and City of Boston planners who have been working together to represent and advocate on behalf of the North End Waterfront community for flood resilience solutions that are strongly supported by our community. In 2024 we began working directly with all waterfront property owners and many inland property owners, residents, and businesses in our neighborhood to create the NEWCA Flood Resilience Plan, available at https://www.newra.org/newca. The NEWCA Flood Resilience Plan directly advanced the strategies laid out in the City’s Climate Ready Boston Program, and is unanimously supported by all waterfront property owners along the North End Waterfront, from Battery Wharf to Commercial Wharf, where the Boston CSRM project currently proposes a new flood protection system to be constructed along the waterfront.

We thank you for this opportunity to submit comments on the USACE Boston Coastal Storm Risk Management Study (CSRM) Draft Integrated Feasibility Report and Programmatic Environmental Assessment (IFR/EA). We have been grateful for the collaborative process between U.S. Army Corps of Engineers (USACE), City of Boston, NEWCA, and our community to date, and truly appreciate the work that has gone into the CSRM draft report. We commend the USACE for integrating the planning and design already undertaken by City’s Climate Ready Boston Program along with elements of the NEWCA Flood Resilience Plan and the Wharf District Council’s Flood Resilience Plan. We are also pleased to see that the USACE’s project team has concluded that construction of flood protection projects along Boston’s waterfront would have a high Benefit Cost Ratio exceeding 4:1, confirming the validity of this approach and underscoring the urgency of implementation.

We are supportive of the CSRM project and strongly urge the CSRM project team to recommend Action Plan 2 in the next iteration of its report, with Action Plan 3 as an early actionable element of the overall plan. As Action Plan 2 is the only approach that provides city-wide flood protection, with Action Plan 3 specifically protecting against flood pathways at Moakley Park, it is crucial that the final CSRM report lays out clear priorities and a commitment to implement Action Plan 2 and Action Plan 3 over the next two decades.

The CSRM final report should also provide more clarity and transparency on the USACE methodology for choosing flood barrier locations and project types. When they diverge from Climate Ready Boston proposals and the follow-on resilience plans prepared by NEWCA and the Wharf District Council, we would like to see more details about how and why those decisions were made given the years of community engagement and technical planning work the City, NEWCA, and the Wharf District Council have completed to develop those proposals. Together, the flood resilience plans prepared by NEWCA and Wharf District Council have gained the unanimous support of all waterfront property owners from Battery Wharf to the Fort Point Channel. Understanding the USACE rationale for deviations from these plans will be critical for maintaining this strong community support as the USACE takes the next step in advancing flood resilience design for our community.

While we are generally very supportive of the overall CSRM plan, several refinements are necessary before NEWCA can fully endorse the CSRM plan, as detailed in our comments below.

• Recommend Alternative DT-3 Proceed to Further Design Development

• Our strong preference is for Alternative DT-3 over DT-3A. We urge USACE to select DT-3 as the recommended plan, inclusive of refinements indicated in the comments in this letter. Our concerns regarding Alternative DT-3A include:

• DT-3A leaves all properties in the North End north of Fleet Street exposed to flooding. This plan does not address the significant risks of potential damage to homes and businesses for these properties which may result in significant and lasting impacts on property values, insurance costs, historic buildings, critical transportation infrastructure, and revenue from tourism, which would ultimately impact all of our community members, as well as the region well beyond Boston’s municipal boundaries. The true benefits of DT-3 compared to DT-3A are also significantly understated, as CSRM only quantifies costs and benefits based on National Economic Development (NED) benefits and does not account for the full range of business disruptions that would be affected by coastal storms, impacts to tourism, environmental quality, life-loss, or any potential growth in the coming decades.

• DT-3A requires long-duration closures of Atlantic Avenue. As noted in Section 2.7.1 of the IFR/EA, Nor’easters can last for multiple days. The deployable barrier across Atlantic Avenue proposed by DT-3A would therefore likely need to be closed for several days during these storm events. We also understand this deployable barrier would need to be closed every year or two by 2050, and more frequently by 2070. As Atlantic Avenue is an established local evacuation route and an important route for emergency responders, local commuters, businesses, and residents, DT-3A would have a significant negative impact on response times for first responders, community evacuation activities, traffic, disruption to businesses, and property values.

• DT-3A does not provide a viable approach to protecting Battery and Burroughs Wharves. USACE’s study found that pile-supported structures such as Battery and Burroughs Wharves cannot be protected by non-structural measures alone and would also require structural interventions in water (IFR/EA Section 7.3.2). It therefore appears USACE has determined that non-structural measures for Battery and Burroughs Wharves are not feasible. As no feasible strategy has been identified by USACE to protect these properties other than DT-3, we strongly recommend USACE select DT-3 as the recommended plan.

• The CSRM project’s approach to infilling beneath the Battery and Burroughs Wharf decks unnecessarily inflates the costs of DT-3 compared to DT-3A. We believe this infill approach may be excessively conservative. We request subsequent design efforts consider not infilling beneath these wharves but instead leaving the space beneath the wharf decks open for use as stormwater storage. Associated cost savings should be considered when comparing the costs and benefits of DT-3 to DT-3A.

• DT-3A does not assess potential damages associated with leaving the harbor tunnels and underground structures unprotected. The avoided losses included in the assessment of DT-3, and the potential losses included in the assessment of Action Plan 1 – ‘No Action Alternative’ and DT-3A should include an assessment of the impact of the increased weight of water associated with a 2070 100-year flood event on existing underground structures (e.g. the Sumner and Callahan Tunnels, underground garages at Battery and Burroughs Wharves, etc.), and the potential need for reinforcing any of these structures to accommodate the additional water load. This assessment should include the cost of potential damage to the tunnels and surface structures above the tunnels, economic impacts associated with loss of use of the tunnels, and potential loss of life. Alternative DT-3 protects these underground structures by preventing deep storm surge waters from adding load to the land areas above them. Refer to Appendix A of this comment letter for additional information regarding potential risk of damage to underground structures caused by additional weight of water during a storm surge.

• DT-3A should include non-structural measures for properties north of Fleet Street. If the DT-3A cutoff alignment is advanced in the final design, non-structural measures should be provided for all unprotected properties exposed to flood hazards in the North End. As many buildings in the North End are left unprotected by DT-3A, we request USACE’s final report identify the specific non-structural options that may be covered by the USACE program for properties that are not protected by DT-3A.

• Increase Level of Protection:

• Enable Improved Future Adaptability: The Massachusetts Coast Flood Risk Model (MC-FRM) is used by the City of Boston and State of Massachusetts to assess future anticipated storm surge elevations for planning, design, and permitting of flood protection systems. Importantly, the MC-FRM is broadly used and supported as the de facto model our communities have agreed upon for defining our risk tolerance to flood hazards. The MC-FRM anticipates higher future storm surge elevations compared to the USACE’s analysis.

To avoid precluding the City of Boston from eventually providing the level of protection necessary to address the flood risks identified by the MC-FRM model, we request the CSRM flood barrier structure foundations and concrete reinforcement be designed to allow future height increases to the 2070 1% AEP significant wave height based on MC-FRM at a minimum.

• Provide Protection Against Wave Overtopping: Appendix B, Section 8 of the IFR/EA report notes that in general, the target crest elevation for city-wide flood protection systems was selected by USACE to protect against the USACE High SLC 2090 1% storm surge water levels, inclusive of a provision for wave overtopping. However, in the North End/Downtown neighborhood, a lower level of protection is being provided, between the USACE Intermediate and High SLC scenarios for stillwater, with no provisions for preventing wave overtopping from causing inland flooding in this neighborhood. This results in a top of barrier elevation of 14.0’ NAVD88 for the North End/Downtown neighborhood. The CSRM study notes this lower level of protection being provided to the North End/Downtown neighborhood based on USACE’s assumption that a higher level of protection would result in a stark contrast to existing conditions and would therefore not be acceptable to the community.

We request each neighborhood be provided an equivalent level of protection. This should be accomplished using different approaches sensitive to site-specific considerations for each neighborhood. For the North End, we request no change to the 14.0’ top of barrier elevation but do request USACE include the floating breakwater docks proposed by the NEWCA Flood Resilience Plan plans (or other wave dissipators) to reduce the risks of wave overtopping, and thus increase the level of protection provided to these neighborhoods to a similar level being provided to Charlestown and Dorchester.

• Include Hybrid Solutions of Flood Barriers + Wave Dissipators + Nature-Based Strategies: The report notes breakwaters and similar approaches such as wave dissipators, and nature-based strategies were screened out as “they alone are not adequate as storm surge reducing measures.” Rather than screening out solutions that may not work as stand-alone solutions, we request the USACE supplement the currently proposed flood barriers (e.g. seawalls, floodwalls, levees) with additional wave dissipators and nature-based strategies (e.g. floating breakwater docks, living shorelines, living seawalls, floating wetlands) to create a hybrid solution that increases the level of storm surge protection beyond what the currently proposed flood barriers can provide on their own, and to provide co-benefits such as preserving or enhancing access to and views of the Harbor, water transportation and recreation dock slips, and environmental resources. In particular, the floating breakwater docks, living shorelines, and floating wetlands indicated on the NEWCA Flood Resilience Plan and the Wharf District Council’s Flood Resilience Plan (available at www.wharfdistrictcouncil.org/climateresilience) should be added to the CSRM project.

• Protect the Union Wharf Townhouses. The townhouse buildings on Union Wharf are not protected by the CSRM project. While enclosing these townhouses with a flood barrier to elevation 14.0 is not desired due to the significant negative impacts such a wall would have on these buildings, we request the CSRM project include an outboard/water-based flood barrier to protect these townhouses against more frequent, less severe storm events, as indicated on the NEWCA Flood Resilience Plan. We request the flood barrier around the townhouses have a top of wall elevation of 11.0’+/- NAVD88 and be designed to be elevated to elevation 14.0’ in the future.

• Reconstruct the Harborwalk. As the CSRM project will be impacting all existing Harborwalks throughout the neighborhood, the project should include reconstruction of all elements of these Harborwalks at an elevation that provides views and access to the Harbor, consistent with Chapter 91 requirements and as indicated in the WDC and NEWCA Flood Resilience Plans.

• Provide Redundancy Against Single Points of Failure

• The current plan appears to rely on a single line of protection. We are concerned that any single point of failure could result in significant widespread flooding throughout the City. We request USACE consider including the Secondary Flood Protection Systems proposed by the NEWCA and Wharf District Council Flood Resilience Plans in the CSRM project.

• We request a sensitivity analysis be performed for potential blocked deployable gates, including considering potential reduction of residual risks associated with including the Secondary Flood Protection Systems proposed by the NEWCA and Wharf District Council Flood Resilience Plans.

• Avoid Precluding Future Urban Realm Improvements

• Design flood walls for future loading associated with planned land modifications. Design all flood protection wall foundations and concrete reinforcement to support additional loading associated with backfill and surface features associated with urban realm improvements (elevated land, public open space areas, Harborwalk areas, waterfront access routes, etc.) indicated on the WDC and NEWCA Flood Resilience Plans.

• Collaborate with the City and its partners to consider future public realm projects in the design of the CSRM project. Moving forward, we urge USACE to collaborate with the City to ensure the CSRM project is designed in consideration of supplemental projects to amend and connect the public realm to the CSRM project’s coastal flood protection work, to avoid precluding public realm improvements such as for the Harborwalk, parks, nature-based strategies, and fill for placemaking.

• Protect the Boston Sail Loft restaurant and avoid precluding future expansion of the Harborwalk deck around the restaurant. The Boston Sail Loft restaurant on Commercial Wharf is partially cantilevered over the water. The CSRM flood barrier design does not appear to reflect this existing condition. Design the CSRM flood barriers to avoid impacting the existing building, and to avoid precluding the future Harborwalk deck expansion at this restaurant proposed on the NEWCA Flood Resilience Plan.

• Accommodate Future Stormwater System Improvements

• Accommodate future planned improvements to the City’s stormwater management system to protect against combined rainfall and high storm surge events. Boston Water and Sewer Commission’s (BWSC) Coastal Stormwater Discharge Analysis report concludes that shoreline flood protection projects that do not improve the City’s current stormwater infrastructure will leave the neighborhood exposed to extensive flooding during combined rainfall and storm surge events. We request USACE consider the potential interior flooding associated with a 100-year rainfall combined with a storm surge of 13.8’ NAVD88 as indicated in the BWSC Coastal Stormwater Discharge Analysis study, and ensure the CSRM flood barriers do not preclude or make it more difficult or expensive for the City to construct the stormwater storage and pump systems necessary to protect against such a storm. This includes the following stormwater system improvements identified by BWSC, WDC, and NEWCA:

• BWSC-proposed pump system at Christopher Columbus Park.

• NEWCA-proposed stormwater storage below the decks of Battery Wharf, Burroughs Wharf, Boston Yacht Haven and the Urban Spaces building on Commercial Wharf.

• WDC-proposed stormwater storage at Central Wharf, Harbor Towers, and Rowes Wharf (note this requires a revision to the USACE flood barrier alignment at Harbor Towers to match the alignment indicated by the Wharf District Council’s Flood Resilience Plan) and associated outfall pipe from Rowes Wharf to the Fort Point Channel (refer to WDC’s Inland Stormwater Drainage & Flooding Study available at https://www.wharfdistrictcouncil.org/climateresilience)

• Use the area beneath the decks at Battery, Burroughs, and Commercial Wharves for stormwater storage, rather than infill.

• Infilling beneath these decks precludes the ability of the City to use these below-deck areas as rainfall storage to mitigate the risk of increased inland flooding associated with rainfall during a storm surge event, as indicated in the NEWCA Flood Resilience Plan. This is particularly relevant as the CSRM project does not account for wave overtopping for this neighborhood, and the flood maps in Appendix J of the IFR/EA report indicate over 2 feet of flooding will remain at Burroughs Wharf due to rainfall during a 100-year rainfall event. We note these property owners have expressed support for using the areas beneath their decks for stormwater storage as indicated on the NEWCA Flood Resilience Plan and as further described in Appendix B of this comment letter.

• Mitigate Increased Stormwater Hazards Induced by the CSRM Project

• Include Non-Structural Measures to protect Burroughs Wharf garage against rainfall-based flooding induced by the CSRM project. Figure 29 of the IFR/EA Appendix J indicates the CSRM flood barriers will increase rainfall-induced flooding at Battery Street in the North End. This coincides with the entrance to an existing underground garage at Burroughs Wharf, which may cause significant damage to the garage and below ground facilities. We request non-structural measures be provided in the CSRM project to mitigate this induced flooding and protect the existing garage.

• Elevate the Sargents Wharf parking lot to protect against rainfall-based flooding induced by the CSRM project. Figure 29 of the IFR/EA Appendix J indicates the CSRM flood barriers will increase rainfall-induced flooding at the Pilgrim Parking lot at Sargents Wharf in the North End. The project also does not address the over 3 feet of flooding anticipated at the parking lot, as indicated in Figure DB-5 in the Appendix J Attachments. This is an important parking lot for residents to park vehicles off-street during climate emergencies. We request the CSRM project address this induced risk by raising the grade of Sargents Wharf as indicated on the NEWCA Flood Resilience Plan. At a minimum, the CSRM flood barriers at Sargents Wharf should be designed to allow the parking lot to be raised to Elevation 12.0 NAVD88 in the future.

The North End Waterfront Climate Alliance appreciates this opportunity to comment on the USACE Draft Boston CSRM report, and we look forward to future refinements of this critical plan to protect our communities from flooding.

Sincerely,

Cheryl Delgreco, president

On behalf of the North End Waterfront Climate Alliance

—————

September 17, 2026

Mr. Todd Randall

U.S. Army Corps of Engineers, New England District ATTN: COB CSRM Project Team

696 Virginia Road Concord, MA 01742-2751 Via email: boston-csfrm@usace.army.mil

Subject: USACE Boston CSRM Study Draft Integrated Feasibility Report and Programmatic Environmental Assessment

The North End/Waterfront Residents’ Association (NEWRA) appreciates this opportunity to comment on the U.S. Army Corps of Engineers (USACE) Boston Coastal Storm Risk Management Study (CSRM) Draft Integrated Feasibility Report and Programmatic Environmental Assessment (IFR/EA). For 30 years, NEWRA, a 501c3 membership organizaion, has provided the North End/Waterfront residential community a process by which it can provide informed input to decision-making by city, state and federal agencies.

NEWRA has followed and been presented the work of the U.S. Army Corps of Engineers’ CSRM, the City of Boston’s Climate Ready Boston, and the North End Waterfront Climate Alliance (NEWCA) toward recommending short-term and long-term measures and projects that can reduce risks to the Downtown and North End neighborhoods from climate change, sea level rise, storm flooding, and storm surge.

NEWRA appreciates the enormous amount of work and associated public engagement in those e?orts. NEWRA supports NEWCA’s Flood Resilience Plan haps://www.newra.org/newca, the culmination of a collaborative e?ort by our neighbors across the entire North End waterfront from Commercial Wharf to Battery Wharf. While we generally support USACE’s CSRM plan, several re?nements are necessary, as described below.

• Increase Level of Protection.

• Design CSRM ?ood barrier structure foundations and concrete reinforcement to allow future height increases based on MC-FRM projections. The Massachusetts Coast Flood Risk Model (MC-FRM) is used by the City of Boston and State of Massachusetts to assess future anticipated storm surge elevations. The MC-FRM anticipates higher future storm surge elevations compared to the USACE’s analysis.

• Include the floating breakwater docks proposed by the NEWCA Flood Resilience Plan to reduce the risks of wave overtopping. Each neighborhood should be provided an equivalent level of protection using di?erent approaches sensitive to the site-speci?c considerations for each neighborhood. The CSRM plan provides the North End neighborhood a lower level of protection – at top of barrier elevation 14.0’ NAVD88 – than other neighborhoods.

• Supplement the currently proposed ?ood barriers with additional wave dissipators and nature-based strategies (e.g. ?oating breakwater docks, living shorelines, living seawalls, ?oating wetlands). These additional measures would increase the level of storm surge protection beyond what the currently proposed ?ood barriers can and help protect and/or enhance waterfront access and enjoyment and environmental resources, all of which are important contributors to Boston’s quality of life and economy. These measures are indicated on the NEWCA Flood Resilience Plan and the Wharf District Council Flood Resilience Plan (www.wharfdistrictcouncil.org/climateresilience) and should be added to the CSRM project.

• Protect the Union Wharf Townhouses. The CSRM project should include a new seawall that cuts o? below-ground ?ow paths into the townhouses and that can support eventual installation of a 4-Y glass wall above.

• Protect the Boston Sail Lo9 restaurant.

• Alternative DT-3, not DT-3A, should Proceed to Further Design Development.

We urge USACE to select DT-3, along with the re?nements outlined in this letter, as the recommended plan. Our concerns regarding alternative DT-3A include:

DT-3A leaves all properties in the North End north of Fleet Street exposed to ?ooding.

• DT-3A’s proposes a deployable barrier across Atlantic Avenue that would necessitate long-duration closures of this primary roadway and local evacuation route to protect from Nor’easters that can last for multiple days.

• DT-3A does not provide a viable approach to protecting Battery and Burroughs Wharves.

• The cost of DT-3 compared to DT-3A is in?ated with the CSRM project’s approach to in?ll beneath the Battery and Burroughs Wharf decks. Serious consideration should be given instead to leaving the spaces beneath the wharf decks open for use as stormwater storage.

• DT-3A does not assess potential damages associated with leaving the harbor tunnels and underground structures unprotected. alternative DT-3 protects these underground structures by preventing deep storm surge waters from adding load to the land areas above them.

• Advance AcBon Plan 2, with AcBon Plan 3 as an early element. USACE is currently considering advancing only Acton Plan 3, which protects against ?ood pathways at Moakley Park in South Boston. We urge USACE to advocate for advancing both Acton Plan 2 and Acton Plan 3 to provide assurance of federally-funded city-wide ?ood protection, including protection to North End properties and pathways that already experience coastal ?ooding.

• Reconstruct the Harborwalk. As the CSRM project will be impacuag all existing Harborwalks throughout the neighborhood, the project should include reconstruction of all elements of these Harborwalks at an elevation that provides views and access to the Harbor.

• Provide Redundancy Against Single Points of Failure. We request USACE conduct an analysis of potential risk reduction associated with including the Secondary Flood protection Systems proposed by the NEWCA and Wharf District Council plans.

• Avoid Precluding Future Urban Realm Improvements. Design all ?ood protection wall foundations and concrete reinforcement to support additional loading associated with urban realm improvements (elevated land, public open space areas, Harborwalk areas, waterfront access routes, etc.), such as those indicated on the WDC and NEWCA Flood Resilience Plans.

• Accommodate Future Stormwater System Improvements. Accommodate planned/avoid precluding proposed improvements to the City’s stormwater management system to protect against combined rainfall and high storm surge events. These include and may not be limited to a BWSC proposed pump system at Christopher Columbus Park; NEWCA’s proposed stormwater storage below the decks of Battery Wharf, Burroughs Wharf, Boston Yacht Haven and the Urban Spaces building on Commercial Wharf; and WDC’s proposed stormwater storage at Central Wharf, Harbor Towers, and Rowes Wharf.

• Mitigate Increased Stormwater Hazards Induced by the CSRM Project

• Include Non-Structural Measures to protect Burroughs Wharf garage against rainfall-based ?ooding induced by the CSRM project.

• Elevate the Sargents Wharf parking lot to protect against rainfall-based ?ooding induced by the CSRM project.

NEWRA appreciates this opportunity to comment and looks forward to future re?nements of this critical plan to protect our community from ?ooding.

On behalf of the North End Waterfront Residents association,

Cheryl Delgreco, president

Jenn Crampton, vice president

Kirsten Ho?man, secretary

Mary Ann D’Amato, treasurer

cc: Michelle Wu, Mayor, City of Boston Senator Lydia Edwards, RepresentaUve Aaron Michlewitz, City Councilor Gabriela Coleaa Zapata, At-Large City Councilors Ruthzee Louijeune, Julia Mejia, Erin Murphy, and Henry Santana Brian Swea, Chief Climate O?cer, City of Boston, Kate Roosa, P.E., O?ce of Climate Resilience, City of Boston