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A n A ll- olunte e r Non-P rofit C ommunity O rga nization V

201 Brighton 1s Road, S uite 4D, Brooklyn, NY 11235 t

T el. (7 18) 74 3-10 27

F rie n d s o f t h e B o a rd w a k
A voluntary Not- Profit 501(3)c Organization lncorporated in the State of New ForYo rkw w w .fo bco ney isla nd .co m

De a r NYC De sign Co m m issio ne rs,

W e are residents of the various Riegelmann (Coney lsland) Boardwalk communities, as

well as New Yorkers living elsewhere in the City. W e are members of two community groups,

the ConeyBrighton Boardwalk Alliance and Friends of the Boardwalk, and we were present at

the Design Com mission's hearingon October 24th 2 , 011. We wishto provide youwith information in response to questions and areas of concern that you raised with officials of the NYC Departmen of Parks and Recreation ("Parks D t epartm ent") at that m eeting regardingthe Riegelmann Boardwalk and the Parks D epartm ent's proposal, which includes the use of
substantial amounts of concrete to replace currently deteriorating wood. W e also hope to clear

up certain inaccurate or wholly false statem ents made by Parks Department officials at this meeting, and to provide you withthe sources fromwhich we obtained our information, which
can be inde pende nt ly ve rified.

lt is helpful to have an appreciation of some of the main factors that have led to the premature deterioration of the Boardwalk. First, the Parks Departm has packed in sand ent
under the Boardwalk, and piled it right up to the level of the boards and into the spaces

between them, leaving no space for the wood to breathe. This causes pressure that loosens,

damages, and rots them. Second, the Parks Department runs heavy trucks alongthe Boardwalk,
mostly for trash collection, which also loosens and otherwise damages the boards Creative
solutions to ameliorate this include the use of lightweight vehicles and trash pickup from the

beach, with trash cans arranged at the railing next to the sand. These are solutions that other
*

communities have used, but neither has yet been tried here. Finally, there is little to no

maintenance done when small repairs are necessary and replacement of a few boards would

address the problem. lnstead, large sections are allowed to fall into disrepair. This combination
of factors contributes to the creation of the very condition that the Parks Department then says

requires new capital projects, and now a new material, concrete, to address.

As was stated by one of the gentleman Commissioners at the hearing, we believe that,
absent the existence of an overwhelmingly compelling reason to do so, it is thoroughly

inappropriate to replace this aesthetic jewel of our city, which has been in existence since 1923,
w ith concrete. Concrete would transform our beloved Boardw alk into a w holly different entity

- no longer a boardwalk but instead a sidewalk or roadway, with its aesthetic integrity severely
diminished. W e believe that no sufficiently compelling reason to radically alter the Boardwalk

in this way exists. For each reason to use concrete that is posited by the Parks Department, there are other structurally, aesthetically, and financially viable and superior options that would
maintain the Boardwalk as a true boardwalk, allowing substantial numbers of people - local residents and visitors alike - to continue to enjoy the unique properties and special benefits
t hat only a true boardw alk can offer!

Amusement area vendors understand the value and special quality of a true all wood

boardwalk, and they fought for it ! As a result, they were given the concession that in their area,
the boardwalk would always remain wood. Residents of our 8oardwalk communities

strenuously objected to this blatant and disrespectful double standard of treatment, giving

special preferential treatment to this amusement area, while the rest of the Boardwalk, traversing more than two miles through the Brighton Beach and Coney lsland neighborhoods, would be destroyed, either entirely or partially cpnverted into a concrete walkway. The cynical

justification that was offered for this, was that this could be seen as the "historic district" To
those of us who live there, this was a transparent attempt to justify the unjustifiable. Clearly,

for any objective observer, the Boardwalk, as both a historic and an aesthetic entity, cannot be
segmented into dist ricts!

The Parks Department cites three major reasons to use concrete on the Boardwalk. 1) as a result of a decision made by the City of New York, rainforest wood can no longer be used; 2) a supposed need for a material that can support heavy vehicles and not degrade too quickly as a
result of such traffic; and 3) concrete is supposedly cheaper. W e w ill address each of these
is s u e s in t u r n

The citywide policy to reduce or eliminate the use of rainforest wood does not require
t hat w e t urn to concret e instead - t he Parks Depart me nt' s claim t hat concret e is t he best

material to use in its place is unfounded. ln 2011 there is a w ide spect rum of available

materials, including sustainable domestic hardwoods, recycled structural composites, and

thermally modified hardwoods. Concrete is by no means the only viable alternative, and is in
fact not t he best alternat ive eit her. The City can remain committed to using a material t hat is

durable and meets other requirements, w hile still remaining as close in nature to the wood that

has long been used on the Boardwalk as possible. Doing so would maintain two crucial
elements of a boardwalk - an appearance and a feeling, both literal in the feel on one's feet

and also in terms of ambiance - keeping it as similar as possible to that w hich our community

and our city have enjoyed for nearly a century. Not only are a variety of sustainable woods available, a study commissioned by the Parks Department in 2008 and conducted by the
Columbia School of Engineering concluded that, given all of the different groups that use the Boardwalk in a variety of ways, the desire to keep the ambiance and feel of a true boardwalk,
installation and maintenance cost factors, strength and durability (particularly with respect to

vehicles), as well as a host of other factors, Black Locust wood was the best material to use in

repairing and rebuilding the Boardwalk! For reasons unknown, the Parks Department did not
include this determination or the recommended wood in its plan. The only reason that was

cited for not considering Black Locust wood was that it is not available in the quantities

necessary, but this can be easily amended by doingjust asthe Parks Department had done for years while it was using rainforest woods - stockpiling Black Locust wood until desired quantities are achieved. Moreover, the veracity of the Parks Department's assertion is questionable, consideringthat a quick, elementary search on the internet reveals suppliers of
B lack Loc ust w oo d fo r large-scale project s.

Your Commission asked the Parks Department to look at w hich materials other seaside

communities are using for their boardwalks. W e have contacted officials at many different
boardw alks and found t hat the vast majority are using a real and sustainable domestic

hardwood. For example, Orono Bog in Maine uses a plasticwood composite to hold up natural wood decking, a plan that would also make sense for Riegelmann Boardwalk. Myrtle Beach,
South Carolina has a 1.2 mile traditional boardw alk. Decades ago, they replaced their .

traditional boardwalk w ith a concrete walk, but thereafter replaced that concrete w ith real

wood, returning to a true boardwalk. Ultimately, their experience suggested to them that
w hen all factors w ere considered, a tradit ional wood boardw alk w as preferable and thus t hey
ret u rne d t o t he use of w oo d, w hic h re ma ins t o day .

Ocean City, M aryland, is another case of a boardwalk community w hose experience

might be instructive for our own situation. The city decided to convert the wood boardwalk to
concrete in t he mid-1950s after a storm severely damaged it. ln t he late 1990s, how ever, the
b o a rd w a lk w a s co n v e rt e d ba c k t o w o o d . J im M at h ia s, O ce a n Cit y M ay o r, w a s a st ro n g

supporter of the change. "The reason we did that was, very simply, nostalgia. People used to
come dow n t o t his sout he rn e nd of t he boardw alk and say 'W hat happe ned? W here' s t he

boardwalk?' W e'd say, 'This is it,' and they'd say 'No, this is concrete. lt's not the same thing.'
That was important to people. lt seems like a little thing but it made a huge difference. ... The
tow n's name is Ocean City, and the heart of t he tow n is t he ocean. But t he soul of t he tow n is

' http:h communitv^ seas^ columbia^ edu/cslp/reports/springO 8/Boardwalksfinal% 20Report^ od

the Boardwalk."2 The wooden boardwalk proved to be a catalyst for economic prosperity. ln

1999, the second year of the new boardwalk's life, the Baltim Sun reported that "Beach ore business is booming alongthe 10 mile Atlantic strand, and everyone ... is practically delirious at the prospect of back- back record seasons." (Please see attached letters from Ocean City tooff icials.)

Ocean City looked at a variety of materials and tried them out using very small test sections - a few feet square each - unlike our Parks Department's use of 15 million dollars on
two "test sections", each between two and three blocks long of slab concrete, to determine

that it didn't work well. lnitially, Ocean City was interested in the possibility of using recycled

plastic lumber for the decking. ln a leng conversation we hadwiththeir Chief Engineer, Mr. thy Terry McGean, he explained their disappointm withtheir test results. "The plastic", he said, ent "just looked awful? lt looked like what it was - cold, gray plastic!" "ln reality it was not at all
like real wood", he continued. "lt was so bad that many people told us that if that's was we decided to use for the Boardwalk decking, they would no longer visit the 8oardwalk!" Mr.

McGean not only did an intensive investigation of a variety of possible materials, he then did a projected 50 year cost comparison of three different plans Two of them used concrete forthe
middle section of the 8oardwalk to support the tram that operates continually, while the third
was all wood. He determined that over 50 year time span, the all wood Boardwalk would cost 1 million dollars more to install and maintain. On a yearly basis, that is $24,O O more for an all O wood 8oardwalk two miles in length. Based on a poll they conducted, sentiment in Ocean City,
as here in New York, was overwhelmingly in favor of an all wood Boardwalk. Mr. McGean

noted that, given the preference of most people and determiningthat the additional cost was moderate, the Ocean City Council with the Mayor's support, voted to maintain an all wood 8oardwalk. Their Mayor, Mr. James Mathias stated that, whatever the cost differential, even if substantial, he would still have supported maintaining a true wood Boardwalk. lt's value he said, can't be measured solely, or even mainly, in dollars and cents. lts value lies in its special
and unique qualities, and the great enjoyment that all citizens derive from it.
There are many other boardwalks that we could cite that are using various woods, and
ot he r w at e rf ro nt co m m unit ies w hose off icials hav e st at ed t hat t hey w o uld nev e r co nside r

concrete, as that would defeat the purpose for which their boardwalk is intended. Additionally,
four boardw alks are eit her considering or using recycled plastic lumber, w hich is very durable,

and might be considered as a costsaving alternative for the support structure - so durable, in
fact, that the U.S. military has used it for its own bridge, over which it successfully drove a

2Liliefors, J . (2006). America's Boardwalks - from Coney lsland to California. Rutgers University Press, pp.118-119

tank3 Moreover, in addition to this durability, these officials and communities keep a .

reasonable maintenance budget and use creative planningto mitigate or eliminate the use of

heavy vehicles on their boardwalks as a means of making damage even less likely, a strategy not employed previously for our own Boardwalk. On our Boardwalk, small repairs are not
attended to as they arise by the Parks Department, so that eventually entire sections are

blighted and borrowed capital funds are then used for largescale redesign - something that
would be completely unnecessary if small repairs were made in a timely manner and proper
m a int e n a n ce f u n d s w e re re t a in e d .

For extensive and detailed information regarding the availability and viability of the

range of materials that would be betterto use than concrete, please consider the information
contained in the attached letter from Mr. Tim Keating, the Executive Director of Rainforest

Relief (http://www.rainforestrelief^ org/) for 20 years and an expert in this area who has been
consulted by the Parks Department many times over those years Related to the issue mentioned above of vehicular traffic on boardwalks and the Parks

Department's second major claim, Parks officials stated to your Commission that fire engines
and ambulances come on the Boardwalk. Those of us who live in the community were stunned

by this assertion, since it is not the general policy of these two agencies. Ambulances stay on the street right next to the Boardwalk and EMS workers come up on the Boardwalk to attend to
someone, carrying their bags and a stretcher. Especially in the summer months, there is so much pedestrian traffic that it would be impractical for these vehicles to do otherwise.

Additionally, in the summer, lightweight EMS vehicles ride along the sand. Further, fire engines also stay on the street - there are no hydrants on the Boardwalk. Small pumper trucks sometimes go up on the Boardwalk with the hose line attached. Even this is exceedingly rare,
as we have had, based on the memory of several longtime residents of the area, perhaps two

major fires in the last 30 years. The Fire Department and EMS can be contacted to verify their
policies w ith respect to the Boardw alk.

Thus, the need for the Boardwalk to carry heavy vehicles is not as compelling as the

Parks Department claims it to be. Moreover, a hardwood such as Black Locust meets the

required tolerance for supporting Parks Department trucks and police cars, the two types of
vehicles that are commonly seen on the Boardwalk. Additionally, the Parks Department could

mitigate the use of heavy trucks for trash collection by followingthe example of other
boardwalks and placing their trash cans along the edge of the boardwalk so they can be

3See http://www.usace- org/presentation/Structural% 20isc^

% 20Bridges%20and%20Concrete/Load%20Test%20and%20Load%20Rating%200f%20an%20'nnovative%20Recvc'e
d% 20plastic% 20Lumber Diaz Henr M cHenna % 20M lhan Lam o % 20Rlchard. df

em ptiedfromthe sand usin the sm g aller vehicles with m etallic arm that reach up and over the s edge to grab the trash cans, som of whichthe Parks Departm already has Furtherm e ent ore, the underlying portions of the Boardwalk supportingthe decking could be made of recycled plastic lumber, which, as previously m entioned, is strongenough to carry tanks.
The Parks Department's third main point is that concrete is the cheapest viable material. While concrete may be somewhat less expensive initially during material purchase and installation, longterm maintenance costs, especially in a saltwater environment, are inevitably
similar to wood. One has only to look at the concrete walk on the next beach over from

Brighton, Manhattan Beach, to witness the con tinued state of disrepair that it has been infor many years. ln addition, it was dem onstrated at the C omm ission's October hearing regarding
the Boardwalk, that after less than a year since installation, the necessity for extreme and costly

repairs to the two concrete sections onthe Boardwalkwas obvious and undeniable. Additionally, concrete deteriorates in a particularly unsightly and unsafe manner. Furthermore, repairing wood is also much less intrusive with respect to the use and enjoyment of the
Boardwalk than repairing concrete. W ith concrete, people are banned from large sections while waiting for concrete to be installed and to dry. Wood does not require such a major
intrusion - one that is a tremendous inconvenience to visitors as well as local store owners.

ln November 2010, on a walkthrough of various Boardwalk sites with the Brooklyn

Borough President, other politicians, and officials fromthe Parks Department, Mr. John Natoli,
the Head Engineer of the Parks Department, was asked what research had been done that

suggested that concrete was the best, or even an appropriate material, to spend $15 million in
funds on and to use on our Boardwalk. His response was: " Research? W hat research? W e didn't have time to do research; we had to spend the money !" W ith respect to the diligence

and quality of the Parks Department's efforts to appropriately care for our Boardwalk, this
st at e me nt speaks fo r itse lf.

At the October Design Commission hearing, Mr. Natoli, stated that the problems that
we were seeing on these concrete sections - many broken pieces, cracks, staining, etc. - were

the result of the Parks Department having had to rush its installation to get the sections opened
for the season. ln fact, it is the poorly researched, wasteful and misguided choice of concrete as

a boardwalk replacement material, that has resulted in the scarring and discontinuity of our boardwalk. The Parks Department's shoddy workmanship should be no consolation. lndeed, its negligence suggests that it either is unaware of the problems inherent in using concrete -

revealed now by these concrete sections- or may in fact be using the workmanship excuse as a

cover for these problems. We beseech you to not approve a plan that will contribute to further

similar problems, even as our community w orks tow ard having t hese sections removed and
re st o re d co rre ct ly !

Everyw here concrete has been used, it has regularly suffered from t hese same problems. Patchw ork repairs on concrete do not w ork effectively, and only make t he problem
w orse, leading to mo re chipping and cracking, as w e ll as an ext re me ly unatt ract ive appearance .

The re peat ed failure of concret e in past uses has bee n blatant ly ignored by t he Parks

Department, and should not be allow ed to recur on our beloved Boardw alk.
The re are many affordable t rue-w ood opt ions for t he Boardw alk, including, but not o nly
t hose w e hav e list ed. Ev e n if co ncret e w ere slight ly cheaper, w hich arguably it is not in t he lo ng
t e rm, t hat sho uld not be t he basis fo r dest roy ing t he Boa rdw a lk. O ne w o uld not co nside r

pav ing over Central Park because it is cheaper t han allocating appropriate maintenance funds
t o sust ain it . This is ve ry short -sight ed t hinking by t he Parks Depart ment, w hich, if allow ed to

prevail, w ould truly diminish t he quality of all of our lives in t his great metropolis. W ith a proper
design and maintainance, an all w ood boardw alk can be preserved that is only slight ly more expensive t han a concrete w alkw ay, as t he example of the tw o mile long Ocean City boardw alk
demo nst rates. The ir e nginee r calculated t hat w ith t heir creative design, installat io n and

planned maintainance w ould cost about one million dollars more for w ood, over the course of
fifty years. Thus, for $24,OOO more pre year t han concrete, t hey w ere able to preserve w hat t he
people in t he ir city e njoyed and desired, t heir aut he nt ic w ood boardw alk!
Hav ing addressed t he main reasons t hat t he Parks Depart ment be liev es co ncrete is t he
be st cho ice fo r re plac ing t he B oa rdw alk, w e w ish to re it e rat e he re briefly , so m e of t he re aso ns fo r m a int a in ing Riege lm a nn B oa rdw a lk as a t rue w oo d bo ardw a lk t hat w e re pre se nt e d t o y o u

by t he cit ize ns w ho show ed up to t est ify at yo ur Oct o be r hea ring. First, pract ica l be nefit s a re de riv e d f ro m using a mo re giv ing m at e rial t hat w ill not increase t he cha nce of im pact st re ss
inj ury fo r t he m any w a lke rs, run ne rs, a nd se nio rs w ho use t he Bo a rdw a lk o n a d aily basis.

Se co nd, co ncret e w ill ref lect m o re he at in t he sum m e r, m a king ext e nde d pe rio ds of t im e o n t he
B o a rdw a lk unco mfo rt a ble at best, a nd is mo re pro ne to icing in t he w int e r. T hird, in t he ev e nt

of a majo r sto rm, t he re w ill be mo re risk of prope rty damage to t he many peo ple w hose ho mes
a but t he B o a rdw a lk. W it h a t radit io nal boa rdw alk, t he spaces bet w e e n t he slat s prov ide a

dissipat ing effect during storms. A hard, so lid mat erial like concrete has precise ly t he o pposit e
eff e ct . Due t o it s pro pe rt y of reflect ing and e nhancing t he e ne rgy of t he w at e r co nt aine d in
w av es, it s use w ill like ly result in mo re da m age t ha n ot he rw ise w o uld hav e o ccu rred . Fo u rt h, as

st at e d, t he lit e ral fe e l of t he Bo a rdw alk and its a m biance is at o nce uniq ue a nd sublim e . lt is

o ne of t he few places in o ur city to w hich peo ple grav it ate in order to experie nce a respit e fro m
t h e co ncre t e a ll a ro u n d us. lt le ads t o inc re ase d re v e n ue f o r t h e bus ine sse s o n t he B o a rdw a lk,

as t he exa m ple of O ce a n Cit y cle a rly de m o nst rate s. The de m ise of t he B o a rdw a lk w o uld le ad t o

many people being disinclined to eve n visit t he area, as some have already indicat ed on our Face book page . The Riegelmann Boardw alk is historic and w orldfamous. lts aest het ic int egrity
and t he v ario us w ay s in w hich it cont ributes to our com m unity' s and city' s v itality sho uld not be

dest royed because of a lack of appreciation of these factors and the result ing lack of passion by
t he Parks De part me nt to do appro priate research and planning to prot ect and e nhance t his
ico n ic j e w e l

By contrast, the residents of New York City - voting citizens and const ituents of the

many elected officials throughout the city - do have a deep passion for their Boardw alk and do
not w a nt t he B oa rdw a lk t urne d int o co ncret e . T ho usa nds of signat ures co llect e d o n pet it io ns, f ro m loca l a nd no n-lo ca l resid e nts a like, att est to t his. T he o nly pe o ple pushing t his a re

me mbe rs of t he Parks De part ment, and t hey do not represent t he opinions and desires of t he

peo ple of New York. M any of our elected officials support maintaining a true boardw alk,
including t he B rookly n 8orough P reside nt M arty M arkow itz and many local re prese nt at ives.

One year ago, at the December 17, 2010 meeting of our local Community Board 13, our
Co u ncilm a n Do me nic Recchia st at e d t hat " a ll t he e lect e d off icials a re w o rking t oget he r o n t he

Bo ardw alk issue... and have bee n w o rking hard to find an alte rnat iv e to co ncrete ."

Congressman J errold Nadler formulated a letter t hat w as signed by all the Council members

asking t he City and the Parks Depart ment to preserve the Boardw alk free of concrete. Furt her,
in M arch of t his y ear (2011), our Community Board, represent ing t he desires of local reside nt s,
voted 21-7 against t he Parks Depart me nt's plan to use any co ncret e o n t he Boardw alk. The

Parks De part ment chose to ignore t his, t he expressed w ill of our community, and proceeded to
att e m pt t o hav e its pla n e nact ed no net he less.
M o reov e r, in a new slett e r se nt to co nst it ue nt s in t he B righto n B e ac h and Co ney lsland

com munity j ust last mont h (Nove mber 2011) and directed ent irely t o t he issue of our
Bo a rdw a lk, o ur St at e Se nato r st at e d t he fo llow ing. " Now t hat t he Pa rks De part me nt has t he
m a ndat e t o go bac k t o t he d raw ing bo ard a nd co m e up w it h a bett e r plan, l re ac he d o ut t o Cit y P a rks Co m m issio ne r A d ria n B e ne pe, urging his age ncy to giv e se rio us co nside rat io n t o no n-

co ncret e a lt e rnat iv es (such as sy nt het ic o r do m est ic w oo d, fo r exa m ple ) t hat a re bot h co st effe ct iv e a nd prese rv e t he ae st het ics t hat hav e made t he B oa rdw a lk a t re asure d part of o ur

hist o ry a nd la ndsca pe . No a mo unt of sav ings w o uld hav e co m pe nsat e d fo r t he t re m e ndo us

lo ss in v isua l a ppe al sho uld t he o riginal p la n be e n allow ed to proce ed ." He co nc lud es, " T he city

ne e ds t o use t his cha nce to t ransfo rm t he Bo a rdw a lk, not int o a hideo us but st ruct ura lly so und sla b of co ncret e, but a v isua lly ple asing and e qua lly so und st ruct ure t hat pre se rv es t he

e lem ents of w hat a Boardw alk sho uld, in fact, be. As t he Design Com missio n agrees, co ncret e
isn't high o n a nyo ne' s list ." This st at e m e nt reflect s t he o pinio n not o nly of mo st loca l offi cia ls, but a lso t he ir co nst it ue nt s - t he peo ple w ho love Co ney lsland a nd t he 8o a rdw alk and w ant t o se e t he be st possible o ut co m e fo r t he m .

P lease e nsure t hat the desires of t he people are uphe ld in t he re pairs of the B oardw alk.

Thank you for your consideration of t his important issue t hat is so crucial to the heart of t his City. lf w e can provide furt her information, please do not hesitate to contact us at your
convenience. As members of the Design Commission, committed to preserving, enhancing, and

being t he guardians of the City's aesthet ic life and treasures, w e hope and trust that you appreciate the w isdom of this and w ill only approve a plan that revitalizes the 8oardw alk as the
t rue w oo de n bo a rdw a lk it has lo ng bee n and is me ant t o be !
Co nce rne d Reside nt s of t he Riege lma nn Bo a rdw a lk Co m m unit ies
F r ie n d s o f t h e B o a r d w a lk T o d d D o b r in -P r e s id e n t

Co ney-8right o n Bo ardw a lk A lliance

R o b e rt B u r st e in -C h a i r m a n