The 2030 plan is a mixture of good and bad. The most problematic proposals would let the city continue to subsidize development in waterways and floodplains, harming irreplaceable marine habitats in the waters around the city.

This policy will make the city more vulnerable to the rising sea levels, more violent windstorms, severe storm surges and flooding that the plan acknowledges are coming with climate change. The city is overdue for a hurricane like Katrina. When it comes, as many as 3 million people may have to be evacuated to shelters, the plan says.

Retreat from the Coast?

If New York wants to be a model for other cities and for sustainable development around the globe, it needs to limit subsidies for sewers and other infrastructure to support development in flood-prone areas, and end subsidies almost entirely for construction in or on the waters around the city. Climate scientists refer to such policies as a "retreat from the coast." These sensible measures are completely missing from the plan.

PlaNYC proposals for protecting New Yorkers from looming storm and flooding threats are weak or counterproductive. Having the city planning department, which advocates waterfront development, continue updating the Federal Emergency Management Agency's floodplain maps will do no good if the information is unreliable, if citizens can't get it or use it easily, or if officials ignore it in budget decisions. PlaNYC's proposal to complete the city's application to FEMA for discounted flood insurance could just create incentives for development in floodplains, putting people in harm's way.

Building out into the water is even riskier than building in upland floodplains--and far more environmentally destructive. The waters around the city provide invaluable habitat for an astonishing variety of species. Habitat loss and destruction is the single most important factor in declining global fisheries, and a recent study warned that worldwide fisheries stocks will collapse by 2048 unless the way we use aquatic resources changes. With fisheries the most important source of essential protein for the world's malnourished populations, we need to halt all possible in-water construction. The great Hudson River system (including waters around the city) is one of the most important contributors to East Coast fisheries. Its natural ecosystems can sustain and renew themselves forever--but only if public officials leave aquatic habitats alone.

When a Park Is Not A Park

The plan pledges to promote parks, recreation and waterfront access and revitalization. But the administration has used this same rhetoric before to cloak its support for misplaced development and other habitat-threatening ventures on and in the water. New water and sewer infrastructure, paid for with skyrocketing ratepayers' fees, may be extended out into the water to serve the catering halls, sports complexes and multiplexes proposed as part of the so-called Hudson River Park project. PlaNYC's proposed mini-power plants and new brownfields programs could be used to subsidize this kind of misplaced, non-water-dependent development in the water as well. The way plaNYC mischaracterizes the 1972 Clean Water Act to support using public waterways for "recreation" is especially disturbing, since football fields, stadiums and huge playing fields that don't need to be in the water could be sold as "recreation."

PlaNYC's unexamined premise is that the City must grow by nearly a million people by 2030. This is a questionable assumption for a coastal city built primarily on islands, and especially for Manhattan, which is nearly impossible to evacuate in catastrophes. New York's top public spending priority should be making the city safer and better for all the people who live and work here already--maintaining an unparalleled existing mass transit system in good repair; keeping its superb stock of existing housing affordable; reducing class size until every child can read. Using taxpayers,' ratepayers,' straphangers' or drivers' money to expand the city at its periphery for a wealthy few would be gross misallocation of public resources--both natural resources and limited public funds.

Marcy Benstock is director of the Clean Air Campaign.