Congestion pricing advocate Carolyn Konheim and consulting partner Brian Ketcham are advising the Bloomberg administration to drop its resistance to a congestion pricing Environmental Impact Study.
The two say a study is needed to head off "likely 11th hour litigation" aimed at stopping the three-year pilot program from taking effect, a possibility Streetsblog alluded to following the first meeting of the Traffic Congestion Mitigation Commission late last month.
"[D]ecision-makers need to know that the selection of the system to be tested has considered all reasonable alternatives to achieve the Mayor’s admirable goals," reads a press release announcing Konheim and Ketcham’s open letter to Mayor Bloomberg.
The most promising alternative to be examined in an environmental assessment is "charging at the real chokepoints in roadway capacity — our river crossings and highways," according to Ketcham, a traffic engineer who has regarded bridge tolls as the premier congestion pricing strategy since he introduced them in his landmark Clean Air plan for New York City in 1973. Tolling the four free East River bridges equal to all MTA crossings and across 60th Street, river to river, he calculates "would be at least as effective as PlaNYC in reducing congestion and would generate far more funding for transit."
The independent Brooklyn-based planners estimate that a pricing cordon that crosses bridge and tunnel spans and 60th Street would require E-ZPass monitors on about 50 inbound lanes, whereas the charging network necessitated by PlaNYC’s complex avoidance of tolls could require detectors and cameras on1,000 to 2,000 lanes. Based on London’s operating costs for a simpler single cordon, they foresee that the charging grid in PlaNYC would consume most of the congestion pricing revenue, leaving little funding for transit — a major goal of the mayor’s plan and the long-term aim of transit advocates.
Mr. Ketcham and Ms. Konheim suggest numerous strategies as alternatives to or companions of congestion pricing, particularly, the kind of comprehensive parking control and parking pricing program instituted in London before road pricing, and measures to reduce taxi cruising, a "major source of New York’s congestion."
The full text of the letter appears after the jump.
Hon. Michael Bloomberg
New York, NY 10007
Re: Congestion Pricing Pilot Test Must Undergo Environmental Review
As long time advocates of congestion pricing in New York City, we fear that your entire plan could be in self-imposed jeopardy. Some of your PlaNYC team wrongly assert that compliance with the State Environmental Quality Review Act need not occur until after the three-year pilot test. It is a mistake to dismiss this clear legal mandate as a delaying tactic of opponents of congestion pricing. Their call for an EIS now is a sure signal that they will see you in court if you have not taken some defensible action to comply with SEQRA, described further in the enclosure. The SEQR process may be inconvenient and is certainly imperfect, but it is mandatory in New York State for all discretionary actions of government that have the potential for causing a significant impact — as, indeed, is your intent. The virtue of your program’s goals does not exempt compliance with the SEQR process. Nor does virtue protect your proposal from 11th hour litigation that could de-rail implementation on the grounds of failing to identify unintended consequences or not adequately evaluating alternatives that further PlaNYC goals.
Your team cannot argue both ways. On one hand, they are saying that the data already collected are adequate to meet the purpose of SEQRA, which is to enable government agencies to make informed decisions. At the same time, they are saying that any SEQR review requires collecting data during the 3-year pilot because the regional model is an imperfect tool for predicting local impacts. If so, they cannot then cite the model to assure communities outside the pricing zone that they would not be adversely affected by commuter parking or over-crowded trains.
Most of all, decision makers need to know that the selection of the system to be tested has considered all reasonable alternatives to achieve your admirable goals: reducing congestion and global warming emissions; generating funds to improve transit; maintaining the city’s global economic leadership; and promoting community quality of life and air quality. Thus, the most promising cost-effective alternative must, by definition, be identified in advance of the pilot test.
It is also specious for your team to claim SEQR exemption on the grounds that the Action is reversible and is "not like having to tear down a building." Overhead gantries at hundreds of charging locations would, in fact, be major construction. Last week, the MTA reported that the half-billion dollar cost of transit services to support the pilot period would cause a major reordering of its adopted capital program. The 3-year test will extract well over a billion dollars from the region’s motorists. A 3 year change of travel patterns will have long-term effects — for good or ill — on the business climate, people’s lifestyles and investments across the region. In no way can it be argued that a full scale 3-year "trial" qualifies for the SEQR exemption allowed for feasibility, engineering and planning studies and other purely paper exercises.
Your compelling case for road pricing finally permits rational assessment of closing New York’s free bridge loophole, especially in combination with a single charging cordon across Manhattan. Charging at the chokepoints in roadway capacity — our river crossings and highways — could be at least as effective as PlaNYC in reducing congestion and would generate far more funding for transit, a major goal. Based on London’s costs for operating a ring of street charging monitors, it is evident that administering the more complex charging network in PlaNYC of monitors on 1,000-2000 lanes would consume most of the revenue, leaving little for transit. When your advisors seized on London’s street cordon charging system as a way for New York to avoid the historical political stigma of bridge tolls, we think they had no idea of the power of the campaign you would mobilize. Nor did they gauge the latent anti-traffic fervor across the city that now seeks the local traffic relief of bridge tolls, the premier "congestion pricing" strategy in NYC for three decades.
Most promising, but rarely discussed, is the reduction of congestion far beyond the pricing zone that will likely result from reducing trips to the city center and eliminating the distortions of travel due to toll differentials. Our modeling in 2003 shows that tolling the four free East River bridges at the same rate as the MTA crossings would cut more than 9% of the time citywide that motorists, truckers and bus riders now waste stuck in traffic. Most of the travel time savings would be in Brooklyn and Queens where drivers would no longer clog routes to the free bridges. The ripple effect of faster travel would benefit motorists not even using the bridges — and communities everywhere. Not only would this exceed your goal of 7% less congestion delay in Manhattan, but it could be accomplished virtually overnight with about 25 overhead E-ZPass scanners on the four free East River bridges. Adding another 28 charging points across 60th Street, river to river, would capture the other half of the traffic that now escapes tolls and it would achieve the political equity missing in past tolling proposals. Instituting London-style annual fees for residential parking permits and strict limits for parking in the pricing zone could provide an equitable revenue trade off for eliminating fees for Intra-zonal trips and the costly collection grid.
Our 1995 Four World Cities Study, a milestone comparison of transport in the global financial capitals, revealed strong similarities between London and New York. But important differences must be accounted for in predicting the effects of congestion pricing. In New York, the tolls at most entrances will be deducted from the new charge, lowering its differential impact. Manhattan highways fall far short of London’s ring road bypasses with their capacity improvements that smoothed the absorption of traffic diverted from the congestion zone. New York lacks London’s comprehensive parking pricing program that prevents long term parking almost everywhere. New York has none of London’s initiatives to curtail taxi cruising and erratic maneuvers which are a major cause of congestion. And New York has not created the pervasive pedestrian streetscape, which London First Deputy Mayor Nicky Gavron cites as the real objective of congestion pricing. When you are next in London, get the lowdown on reliance on high-tech charging systems from Deputy Mayor Gavron. Last May at NYU, she confided: If London had New York’s bridges and tunnels, it would never have created a street cordon. Why would New York propose multiple cordons-London has enough trouble with one. You’ve got parking all wrong in New York. Parking pricing should come first or, at least, as a companion to road pricing
Your PlaNYC team cannot continue to validate their public assurances by referring to London without these caveats and without making the PlaNYC model completely transparent, reporting all its underlying data and assumptions. To maintain the momentum of your potential congestion breakthrough, the City should now be preparing at least an EAS to preempt 11th hour litigation. This necessitates gathering and openly analyzing the extensive baseline data, as preceded London’s test program. A forthright SEQR/CEQR process will build confidence in the selected outcome by enabling public scrutiny of the analysis of alternatives and their consequences. A full accounting of the societal costs of vehicle travel would also show that the economic benefits of comprehensive congestion reduction are even greater than have been reported to you to date. With a vested interest in your success that goes back 30 years when we first introduced the pricing concept, we stand ready to help you and your team assess what works best for New York.
Carolyn Konheim & Brian Ketcham, P.E.
cc: Traffic Congestion Mitigation Commission; other interested parties