RPA Refutes Anti-Pricing “Alternatives” Study

On Wednesday, Jeffrey Zupan, Regional Plan Association’s transportation analyst, issued a comprehensive
of the main traffic reducing measures proposed in Keep NYC Congestion Tax Free’s anti-congestion pricing report, “Alternative Approaches to Traffic
Congestion Mitigation in the Manhattan Central Business District."

Thanks to Zupan, Transportation Alternatives and other critics, four fundamental problems with the Keep NYC Congestion Tax Free plan have emerged:

1. Any alternative
plan which does not include some form of congestion pricing will forfeit $354.5
in federal transportation aid
— much of which is dedicated to bus
improvements in Brooklyn and Queens.

2. The plan does
not address through traffic, which accounts for 39%
of driving in the
Manhattan CBD. Congestion
pricing does.

3. The plan does not
address — and may worsen — traffic diversions from paid river crossings to free
East River and Harlem River bridges,
which hurt neighborhoods including Downtown Brooklyn, LIC/Woodside, Harlem and the South Bronx. Congestion pricing directly addresses these traffic diversions.

4. Some of the traffic reducing measures in the plan — value parking pricing, variable tolls and BRT,
for example — would be far more
effective if used with congestion pricing, instead of as a substitute for it. Many of the measures are not "alternatives" to congestion pricing but complements.

Among other problems with the report, the Keep NYC Congestion Tax Free plan applies an "equity double standard":  It harshly criticizes congestion pricing for its pocketbook impact on middle class motorists while ignoring the impacts of value parking, variable tolling and $200 double parking tickets that the plan would impose on these same motorists.

Zupan sums up the "Alternatives" report:

While many of these measures are
worthwhile, the report overstates both their traffic reduction impact and their
revenue potential. Many of these
estimates are speculative, and the costs and difficulties of implementation are
largely unaddressed. More importantly,
nearly all of these would be far more effective if implemented in combination
with congestion pricing.

The full text of Zupan’s comments appears after the jump.

Comments by Jeffrey M. Zupan, Senior Fellow for Transportation
October 15, 2007
on “Alternative Approaches to Traffic Congestion Mitigation in the Manhattan Central Business District (October 2007)”
by Keep New York Congestion Tax Free

This report argues for a set of 13 proposals that could
reduce vehicles miles traveled and congestion by as much or more than PlaNYC’s
proposed congestion pricing pilot program. While many of these measures are worthwhile, the report overstates both
their traffic reduction impact and their revenue potential. Many of these estimates are speculative, and
the costs and difficulties of implementation are largely unaddressed.  More importantly, nearly all of these would
be far more effective if implemented in combination with congestion
The following comments address
the specific proposals in the report.

Meter 10,000 now free
on-street spaces and charge double the current rate:
The report estimates that this action would
reduce vehicle miles traveled (VMT) by 1.8 to 2.4 percent and increase revenues
by $80 to $100 million per year. The report indicates that a 1995 study found
that cruising for on-street parking accounts for 15 percent of VMT in west
midtown during midday, and they extrapolate this to all day for all of the
charging zone, an unsupported assumption. The revenue assumptions are equivalent to each parking space being used
fully for 13 hours each weekday, which may be overly optimistic. They do not account for the added cost of
meter installation, enforcement, and administration. Conclusion: Traffic impacts are conjectural
and net revenue gains are likely to be too high.

Reforming placard
The report indicates such
reform could lead to reductions of “perhaps 2 to 3 percent” and add $50 to $60
million in revenues. They cite Bruce Schaller’s reports on the subject. There
are three problems with their analysis. First, they rely on a hypothetical example by Schaller of a 14,000
reduction in cars driven by government employees, i.e. a “what if” not an
estimate. But they also say that a
review to identify which workers should receive (or keep) placards must be
done. There is no certainty that the resulting review would eliminate 14,000
workers from the placard pool. Second,
they assume that each worker travels 4 to 5 miles per day within the zone,
which is much too high since most of the workers are destined for Lower
Manhattan and the vast majority are likely to cross into the zone across the
nearby East River, and if they do come from the north use the FDR Drive or West
Street. Third, the report takes credit
for added revenue as former placard users switch to on-street meters.  This assumption is flawed in two respects: a)
it cannot assume that these workers would continue to drive and switch to
on-street meters, as many may switch to public transit or off-street parking,
and b) the added revenue has already been counted in the on-street meter
proposal discussed above. Conclusion:
Both the VMT reductions and revenue potential are likely to be much lower than
estimated in the report and implementation will be difficult.  

Reduction in taxi
This action is estimated to reduce VMT by “perhaps 2 to 3
percent.”  No revenue potential is
assumed. They target a goal of 50
additional cab stands to accomplish this, but do not discuss locations or the
difficulty in finding locations where it can make sense from a traffic impact
perspective. The report states that
cruising accounts for 13 percent of VMT and takes credit for reductions in
cruising by 10 to 20 percent, not out of line IF you could install 50 cab
stands. Conclusion: Ability to implement is unproven.

Higher taxi fares:
A $3 surcharge for trips starting or ending in the zone is suggested, which is
estimated to reduce VMT by 1.5 percent. The report points out that taxis are excluded from the current
congestion pricing (CP) plan. No revenue gain is assumed for the City. In effect, this is a policy that could also
be effectuated through congestion pricing by eliminating or reducing the taxi
exemption. There is no discussion of the
City’s argument that this could have negative economic impacts, or the
political difficulty of getting it enacted. Conclusion: This measure, if included as part of the City’s congestion
pricing plan, would increase the revenue potential to be directed toward public

Higher and variable
tolls on existing tolls facilities
: The report’s proposal is estimated to
reduce VMTs by 1.5 percent and bring in $195 million per year. The assumption about these tolls increase is
that the added revenue is a substitute for the revenue achieved by the
congestion pricing proposal. However, it tries to take credit for expected
increases in PA and MTA tolls that have to
be made in any case to cover rising operating, maintenance and debt service
costs rather than the new money for state of good repair and system expansion
that CP would generate. So the revenue cannot be counted as a replacement for
congestion pricing revenue. It does
raise the unanswered question of whether the CP charge will increase along with

This proposal also highlights the inequities and
inefficiencies of the current system, flaws that congestion pricing would
correct. The increase of tolls on
current facilities while leaving other entry points free places the entire
financial burden on only a portion of drivers entering the CBD. It will also exacerbate congestion in
neighborhoods leading to the free crossings as drivers seek to avoid higher
tolls. Variable tolls would also be far
more effective when combined with congestion pricing. In fact, a study
commissioned by the Tri-State Transportation Campaign in August found the
largest time saving benefits would be realized if MTA
instituted a value pricing program consistent with PlaNYC’s proposed congestion
pricing plan. Conclusion: Periodic toll increases cannot be seen as a
substitute for congestion pricing, and in the absence of it would be inequitable
and lead to more traffic problems, especially in Brooklyn
and Queens, not less. Variable pricing is an effective
tool that should be implemented along with congestion pricing.

Two-way truck tolls
on the VN Bridge
are estimated to reduce VMT by 0.1 to 0.2 percent and add
$10 million in revenue. These estimates are small and conjectural and the
proposal, no matter how sound, will and has received tremendous resistance from
Staten Island. Conclusion: This proposal, although a
sound one is largely irrelevant as part of a substitute for the City’s Plan.

Increased fines from
traffic enforcement
are estimated to gain from $75 million to $150 million
in revenue annually. At the proposed fine levels, this would require an average
of 6,000 summonses a day. It would be useful to know how much of an increase in
summonses that represents. The estimates are conjectural and the cost of issuing
these summonses is not accounted for. If
successful in reducing violations, which is not ensured, the revenues would
diminish over time. One cannot take
credit for both traffic gains and sustained revenue gains from enforcement
measures. Conclusion: In the absence of
more analysis, it appears that the revenue estimates are overstated and the
enforcement costs understated.

Block the box
is proposed and estimated to gain $15 or to $25 million in revenue
based on 300 to 500 additional summonses daily. This is highly conjectural, but
like other traffic enforcement measures that issue summonses, even should the
program be successful in reducing block the box violations, the revenue gains
would diminish over time. Conclusion:
The revenue gains are likely to be overstated.

Black car enforcement
measures, construction project regulations, traffic signal upgrades, and
implementing 511
are proposed but all traffic gains are conjectural and
revenue gains, if any, are modest. Conclusion: These measures are useful
complements to the City’s CP plan, but traffic and revenue benefits are
conjectural and modest.

Added bus and ferry
are assumed to attract 5,000 auto commuters, but this estimated is
highly conjectural and unlikely; there will be no financial incentive for
drivers to shift, as there is with the congestion pricing plan.  The shift is presented as hypothetical and
none of the net added costs associated with these new services are accounted
for. Conclusion: The traffic benefits are
conjectural and the net revenues are likely to be exceeded by the costs to

  • Jason A

    I’ve grown increasingly uncomfortable with any pro-CP argument that instantly trots out the Federal Grant monies that hang in the balance… I really think this should be put to rest. While it’s great that Washington is going to offer support and assume some of the start-up costs, I can’t envision how any of this will ever change the minds of CP opponents…

    It really plays out like a glorified bribe–not to mention obscures the larger budget injustice of just how many billions Washington cheats big metro areas like NYC.

    Let CP stand on its own merits. Don’t demean the city and make us out to be beggars thankful for any scraps thrown from the king’s table…

  • JK

    This is a political process. It is impossible to ignore the federal money, just as you can’t ignore the revenue raised by pricing or the fact that pricing fees will be paid by real people who do not want to pay more to drive. If it helps, think of the federal grant as new buses, new signal controllers for BRT and new bus depots to house those buses.

    Pro-pricing supporters have made strong arguments for the environmental and economic benefits of pricing. Ideally, these would be enough to put pricing over the top. So far, they have not.

  • plist

    All politics is bribes/coercion of one sort or another. Vote for A and I’ll vote for that, vote for this or I’ll call you that, special interest group A just donated a lot of money to foundation B, gimme this or I won’t vote for that…
    And what is wrong with accepting federal money? It comes from our taxes, we’re due as much as anyone else. It’s a valid point to raise, that’s a significant amount of funding. And what sense does it make to turn down the money because metro areas are short changed in federal budgets? Cutting off your nose to spite your face.

  • Larry Littlefield

    It’s about the money in the end. The MTA has been hocked. They did the same to the road trust fund.

    Read my latest Room 8 Post to see where our tax dollars are going; we’ll be lucky if public education (as opposed to just pensions) exists for my grandchildren if and when I have them.

    One way or another, transportation will have to pay for itself. Plus pay for the past, plus interest.

  • Federal funding has always been used as an argument for freeways – including freeways to nowhere. I am happy that federal funding is now being used as an argument for congestion pricing.

  • rhubarbpie

    I have to agree that the federal funding is unlikely to convince opponents. I say that as a supporter of congestion pricing in part because of the steady money it could bring in to transit.

    While I myself would welcome $300-$400 million in my own bank account, it really isn’t a huge amount of dough these days. And the dollars that congestion pricing would bring in when the program is running, if they are used for foolish projects like the 7 line extension, may not be worth it either. It’s not like it’s billions, anyway.

    So the question really is: is the mayor’s proposal — sweetened by the money that would go for new buses and other improvements — enough to both stem traffic and help transit? And are enough people convinced of that?

    So far, the idea hasn’t caught on with anyone but Manhattanites, so perhaps these additional ideas, maybe linked to fare relief and some sort of additional transit funding, are worth a real discussion as the congestion pricing debate goes on. (I also have my doubts about how willing the proponents of these other ideas would be to actually promote them, so that’s worth throwing into the discussion.)

  • Niccolo Machiavelli

    There is a big unsolved policy piece that deserves legitimate wonking regarding the Federal piece in this. How will Fed funds earmarked for CP be figured into the New York split of future Fed Transportation dollars? How will it be considered for Federal matching purposes with regard to the giant capital projects? Is that money in addition to or in replace of our Federal split?

    However, as someone above said “its all about politics”. And, the politics of this are that the Mayor has held that Federal money out there as a stick to beat his political opponents with. And, it is all out of the Robert Moses playbook and has nothing to do with good policy. Silver called his bluff on the drop dead date of the whole thing and the conoscenti got a big laugh.

    The whole entire, “Oh my God you can’t let them waste the Federal money.” sky is falling aspect of it is just a political play. And, if Bloomberg wants to play that card there is little we can do about it to discourage him. Its his game. But, that he never contacted anyone in the New York Congressional Delegation to go over either the policy or the politics before he started pushing it forward has not helped him build the political momentum or center of gravity to make it happen.

    No accident that Mayoral Wannabe Anthony Weiner , who has become one of the antagonists in the political battle, used to sit on the Transportation Committee and knows a little about the distribution of Federal money.

  • Sproule Love

    While I agree with Zupan’s, TA’s and others’ assessments of the recent Keep NYC CP Free alternative report, and I support a well-designed CP program along with East River tolls, we have to give credit to the group for putting *some* good ideas out there. Their report even mentions “encouraging greater use of bicycle transportation “(p.3). It doesn’t go far enough, but you know you’re getting somewhere when the opposition usurps some of your ideas and language. It’s classic mid-90’s Bill Clinton. The general conversation has really come a long way.

    One glaring inconsistency I see in the report, however, is that while it cites no fewer than THREE Bruce Schaller studies (p.37) to further its case, this group continues to harp on the regressive nature of CP (p.6) with regard to hitting “the middle class” hardest. Yet, Schaller himself has put out several studies debunking this myth, showing that only 5% of CBD workers drive to work, and those that do have higher incomes than people who commute by public transit and they choose driving over other available options.

    Corey Bearak, care to comment?

  • NYC is lucky to have this lively public debate. It sure beats deathly silences other than the sweet sound of concrete hardening. At one point someone will have to sit down (one very much hopes) with the players, opposing proposals, contradictions, etc. and come up with the game plan that’s going to do the job. Great stuff. GO NYC,

    Eric Britton, from a Paris that is trying hard to green itself and every once in a while doing quite a good job of it. Come check it out for yourself. (And by the way, CP is for now at least not in the cards here.)


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