Congestion Pricing Questions the Mayor Will Need to Answer

glick.jpgNew York State Assembly Member Deborah Glick represents Chelsea, Greenwich Village, Tribeca and a good piece of Chinatown and Lower Manhattan. Encompassing the Holland Tunnel, Canal Street and a section of the Westside Highway, her district suffers from some of the worst traffic congestion in all of New York City. Transit-rich and offering some of the city’s most walkable and bike-friendly streets (Jane Jacobs lived and worked in this Assembly district) Glick’s constituents would likely be among the greatest beneficiaries of any traffic reduction plan.

Glick, however, isn’t a fan of Mayor Bloomberg’s congestion pricing plan. In the 1,300 word letter below she lays out her concerns and explains to a constituent why she and her colleagues opted to create a 17-member traffic mitigation commission rather than approve the Mayor’s plan.

While many of Glick’s questions and concerns have been answered repeatedly in public forums, through local studies and by examples in other cities, there is a certain thoughtfulness and sincerity to her letter that you tend not to hear in the arguments of congestion pricing opponents like Richard Lipsky and Walter McCaffrey who, one suspects, are doing little more than representing the deeply regressive interests of the parking garage / Automobile Club / Queens Chamber of Commerce cabal.

Glick calls herself a "responsible legislator" who "has long been concerned with traffic congestion" problems in her district. The questions that she raises are questions that will need to be answered again and again and again in the coming months.

Fundamentally, Glick believes "there is no consensus" on whether Mayor Bloomberg’s pricing plan "would reduce congestion, or simply raise revenue." She "had too many unanswered questions and found too many flaws in the congestion pricing legislation to be supportive of it in the form that was presented to the Legislature by Mayor Bloomberg." And she seems to have resented the intense lobbying and the feeling that New York City’s Republican Mayor was trying "to stampede the Legislature into a vote" on his plan. Glick raises the following as an example of the kind of question that she feels was not answered:

The proposal purported to reduce asthma, especially for children. However, many communities just outside of the congestion pricing zone have significant asthma rates and it is possible that those communities might have to contend with increased vehicular traffic as commuters driving into the city attempt to park in these neighborhoods outside of the zone.

Other questions that Glick felt were not properly answered by the Mayor:

  • Why create a new authority?
  • Will the money raised be used strictly for mass transit improvements?
  • Why aren’t there exemptions for people who drive into the designated area for serious medical treatment?
  • How will residents of the congestion zone be charged for moving their cars for alternate side parking or for leaving the city for the day?

Finally, Glick isn’t convinced that the Bloomberg Administration has suddenly gotten religion on traffic reduction. The Administration, she writes, "has in fact been irresponsible and disingenuous, because, after years of ignoring more simple congestion mitigation efforts, they are trying to rush through congestion pricing legislation with almost no study or debate." She wonders why the Mayor isn’t doing more to control parking permit abuse among government employees, a problem that plagues her Lower Manhattan district.

You can read Glick’s letter, in its entirety, after the jump…

From: NY State Assembly Member Deborah Glick

To: A Constituent Who Supports Congestion Pricing

Subject: Re: Support a Cleaner New York City

Date: Fri, 03 Aug 2007

Dear constituent,

Thank you for contacting my office regarding congestion pricing. I have long been concerned with traffic congestion in my district (which is among the worst in the city) and have been involved with a number of efforts to mitigate congestion. I have also been concerned with growing asthma rates in the city and well aware of how traffic and other environmental factors have exacerbated the problem.

For the past two months, there has been a general discussion of Mayor Bloomberg’s congestion pricing proposal in the press. There have also been direct mail appeals urging New Yorkers to contact their state legislators, resulting in calls to my office advocating for "clean air," as well as calls against "congestion pricing." These disparate messages reflect the lack of clarity and specificity with which congestion pricing has been discussed.

Unfortunately, I have also been confronted with a dearth of information regarding the Mayor’s proposal, as have my colleagues who were looking closely at the proposal and trying to get answers to very specific concerns about how the program would be implemented. Regrettably, there were too few answers from the City Administration about our legitimate concerns. It was because of the numerous questions that were raised, but not sufficiently answered, that the Assembly did not vote on congestion pricing. In fact, even the State Senate did not vote on the issue when they convened in Albany on July 16th supposedly with the understanding that a vote could be taken.

Though I am fully supportive of the need to reduce traffic congestion and improve our air quality, I cannot vote on legislation without a sufficient understanding of its impacts, particularly when it will substantially impact neighborhoods throughout New York City as well as the entire tri-state region. As a responsible legislator, I must look beyond press releases and public relations campaigns and vote on the merits of the actual legislation. Often, legislation purportedly aims to address an important issue, but the legislation as crafted is not the best way of doing so. I had too many unanswered questions and found too many flaws in the congestion pricing legislation to be supportive of it in the form that was presented to the Legislature by Mayor Bloomberg. While I appreciate

the goals of congestion pricing, I do not appreciate the Mayor’s effort to stampede the Legislature into a vote on congestion pricing without an appropriate vetting of the myriad issues generated by the proposal itself.

For example, the proposal purported to reduce asthma, especially for children. However, many communities just outside of the congestion pricing zone have significant asthma rates and it is possible that those communities might have to contend with increased vehicular traffic as commuters driving into the city attempt to park in these neighborhoods outside of the zone. So far, no environmental impact statement has been prepared to address this and other concerns. By embarking on such a dramatic change without this important review, the Legislature would set a very questionable and dangerous precedent. For many of us in the environmental and preservation movements, we rely heavily on the legal requirement for environmental impact statements. I will not act to undermine this critical tool used by communities to defend themselves against inappropriate actions and development threats. While I am not surprised that the City Administration has not been concerned with ensuring a proper environmental review, I have been disappointed that so many in the environmental movement were willing to abandon this essential process.

Furthermore, there are numerous issues raised but left unanswered by the Mayor’s proposal, such as: Why create a new authority to receive the increased fines and new fees for entering the designated zone when we already have a mass transit authority? Will the money raised be used strictly for mass transit improvements? If there are exemptions from fees for taxis and the black car services, why aren’t there exemptions for people who drive into the designated area specifically for chemotherapy or other regular serious medical treatment since they are unable to use mass transit? How will residents of the congestion zone be charged for moving their cars for alternate side parking or for leaving the city for the day?

While we all agree that traffic has become impossible and that the additional construction of so many buildings will only bring more people and congestion into Manhattan, there is no consensus on whether the proposal would reduce the congestion, or simply raise revenue. One aspect of the plan would allow for auto commuters who paid a toll to have that toll deducted from the congestion fee. For example, a New Jersey driver who pays a $6.00 toll to enter New York City would have that toll deducted from the $8.00 congestion fee, making the additional cost to New Jersey drivers $2.00 a day. Many legislators do not believe that this will discourage any drivers from driving their cars into the city or encourage them to take mass transit.

These are just a few of the issues for which there were no clear answers. In my humble opinion, it would be irresponsible to vote for any legislation that generated so many significant questions without getting any answers. The City Administration has in fact been irresponsible and disingenuous, because, after years of ignoring

more simple congestion mitigation efforts, they are trying to rush through congestion pricing legislation with almost no study or debate.
Among the non-legislative changes the City could have implemented are dramatically reducing the number and the abuse of City issued parking permits, enforcing existing laws about blocking the traffic box, and enforcing no standing restrictions, which, when violated, force trucks to double park in order to make deliveries. To illustrate, the estimated number of City parking permits is between 10,000 and 20,000. While there are many legitimate uses for these permits, many are misused at times and greater enforcement and perhaps a significant reduction in the number issued may be appropriate. The City has also just recently started to focus on
promoting alternative modes of transportation, such as bike riding, and they have largely not been involved in efforts to promote mass transit.

While none of these strategies alone would solve New York’s congestion problems, a comprehensive, broad-based review of all the strategies that New York City could employ to reduce congestion is sorely needed. Since many parts of our transit system are at capacity, we need to be certain that the facilities necessary for a shift to mass transportation are either in place, or substantially on their way to being a reality. For example, it is crucial that there be adequate parking near commuter rail stations and certain subway stations outside of Manhattan where there are few or no bus connections.

Instead of rushing through congestion pricing, a commission on congestion mitigation must be convened to examine all the possible options and combinations of options to best address New York City’s congestion challenge. Accordingly, I believe that the Legislature was wise to pass a statute creating this commission and enabling us to draw down any funds that the federal government might award New York City. Interestingly, while the City Administration insisted that the Legislature must act immediately in order for us to receive $500 million in federal funds, it always seemed more than optimistic to assume that we would get this amount- the federal government had only a $1.2 billion funding pot from which it would give funding to 5 selected cities. While I wish we could get the lion’s share of federal funds to address congestion, there is no evidence that the Bush administration planned to depart from their standard practice of awarding New York City much less than our deserved share of funds.

In closing, I wish to thank you once again for contacting me on this critical issue of concern to all of us. Improving the health and quality of life for people living in neighborhoods plagued by congestion, ensuring better mass transit, and improving the environment have and will continue to be priorities for me. However, I believe we are on our way to determining the best possible strategies for addressing these challenges. If you would like to receive further legislative and policy updates regarding health and environmental issues such as congestion pricing, please respond accordingly to this email and we will email you periodic updates about these issues.


Deborah J. Glick


  • Steve

    As sympathetic as the claims of people entering the congestion zone for medical tretment may seem, I would oppose creating a CP exemption for them. The same people do not get an exemption on toll bridges or tunnels, why should this be different? Let them operate within the proposed exemption for cabs and liveries, instead of in addition to that exemption. CM Glick’s use of this population to argue against congestion pricing is akin to Brodsky’s professed concern for my civil rights.

    Another red herring is that there is “no consensus” that CP will reduce congestion rather than raise revenue. Since when is government run by consensus? Even if she is merely waiting for a consensus among experts rather than political forces, she will wait forever.

    “The City Administration has in fact been irresponsible and disingenuous, because, after years of ignoring more simple congestion mitigation efforts, they are trying to rush through congestion pricing legislation with almost no study or debate.” CM Glick is right on the money here, except that there has been enough study and the lack of debate is as much the fault of the legislators as Bloomberg.

    CM Glick is right that the Mayor’s approach to alt-side parking issue is fuzzy, and not in the proposed legislation. As understood it, there were only verbal assurances that these people would not have to pay.

    However it was reasonably clear in the legislation that residents of the zone who leave for the zone would be charged the $8. I think CM Glick wonders out loud about the details of this not because they are unclear, but (one might say disingenuously) to highlight this feature of the plan to her constituents.

  • As another one of her constituents, I wonder why she’s so eager to second guess the potential health benefits to people in other districts, or fret over their ability to drive without paying $8 to drive medical appointments that cost them or the public hundreds of dollars once they arrive. As a member of her district, I have to take a taxi if need such an appointment, and that will cost about $10. Poor me.

    Other parts of Manhattan that drive more (UES), and other boroughs, and the NY suburbs–these places are well represented in the state assembly. Ms. Glick, if it’s not too much trouble, could you please represent your own constituency? Who by the way do not drive for the most part and do not care in the least about “alternate side parking” other than the way it disrupts our mornings when the freeloaders noisily fight for spots during street cleaning? That would be great, thanks!

  • Dan

    Although I’m inclined to believe that she has genuine questions about a congestion charge, her inquisitiveness seems to have led her to do no research on the issues. Her contention that there is no evidence that the congestion charge would reduce traffic is laughable. The mayor has proposed a plan that he thinks will remove cars from the roads by tolling drivers, if she feels that this will not reduce traffic she must show evidence for such a belief. The Mayor cannot at once be responsible for providing evidence and also have that evidence dismissed out of hand.

    The same thing goes for much of her arguments. If she thinks that the numerous studies about regional traffic show other patterns of use and behavior she should tell her constituents. If she finds the mayor’s evidence unconvincing, she should say that as well. But she’s not doing either of those things. There’s no research or new perspective here. For all her concerns she apparently feels that the problem should be studied by OTHER PEOPLE. But what happens when these people reach the same conclusions as the mayor? Will she still have “concerns?”

  • flp

    “The proposal purported to reduce asthma, especially for children. However, many communities just outside of the congestion pricing zone have significant asthma rates and it is possible that those communities might have to contend with increased vehicular traffic as commuters driving into the city attempt to park in these neighborhoods outside of the zone.”

    YES, YES, YES, YES!!!

    Doc Barnett, Glick may not “represent” those neighborhoods, etc. However, she is still correct to bring up that issue (among others), and it is EXTREMELY responsible and considerate of her as she is one of the stronger and more respected council members compared to the ones from those neighborhoods.

    Kudos are due to CM Glick for taking this thoughtful stand. While it would be great to have congestion pricing, it would be even better or best to have a plan that actually solved some of the problems that many supporters purport to be concerned with.

  • Hilary Kitasei

    I’ve been thinking about the alternate side parking problem and have concluded that $4/day is not an unreasonable charge for the use of (often free) street parking in the CBD. Those who use it contribute to more than their share of cruising for parking and double-parking. A fixed rate of say $50/month would certainly be unobjectionable. Relative to the cost of car ownership (even a clunker), it’s negligible.

    As for exempting medical or even worthy business-driven (art? education? community service?) trips, should we be favoring one industry or activity over another? The system should be transparent and simple above all, lest we end up with a new form of placard abuse. Let people take advantage of our tax complexity to deduct the expenses if appropriate.
    Glick constituent and multi-modal traveller

  • Dan and Doc,

    That’s a great point: It seems as though the suburban and outer borough Assembly districts are very well represented by their electeds, many of whom are vehemently opposed to congestion pricing. It’s nice that Glick is looking out for regional interests but what about the purely selfish interests of her Lower Manhattan constituents who’d like to have less traffic congestion and better transit? Who is looking out for them if not her?

    And what about the broader, regional — even global — benefits of congestion pricing?

  • flp, I do think that’s a job for representatives of the Bronx, and the facile way that Glick and other reps question the asthma benefits is unconvincing. People that oppose pricing, and for whatever reason that includes Glick, know that the asthma problem is a winning argument for pricing. The best they can do is try to cast doubt on that. Clumsily. Any cars that try to park in the Bronx are cars that would be driving through it anyway. So the argument is that the increased pollution from them looking for spots will exceed the reduction in position from many cars no longer passing through the area at all. I think this is highly unlikely, but if Glick is so concerned about asthma in the Bronx, the best thing to do is support pricing and fight for residential permits in each borough, or the elimination of free/cheap parking entirely.

  • The adjacent zones/asthma argument is a shoddy red herring. What is the scenario, practically speaking, vis a vis ‘moving’ congestion? That outer borough and suburban commuters will attempt to street park at 96th street and take the train downtown? Or that someone will drive them halfway to work?

    Destination charges will discourage people from getting in their cars at the source, not change destinations.

    The in town charge should applying, even for street parking. In practical terms, short moves probably won’t trigger a fee, unless you live near a perimeter or major intersection. But that shouldn’t matter.

    When I head about charges to leave town, I was a little piqued; it made me think, hmph, maybe I should get rid of my car. Which it is intended to do.

  • It should be noted that those needing serious medical treatment will benefit by either a) an easier drive into the zone or b) better transit options to get into the zone.

    That one’s easy.

  • Larry Littlefield

    Like most state legsislators, Glick does not represent the majority of the people who live in her district. She represents people with deals, and those cashing in and moving out.

    I only hope that issues like these will get more people to realize what the state legislature is.

  • flp

    miss representation – do you really think that suburban folks’ driving habits will change so easily AND that the commuter rails will be able to sustain the increased ridership? wow! i wish i was that optimistic. oh, and don’t forget there also is the need to improve the subways and buses. remember, money is not the real problem – its the MTA management.

    doc barnett – while many of those who may park in the bronx would drive through anyway, don’t forget the truck traffic could well increase if truckers wish to avoid the congestion price and head north then east or west via the XBronx/Bruckner/etc depending on starting point. in addition, driving around in search for parking spaces could actually add to the amount of time car engines are spewing out their exhaust in the bronx, yes, a permit system could be helpful, but have the politicians thought of that?

    i support congestion pricing – i just think a lot needs ot be worked out which is why it is good that all possible issues are raised and discussed. for those of you who are so certain that all of the repeated questions have been answered and soundly so, then there is no need for you to worry about the CP being passed, is there?

  • flp: I didn’t say it would. I’m just saying I know they aren’t going to cruise back and forth on 86th street in protest, or to look for street parking everyday.

  • Congestion Pricing? No, way, not yet

    No one has mentioned the fact that NYC has lost $250-million due to illegal parking placard abuse. This has all occured on Bloomberg’s watch [Schaller report – 2006, NYC loses $46-million a year to government salaried employees parking illegally on meters]. Contrary to Assembywoman Deborah Glick’s incorrect number of 10-20,000 parking placards, there are 150,000 parking placards in NYC (Transportation Alternatives study – google it). Any significant dent in reducing illegal placard abuse done by 150,000 placard users would:

    1) Cause much cleaner air conditions in NYC.

    2) Get the City back its $46-million/year (to improve mass transit and keep fares low).

    3) Improve quality of life – already existing laws would finally be enforced and thousands of government sector cars would stay home instead of coming into Manhattan.

    4) Cost NYC next to nothing.

    Of course, I am not saying that all placard/permit users break the law, but it is a documented fact that parking violations occur many thousands of times everyday in NYC by government salaried employees and it costs the City dearly in terms of added congestion, added air pollution, diminished quality of life and business, and lots and lots of money.

    Do the above four points sound like everything that congestion pricing promised? I do feel that the information in the top paragraph needs to be made public and the traffic commission’s first priority to investigate as an alternative. Elimination of illegal placard abuse would cost the City nothing!

    Thanks for your consideration of the facts.
    No congestion pricing/commuter tax, just lose illegal placard parking.

    Downtown Resident who loves NYC

  • Congestion Pricing Exemptions? None for Goverment sector!!

    Don’t everybody realize why the Mayor has not mentioned EXEMPTIONS to congestion pricing for 150,000 government sector employees with parking placards yet? When Bloomberg mentions exemptions, or if the press ever wises up and exposures this MAJOR flaw, the poop will hit the fan and the grand congestion pricing scheme will fall on its unprepared back. With 150,000 exemptions (and you know Bloomberg will grant exemptions to government sector commuters – he has virtually ignored illegal parking permit abuse since he has been in office) NYC will be inundated with even more pollution and congestion and more illegal parking permit abuse – 150,000 cars with carte blanche – NYC definitely cannot afford this.

  • The press can’t expose made-up flaws, CPE?NFGS!! Because the congestion pricing opposition is capable of little more than a series of increasingly implausible doubts and distractions, the plan will move forward to implementation and you will find that there are not 150,000 pricing exemptions to be jealous of. All drivers will pay the fee. If we see pricing before we see reduced placard abuse, it will only mean that it’s easier to build a clean new system than to dislodge entrenched corruption. Contrary to whatever the crazy site that is linking here says, Bloomberg does not have some secret desire to perk-out city employees (to whom he has shown little love in the past).

  • JF

    Maybe people who know Glick find it easier to stomach this crap coming from her, but the lack of initiative on the part of State Assembly representatives is just weird. You’d think that these people have no power to write legislation and only have the right to an up-or-down vote on proposals from the Mayor.

    Want an exemption for people who “have” to drive into the city for medical appointments, or even just for your top campaign contributors? Mistrustful of the “SMART” Authority (when has an Authority ever been smart, after all)? Well then write your own damn proposal!

    I suppose it’s possible that the Speaker will not allow any assembly members to write legislation. Baaa!

  • Niccolo Machiavelli

    Ftp’s entirely unsupported broadside against the MTA “remember, money is not the real problem – its the MTA management.” is really the big problem here. People do not trust their government institutions and until they do why raise any funds for anything. That is the chief source of resistance to Congestion Pricing. This is not analysis it is a “blanket party”. Make a large unsupported attack as if it were a truism and there is no need to counter with facts or actual argument.

    CP, and by insinuation (unsupported) the MTA, has been the entire focus of the debate on PlaNYC. The plan has other enormous weaknesses, flaws and red-herrings. Chiefly it avoids the word “freight” as if it were a curse. The well-documented unscrupulous Jersey trucking industry, in effect subsidized by the Mayor’s proposal, skates by with no scrutiny at all while the MTA, operating the systems with the highest fare box recovery ratios in the nation and moving more people than all other US public transit systems combined is demonized by the good green bloggers. Go figure.

  • A failed constituent

    Why is no one mentioning Assembly Speaker Sheldon Silver’s control over Glick as her reason for not supporting congestion pricing, and his reward to her in terms of PORK?

    To wit, the politician’s name, pork projects, total dollar amount and percentage of total Assembly dole:
    Name Number Amount Pct. of Total $
    SILVER 391 $30,396,200.00 7.40%
    GOTTFRIED 142 $7,897,600.00 1.90%
    BRUNO 223 $6,417,500.00 1.60%
    LENTOL WEINSTEIN 42 $6,241,000.00 1.50%
    JOHNSON 194 $6,027,080.00 1.50%
    GLICK 128 $5,970,000.00 1.40%

    Of the hundreds of Assemblymembers, Glick gets the sixth largest largesse of Pork from Silver, 1.4%. She never reveals where it goes incidentally.

    One source has revealed that some has gone to the discredited Federation to Preserve the Waterfront (they opposed the current Hudson River Park for years, because it would bring in ‘outsiders’ to the Village. Damn those cyclist peddling through her neighborhood?)
    Federation members in turn showed proper obeisance to their benefactor by collecting signatures for petitions putting her name on the ballot. One hand washes the other.

    The scenario:
    Silver wants to remain Speaker. He needs the support of the many out-of-city legislators who oppose Congestion Pricing to remain speaker.

    Silver gives Glick a disgustingly disproportionate amount of Pork to ensure she supports his positions.
    She uses this Pork to keep herself in office. To cross Silver on congestion pricing would endanger the bucks to her and her reign.

    She then dutifully follows whatever Silver says, and although Canal Street (which crosses both their districts) has the WORST PPM in the city(pollution particles), she will sell out her constituents’ health to stay in office.

    She obfuscates, weaves, shifts blame to the Mayor, jive talks, introduces partisan politics, etc. In a classic debating tool, she asks us questions to answer, instead of giving hard facts for her stand.

    She should be ashamed of herself, if only she knew the meaning of shame.

  • Plan does not impress

    I agree with AM Glick. The Mayor’s proposal was poorly thought through with little attention to the details – making the implementation of this plan a disaster. Further, he offered little in the way of effective communication on the plan to the folks he dumped it on. No wonder they booted it.

    I recently spoke with an urban planner who was a big advocate of the plan. My impression after our conversation was that this was put together by people infatuated with the idea, but who could care less how it impacted people and if their “rationale” for its implementation were ever forfilled. As for Mayor Bloomberg, he simply wants the money it would generate.

  • JF

    7:46, your comments do not impress. The Assemblymembers who were similarly unimpressed had months to write their own legislation, but instead they nominated freshman Rory Lancman as their sacrificial lamb to write some hack job. They obviously only identified with the tiny minority of their constituents who drive to Manhattan, and didn’t dare do anything to upset them.

    The people who choose to drive to Manhattan when there are plenty of subways, who chose to live in the car-dependent suburbs instead of near transit, who choose to drive to their doctors in Manhattan, made all of these choices without thinking about how it would impact the people whose neighborhoods they drive through every day. Why should we care how the plan impacts them?

    And please don’t give me the parking-in-the-border-zones bullshit or the Bronx-asthmatics bullshit. We’ve been through that so many times before; read the archives. Lies! All fucking lies!

  • Hilary

    Sometimes anecdotal information is more informative than broad surveys. Today, I asked two shampooists (the lowest paid rung in a salon) how they got to work in lower Manhattan (Glick’s district) this morning. Each of them had driven in from Staten Island and parked their cars in BPC, as they often do. The Staten Island Ferry is a stone’s throw away. The train (above-ground subway) in Staten Island delivers them to a short walk of their homes. It costs $2. It is the fastest option. YET THEY ARE AS APT TO OPT FOR DRIVING OR THE $5 EXPRESS BUS, even on a day like today. Why?? “It depends on if I’m in a ‘ferry’ mood.” I was incredulous. Most of us would die for a ferry/”light rail”/door to door commute, and would pay a premium for it.

    I can only conclude that people are irrational. Which means we should not waste time tweaking the system. Only intense pain and irresistable incentives will change behaviour.

    Assemblyman Glick — what can you suggest that would alter these girls’ choices?

  • usq

    Could just be politics as usual of newly arrived West Village fat cats with pristine views, long-time nabobs, and excruciatingly expensive restaurants proximate to the scheduled Gansevoort waste transfer station not in my backyard or in other words: “What can you do for me?”

  • blap

    exactly, hilary!!!!

    i don’t think 8 bucks (or whatever the latest “MSRP” is) will put much of a dent in most drivers’ habits. i say bankrupt the f*****s or drive them underground (god willing the MTA will evolve!!!). i actually think placing massive tolls on ALL bridges and entry points into the city (not just manhattan) would do the trick better.


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