The area around Ground Zero is going to be ground zero in the battle over congestion pricing exemptions.

Buried in the MTA’s environmental assessment for congestion pricing is this astounding factoid: one small slice of Lower Manhattan laps the field when it comes to people driving to work. And those people are, surprise!, mostly police.

According to the “Economic Conditions” chapter of the EA, Census tract 29 has the largest number of car commuters into the Manhattan Central Business District out of any CBD Census tract — and of those car commuters, a plurality of them are in the “protective service” job sector. The tract will also surely be the epicenter of the fight over congestion pricing exemptions, since any exemptions given out to people driving and parking in this slice of lower Manhattan could eviscerate the entire program.

“By far, the greatest number of car commuters to the Manhattan CBD drive to jobs in Census Tract 29 in Lower Manhattan,” the agency wrote in the EA. “Of the estimated 16,453 workers commuting to jobs in Census Tract 29 from outside the Manhattan CBD, an estimated 6,832 workers (over 40 percent) drive to work. … Roughly 40 percent of those working in Census Tract 29 are employed in protective service occupations, a category including NYPD officers. Over the entire Manhattan CBD, only 2.5 percent of jobs are in this occupational category.”

The Census tract in question is home to a number of law enforcement and government buildings, including One Police Plaza, Manhattan Criminal Court, New York Supreme Court, New York County Supreme Court, the Thurgood Marshall United States Courthouse, One Centre Street and of course, City Hall.

The large number of NYPD and other law enforcement officials driving to lower Manhattan  could come into play when the Traffic Mobility Review Board, the panel tasked with recommending price and exemption policies for congestion pricing, begins to consider the various screams for exemptions. PBA President Pat Lynch has been demanding a carveout for cops, asking for one almost immediately after state legislators authorized the traffic toll.

Whether the lobbying works is an open question. The six members of the TMRB have been quiet on the question of exemptions and credits since they were appointed in July — with the exception of Partnership for New York City President Kathryn Wylde, who has adamantly insisted on no credits or exemptions when the traffic toll is implemented.

“Anything that reduces the impact of the congestion pricing zone is going to make it less effective and less attractive,” Wylde told Streetsblog in September. “It’s not just a matter of raising more money. It’s a matter of people seeing a real improvement in the city as a result of reducing excess congestion.”

Other officials have at least signaled some openness to exemptions or credits, though those discussions have focused more on taxi drivers and other potentially disadvantaged groups and not government employees or the state security machine. Mayor Adams, himself a former police officer, has also expressed openness to some exemptions as both a candidate and as mayor, but has mostly talked about theoretical chemotherapy patients and other people for whom he says driving is not “a luxury.”

The EA also points out an important reason why lower Manhattan, with its bountiful subway connections, is such a rich vein of drive time radio listeners: parking placards.

“The higher rate of auto commuting to these census tracts, and the high volume of auto commuting to Census Tract 29, are likely due to the availability of free parking and/or parking placards for some public administration employees,” the assessment authors wrote. (A Streetsblog placard census earlier this year certainly confirmed that.)

NYPD officers have the option to park on Park Row, which has been closed to civilian vehicle traffic since the 9/11 attacks, and they do.

NYPD officers, at the very least, have less of an excuse to insist on driving to work, because they can get a free ride on transit if they choose. According to the MTA, the agency has given out 36,681 MetroCards to members of the NYPD.

But they, and their siblings in the federal building and court officer services, also go buck wild with placards all over lower Manhattan, especially on blocks just outside of Census Tract 29. As shown in the Streetsblog Placard Census, almost every car parked in the 30-block radius of Canal, Lafayette and Chambers streets and West Broadway and Varick Street had either a real or fake placard, or some other dashboard emblem that passes for a free parking sticker around here.

Danny Pearlstein of Riders Alliance thinks the quest for exemptions is absurd.

“Special interest exemptions for privileged groups of drivers would be a disaster for the millions of riders counting on congestion pricing to fix the subway,” he said. “A Swiss cheese policy that doles out favors will prove to undermine trust in government at the worst possible time.”