Dear Members of the Traffic Mobility Review Board,

We, the Congestion Pricing Now Coalition, write to express our strong support for New York’s Central Business District (CBD) Tolling Program and to thank the members of the Traffic Mobility Review Board (TMRB) for your service. In the NYC metropolitan area, congestion in the central business district creates untenable delays for emergency vehicles, buses, delivery vehicles and drivers who have no other choice but to take cars and trucks into the zone. Chronic disinvestment in transit has meant an unreliable, inaccessible system that lurches from crisis to crisis. Congestion pricing would create a multi-billion dollar investment to modernize and upgrade public transportation and lessen the burden of traffic congestion that would otherwise continue to undermine our economy and pollute our air. Congestion pricing is a win-win-win for the region that will fund public transit, reduce traffic congestion, and clean our air.

Members of the Congestion Pricing Now Coalition make the following recommendations for the TMRB to consider:

Recommendation #1: Use bridge and tunnel toll credits to reduce excess travel ‒ particularly through environmental justice communities

Right now, about two thirds of drivers enter the CBD for free, while about a third pay a variety of different toll rates depending on the route used. This increases traffic congestion in neighborhoods that host the free crossings, causing substantial health and environmental impacts. Ideally, the congestion pricing program should equalize tolls and reduce so-called ​“toll shopping” to the greatest extent possible. A priority should be given to reducing any disproportionate burden on environmental justice communities in both New York and New Jersey.

In order to do this, the congestion pricing program will need to apply toll credits, or off-sets, to reduce any incentive to drive further to avoid a particular toll as much as possible. This will require looking at the total cost of trips and to consider MTA and Port Authority tolls rather than simply looking at the congestion pricing charge in isolation.

Recommendation #2: On for-hire vehicles, assess a per-ride surcharge paid by the passenger, rather than a once per day toll paid by the driver

For-Hire Vehicles (FHVs) are a significant cause of congestion and vehicular emissions within the central business district. However, the Federal Highway Administration (FHWA) has determined FHV drivers are an important environmental justice (EJ) community. As a result, the Environmental Assessment approved by FHWA limits tolling on FHVs to once per day. Our coalition firmly believes that eliminating the once-per-day toll and replacing it with a per-ride surcharge will do far more to reduce congestion, protect drivers, and generate revenue for public transit.

It is important that vulnerable communities are not negatively impacted by the program’s implementation. A per-ride surcharge is designed to be passed along to the customer, reducing the financial burden of the program on drivers compared to a once-per-day toll. A per-ride surcharge also has significant revenue-generating potential. According to the NYC Taxi and Limousine Commission, in 2022, the existing congestion zone surcharge of $2.75 for for-hire vehicles (FHV) and $2.50 for yellow taxis, raised $343 million, including $91 million from taxis and $252 million from HVFHVs.

We urge you to give special consideration to FHVs who are transporting people with disabilities to maintain alignment with the equity goals in the MTA Reform and Traffic Mobility Act of 2019. Given the clear benefits to reducing congestion and to FHV drivers, we strongly urge the TMRB to include a per-ride surcharge for FHVs in the chosen congestion pricing tolling scenario. Doing so will ensure that FHV drivers are protected, and that the tolling system generates substantial revenue, effectively combats traffic congestion, improves air quality, and aligns with the objectives of the MTA’s capital plan. This can also help offset the revenue impact of other recommendations.

Special consideration for taxis: The Congestion Pricing Now Coalition does not believe that a per-trip surcharge should be applied to taxis. Taxi drivers have suffered greatly and are already burdened by the investments taxi owners have made in medallions that are now valued at significantly less than the original investment.

Recommendation #3: Commuter buses, both public and private, must be exempt from tolls

We support the exemption of both public and private commuter buses. One of the many goals of the program is to disincentivize private car trips into Manhattan’s CBD and incentivize more commuters to use mass transit. To support this goal, we believe that private and public commuter buses should be exempt. The coalition defines ​‘public’ as those buses owned or operated by any municipal transportation entity (ex: MTA Bus, NJ Transit, etc.) and defines ​‘private’ as privately-owned buses that operate on behalf of any municipal transportation entity
and/or provides a supplemental service that connects riders to a fixed, intermodal transportation hub located within the congestion pricing zone.

Incentivizing commuters to travel by bus will decrease the number of private vehicles entering Manhattan by consolidating commuters into high-occupancy vehicles and reduce emissions per
passenger mile. This move will encourage the use of public and group transportation and discourage the use of private vehicles.

Note, the coalition does not believe this exemption should apply to tourism buses, which carry significantly fewer passengers.

Recommendation #4: No additional exemptions should be granted besides commuter buses and legislatively mandated exemptions

The 2019 legislation provides exemptions for disabled riders, including those utilizing the Access-A-Ride program, and for those within the CBD earning less than $60,000 a year. Earlier this year, the MTA pledged an additional $207M to mitigate possible adverse effects to the policy, which included additional exemptions under a low-income driver toll discount program. Outside of these exceptions, any additional exemptions will raise the base toll paid by all other commuters, as the legislation requires the program to generate enough revenue to fund $15 billion for the MTA capital plan. Allowing for additional exemptions will deteriorate the effectiveness of the program. The Congestion Pricing Now Coalition does not support further exemptions (other than for those included in the 2023 mitigation package and commuter buses as defined in Recommendation #3).

Recommendation #5: Trucks and large vehicles should pay a per axle toll

Trucks and large vehicles have a significantly greater impact on regional infrastructure and air quality. Therefore, the coalition believes that these vehicles should pay more than passenger vehicles and that they should be charged an increasingly graduated amount based on the number of axles, which is a proxy for their size, weight and impact. Similar graduated pricing schemes are currently used on existing MTA bridge and tunnel facilities. The introduction of an escalating charge per axle is a proven tolling method in the trucking industry, which provides an incentive for both private and public investment in other modes of transportation for moving goods in a more environmentally sustainable fashion.

Thank you for your attention to these important issues. We trust that you will carefully consider our requests and make decisions that serve the best interests of the region. Should you require any additional information or wish to discuss these recommendations further, please do not
hesitate to contact us.

Thank you,
Congestion Pricing Now

The Congestion Pricing Now Coalition members who sign this letter include: