Thank you for accepting comments from the Regional Plan Association, a 100-year-old civic organization working toward better mobility, economic opportunity, affordable housing, and a more resilient New York City metropolitan region. We work in the five boroughs of New York City, Long Island, Westchester and the Hudson Valley, along with New Jersey and southwestern CT.
For decades, RPA has strongly supported congestion pricing because it is a centerpiece of a set of policies that will lead to a greener, more equitable region.
The Environmental Assessment proves congestion pricing will achieve its stated goals of traffic reduction and increased transit investment and RPA supports approval of the Finding of No Significant Impact. The EA indicates that congestion pricing will have the following benefits:
Congestion pricing will reduce traffic congestion. We are pleased to see that the MTA has clear objectives for this program – a 5% reduction for Vehicle Miles Traveled (e.g. the overall measure of driving) in the CBD and a 10% reduction in the number of vehicles entering the Manhattan CBD. The Environmental Assessment shows that the seven congestion pricing scenarios studied will succeed in these objectives. They will reduce Manhattan CBD Vehicle Miles Traveled by 7.1% - 9.2% and they will reduce the number of vehicles entering Manhattan by 15.4-19.9%. RPA’s own estimates show congestion pricing will decrease traffic delays by about 15% during busy periods. Traffic levels are already surpassing pre-COVID levels so managing traffic is key to our economic recovery.
Congestion pricing will raise vital revenue for public transit. The program will raise $15B in revenue and 100% of this net revenue will go into paying for improvements to our public transportation system. All of this revenue will be dedicated to the MTA’s capital program, which includes hundreds of vital projects such as signal upgrades on subways, accessibility improvements at stations, electric bus purchases, new train cars, transit expansion projects, and many, many more.
Congestion pricing will make the transportation system more equitable. The majority of households in NYC do not own cars and on average, across the region, households with cars have an income that is nearly double those without. By investing in public transit, we will help reduce travel times, clean the air, and expand transit service to new communities.
Congestion pricing will benefit the region including northern NJ, Long Island and the Hudson Valley. Most residents in areas outside of NYC do not commute to NYC for work and only travel to Manhattan on occasion.
The vast majority of Manhattan-bound commuters use public transit. They use transit to get to and travel within the congestion zone, thereby benefiting from the transit improvements this program will bring. For drivers, congestion pricing will make trips more reliable. Managing traffic and investing in public transit is vital to ensuring the future economic and environmental health of our region.
Congestion pricing will improve regional air quality and set us on a greener path to address the challenges of climate change.
RPA recognizes that there are still many important specifics to work out on key issues including:
Mitigating Localized Air quality and traffic impacts. While congestion pricing would improve regional air quality, the Environmental Assessment shows potential impacts on select highway sections throughout the region. This includes air quality and traffic effects on the Cross Bronx Expressway, the Staten Island Expressway and around the George Washington Bridge. We believe these potential effects can be addressed and we urge the Governor, MTA and City leaders to develop a comprehensive approach to address localized impacts in a way that prioritizes health of vulnerable communities.
This should include investing more resources from the Infrastructure and Investment Jobs Act in mitigation strategies. For the South Bronx, for example, these could include:
Electrifying Hunts Point terminal and the trucks accessing it
Electrifying the Bronx bus fleet and related infrastructure
Directing money for EV and EV charging infrastructure to the Bronx
Accelerating plans to cap the Cross Bronx Expressway
Many of these investments should occur regardless of congestion pricing. The South Bronx has long hosted more than its share of polluting infrastructure leading to poorer health outcomes.
FHV and taxis
Additionally, we hope the MTA will identify scenarios that limit additional surcharges for taxis and FHVs. Since 2019, customers using taxis and FHVs have been paying a fee for trips south of 96th Street in Manhattan. This has raised hundreds of millions of dollars for transit investment. In our 2019 report, we recommended that the MTA study a small additional fee for trips within the cordon tolling program south of 60th Street.We still believe that this may accomplish traffic reduction and revenue generation without as many unintended consequences.
Toll credits
The final congestion pricing scenario should, to the extent possible, equalize trip costs. This will likely require giving toll credits for all or a portion of tolls paid on MTA and Port Authority crossings entering Manhattan. This approach would limit so=called “toll shopping” and reduce the likelihood of localized traffic impacts as a result of the congestion tolls.
While we believe attention must be paid to these and other important issues, we believe they can largely be addressed as the planning process continues after the Environmental Assessment is completed.
RPA urges the federal government to sign off on the environmental assessment as soon as possible, so New York can move forward with implementing this vital program.
