The following letter was sent to the U.S. Department of Transportation Federal Railroad Administration and NJ Transit regarding the scoping of the Hudson River rail tunnel project.

Regional Plan Association (RPA) appreciates the opportunity to offer comments to Federal Railroad Administration and New Jersey Transit on the Hudson Tunnel Project scoping.

To unlock the full potential of the new tunnels, better serve commuters and contain costs, RPA recommends that the Hudson Tunnel Project scope incorporate the following operational and design elements:

1.Accommodate future freight - passenger mixed operations.

• The study should determine the height, width and grade requirements necessary to allow for the future operation of freight rail, double-stack containers (20’2” clearance, with buffer likely closer to 22’) through the tunnels during off-peak/overnight periods, and how they can be accommodated.
• Once the two new tunnels are completed and the North River tunnels are rehabilitated, there will be sufficient capacity to support overnight freight service.
• Running freight through Gateway may be a far more efficient means of moving long-haul intermodal and bulk commodities from New Jersey to geographic Long Island than existing truck and rail options. Overnight freight service would utilize idle rail capacity, reduce roadway congestion and contribute revenue through track access fees paid by the private railroads.

2.Tunnel alignments should improve rail to local transit (subway/bus) connections and accommodate future through-running service- providing direct commuter rail connections between New Jersey, New York City, Long Island, the Hudson Valley and Connecticut.

• The alignment of the new tunnels should prioritize the needs of commuters, improving connections between rail and subway platforms at Penn Station New York - the tunnels should be sited closer to subway stations.
• Alignments that promote through-running of commuter rail services and more direct connections to urban transit should be evaluated, even if those alignments don’t ​“align” with current block 780 proposal.
• Tunnel alignments that are evaluated should not be limited to only alignments that support existing tunnel boxes constructed as part of the Hudson Yards development and the block 780 proposal. All feasible alternatives must be explored.

3.Explore project design and delivery alternatives that will lower the capital costs of the project.

• Assess the costs and benefits of shorter full service closures at work sites compared to extended partial closures.
• All alternatives studied in the EIS should consider constructability issues and aim to create a work site, timeline and project design that is as efficient and cost effective as possible.
• The project team should, for instance, preference alternatives that would result in a site that is more accessible (porous) even if this means some increase in surface disruption, and evaluate means of accommodating construction work windows by providing greater flexibility in existing service plans.

4.Design of passenger areas (Penn South or other) should be incorporated into the plans for the tunnel and track level.

• Although the raid deterioration of the North River tunnels calls for expediency, the alignment of the tunnels will dictate what capacity improvement are eventually implemented at Penn Station. Ignoring this fact will limit the options available at Penn Station and could result in a subpar outcome for commuters.
• The tunnel alternatives should be paired with various station options, including, but not limited to the existing Amtrak block 780 concept.

5.Assess the diversion of passengers from other trans-Hudson travel modes, bus and car, with additional tunnel capacity and any service plan changes for through-running and one-seat rides.

• RPA understands that the Hudson Tunnel Project is not a ​“new capacity” project but instead a replacement and rehabilitation effort. However, it is clear that once completed, the tunnels will pave the way for new commuter rail capacity. How much new capacity is created will depend on whether new Penn Station capacity is configured for through-running from the outset or not, among other factors.
• The EIS should estimate a range of the new capacity that the four tunnels could eventually deliver under different assumptions. This information could be used to better plan for additional rail improvements in New Jersey and in properly planning the Port Authority Bus Terminal replacement in midtown Manhattan.