Dear Cross Bronx Expressway Project Team,
Thank you for the opportunity to submit written comments.
Regional Plan Association (RPA) is a 103-year-old civic, non-profit organization, focused on supporting the health, equity, sustainability, and prosperity of the New York, New Jersey, and Connecticut region. RPA has consistently advocated for investments in the tri-state area’s transportation infrastructure that accomplish necessary repairs and maintenance without imposing additional environmental harm to surrounding communities.
We were greatly encouraged by the dismissal of Options 1A, 1B, 1C, and 1D in the Cross Bronx 5 Bridges Project which included a traffic diversion structure. We encourage NYSDOT to continue engaging with stakeholders to improve the process and results of the environmental review. After reviewing the Draft National Environmental Policy Act Environmental Assessment (NEPA EA) and the State Environmental Quality Review Act Environmental Assessment (SEQRA EA), we developed a set of comments and recommendations which we believe will result in clearer and more effective Final EAs, as well as a process which ensures selection of the best alternative to meet community and state needs.
RPA recommends that NYSDOT undertake the following steps in preparing the Final EAs:
Clarify the impacts of the Alternatives A, B, and C and eliminate results referring to the dismissed Options 1A, 1B, 1C and 1D
Clarify social and environmental impacts of Alternatives A, B, and C vs. impacts of No Build Alternative related to air quality and stormwater flooding, and construction effects
Balance essential safety improvements with the desire of the community to avoid widening the Cross Bronx Expressway (CBE)
Adapt design guidance to fit project context rather than employing a one-size-fits all approach to “obsolete” features
Ensure streetscape improvements accompany new Bronx River Parkway (BRP) ramp to westbound CBE to reduce capacity on local streets
Ensure alternatives reflect community demands and conduct further engagement with community stakeholders in alignment with the Reimagine the Cross Bronx study
1. Clarify the impacts of the Alternatives A, B, and C and eliminate results referring to the dismissed Options 1A, 1B, 1C and 1D: It is unclear where NEPA EA results relate to the remaining Alternatives A, B, and C rather than the previously dismissed Options 1A-D. For example, the local traffic analysis at the end of Appendix C - Traffic Information explicitly refers to 1A-D. This inconsistency calls into question whether the results of the NEPA EA analysis have been fully updated to reflect the effects of Alternatives A, B, and C or whether the NEPA EA still reflects outdated information related to the dismissed alternatives. This raises issues when other findings, such as the air quality impacts under Alternatives A, B, and C, hinge upon the results of the traffic analysis.
2. Clarify social and environmental impacts of Alternatives A, B, and C vs. impacts of No Build Alternative related to air quality and stormwater flooding, and construction effects: The Final EAs should expand on the analysis and discussion of social and environmental impacts expected as a result of the proposed alternatives, especially regarding air quality, stormwater flooding, and construction effects in the following ways:
- Air Quality:
The Mesoscale analysis in Appendix B4 of the NEPA EA finds that Vehicle Miles Traveled (VMT) is projected to be two percent higher across Bronx County under Alternatives A, B, and C than under the No Build Alternative because the proposed improvements would increase the efficiency of the roadway, attract rerouted trips from elsewhere in the transportation network, and overall allow more throughput in the analysis area. However, this statement is not aligned with the Transportation Conformity section in Appendix B4, which states that a PM2.5 hot-spot analysis is not required because “the Project would not attract traffic to the study area.”
Appendix B4 of the NEPA EA does not address the air quality impacts of this 2 percent increase in VMT and instead proposes that “pollutant emissions would be reduced between 2030 and 2050 due to USEPA’s stricter emission standards for new vehicles and fleet turnover” when claiming minimal air quality impacts despite an increase in VMT. The Final NEPA EA should discuss this claim in more detail to clarify just how effective increasingly strict emissions standards will be at minimizing emissions even as VMT increases overall. By this logic, emissions in the no build scenario would also decrease, the emission differential should be discussed in detail.
Finally, in the NEPA EA, it is unclear why levels of pollutants from emissions would be lower in future years under Alternatives A, B, and C compared to under the No Build Alternative given that the level of service under Alternatives A, B, and C is still poor (Levels D-F in most sections during AM and PM peaks as of 2050).
Stormwater Management: Section 4.10 of the NEPA EA, “Stormwater Management,” finds that the Alternatives will result in additional impervious surfaces (Alternative B (1.94 acres), Alternative A (1.50 acres) and Alternative C (0.98 acres)) causing negative effects to vegetation and runoff, but that improvements such as bioretention basins and hydrodynamic separators included under all three alternatives will result in better stormwater management overall. However, it is challenging to understand the effectiveness of the mitigation strategy because the final stormwater management design will not be determined until the final design of the selected alternative. The Final NEPA EA should clearly explain the extent to which the stormwater mitigation strategy of the selected alternative will compare to the No Build alternative.
Construction Effects: Section 4.21 of the NEPA EA, “Construction Effects,” shows that 2030 traffic conditions under construction are more similar to No Build conditions than RPA would have expected given the extent of the work to be completed and the significance of the CBE to the New York State transportation system. For example, CBE Westbound speeds under construction would be twice as slow compared to the 2030 No Build Alternative, yet vehicle hours of delay (VHD) are projected to be almost the same (2309 VHD for No Build and 2351 VHD for construction). RPA is curious whether the sole focus on peak-hour conditions in the traffic analysis may have led NYSDOT to overlook more severe construction-related traffic impacts during off-peak hours compared to the No Build alternative. The NEPA EA does not analyze off-peak conditions because traffic data was collected and projected only for peak hours, which is also when construction mitigation measures are strongest, meaning that all CBE travel lanes are open. During off-peak hours, when some CBE travel lanes are closed, construction-related traffic impacts may be significantly worse than under the No Build alternative. Therefore, RPA recommends that the Final NEPA EA include a more comprehensive analysis of construction effects during off-peak hours.
3. Balance essential safety improvements with the desire of the community to avoid widening the CBE: Proposals to widen shoulders and add acceleration lanes should balance essential safety improvements with the desire of the community to avoid widening the CBE. We would appreciate seeing clear explanations of how the proposed corrections impact traffic in order to gauge what changes are absolutely necessary to improve safety. It is not clear that widening shoulders to the extent proposed is required given other strategies in place, such as proposals to consolidate on-ramps and increase acceleration lane length. Shoulders should only be widened, and acceleration lanes added, to the extent they address safety. Otherwise, in order to minimize impacts on the surrounding community and environment, the CBE should not be widened and congestion relief should not be attempted through this project. Alternatives to widening should be considered, such as smaller or non-through shoulders or adding retractable bollards so emergency vehicles can maintain use of the shoulders.
4. Adapt design guidance to fit project context rather than employing a one-size-fits all approach to “obsolete” features: While we understand the urgent need to upgrade and replace these bridges, RPA also understands that building to the published design standard is not the only appropriate way to address issues of road safety. NYSDOT should explore creative solutions rather than defaulting to recommended values or accepted practices which are not absolutely necessary to this project. RPA appreciates the justification of a smaller left, Westbound CBE shoulder and encourages NYSDOT to evaluate whether there is additional flexibility to justify smaller shoulders throughout the project in order to minimize the footprint of the CBE throughout surrounding neighborhoods while still addressing safety concerns.
5. Ensure streetscape improvements accompany new Bronx River Parkway (BRP) ramp to westbound CBE to reduce capacity on local streets: RPA understands that there is a need for a direct connection between southbound Bronx River Parkway (BRP) and westbound CBE, but this ramp must be accompanied by strict traffic calming and traffic reduction efforts to reduce capacity on the local streets no longer intended to make that connection.
Without a local capacity reduction, in the event of a back-up (which seems likely due to the F Level of Service projected in NEPA EA Appendix C - Traffic information), drivers will use local streets trying to by-pass the ramp. This possibility should be studied further in the Final NEPA EA and in general, streetscape improvements should be included in the selected alternative to avoid unintended traffic on local streets as a result of the project.
Additionally, the project study area should include areas that may experience a traffic impact, whether it is increased or reduced traffic. Where NYSDOT anticipates traffic reductions, there must be design solutions to ensure those reductions remain in perpetuity (such as on 177th St). NYC DOT has an expansive toolkit in this respect and should be engaged to develop bike or bus lanes, wider sidewalks, planters and swales for storm water mitigation and cleaner air where appropriate.
The Bronx has historically been overburdened with impermeable roadway infrastructure. We cannot support any project options that may perpetuate this harm. Project outcomes should remain focused on bridge replacement as a safety improvement and roadway width reduction to lessen future environmental burdens. Therefore, any engineering options that include new ramps to keep highway-to-highway connections must include stringent traffic calming and reduction improvements to deter vehicle travel on local streets in order for RPA to consider supporting the proposal.
6. Ensure alternatives reflect community demands and conduct further engagement with community stakeholders in alignment with the Reimagine the Cross Bronx study: Alternatives A and B do not fully reflect community needs and require further engagement to improve connectivity and deliver community-proposed designs. Additionally, this project is relevant to the Reimagine the Cross Bronx study, and NYSDOT should provide additional clarity on how it fits into the transformative infrastructure changes envisioned for the future of the CBE corridor as proposed in the study.
Throughout the public engagement process, the community has repeatedly expressed the need to avoid expansion of the footprint of the CBE as well as the need for a community-led process to design and deliver community benefits. The Shared Use Path and connection to Starlight Park included in Alternatives A and B do not correspond to community needs because they do not provide continuous connectivity beyond the study area, improve existing east-west connections, or minimize the footprint of infrastructure in the park. The construction of Alternatives A or B would preclude some future community-led design processes including the greening of the MTA West Farms Bus Depot parking lot. Further community engagement is essential to deliver meaningful benefits and connectivity to the larger neighborhood.
Additionally, regarding the SEQRA EA, the Smart Growth Screening Tool presumes certain benefits that are not borne out by the proposed alternatives. For example, the Smart Growth Screening Tool states that the project will “enhance beauty in public spaces,” yet in practice Alternatives A and B are not aligned with community-proposed designs, for example, in the addition of negative visual effects compared to the No Build Alternative. The application of this tool presents an opportunity for further community engagement to ensure alignment of the proposed alternatives with community goals and values.
We appreciate NYSDOT’s consideration of these comments, and we look forward to reviewing the Final EA when released. We will continue to call for innovation and community alignment in infrastructure projects which present an opportunity to show NYSDOT’s commitment to reconnecting communities, improving public health, and creating a better transportation system statewide.
Thank you.
