To: United States Coast Guard
Attn: Donna Fisher [email protected]

Re: PUBLIC NOTICE D01-209-2024 NEPA Environmental Assessment New Jersey Turnpike Interchanges 14 to 14A/Newark Bay Bridge Replacement and Associated Improvements

Commander Fisher:

Thank you for the opportunity to submit written comments on the Draft Environmental Assessment regarding the proposed Newark Bay-Hudson County Extension (NB-HCE) Improvements Program.

Regional Plan Association (RPA) is a private, non-profit civic organization dedicated to regional planning and development that, since 1929, has published four comprehensive long-term plans to direct the growth and development of the New York-New Jersey-Connecticut metropolitan area. The ideas and recommendations from these plans have shaped the region’s infrastructure, open spaces, and economic development projects for the past century.

Building on this legacy, RPA strongly supports investment in transportation infrastructure and sees it as essential for the growth and development of the region. However, we cannot support the NB-HCE Improvements Program as currently planned. While we agree with the need to replace and upgrade the bridge, ramps, and approaches along the project corridor, we have significant concerns about the project’s approach to addressing future traffic volumes and predicted impacts to the environment and surrounding community.

The Proposed Action includes replacing all existing structures between Interchange 14 and 14A, including the Newark Bay Bridge (NBB), with two parallel spans to address structural integrity. The project, part of a larger corridor expansion, would more than double capacity by increasing the number of travel lanes from two to four in each direction and by providing wider roadway shoulders for safety and emergency access.

After a thorough analysis of the draft Environmental Assessment for Interchange 14 and 14A, RPA has identified a number of concerns about the current design of the NB-HCE Improvements Program. We urge the United States Coast Guard (USCG) to seriously consider the issues below and to withhold issuance of a Finding of No Significant Impact. A project of this size and scope requires the preparation of an Environmental Impact Statement for the entire project corridor.

Primary Concerns:

Isolating Interchange 14 to Interchange 14A from the rest of the project:

Replacement of the Newark Bay Bridge is the first segment in a multi-phase project that will expand the entire 8.1-mile Newark Bay Hudson County Extension of the New Jersey Turnpike at a 2022 projected cost of $10.7B. The majority of the project area falls in or around overburdened communities as designated by New Jersey’s Environmental Justice Law. Isolating the impact analysis to a single phase – and failing to produce a corridor-wide environmental review according to federal standards – necessarily means that the EA is incomplete and fundamentally flawed.

Federal statute is clear on this requirement; 40 CFR §1501.3(b) explicitly states that, ​“The agency shall evaluate, in a single review, proposals or parts of proposals that are related closely enough to be, in effect, a single course of action. The agency shall not avoid a determination of significance under paragraph © of this section by … or segmenting an action into smaller component parts. The agency also shall consider whether there are connected actions, which are closely related Federal activities or decisions that should be considered in the same NEPA review that: … (3) Are interdependent parts of a larger action and depend on the larger action for their justification.”

Further illustrating the need for a full-project assessment is that the demand analysis performed for this EA assumes the completion of the ​“full long-term Program limits (the length of the NB-HCE corridor)” as stated in Sec 2 Introduction of the Appendix B traffic analysis report. This inclusion shows that the project sponsor views Interchange 14 to Interchange 14A as one component of a single project, making this analysis non-compliant with federal requirements.

Given this direct, physical connection to a much larger project, USCG should require the preparation of a comprehensive environmental impact statement for the entire project area of the NB-HCE program.

Failure to Consider Alternatives:

Despite the extensive scope of the project, as noted in section 2.3, there is limited analysis available to support that NJ Turnpike Authority (NJTA) fully evaluated feasible alternatives for the bridge replacement, as required by NEPA guidelines. The analysis dismissed the option of replacing the existing structure with a new five- or six-lane bridge with the possibility of reversing one lane during rush hours. These alternatives could reduce environmental impact, significantly reduce project costs, and meet all safety and longevity requirements, and thus merit serious analysis and consideration.

The analysis presented in appendices B and C fails to mention future efforts to coordinate with NJ Transit to explore additional public transportation investments or service adjustments that could help reduce traffic congestion. New Jersey’s transit and road networks are inextricably connected, the State must analyze mobility across modes, especially when congestion issues are largely limited to peak hours.

Failure to Sufficiently Consider Induced Demand:

As shown in sub sections 3.9.4 and 3.9.5 of the ​“Affected Environment and Environmental Consequences” section, the No-Build scenario traffic demand is projected to increase by 8%, while under the Build scenario, traffic demand is projected to increase by 32%; a partial recognition of induced demand. It is well-documented that added highway capacity provides only a temporary reduction in traffic, and in fact, that congestion relief from expansion typically vanishes within five years. Given the overall project cost, this project warrants further analysis for long-term efficacy. Travel demand strategies may significantly address congestion, but none were considered during the design of this project.

Assumption that planned expansion of New York Penn Station will not advance: Page 34 of Appendix B shows that the traffic analysis specifically excluded the Gateway Program from the demand model. Table 5-1 – Future Projects Included in the NJRTM-E Travel Demand Model - states, ​“The Gateway Program provides redundancy and reliability as it is currently proposed. Increases in service and capacity are not the intended purpose or need for the project; therefore, no capacity improvements are incorporated.”

This assumption is incorrect. The Hudson Tunnel portion of the Gateway Program is now fully funded and advancing to construction. While the expansion of New York Penn Station is technically separate from the Hudson Tunnel, one of the primary goals of the Gateway Program is to double rail capacity into New York City, which will allow NJ Transit to greatly increase trans-Hudson service. All the Gateway projects partners – New Jersey, New York State, Amtrak and the USDOT – are committed to expanding capacity at Penn Station to allow for this doubling of capacity. The traffic analysis for the Turnpike expansion must include this scenario in the demand model and demonstrate how the proposed capacity expansion for the turnpike would be necessary in the face of this increased capacity on NJTransit.

Additional Items of Concern

Freight:

As mentioned in the previous section, travel patterns (of passenger and freight) have changed since 2019. As dependency on freight movements by truck continues to grow in our region, RPA continues to support all efforts to creatively transport goods by other means. In 2022, our ​“E-Commerce at a Crossroads” report calls for rethinking e-commerce logistics for cleaner ports and sustainable practices to accommodate changing patterns of freight mobility. Our research further emphasizes the need for a comprehensive environmental review to explore alternative freight solutions for environmental and community health benefits.

Inconsistencies with the State Plans and Plans of Local Communities

• The 2030 New Jersey Long Range Transportation Plan advocates for reducing travel demand on the highway system, significantly alleviating congestion. This includes encouraging individuals to minimize solo driving trips, increase walking and bicycling, shifting trips to non-peak hours, and eliminating unnecessary trips altogether.The plan also advocates for expanding public transit, using population growth as a necessity to improve its public transportation infrastructure and therefore ridership. Given that this project is likely to increase emissions, it is also in conflict with the state’s environmental goals. Specifically, 2021’s Executive Order 274, which established an interim greenhouse gas reduction target of 50 percent below 2006 levels by 2030.
• While this project contradicts state-level strategies for addressing congestion and emissions, it also conflicts with the strategies employed by the local communities most affected by the expansion. Hudson County, in particular, would be significantly affected by the expansion. Its officials and community groups have been advocating for safer and more sustainable road designs, as well as increased public transit funding, in an effort to reduce car dependency overall.
  
• Hudson County’s Vision Zero Action Plan and the Hoboken City Council’s implementation of their Vision Zero Plan, which has led to zero traffic deaths for seven consecutive years, highlight local priorities for safety and sustainability. Both Jersey City and Hoboken City Councils have unanimously opposed the highway expansion, citing its environmental impact and misalignment with community goals.
  

Potential for Increased Air Pollution

It is well documented that highway expansion projects often lead to a projected increase in vehicle miles traveled (VMT), thereby increasing carbon emissions and lowering air quality. This is cause for concern as the Environmental Justice Mapping and Screening Tool (EJMAP) indicates that all Census block groups in the project study area are classified as having a Combined Stressor Summary higher than the 50th percentile, identifying them as environmental justice communities. This designation underscores the importance of understanding the full impact of the project, as these communities are already experiencing significant environmental and demographic stressors.

Conclusion

RPA appreciates the opportunity to provide comments on the draft environmental assessment for the NB-HCE improvements program. Given our concerns as noted above, we ask that USCG produce a full environmental impact statement that is inclusive of the entire project corridor and in compliance with the federal NEPA environmental review process. RPA looks forward to continued public engagement and project transparency as part of this program.

Thank you,

Zoe Baldwin
Vice President of State Programs at Regional Plan Association