Good evening, and thank you for this opportunity to testify on the Final Environmental Assessment regarding the proposed Newark Bay-Hudson County Extension (NB-HCE) Improvements Program.
My name is Olivia Haller and I am the New Jersey Associate for Regional Plan Association (RPA), the nation’s oldest metropolitan planning, research, and advocacy organization.
RPA strongly supports investment in transportation infrastructure as it is essential for the health and economic development of our region. However, we cannot support the NB-HCE Improvements Program as currently planned. While the bridge replacement and related structural upgrades are necessary, we have significant concerns beginning with a lack of broader transportation strategy including demand management and the need for a full EIS. We also have concerns about the project’s approach to addressing future traffic volumes and mitigating predicted impacts to the environment and surrounding communities.
Our analysis of the draft and final environmental assessment for Interchange 14 and 14A has identified a number of concerns about the current design of the NB-HCE Improvements Program. These include the lack of examination of other demand management approaches, the limited scope of the environmental assessment, inconsistencies with state and local transportation initiatives, and the project’s failure to sufficiently consider induced demand, which is the well-documented phenomenon where adding road capacity leads to more driving, not less congestion..
A full EIS Must Be Prepared
A project of this size and scope merits the preparation of an Environmental Impact Statement for the entire project corridor. Replacement of the Newark Bay Bridge is the first segment in this multi-phase project that will expand the entire 8.1-mile Newark Bay Hudson County Extension of the New Jersey Turnpike. The majority of the project area falls in or around overburdened communities as designated by New Jersey’s Environmental Justice Law. RPA believes it is incongruent to only conduct an environmental assessment on the first segment of the project. Failing to do so limits the understanding of potential impacts for phase I as part of a comprehensive action. This is a disservice to the local communities that will be facing the unavoidable consequences of this expansion.
Furthermore, communities surrounding the project area, including Newark, Jersey City, and Hoboken, have made it abundantly clear that they oppose this expansion. It is essential for the state to seriously consider opposition from the communities who will bear the direct environmental, health, and quality-of-life impacts of this proposed expansion.
Alternative demand Management Strategies Must be Considered
As stated, expanding roadways is a short sighted response to congestion that often worsens the very problem it aims to solve. As such, any expansion such as this should be weighted against more sustainable and cost-efficient alternatives such as expanded transit service, peak-hour demand management, and flexible capacity options. Forecasted traffic patterns must also include the benefits projected from regional projects like the Gateway Program and the implementation of congestion pricing. Gateway will allow more people to take the train into New York City and congestion pricing has already demonstrated significant traffic reduction for drivers and bus riders entering the congestion zone from New Jersey. Researchers from Stanford, Yale, and Google analyzed Google Maps data and found that drivers from Hudson and Bergen counties were making their trips into the congestion zone 8% faster.
Given our concerns as noted above, we ask that NJTA reconsider this project entirely or, at a minimum, prepare a full environmental impact statement that is inclusive of the entire project corridor and potential alternatives.
Thank you.
