Testimony to the Port Authority of New York & New Jersey and the Federal Highway Administration on Cross Harbor Freight Study DEIS.

Regional Plan Association appreciates the opportunity to offer testimony to the Port Authority of New York & New Jersey and the Federal Highway Administration in response to the Cross Harbor Freight Study DEIS. Our comments highlight RPA’s concerns with portions of the technical analysis as well as with the list of alternatives.

Purpose, Goal and Objectives of Study

In our view, the focus of the study is too narrow for the problems identified in the DEIS. While the study thoroughly documents existing conditions of the region’s freight system, it focuses attention too narrowly on a single freight rail corridor. In doing so, the study neglects modal alternatives, including transportation demand management measures. Since all four of the study’s goals articulated in Section 1 on pages 17-18 of the DEIS are truly regional in nature – reduce truck trips, modal alternatives for freight, resiliency (safety and security) and integrated freight and land use planning – the evaluation of the corridor should have taken into greater consideration the regional scale of the freight transportation challenge.

Market Analysis

According to the market analysis (Table A-6), just 27% of the freight that moves through the 54-county region crosses the Hudson River, and of that total, 41% of the truck tons (the overwhelming majority modal share) are passing through the region, 32% are passing between origin/destination pairs within the region and the remaining 27% are passing between a place within the region and a place outside its borders. Moreover, 44% of this freight, or 111 million tons, are carried by small trucks, which are used for short-haul, last-mile deliveries. These data indicate that about a quarter of the freight that moves through the region touches the east-of-Hudson market, with more than a third of that traffic just passing through, and almost half of remaining tonnage being delivered by small trucks for short-haul trips. Thus an improved rail freight crossing would only address a small portion of freight movements in the region.

The market analysis also raises several concerns and questions:

• The assumption of 0% growth rate used for passenger trains for the network modeling (page A-19) doesn’t appear to take into account new passenger service that will be added as part of the LIRR East Side Access and MNR Penn Access projects.
• The practical capacity table (A-12) indicates that running 150 trains is possible with conventional track circuits on three tracks, which is adjusted for mixed traffic to 74 trains. It doesn’t appear that the more advanced cab-signaling system used by LIRR was evaluated, which would likely result in a finding of even greater capacities.
• The analysis assumes that roughly a third of the freight would be destined for New England, and almost a third of that portion destined for Massachusetts, Rhode Island and Maine. While it makes sense that some freight destined for southwestern Connecticut might be diverted from existing Hudson River crossings to the Bay Ridge line, freight bound for destinations in northern New England is better served by existing crossings.

These concerns raise the question of whether an exclusive twin-tunnel rail freight facility is needed. There is clearly a mismatch between the demand of freight east-of-Hudson and the capacity that the two tunnels would create.

Alternatives Analysis

The alternatives analysis wrongly dismisses mixed passenger and freight alternatives. The selection of alternatives also appears inconsistent.

We disagree that Alternatives 16, 17 and 18 were ​“fatally flawed,” as indicated in section 4, page 8 of the DEIS. The following details our concerns regarding each of the three alternatives:

• Alternative 16, which considers using capacity on new trans-Hudson tunnels for freight, is rejected based on an analysis completed for the cancelled Access to the Region’s core project more than seven years ago. This analysis is out of date and shouldn’t be applied to the proposed Gateway trans-Hudson project – as stated in the DEIS. The two projects are fundamentally different, with different alignments and serving different facilities. Advancements in technology and techniques over the past decade could result in a different outcome today.
• The DEIS assumes a subway option for Alternative 17, which analyzes passenger and freight tunnel to Staten Island. More compatible freight and passenger options exist but weren’t examined, and the isolated nature of the Staten Island Railway doesn’t require that it operate subway-compliant rolling stock if connected to the Bay Ridge line.
• Alternative 18 should not be dismissed based on an outdated analysis. Especially in light of investment being made at the New York Container Terminal and the need for greater redundancy between the five boroughs of New York City, this option could have served these goals as well as connecting to New Jersey.

We believe that dedicating a cross-harbor tunnel and the Bay Ridge line exclusively to freight services misses an opportunity to improve regional mobility and ignores the changing travel patterns of our growing region. The proposed five tunnel alternatives identified in the DEIS imply that solutions that would improve both freight and passenger mobility are incompatible. As noted above, the DEIS prematurely dismisses alternatives that propose dual use. The DEIS also fails to take into account technological developments that allow for safe mixed passenger-freight operation and experience in other dense metropolitan areas.

The DEIS assumes that the Bay Ridge line will be used for long-haul freight trains – slow, mile-long trains snaking through residential communities. We agree that it is difficult to imagine how these long trains could share the right-of-way with shorter, faster, more frequent passenger service. But for more than two-thirds of the freight usage envisioned in the DEIS, integration with passenger rail will be required because those trains will be bound for destinations in Long Island or New England only accessible via rail lines used by passenger traffic. Specifically, the DEIS projects that for the highest-use tunnel alternative, 16 out of 23 trains using the cross-harbor tunnel would continue on to the main passenger lines in Long Island or New England during peak hours, where they would need to integrate with passenger service. Dedicating the Bay Ridge line exclusively to freight only delays the inevitable comingling of freight and passenger trains. It would squander an opportunity to improve access to communities in Brooklyn, Queens and the Bronx underserved by transit today.

RPA recommends that the Bay Ridge right-of-way be repurposed to accommodate improved freight service and new passenger service. In RPA’s recently released report ​“Overlooked Boroughs,” we detail how passenger trips within and between boroughs have increased significantly over the past decade, at more than twice the rate of trips to and from the boroughs to Manhattan’s central business district. Our transit system is ill-equipped to handle these trips. Buses are slow and hampered by mixed traffic, and our radial subway system is designed predominately to serve those destined for Lower and Midtown Manhattan. The Bay Ridge line running through Brooklyn and Queens offers a once-in-a-generation opportunity to develop a transit solution to this growing problem.

A new transit service on the right-of-way would bypass the Manhattan central business district and instead allow residents in the Bronx, Brooklyn and Queens to rapidly move within and between boroughs. It also crosses over or under 20 subway lines and the LIRR, creating numerous opportunities for transfers. No other right-of-way exists that can provide effective transit service connecting these areas. If passenger service were precluded with the enhancement of a freight-only corridor, a valuable option to connect millions of residents of New York City’s outer boroughs would be permanently lost.

It is important to underscore that this transit service would not preclude freight operations on the corridor. Other metro areas in the U.S. and around the world have successfully mixed freight and passenger operations. One excellent example is in Chicago, where some of the nation’s busiest main line freight corridors mix with frequent passenger rail service.

A freight solution that is focused on a single corridor isn’t the answer to the goods movement dilemma facing the New York metropolitan region. Instead, we should comprehensively rethink our rail operating environment and our investment strategy, including focusing on improvements to signaling, rail equipment, freight clearance and weight issues, and train operating rules. This will allow us to create conditions that will foster regional interoperability of freight and passenger rail and make the improvements in both services that the region urgently needs.