Thank you for the chance to submit written testimony regarding the LaGuardia airport ground access improvement project. Regional Plan Association (RPA) is a non-profit civic organization that conducts research, planning and advocacy to improve economic opportunity, mobility, environmental sustainability and the quality of life for those who live and work in New York and the rest of the New York City metropolitan region. We are pleased to provide written comments in support of the Port Authority of New York and New Jersey’s (PANYNJ) preferred alternative to build an AirTrain connector between LaGuardia Airport and Willets Point, and to offer recommendations to ensure that the project meets its goals.
Background
RPA has long advocated and provided recommendations for upgrading the region’s airport infrastructure, as far back as 1947, when we hosted the Airports of Tomorrow conference which determined the region’s priorities for establishing a regional airport system. In 2011, our report Upgrading to World Class made recommendations for modernizing that system, reducing delays and increasing capacity. These reports provided concrete ideas on how to expand gate and terminal capacity, which would be addressed by rebuilding terminals at LGA, EWR, and JFK; increasing runway capacity at EWR and JFK; and improving transit access for all three airports. RPA initially laid out the conditions for a successful LGA ground access project, and in particular for the PANYNJ’s preferred alternative, in our Upgrading to World Class Revisited report in 2018. These reports have played a key role in our discussions and position on this project. RPA echoed these recommendations in previous testimony submitted to the FAA during the environmental review scoping process on June 4, 2019.
In the nine years since RPA released its 2011 report, the number of passengers flying through LGA increased from 24 million annual passengers to 31 million. While air travel has declined dramatically since COVID hit, the region must continue to plan and build for the future when air travel comes back, and the trends from recent years showing increased demand are resumed.
Last year and as part of the environmental review scoping process, RPA supported the PANYNJ’s preferred alternative and listed a number of criteria for the project to successfully accomplish its goals. Perhaps most important was the need to foster interagency coordination between the PANYNJ and the MTA to ensure frequent service on the Long Island Rail Road (LIRR) Port Washington branch. We also highlighted the importance of fare control, price, station design, rolling stock, and resiliency improvements along the waterfront. We have had ongoing dialogue with Port Authority officials to follow up on the progress of these items. There has been substantial and continuing progress in advancing these in measurable ways. However, some key points require further clarification and discussion.
The PANYNJ’s preferred alternative is the most viable solution to improve ground access to LaGuardia Airport. The FAA and Federal administration should continue to support the project to ensure its timely completion.
After examining different alternatives, RPA concludes that the proposed LGA AirTrain is currently the most viable option for providing rail transit to an expanded, improved and modernized LGA. The preferred alternative also makes use of passenger facility charges (PFCs) and other airport-derived funds, which federal regulations require to be spent on facilities used by air passengers.
An AirTrain connection from LaGuardia to Willets Point would provide convenient and reliable access to the airport for passengers and employees. This alignment would leverage the substantial public investment by the MTA’s East Side Access program by connecting passengers to Midtown Manhattan via the LIRR. By connecting to mass transit services and not relying on the existing roadway network, this alignment would remove uncertainty around expected ground travel time - a significant benefit to travelers who need to catch a flight.
Since the scoping sessions last year, the COVID-19 global pandemic has caused great harm and loss of life to our communities. It has also created enormous fiscal challenges for the Port Authority and all levels of government. Some have maintained that in this new environment, the Port Authority should pull back from this project, or invest the funds in other regional priorities. The problem with this argument is that the LGA AirTrain proposal takes advantage of dedicated revenue sources – specifically the Passenger Facility Charges levied on tickets paid by LGA travelers – that can only be used on projects that benefit the travelers paying the fee. So the LGA AirTrain is not in competition with other regional investments, but instead should be evaluated on whether it will address an important need at LGA, and whether it is the best way to address that need.
All across the country, airport operators’ efforts addressing ground access constraints have been hampered by federal legislation that limits their right to use funds derived from airport operations, federal Airport Improvement Program (AIP) grants, and Passenger Facility Charges (PFCs) for ground access projects. The current rules intended to ensure that these airport funds are allocated towards facilities used by air passengers have resulted in regulatory constraints that limit the ability to finance ground access improvements and projects that could otherwise be better integrated with existing transit systems. An analysis published in The Air & Space Lawyer - American Bar Association in 2016 by author David Y. Bannard stated the following: “With few exceptions, federal law prohibits the use of these funds for projects that are not located within airport boundaries or that serve users other than airport passengers or workers.” The rationale for maintaining these restrictions is that an unlimited ability to use airport revenues to fund access projects could divert critical capital from airports to serve largely local transportation needs that have limited or no relation to airport operations.
RPA also examined other ground transportation alternatives, including those evaluated in the DEIS, of which some had been recommended by RPA in past years. In varying degrees, we find that these options would face very significant physical planning challenges, including: constructability issues, conflict with existing infrastructure and public utilities, residential and community disruption, and the use of eminent domain. Taken together, these obstacles would at best be prohibitively expensive to overcome.
Given that other LGA rail transportation alternatives would face even greater physical planning challenges and higher construction costs than the AirTrain, and our understanding of the limitations that federal regulations impose on how funding can be structured for improvements to airport facilities, we conclude that the PANYNJ’s preferred alternative remains the best solution to substantially improve ground access to LGA.
Alternative alignments face too many obstacles to be viable.
Throughout the review process, critics have charged that there are alternative alignments -- either extending the N/W subways lines, or building a transfer station at Woodside instead of Willets Point -- that are preferable to the PANYNJ’s preferred alternative. RPA has also looked at these alternatives and concluded that they all faced obstacles that make them non-viable for this project.
Extension of the N/W subway line
Extending the N/W subway line from its terminus at Ditmars Boulevard could theoretically provide a one-seat ride from multiple locations and potentially attract more riders than the Authority’s preferred alignment. RPA considered this alternative in our own analysis, and concluded that the extension would be prohibitively costly and disruptive -- much more so than the proposed station at Willets Point. In addition, constraints around the use of fees generated by the federal PFC program and other airport generated funds limit the ability to access revenues for a project of this nature.
One proposed alignment would start at Astoria Boulevard (the second to last station on the subway line) and extend east along the Grand Central Parkway (GCP). This portion of GCP is sunken at a lower elevation when compared to surrounding neighborhoods. There are over a dozen bridges (mostly vehicular) that cross over this strip, including the approach to the Hell Gate Bridge -- Amtrak’s Hell Gate Trestle -- a structure that rises about 100 feet over ground and is used by millions of transit riders on an annual basis. To clear the trestle, the elevated N/W extension would need to rise more than 100 feet into the air to cross over these structures, making it the tallest structure in northern Queens. Even then, there would be severe disruption of infrastructure services. Given the sunken nature of this portion of GCP, it would be extremely difficult to place foundations and construction staging areas. Finally, once the AirTrain crosses over the Amtrak right of way and approaches the airport, the alignment would need to go underground into a tunnel in order to avoid obstructing the airspace of LaGuardia’s #04 runway. The Bowery Bay treatment plant sewer interceptor would be in the way of this tunnel, which would require modification of the GCP and relocating the interceptor. The costs of this tunnel and interceptor relocation would be prohibitive to the cost of the entire project.
A second subway extension option would start at the Astoria Ditmars station and run along 19th Avenue. Three residential blocks located just north of the station would be severely negatively affected by this alignment. Local residents in this area will not benefit because they are already served by the subway. Further along 19th Avenue, as the alignment goes below surface, the Bowery Bay sewer interceptor once again becomes a significant problem. The 19th Avenue alignment and the sewer interceptor would run parallel to each other for over a mile, and require a substantial portion of this stretch of the interceptor to be retrofitted or relocated. The subway extension could avoid the interceptor by moving the alignment south, but would then approach residential blocks, requiring eminent domain and significant relocation. While eminent domain is an important tool for projects that meet critical public needs, its use should be minimized as much as possible.
All the physical planning challenges and constructability issues previously mentioned could be resolved, but at a very high cost. Limitations around the use of fees generated by the federal PFC program and other airport generated revenue presents are perhaps a greater challenge. The PFC program allows the collection of fees up to $4.50 for every eligible passenger at commercial airports controlled by public agencies. Airports use these fees to fund FAA-approved projects that enhance safety, security, or capacity; reduce noise; or increase air carrier competition. As stated previously, current federal law imposes regulatory constraints that limit the ability to use these funds and finance ground access improvements that could otherwise be better integrated with existing transit systems. Such regulations can only be modified at the federal level.
AirTain alignment connecting to Woodside LIRR Station
A proposed Woodside off-Airport terminal could be located at the Woodside LIRR station, which is also the location of the 61st Street-Woodside (7 Line) subway station. RPA first proposed this alignment in the 2011 Upgrading to World Class report. While the Woodside alignment would be the most direct alternative that provides the best connection between the LIRR (all eleven branches vs. just the Port Washington Branch) and the #7 (further west), the PANYNJ preferred AirTrain alignment to Willets Point could still substantially improve access to LGA if done properly and at a significantly lower cost than the Woodside alternative.
Woodside station is farther from the airport than Willets with a much more complicated alignment along the Grand Central Parkway (GCP) and Brooklyn Queens Expressway (BQE). As with any other alternative using a western approach, this alignment would require a tunnel in order to avoid obstructing the air space of runway #04. As mentioned earlier, this tunnel would be blocked by the Bowery Bay treatment plant sewer interceptor, which would require relocating the interceptor at a much deeper level. At least two other sewer and stormwater lines are approximately 20-30 feet below grade at the intersection of 80th & 82nd streets and GCP, presenting a similar challenge.
Finally, the off-airport station would also likely need to be constructed under the Woodside complex due to the existing site constraints. The section of the BQE alignment in between Northern Blvd and Queens Blvd is densely populated and traversed by several traffic and transit lines, including Amtrak, the #7 line, and six vehicular bridges. This alignment would also cause substantial community disruption and require the acquisition of commercial and residential properties.
In summary, RPA agrees with the PANYNJ that the proposed Willets Point alignment is the most cost-effective and constructable project.
Criteria for a Successful LGA AirTrain
As RPA has testified before, to fully succeed, the LaGuardia AirTrain project must incorporate the following:
- Sufficient LIRR service and frequency
- Adequate pedestrian access at Willets Point
- Allow for future expansion to Jamaica
- Parkland and waterfront improvements
- Robust mitigation and resilience measures
The PANYNJ has been working on all these criteria, and the project has made substantial improvements as a result. Our priority issues at this point are the LIRR service and frequency, the constraints imposed by the federal PFC funding, and the parkland and waterfront improvements and resiliency measures.
LIRR Service and Frequency
The ultimate success of the PANYNJ preferred alternative will largely depend on the quality of the MTA’s service on the LIRR Port Washington line. Service frequency, fare control, price, and station design will influence the number of passengers that choose to use the AirTrain over other modes of transportation, including taxis and For-Hire Vehicles (FHV). While there has been great progress in advancing these items in measurable ways, frequency and service on the LIRR Port Washington branch and other issues remain uncertain and need to be addressed as the project moves forward.
Our previous analysis and testimony emphasized that at least four trains per hour via the LIRR Port Washington Branch would be needed. However, this is a minimum requirement, and may prove insufficient to encourage air passengers to select the preferred alternative over taxis or For-Hire Vehicles (FHV). Even with the added shuttle service described in interagency correspondence, half the trains from Willets point would go to Penn Station and half would go to Grand Central Terminal (GCT). This means that each station would actually see a train coming to or from Willets Point every 30 minutes, not the 15-minute service headway suggested by the PANYNJ ridership model. While air passengers commuting from Manhattan towards LGA could plan their schedule around which station to depart from (Penn or GCT) and minimize their waiting time, incoming passengers landing at LGA do not have that same option. For some passengers, it will not matter which Manhattan-based terminal they go to -- Penn Station and Grand Central may be effectively the same distance from their final destination. But for others, the benefit of a one-seat ride to the east or west sides of Midtown will be worth waiting 15 minutes for a later train. The benefits of providing access to both stations and demand for the service could justify even more robust scheduling as a way to decrease waiting times.
Interagency correspondence from 2019 indicates that pending MTA board approval, the new shuttle service aimed at increasing frequency at the Port Washington branch would be funded by the LIRR operating budget. Given the MTA’s current budgetary constraints during the COVID crisis, including the possibility of service cuts by as much as 50% on commuter rails, it is reasonable to question whether the Port Washington branch should be prioritized over other LIRR systems as a way to meet the necessary frequency for the preferred alternative to function as intended. The Port Washington Line is the only LIRR branch to not serve Jamaica, a major LIRR transportation hub, as it branches off the Main Line several miles northwest of that station. This raises questions about using scarce operating resources to prioritize service on a branch that is isolated from the rest of the system.
The uncertainty around the future of air travel (particularly business travel) and the FAA’s revised LGA AirTrain ridership forecast, also raise questions about the initial projections forecasted in 2018. The FAA’s modeling has concluded that ridership on the AirTrain would be 30% less than the PANYNJ -- a decrease from 13,167 anticipated daily air passengers (paying ride fares) to 9,173 passengers by 2026. In terms of annual ridership, this is a drop from 4.8 million air passengers to 3.3 million by the year 2026. While we understand that these projections were developed to inform the conclusions of the environmental review process (not planning operations around expected demand), taken together, these issues point to the challenges of developing and relying on ridership forecasts.
Explore Solutions to address Regulatory and Fiscal Constraints
Under these challenging circumstances, all agencies involved including the PANYNJ, MTA, and FAA, should explore alternate fiscal options and present a framework to help prioritize capital programs, general operations, and inform decision making all across their portfolios.
One option that could be explored is a prorated system based on actual ridership as a way to split operation costs in a fair way and without burdening MTA’s operating finances. A proportional cost sharing system would differentiate between air passenger riders and non-airport users. This prorated system in combination with a cross-subsidy framework could also be used to ensure that more non-airport riders can access the new system. The increased frequency/reliability on the Port Washington could then justify the expansion of LIRR NYC programs that provide reduced fares for trips within the city, and implementation in this LIRR branch.
Parkland and Waterfront Improvements and Robust Mitigation and Resiliency Measures
We are also encouraged to see measurable progress on commitments made to improve pedestrian access and resilience at the Flushing Bay promenade. Namely, the memorandum of agreement between the PANYNJ and the NYC Parks Department to commit $35 million for these efforts. We believe that the public process to determine how to invest these funds as outlined in that agreement must ensure that the plan will enhance access to both the promenade and waterfront. We also endorse the idea presented by other civic organizations to include the Flushing Bay Promenade Community Advisory Council to ensure that the community has input into what the enhanced public access and park improvements are to serve the local community as well as the broader Queens and New York City community. The Advisory Council should be continued beyond developing the plan through implementation to ensure the commitments made are met. We also encourage this process to use the Flushing Waterways 2018 Vision Plan developed by Riverkeeper and Guardians of the Flushing Bay as a starting point for the public conversation about park and waterfront access and enhancements.
Conclusion
Intercity travel is at the core of an increasingly interconnected and competitive global economy. Without the ability to efficiently transport business and leisure travelers, both domestic and international business would grind to a halt. Since virtually all long-distance travel is by air, along with a high proportion of shorter distance travel between cities, metropolitan economies depend on their ability to provide high quality airline service to multiple destinations. This is especially true for world city regions like the New York metropolitan area that are even more dependent on industries with a high propensity for flying. In New York, New Jersey and Connecticut, the leading economic sectors — financial and business services, tourism, pharmaceuticals, media and communications, higher education, research and development — all rely on frequent air travel to multiple destinations. Indeed, the region’s status as a nexus for domestic and international air travel is intricately linked to its role as a premier center of global commerce. This was true before COVID-19, and will be essential to the region’s recovery.
The PANYNJ’s proposed LaGuardia AirTrain project utilizes the airport’s Passenger Facility Charge (PFC) funding, provides needed rail transit access to the airport, and identifies the best alignment given constraints in the surrounding community. RPA endorses the Port Authority of New York and New Jersey’s proposed action and urges that the project move forward to help modernize and upgrade the region’s infrastructure.
