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November 30, 2007

Mr. Marc Shaw, Chairman
New York City Congestion Mitigation Commission and
Executive Vice President-Extell Development Corporation
800 Third Avenue, Fourth Floor
New York, New York 10022

Dear Mr. Shaw:

I want to thank you and all the members of the New York City Mitigation Commission for undertaking this critical assignment to review and study plans to reduce traffic congestion within the City of New York and issue recommendations to the governor, state legislature, the mayor and the city council. I also want to thank you for the open process, and the opportunity to comment.

I have expressed my conditional support for Mayor Bloomberg’s bold Congestion Pricing Initiative on several occasions. I believe that some form of this proposal can reduce congestion, increase transit use, provide a funding source for transit capital improvements and enhance the environment of our city. To that end, I want to submit my comments for consideration by the Commission.

A number of commentators have stated that this proposal tries to address too many objectives simultaneously. As I have stated in the enclosed copy of my August 1, 2007, letter to Governor Spitzer, I believe the congestion pricing initiative, the related transit fare and level of service should be viewed primarily as behavior modification tools (i.e. carrot and stick), to get people out of their cars, rather than as a mechanism for maximizing transit income. I agree that there is an urgent need to address transit funding, but any congestion charge would need to be carefully coordinated with transit fares to encourage, rather than discourage, transit use.

If the proposed $8 congestion charge would indeed be in effect daily from 6 a.m. to 6 p.m., consideration should be given to maintaining an attractive level of transit frequencies and services available throughout this period. To encourage transit use, the public must be assured that connections for return trips can be made after the evening rush hour. This may require
expanding availability of service beyond that which is available today to serve a city that never sleeps.
In the short run, provisions must be made for the vulnerable segments of our society, including the elderly and those with disabilities; those populations residing in areas underserved by transit; and those businesses which, by economic necessity, must frequently drive vehicles  into the Manhattan Central Business District (CBD). To that end, I have identified the following opportunities for enhancing the equity and effectiveness of the initiative.

• Provide business necessity exemption: Provide an exemption to those who have no recourse or alternative to entering the CBD by personal, commercial or livery vehicle.

• Provide a senior citizen exemption: Provide free transit use to senior citizens and the handicapped at all times, similar to that implemented in London.

• Implement early transit improvements: Implement transit service and capacity improvements before the congestion pricing plan goes into effect. This must include those areas which do not have subway service, such as southern Brooklyn, where express bus service must be enhanced; the base express bus fare should be the same as the base subway fare; and much needed waterborne/ferry service should be initiated.

• Expand service on lines with capacity: Expand service on those lines that have available capacity, as NYC Transit loading guidelines may not be sufficiently spacious to attract this new crowd of former auto commuters. Some options include extending the V train through the Rutgers tunnel and implementing an express on the Culver line, served by the F train; a super express from East New York to Marcy Avenue on the Brooklyn Broadway line served by the J, Z, M trains; and improved G train service on the Brooklyn Crosstown line, particularly restoration of the six car trains that were reduced to four car trains in conjunction with implementation of the 63rd Street Connector project. In light of the many overcrowded subway lines, implementation of Communications Based Train Control (CBTC) should be expanded and accelerated, particularly on the overcrowded Canarsie line, L train.

• Expand ferry service to CBD: Expand or support ferry service from outlying areas of the city to the CBD, and integrate ferry services with the transit system to enhance our mobility, provide new connections and avoid land based bottlenecks as our waterfront communities grow. Preliminary suggestions include the 69th Street Pier, Atlantic Avenue, Coney Island and the Rockaways as possible stops on a Lower Manhattan/Downtown Brooklyn to JFK service, and a Downtown Brooklyn stop on the high speed Lower Manhattan to LaGuardia service. To be effective, all connections must work together seamlessly and be perceived to be working seamlessly because the public’s perception of service will influence commuter choices.

• Build a park-and-ride facility, including a municipal parking lot, at the expanded Gateway Mall in Spring Creek: This facility would be served by borough-wide local and express bus services and by the Kings Highway/Flatlands Avenue Bus Rapid Transit (BRT) proposed by the New York City BRT Study. This facility should be modeled after the Kings Plaza Bus Terminal and Layover Area and should be included in the Gateway Plaza plan submitted for ULURP approval.

• Provide capacity on the FDR Drive and West Street: This would absorb the volume of vehicles to be diverted from traveling through the Manhattan CBD. The mobility of this route is necessary not only to decongest the Manhattan CBD, but to avoid backups on the Brooklyn Bridge as well.

• Restore the two-way toll on the Verrazano Narrows Bridge: The current one-way toll contributes to congestion in Manhattan and Brooklyn, and also results in lost revenues. In-bound vehicles are currently not required to pay, and returning/outbound vehicles travel on local streets in Brooklyn and Manhattan to avoid the toll.

• Protect neighborhoods from becoming park-and-ride lots: Protect those communities, such as Downtown Brooklyn and other areas near subway stops, which are expected to absorb displaced vehicles and a shift of travel from auto to transit by implementing a resident permit parking program so that residential areas do not become park-and-ride lots.

• Implement pilot program to test assumptions: We should carefully assess assumptions around ideas such as variable time-of-day pricing and congestion mitigation measures. Several experts have recommended that travel data should be measured, factors contributing to congestion identified, and a final program designed for implementation at the end of the three year pilot.

• Reduce and eliminate the availability of free parking: Free parking creates incentive for driving in Manhattan and contributes to congestion. The current proposal should reduce the availability of free on-street parking in Manhattan with metered parking; charging rates approximating those charged at commercial lots should be considered; violations should be strictly enforced with penalties that are proportional to the duration of the violation.

• Eliminate the city’s tolerance for parking permit abuse.

• Establish a network of regularly spaced taxi stands throughout the CBD: Passengers can be boarded at these stands to reduce the concentration and impact of taxis on CBD congestion. Further, multiple-passenger pickup at Penn Station, the Port Authority Bus Terminal and other high use Manhattan taxi stations, as well as targeted taxi stations throughout the city, should be considered to reduce the movement of vehicles required  for CBD circulation and access.
• Implement truck requirements: Enforce a comprehensive policy concerning truck loading requirements, goods movement, night deliveries and oversized trucks.

• Encourage travel by high occupancy vehicles.

• Review the recommended “SMART Financing Authority”: This would issue debt secured by City, State, Federal and Congestion Pricing revenues to fund transit improvements. In light of its costs and the additional bureaucracy it would create, careful review is recommended before a decision is made on its implementation.

  For the longer term, our future transportation needs should be planned and funded more
  comprehensively.
 

• Change the current method of financing transportation in New York City: Given the projected shortfall of transportation funds, all levels of government must assume their fair share. As I have stated in the enclosed copy of my August 1, 2007, letter to Governor Spitzer, the City and State of New York must assume a greater obligation in funding transportation to relieve the unfair burden on the traveling public. As I have said at the recent MTA fare hearing in Brooklyn, I support the legislation recently introduced by Assembly Member James Brennan to provide additional funding to MTA and I welcome the governor’s recent public promise reported in the New York Times to substantially increase State subsidies to the authority’s operating budget. With regard to the congestion pricing  initiative, I agree with Council Member Lewis Fidler that a regional payroll tax is warranted to shift the burden of transit investments on a more equitable basis to all those who benefit from them.

• Do not exempt the suburban commuter: Establish a mechanism to have commuters from suburbs such as Long Island, Westchester and Rockland Counties, as well as New Jersey and Connecticut contribute their fair share to the resolution of the CBD congestion problem.

• Complete the Cross Harbor Freight Tunnel Draft Environmental Impact Statement (DEIS): This city cannot be sustained by continuing its overdependence on trucks for  the movement of goods. As trucks are the fastest growing component of the region’s traffic, it is important to consider this project in terms of its function in the overall multi-modal transportation system of the future. Studies have indicated that the project would remove hundreds of trucks from our highways and streets, stimulate Brooklyn's waterfront activities, and improve air quality. However, representatives of communities along the land route of the tunnel project have expressed concern regarding  the local economic and social impacts. It is, therefore, necessary to quantify all of the impacts, and to design a balanced project that does not solve one set of impacts while creating unacceptable impacts that cannot be mitigated.

• Extend the Second Avenue Subway into Brooklyn: Extend the line as provided in the 1920’s and 1970’s versions of this project, to provide the needed mobility by the year 2030.

• Complete and upgrade the connections between the former BMT, IRT and IND subway lines that have been missing since the subway system was unified by the city in 1940: The connections I have identified in my proposal for Brooklyn Subway Connectivity Improvements would improve the system’s redundancy and make travel on the subway more convenient.

Finally, I am hopeful that the process initiated by the Congestion Mitigation Commission and the legislature, including the need to identify and analyze environmental impacts, will remain transparent. This is especially important due to the broad impact the current initiative may have on the city’s economy and its national competitiveness.

The Commission hearings have started a dialogue among organizations and individuals who care about this city and its future, and I look forward to a resolution of the issues I have identified.

Thank you for the opportunity to comment.

Sincerely,

Marty Markowitz

cc: Brooklyn City Council Delegation
Brooklyn Assembly Delegation
Brooklyn State Senate Delegation
Congestion Mitigation Commission

MM/mjr