It's My Turn
Thank you for this opportunity to comment on the need to address traffic congestion in the City of New York. Mayor Bloomberg deserves credit for helping to focus attention on the need to make headway. At the same time, the problem identifier receives no monopoly to propose fixes.
Keep NYC Congestion Tax Free is a broad-based coalition including many community-based organizations which represent everyday New Yorkers. We take pride that our coalition proposes sound alternatives; we do more than say "no" to a controversial, regressive, exorbitant and complex congestion pricing scheme.
Keep NYC Congestion Tax Free devised a set of alternative approaches that will more effectively meet the need to alleviate congestion - and will do so at a lower cost. This makes much greater sense.
New Yorkers want and deserve such a cost-effective workable plan. Unlike the city plan, the alternatives to congestion pricing we proposed and de- -tailed in our report - already presented to each member of the commission and state and city legislators - meet the test of equity, efficiency and economic sense.
Proponents of the tax scheme falsely argue that their plan addresses all sorts of maladies when most through drivers and truckers who pay Hudson and our East River tolls would receive offsets that negate the impact of the congestion tax on motorists and truckers who use Manhattan as a short cut; should not there be a higher toll for trucks that pass through? Proponents of the congestion tax never criticize the substance of our sound proposals; they just question our intent or want to blend our proposals into their sour mix.
The city plan - essentially an end run around tolling the currently free East River crossings - according to the public record - would provide at best $300 million out of $620 million the city asserts this tax program would raise for mass transit projects. This is after some $240 million in annual operating costs and $104 million the MTAexpects to use for new service operations get deducted from the annual take. So, as a revenue measure with less than 50 percent of the monies collected going towards transit projects, the city plan just fails dramatically.
So do not let Congestion Tax proponents seduce you with arguments on revenue; the London experience suggests the need to impose much higher congestion taxes to achieve revenue. If revenue is the goal, look to other means. Many preferable (revenue) alternatives exist, just waiting for policymakers to consider them. Some members of our coalition offer their own proposals and we would be glad to arrange meetings to explore those options.
And the city plan's exorbitant costs extend beyond the system's annual operation to the construction of an elaborate and expensive infrastructure the system would require.
The lure of federal money, still speculative, and dependent on Congressional allocations and authorizations, offers no justification for bad and costly policies to address a problem. The alternative approaches include measures that satisfy the requirements of the USDOT to qualify for the federal funding. These measures emphasize value pricing and use of technology. This gets done without any need to resort to expensive gimmicks such as the city's scheme.
The critical flaws in the city's proposal remain its failure to focus on the key causes of congestion.
•Taxis cruising the streets of Manhattan;
•The proliferation of black cars;
•City issued placards to people who have no need for them who clog our streets and tie up our curbside space;
•The failure to strictly enforce traffic and parking laws; and
•The 10,000 trucks that have no point of origin or destination in Lower Manhattan that daily use our streets as a pass through, generating massive traffic jams.
Unlike the city plan, our "Alternative Approaches" identifies these and other specific causes of congestion. More importantly, it offers realistic solutions to these problems.
Our plan incorporates the good ideas promoted by our Mayor with respect to traffic mitigation. It also adopts many solutions to the problems of traffic in the Manhattan CBD promoted by our most illustrious traffic experts such as Sam Schwartz, John Falcocchio, Donald Shoup, Bruce Schaller, Jose Holguin-Veras, and Charles Komanoff, and organizations such as NYU's Rudin Center for Transportation, Rutgers University's Voorhees Transportation Center, and Transportation Alternatives.
The city scheme will adversely affect the city's economy; this includes $690 million in lost economic activity, tens of millions of dollars in lost state and city taxes and as many as 8,700 lost jobs. And this does not reflect the impact of the "Buy American" waiver that can cost Americans jobs! And in contrast to the false claims congestion tax proponents aired in commercials and shilled in hundreds of thousands of glossy mailers, the city plan will shift congestion and pollution to many locations in the outer boroughs. Disturbingly, many of those locations already have more traffic congestion and pollution than Manhattan.
These bad results make it imperative to adopt our alternatives which will reduce miles traveled in Manhattan by as much as double the amount as the city plan, and do so without punishing those who can least afford to pay this regressive tax, or harming the city's economic vitality and quality of life. It will keep the free tolls free.
Unlike the congestion pricing plan which focuses solely on vehicle miles traveled, this alternative plan offers many additional traffic mitigating solutions that alleviate congestion beyond the rigid vehicle miles traveled (VMTs) criteria employed by congestion tax proponents. Each measure we propose is focused and impacts at the "margins," but cumulatively, the measures significantly address VMTs and congestion.
Congestion is not solely a factor of the number of vehicles/vehicle miles traveled, but also is a function of inefficient traffic management. The alternatives outlined in this report focus on both reducing vehicle miles traveled and improved traffic management.
The mitigation alternatives identified in this report could generate approximately $428 to $545 million. This amount exceeds the net monies claimed under the city plan without major capital investments or major increases in operating costs. (The city plan will require a minimum investment of $233.6 million and yearly operating costs will be $240 million. Approximately 40 cents out of every dollar charged for the congestion tax will be lost to overhead). The October 22 Daily News exposé questions the ability of the city plan to raise any net revenue - at all!
In contrast to the massive infrastructure (cameras, E-Z Pass, SMART Authority, etc.) needed to sustain congestion pricing, the alternatives outlined in this report use currently existing infrastructure and resources. These conservative calculations of the incidental revenues raised by our alternatives do not reflect measures such as charging a market value permit fee for construction sites. This latter proposal makes clear that our plan raises over $1 billion in revenue. A commission member has ready access to the actual numbers of construction permits and should make that data available to the commission, elected officials and the public.
The city's congestion pricing proposal follows a rigid all-or-nothing approach. This alternative plan incorporates a modular approach. The public, the Commission, and city and state legislators remain free to accept or reject any of the modules, and, each module has a range (providing the flexibility to fine tune each module. They can choose to implement any of the modules more or less aggressively).
Better and real alternatives exist to reduce traffic congestion more effectively and comprehensively without any need to implement a drastic plan, which will disrupt and harm the lives of many residents, senior citizens, working people and small businesses in our city.
This report conclusively establishes irrefutably the city's ability to achieve a reduction well in excess of 6.3 percent in vehicle-miles traveled, while raising revenue for mass transit, without resorting to a complex, expensive, inefficient and inequitable congestion pricing scheme. Keep NYC Congestion Tax Free urges the New York City Traffic Congestion Mitigation Commission to fully review these and all alternative approaches before making any recommendations that will adversely affect our mass transit system and residential neighborhoods.
There exists no need to implement a drastic, costly plan with all of the strong solutions and innovative alternatives that have been promoted by many talented traffic experts and are well within our reach. An 'all-or-nothing' approach is a one-way street New Yorkers do not belong on.