The Real Estate Board of New York to MTA Bridges and Tunnels (MTA B&T), New York State Department of Transportation (NYS DOT), Federal Highway Administration (FHWA) regarding the Central Business District Tolling Program Environmental Assessment

Basha Gerhards

Senior Vice President of Planning, Real Estate Board of New York

September 5, 2022

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REBNY appreciates the dedication of the City, State and Federal agencies for the work so far to bring congestion pricing from statute to reality. Thank you for the opportunity to submit favorable comments regarding the Central Business District Tolling (CBD) Program Environmental Assessment.

REBNY is a proud member of a coalition of transportation and environmental advocates in support of a plan that will provide critical funding to the transit system and avoid fare increases for its riders while decreasing air pollution and protecting our communities. Congestion pricing is a proven tool that provides the opportunity to create a more efficient, equitable, and sustainable transportation network that will greatly improve mobility for all who live in, work in, or visit New York City. In London, for example, congestion pricing has been proven to reduce traffic, lower transportation times, and increase ridership in public transportation.  C40 Climate Leadership Group reports that when first introduced in 2003, congestion pricing led traffic to fall 30% and bus ridership to grow 38% in the first year alone.

Congestion pricing serves as deterrent from using private vehicles that have emissions that pose significant health risks to the public. According to recent work by the Harvard School of Health, “Many states are heavily impacted by out-of-state emissions and some states cause more deaths out-of-state than in-state, including PA and NJ, highlighting the importance of region-wide action to reduce vehicle emissions.” This initiative is a necessary step in decreasing dangerous air pollution that poses a risk for all New Yorkers, particularly those living in transit deserts and environmental justice communities.

Importantly, congestion pricing serves a dual function – to reduce traffic while also providing the funds needed for a modern, clean, and reliable mass transit system. For example, the funds generated through congestion pricing will help secure the conversion of the existing MTA bus fleet to a full electric fleet. Identified as a mitigation measure in the assessment, this change alone will have significant health benefits for New Yorkers living near toll crossings and existing bus depots and along bus routes throughout the city.

Beyond providing an environmentally cleaner mass transportation system, congestion pricing will expand transit options - directly improving subway and bus service to underserved areas and transit deserts where public transportation is not as easily accessible, and toward critically needed projects like the extension of the Second Avenue subway, new express bus lines in Brooklyn, and new Metro North stations across the Bronx, as well as improved accessibility for the disabled.

This past year has arguably been the toughest for public transit across the nation. Pre-pandemic, a lack of dedicated funding historically undermined the MTA’s ability to both keep the existing service well-maintained while expanding to meet the needs of a growing city. Congestion pricing will provide the necessary funding to accomplish those goals. Millions of riders staying home because of the global pandemic has cost the MTA even more much-needed ridership revenue, exacerbating issues that were already dire. COVID-19 relief funds received were utilized to make up for operating losses while ridership was significantly decreased during the pandemic; they are not available for capital expenditures such as critical improvements and repairs moving forward.

Given this challenging financial picture, the MTA’s ability to fund its capital plan is in doubt, meaning the $15 billion in capital funding that can be raised through congestion pricing revenue is now essential. With car traffic and grid lock back to pre-pandemic levels, congestion pricing is also the best bet to improve and expand bus and subway service, which hundreds of thousands of New Jersey residents rely on every day for their commutes. New York drivers commuting into New Jersey pay tolls when using the New Jersey Turnpike and Garden State Parkway. The revenue from these tolls will help fund New Jersey Transit service repairs and improvements.

The cost of not moving forward with a tolling plan will be significant in its adverse effects to the city and region. Without the funds generated through congestion pricing, the MTA will be forced to increase subway and bus fares, making public transportation more expensive and will lack the funds necessary to repair and improve the system, which will continue to deteriorate. Without congestion pricing, local air pollution and respiratory ailments will worsen in New York City as traffic inevitably gets worse, creating a serious risk to public health.

The time to move forward with a plan to generate billions of dollars in funding to make critical improvements to New York City’s subway, bus and commuter rail systems and to eliminate hundreds of thousands of metric tons of greenhouse gas emissions from our atmosphere is now. Through congestion pricing, New York City will have better public transportation, less congested roads, and cleaner air. The environmental assessment makes clear the trade-offs and provides a reasonable road map forward. This process needs to move forward as well.

Thank you for the opportunity to submit testimony.

Topics Covered

  • Environment
  • Quality of Life