NYC Comptroller’s Office Comment on the CBD Tolling Program Environmental Assessment

“Thank you to the Metropolitan Transportation Authority (MTA) for the opportunity to comment on the environmental assessment (EA) for the Central Business District (CBD) Tolling Program to establish congestion pricing in Manhattan. As the Chief Fiscal Officer of the City of New York, the NYC Comptroller works to promote the financial health, integrity, and effectiveness of New York City government to help secure a thriving future for all New Yorkers. Establishing a CBD tolling program is exactly the kind of action we must urgently take to build a more equitable and resilient city.

“Revitalizing the city’s economy will require untangling our snarled streets and bringing ridership back to trains and buses. Though the City saw car traffic plummet at the outset of the pandemic, traffic levels have since rebounded to or above pre-pandemic levels1 while subway ridership has dropped to barely 60% across the system. 2 Even before the pandemic hit, farebox revenues were not nearly enough to maintain and upgrade the nation’s largest transit system. Federal dollars helped reduce some of the MTA’s gaping deficit, but long-term, the need remains and increasing fares for subway commuters, many of whom are from communities of color and essential workers who keep our city running, is neither fair nor financially sustainable.

“With projections of approximately $1 billion in annual revenue, congestion pricing will help to fund long-overdue capital upgrades for our century-old subway system, including modernizing signals and installing elevators, which will improve service and attract riders to the system. A poll conducted earlier this year found that if congestion pricing were implemented, 42% of respondents would drive into Manhattan less often and that 64% of respondents would instead use mass transit. 3 That’s great news for everyone — including drivers, straphangers, cyclists and pedestrian. Fewer drivers will mean faster commute times for everyone, as remaining drivers and cyclists will face less traffic, bus riders faster buses, subway riders better service, and pedestrians safer streets.

“The implementation of congestion pricing will also help support a more equitable City. Prior to the COVID-19 pandemic, the Community Service Society found that just four percent of outer borough NYC residents drive into Manhattan for work, while 56% rely on public transportation to get to jobs in Manhattan and elsewhere. 4 Those high rates of subway ridership among outer borough New Yorkers have remained strong since the outset of the COVID-19 pandemic. While overall subway ridership is down, ridership at stations in the outer boroughs serving some of our City’s most diverse communities like Junction Boulevard and Jackson Heights-Roosevelt Ave/7th Street 5 ranked among the highest in the city. Congestion pricing will ensure the system gets the investments it needs to continue serving our City’s diverse and working-class communities, while creating new opportunities to expand and improve the system in response to these dramatic shifts in commuting patterns.

“The MTA’s multiple tolling scenarios will help maximize flexibility as we advance implementation. As the MTA considers the tolling prices for different vehicle types, we encourage the MTA to consider the economic impacts on different roadway users to ensure the policy is both effective and equitable.

“Our office strongly supports the proposed tax credit for low-income New Yorkers, and changes to E-ZPass for unbanked and underbanked residents. We also support the framework that the MTA has put forth for accountability and adaptive management as they implement this ambitious project. The MTA’s proposal for real-time continuous monitoring of traffic and air quality impacts at specific intersections, roadway segments, and subway entrances will help monitor the project’s impacts on local neighborhoods and swiftly mitigate adverse impacts with measures like wider sidewalks, safer pedestrian crossings, and new stairs and faster escalators at transit stations.

“The EA estimates that 50 to 704 daily truck trips will be added to the Bronx once congestion pricing is implemented. While that would amount to a relatively small increase (2.5% percent) in truck traffic, any potential uptick in air pollution must be monitored and mitigated appropriately, especially in environmental justice communities already bearing the burden of our City’s infrastructure. Our office supports the proposed infrastructure and sustainability improvements at the Kingsbridge and Gun Hill Depots, located in environmental justice communities as well as the MTA’s commitment to establish an Environmental Justice Community Group that will maintain transparent dialogue with environmental justice advocates through project implementation and encourage the inclusion of Bronx community representatives in that working group. The Federal, State, and City also need to work together to reduce truck traffic and particulate matter in New York City overall, through incentives and mandates for vehicle efficiency and electrification and increased use of rail- and water-based freight, among other interventions to reduce truck trips at the local level such as Delivery and Servicing Plans for large commercial buildings and micro-distribution centers to support expanded use of cargo bikes.

“The benefits of the CBD Tolling Program are clear. Our beleaguered transit system needs strong, reliable funding sources if we are going to modernize ancient signals, get trains and buses moving faster, and expand service to better serve New Yorkers in response to shifting commuting patterns. The implementation of congestion pricing is critical to achieving that goal.”

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