Clinton/Hells Kitchen Pedestrian Safety Coalition

DOT Truck Route study -

Lack of Lincoln Tunnel study

We are grateful for the report recommendations for West 15th Street, 16th Street, and 25th Streets in Chelsea and its suggestions of mitigation for West 43rd Street to West 46th Street.

Frankly, we were shocked to discover that the study does not include a single reference to the Lincoln Tunnel and its accesses - in particular 9th Avenue access - as a “Truck Generator site” worth studying in detail, nor was it selected as a” Hot spot” corridor where Truck Routing and Engineering improvements should by applied . It is most surprising since the report points to this corridor as particularly dangerous and congested:

1. 33 accidents per mile on 9th Avenue marks this corridor as the second most dangerous in Manhattan - “9th Avenue - Of the 44 total accidents reported along the 9th Avenue Corridor, 21 accidents occurred along the 0.6-mile span between 34th and 46th Streets.”
2. The truck prohibition in the Holland Tunnel has redirected commercial traffic to the Lincoln Tunnel. “As a result of the truck prohibition at the Holland Tunnel, commercial traffic from New Jersey will be inclined to use the Lincoln Tunnel and West Street to access Lower Manhattan, especially the Canal Street corridor. The situation has been less problematic {at Canal Street}, since the implementation of truck restrictions at the Holland Tunnel as a result of 9/11. The current policy is that the Port Authority of New York & New Jersey (PANYNJ) prohibits all trucks into Manhattan and permits only two and three axle trucks bound for New Jersey to use the Holland Tunnel. All other trucks are prohibited. Nevertheless, this location (Canal street) is included in the analysis because Holland Tunnel access restrictions may change in the future
3. The Lincoln Tunnel is already severely congested “and is included in the list of those truck routes in Manhattan which are forecast to experience severe traffic conditions in 2025 “.

Because the study relies significantly on 5-year-old data (pre 2001), the study ignores critically important locations that have undergone dramatic changes over the last five years
1. West 42nd Street between 9th Avenue and the Hudson River, which is currently a through truck route, is not recognized in the study as mostly residential. However, in the last 5 years over 10 residential high rises have been erected on this segment, which is also a main tourist corridor between Hudson River activities ( museum, park, river trips) and Times Square, just east of 9th Avenue!
2. 9th Avenue is not included in the list of those truck routes in Manhattan that are already highly congested and forecast to experience severe traffic conditions in 2025. Daily evidence proves otherwise as the Port Authority of New York & New Jersey changed its overall access route to the Lincoln Tunnel in 2003 and closed 41st Street access to the Lincoln Tunnel after 9/11, adding major bus congestion to all other accesses to the tunnel - particularly 9th Avenue and 42nd /41st and 37th Streets.
3. The study of the UPS and FedEx truck generator sites ignores the FedEx 48th Street facility, the Verizon facility on 43rd and the new DHL facility on 10th bet. 38-39th, the Javits Center truck-marshalling facility in its current or future location and the Lincoln Tunnel.
4. Holy Cross School, at 43rd Street and 9th Avenue, has been designated the most dangerous school to walk to in Manhattan according to the DOT. Pedestrian and cyclist injuries more than doubled between 2002 and 2004 at eleven intersections on 9th Avenue.

The Hell’s Kitchen Neighborhood Association, which represents over 500 residents, attended the second DOT outreach meeting in Manhattan in November of 2003. Its board members raised the same issues as above. None of their comments has been included in the reports on community outreach. We would certainly like to know why.

Our Comments on the study in general

The report does a good job of describing background context (since the last study 25 years ago), of bringing to light some fundamental flaws of the system, and discussing current technology trends. It predictably recommends simple and obvious steps.
The study does not propose any solutions for the fundamental causes of the problems raised for the City at large and Manhattan in particular.

Reducing the number of private automobiles on the road network is critical to any improvement in the delivery of goods in the city: the report notes that the automobile congestion is a major impediment to the delivery of goods in the city and especially in Manhattan. However, it does not offer any solution to the automobile crowding, except the traditional approach to open more truck routes into parks etc.
“The New York City region’s truck freight network is severely congested. Automobiles account for most of the congestion, yet the congestion is a major problem for freight movement because of the travel delays it causes. It also erodes the ability of the truck freight network to provide reliable and predictable freight service. When roads and highways are saturated, traffic flows are unstable; the frequency of incidents both minor and major increases; the time required traffic flow to recover increases exponentially; and reliability disappears. A one- or two-hour delay can mean a shutdown of manufacturing operations for a day, the loss of considerable retail sales, or a missed train or air flight with a delay of a day in a domestic shipment or a missed boat or plane with a week’s delay in an international shipment. This translates to a loss of revenue for the shipper/manufacturer/merchant, affecting their competitiveness and profitability, but just as directly it impacts the motor carrier’s operating costs.” “A far greater percentage of the Local Truck Route network in
Manhattan is forecasted to be severely congested. This is not surprising because of the shear number of commercial businesses that are located in this densely populated Borough. In addition, the fact that two of the largest central businesses districts in the United States are located in this one physically constrained environment creates a certain level of congestion that is rather unique to this Borough”.

The definition of truck should be aligned with the one used in the rest of New York state and the country. The overall regulations must be simplified to be enforceable. The report deplores the fact that none of the stakeholders understands the rules and proposes an education package rather than a change in definition. However Without changing the definition of trucks any attempt to educate law enforcement officers and stakeholders will be for naught
“The existing truck regulations currently in place for New York State generally parallel those at the national level and in surrounding states. However, while these regulations and policies cover the entire State, there are numerous provisions within State regulations where the existing laws or policies are not applicable within the confines of New York City. These differences have been exacerbated over the past 20 years as both trends in goods movement and federal policies have created a complicated and distinct set of regulations governing truck dimensions and access within the City’s boundaries. Central to this issue is the difficulty in understanding the differences between the State regulations and those within New York City, and the application of both sets of rules on the various arterials which make up the New York City roadway system. In addition, due to the shear volume of daily truck traffic on both on an intra- and inter-city basis, and the regional nature of some of the City’s roadways, the identification and compliance to these regulations is difficult on many levels
A policy of incentives to reduce pollution by diesel trucks must be implemented to bring the city in compliance with basic public health standards. While the report identified many public comments related to this subject and set out a goal to reduce quality of life impact to the residents, its proposal for voluntary off hours deliveries falls very short. Major incentives (positive and negatives) need to be implemented to encourage off hours deliveries and companies to convert their trucks to convert to bio diesel. The testimony below from Environmental defense is compelling:
“New York City's air quality is among the worst in the nation. Presently, all five New York boroughs fail to meet basic public health standards for ozone and fine particulate matter. Both are a product of emissions from diesel vehicles, such as the large trucks currently clogging New York roadways. In New York City, diesel exhaust emissions are the hazardous air pollution with the highest contribution (more than 85%) to air cancer risk." Diesel engines emit nearly 40 toxic substances, smog-forming oxides of nitrogen, and fine particulate matter that can penetrate deep into the lungs and enter the blood stream. Particulate matter exposure is associated with heart attacks, reduced lung function, bronchitis, and asthma attacks. New York City residents suffer from alarmingly high asthma rates - one out of every eight adults (700,000 New Yorkers) has been diagnosed with asthma at some point m their lives. 11J In 2000, children living in the City's five boroughs were almost twice as likely to be hospitalized because of asthma attacks as the average U.S. child." Asthma was the leading cause of hospitalization in New York's children, 300,000 of whom have been diagnosed with this disease.”

Enforcement should be given the mission to enforce traffic rules rather than expedite traffic.
The report points out the maze of traffic enforcement units and their poor records of ticketing in Manhattan, but their remedies fail to address the real problem.
It should be centralized in a single department rather than the seven identified, and concentrate on the accident prone corridors first, rather than the complaints as proposed.

There should be no through truck routes in Manhattan: the report indicates that most of the through truck routes are sufficiently away form residential areas. Information that is more recent would show that major portions of 34th street, of the west side highway and the whole portion of 42nds Street between 9th and 11th avenue are very residential.

If the through truck routes remain in place, DOT should design, distinctive signs well differentiated from local truck routes panels. The recommended signs do not differ in color or sizes between local and through truck routes. Also no through truck routes should begin or end on a local street, as it is the case in the Lincoln tunnel area.

The city council should schedule a new hearing to give the public time to read this large document and ensure that the comments will be taken in account by DOT.

Testimony of Environmental Defense

Presented at a public meeting on NYC DOT’s Truck Route Management and Community Impact Reduction Study
June 11, 2006

Good evening and thank you for the opportunity to comment today. My name is Stephanie Tatham, I am a Program Associate in the Living Cities Program at Environmental Defense. Environmental Defense is a national non-profit environmental organization, headquartered in New York City, with 400,000 members around the country and over 50,000 members and activists in New York. The LIVING CITIES program at Environmental Defense is focused specifically on actions that will help to improve urban water and air quality, clean up contaminated lands, support sound transportation investments, and reduce greenhouse gas emissions.

I am here today to offer Environmental Defense's comments on the Truck Route Management and Community Impact Reduction Study. This type of study is of great importance, and is long overdue; the last comparable study was conducted in 1982. Truck route management is a critical issue in New York City, and will become increasingly important in the coming years as the volume of goods moving into the region grows dramatically. NYC DOT, through an Office of Freight Mobility, should conduct studies like this with greater regularity in the future.

Environmental Defense appreciates NYC DOT’s undertaking of this study and recognizes the hard work that went into producing the 1,000 plus page draft study with NYC DOT’s findings. However, NYC DOT needs to address truck traffic and related-traffic congestion more broadly. First, I would like to speak to the recommendation for creating an Office of Freight Mobility within NYC DOT, and the role that this office could play in developing a comprehensive freight mobility plan for the City of New York. Next, I will address Environmental Defense’s concerns with the truck route management study, including the limited opportunity for public dialogue on the draft study and the report’s failure to fully address the community impacts of truck routes and truck traffic.

Office of Freight Mobility and comprehensive freight mobility planning
Environmental Defense commends NYC DOT for suggesting the creation of an Office of Freight Mobility to deal with issues related to goods movement, including truck routing, in the future. While the Truck Route Management and Community Impacts Reduction Draft Study analyzes existing truck routes and explores options for improving their efficiency, NYC DOT must examine more than the routes along which goods travel. A comprehensive freight mobility strategy is already needed and will become increasingly important as traffic and related congestion on New York’s roadways increase dramatically in the coming years. NYC DOT, through an Office of Freight Mobility, must extend its examination of goods movement to include the entire freight network, rather than just truck routing. To this end, NYC DOT should ensure that the Office of Freight Mobility employs at least one individual specializing in intermodal goods movement.

The Office of Freight Mobility should, among other things, set performance targets for goods movement in New York City. These performance targets should seek, among other things, to reduce congestion on City streets and truck routes during peak periods as well as to increase the volume of goods moved by modes of transport other than trucks. Targets should be set in a public and open analytic process that considers public health and safety, the environment, transportation finances, city and state agencies, community equity and fairness, and economic health. Establishing targets would establish a framework from within which the City and NYC DOT could approach the growing problem of excessive truck traffic in New York City.

After performance targets have been established, NYC DOT, through an Office of Freight Mobility, should study different means and incentives to keep trucks off New York City’s roads and out of New York City’s neighborhoods, particularly during peak periods of congestion. History has shown that building more highway lanes and adding more roads can actually lead to more car and truck trips, more vehicle miles traveled, and more congestion. Paradoxically, more asphalt can result in less free space on our roads. Thus, incentives for using truck alternatives are essential to the success of any goods movement management program in New York City.

Numerous incentives should be explored including congestion pricing, which has enormous potential to reduce goods movement-related traffic or shift it to less congested periods during the day. Charging drivers a fee for using congested roads will encourage shippers to use rail and marine vessels. It will make users of the region’s roadways pay for their maintenance, ease the congestion already afflicting them, and slow the rate at which new vehicles exhaust the roadway capacity. Time-of-day tolls also will shift some traffic, including truck movement, to off-peak hours, reducing congestion even further. The Port Authority has already instituted a form of congestion pricing on their facilities, resulting in a seven percent decrease in morning peak period traffic. In London, congestion pricing reduced congestion by nearly 30%. Congestion pricing is just one of many possible incentives for truck traffic reduction, and New York must thoroughly examine the numerous available options in a manner that allows for public participation.

There has been only limited opportunity for public dialogue on the draft study
Environmental Defense sincerely appreciates the opportunity for public comment on the Truck Route Management and Community Impact Reduction Study. Generally, NYC DOT and the consulting team have done an excellent job with regards to public outreach, and they made numerous efforts to solicit community participation earlier in the study process. Certainly, the draft study reflects this. Our concern is that the public has not yet had the opportunity to review the detailed analysis of how NYC DOT has used earlier public comments in the development of specific recommendations.

While the preliminary recommendations for the study have been available since February 2006, the justifications for those recommendations, found in the full draft report, have only very recently been made publicly accessible. Environmental Defense and other stakeholders have had less than one week to review the full, 1,000+ page draft study prior to this public meeting. This is an inadequate period for review of the full draft study, and has limited the community’s opportunity for meaningful participation in tonight’s meeting. The importance of public comments cannot be underestimated, and Environmental Defense commends NYC DOT for recognizing the inadequacy of this short period for comments in allowing the public until August 2006 to submit written comments.

However, allowing stakeholders to comment in a public forum, in the presence of other affected parties, is essential to promoting community dialogue, learning, and consensus building regarding how New York’s truck routes ought to be managed. NYCDOT must remedy this situation. At a minimum, the agency ought to schedule another round of public meetings after the close of the written comment period. Additionally, NYC DOT should make submitted written comments publicly available on the NYC DOT website.

The study of community impacts from truck route management is inadequate
The study’s goals and objectives include reduction of traffic congestion, improving the qualify of life for residents and workers in New York City, establishing recommendations to mitigate the negative impacts of truck traffic and improve the overall operation of the truck route network (DES, page 2). While NYC DOT and the consulting team have done a good job of examining the existing and future transportation networks to determine where congestion will occur, the extent to which the recommendations in the draft study will reduce congestion, if at all, is unclear and not directly addressed in the report. Additionally, the examination of the community impacts created by this congestion is underwhelming.

It is clear from NYC DOT’s truck-related accident analysis that NYC DOT is concerned with the impact of truck traffic on public health. Why then has NYC DOT failed to consider the effects of truck-related air pollution on public health? New York City’s air quality is among the worst in the nation. Presently, all five New York boroughs fail to meet basic public health standards for ozone and fine particulate matter; both are a product of emissions from diesel vehicles, such as the large trucks currently clogging New York roadways. In New York City, diesel exhaust emissions are the hazardous air pollution with the highest contribution (more than 85%) to air cancer risk. Diesel engines emit nearly 40 toxic substances, smog-forming oxides of nitrogen, and fine particulate matter that can penetrate deep into the lungs and enter the blood stream. Particulate matter exposure is associated with heart attacks, reduced lung function, bronchitis, and asthma attacks. New York City residents suffer from alarmingly high asthma rates - one out of every eight adults (700,000 New Yorkers) has been diagnosed with asthma at some point in their lives. In 2000, children living in the City’s five boroughs were almost twice as likely to be hospitalized because of asthma attacks as the average U.S. child. Asthma was the leading cause of hospitalization in New York’s children, 300,000 of whom have been diagnosed with this disease. In the coming decades, the crisis of congestion in New York City will continue to exacerbate public health problems such as the extraordinarily high prevalence of asthma among New Yorkers, particularly New York children.

Many community members raised these and similar issues early in the public participation process. Of 196 study survey respondents in Manhattan, 97%, or 190, think truck traffic contributes to air pollution (Public Involvement Program, page 17). The draft executive summary repeatedly mentions the importance of these issues to the public. For example:
--“Many of the comments received from the public during the first two rounds of public meetings were related to the following issues… environmental hazards of pollution… health issues in the community related to truck traffic…” (DES, page 10)
--“the issue of trucks is very often a quality of life concern for residents, with many comments addressing off-route trucks, air quality hazards, and noise.” (DES, page 11)

Unfortunately, the study does not contain analysis or recommendations regarding the impact of truck traffic and truck routing on public health and air quality.

This is particularly concerning given increasing evidence that living near high-traffic areas could add to exposed individuals’ risk of adverse health effects. Increased health risks include heart disease, lung disease, respiratory ailments, and cancer. A study of Erie County, New York found that children younger than 14 living in neighborhoods with heavy truck traffic within 200 meters of their homes had increased risks of asthma hospitalization. In one study, children who lived within 250 feet of major roads had a 50 percent higher risk of having had asthma symptoms in the past year than children living further from major roads. These risks cannot be ignored by the agency responsible for managing New York City’s truck traffic and routing.

In order to meet the goals and objectives NYC DOT promulgated for its Truck Route Management and Community Impact Reductions Survey, the agency should:
• Document emissions from truck traffic on NYC DOT truck routes;
• Provide information regarding sensitive populations near all truck routes;
• Identify the health impacts of truck emissions on sensitive populations;
• Identify methods of reducing truck emissions and related adverse health effects near areas with sensitive populations.

Furthermore, NYC DOT should include information on idling regulations in its public education program. Both New York State and New York City have anti-idling regulations. In New York City, idling is limited to less than 3 minutes with limited exemptions. Although NYC DOT extensively covered many truck-related regulations in its Technical Memorandum 1: Traffic Policies and Regulations, and mentions idling as a community concern in the draft study (DES, page 11) it omits idling regulations from this discussion. The City currently accepts engine idling complaints through its 311 hotline. This information should be included as an element of the public education program, especially given NYC DOT's apparent reliance on self-enforcement within the truck route program. Additionally, the New York Police Department is authorized to write tickets for violations of both City and State anti-idling regulations. NYC DOT should include anti-idling education in its Truck Route enforcement education program for police officers.

Thank you for the opportunity to share our thoughts and opinions on the draft Truck Route Management and Community Impact Reduction Study with NYC DOT and interested members of the public. If you have any questions or comments, please do not hesitate to contact me.

Stephanie J. Tatham, Program Associate
LIVING CITIES, Environmental Defense
E-mail: statham@environmentaldefense.org
Phone: 212.616.1233 * Fax: 212.533.6748
257 Park Avenue S. * New York, NY 10010

References:
Environmental Defense, Air in Your City. Retrieved on 8/22/05 at: www.environmentaldefense.org/cleanairforlife.cfm?subnav=aiyc_50cities.
Available at: www.scorecard.org
NY State Department of Health and Mental Hygiene, “Asthma Facts.” Second Edition, May 2003. Page 7. Online resource, available at: http://www.nyc.gov/html/doh/downloads/pdf/asthma/facts.pdf Last accessed 05/16/06.
Ibid.
Ibid.
Studies related to health risks in close proximity to major roads or near heavy truck traffic:
--Pearson et al. (2000). “Distance-weighted traffic density in proximity to a home is a risk factor for leukemia and other childhood cancers.” Journal of Air and Waste Management Association 50:175-180.
-- Hoek, Brunekreef, Goldbohn, Fischer, van den Brandt. (2002). “Association between mortality and indicators of traffic-related air pollution in the Netherlands: a cohort study.” Lancet, 360 (9341): 1203-9.
--Knox and Gilman (1997). “Hazard proximities of childhood cancers in Great Britain from 1953-1980.” Journal of Epidemiology and Community Health. 51: 151-159.
--Speizer, F. E. and B. G. Ferris, Jr. (1973). “Exposure to automobile exhaust. I. Prevalence of respiratory symptoms and disease.” Archives of Environmental Health. 26(6): 313-8.
--van Vliet, P., M. Knape, et al. (1997). “Motor vehicle exhaust and chronic respiratory symptoms in children living near freeways.” Environmental Research. 74(2): 122-32.
--Brunekreef B; Janssen NA; de Hartog J; Harssema H; Knape M; van Vliet P. (1997). “Air pollution from truck traffic and lung function in children living near motor-ways.” Epidemiology. 8(3):298-303.
--Duhme, H., S. K. Iiland, et al. (1996). “The association between self-reported symptoms of asthma and allergic rhinitis and self-reported traffic density on street of residence in adolescents.” Epidemiology 7(6): 578-82.
--Edwards, J., S. Walters, et al. (1994). “Hospital admissions for asthma in preschool children: relationship to major roads in Birmingham, United Kingdom.” Archives of Environmental Health. 49(4): 223-7.
--Jermann E, Hajimiragha H, Brockhaus A, Freier I, EIrs U, Roscovanu A: “Exposure of children to benzene and other motor vehicle emissions.” Zentralblatt fur Hygiene und UmIltmedizin 189:50-61, 1989.
--W.J. Gauderman, E. Avol, F. Lurmann, N. Kuenzli, F. Gilliland, J. Peters and R. McConnell, “Childhood Asthma and Exposure to Traffic and Nitrogen Dioxide,” Epidemiology. Vol. 16, No. 6, November 2005.
Lin, Munsie, Hwang, Fitzgerald, and Cayo. (2002). “Childhood Asthma Hospitalization and Residential Exposure to State Route Traffic.” Environmental Research, Section A, Vol. 88, pp. 73-81.
Rob McConnell, Kiros Berhane, Ling Yao, Michael Jerrett, Fred Lurmann, Frank Gilliland, Nino Kunzli, Jim Gauderman, Ed Avol, Duncan Thomas and John Peters, "Traffic, Susceptibility and Childhood Asthma," Environmental Health Perspectives, Volume 114, Number 5, May 2006.

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