"If you were to design the ultimate system, you would have mass transit be free and charge an enormous amount for cars."

So said Mayor Michael Bloomberg last April, right about the time he unveiled his plan to charge motorists a fee to drive into Manhattan's central business district. Eight months later, as the mayor's original proposal mutates for better or worse, the MTA is hours away from raising transit fares. Neither idea has exactly caught fire with the public, and the fare hikes could actually end up a foil for congestion pricing -- a plan originally intended as a sustained financial boost for the transit system.

And then there's Theodore "Ted" Kheel. The environmentalist, philanthropist, and renowned labor attorney has lobbied for free transit in New York for over 40 years. Last February he commissioned a $100,000 study that, as it turns out, could put the city's money where the mayor's mouth is. A summary of findings released late last week shows that if the city were to impose a $16 congestion fee ($32 for trucks) below 60th Street in Manhattan, 24 hours a day, seven days a week, along with higher curbside parking fees and a taxi surcharge, the MTA could remove its turnstiles and fareboxes forever.

Relying on exhaustive analyses of dozens of factors ranging from vehicle miles traveled (VMT) and transit capacities to emissions and employment data, assembled in an interactive spreadsheet created by Charles Komanoff, the study, managed by the Institute for Rational Urban Mobility (IRUM) and researched by Joseph Clift, George Haikalis, Brian Ketcham and Carolyn Konheim, found that the Kheel Plan would:

• Reduce traffic within the Central Business District by 25% and within the entire city by nearly 10%. Auto trips into the CBD would drop by one-third.
• Save the public a staggering $4 billion a year in recovered productivity, or more than 100 million "vehicle hours" that would otherwise be spent in traffic. (Some 20% of this value would be realized by bus riders, 32% by truck, taxi and auto users within the CBD, and 48% by vehicle users in the rest of the city.)
• More than recoup revenues now generated by fares. The one-two punch of the $16 automobile toll ($3 billion annually), taxi fare surcharge ($340 million annually) and higher curbside parking fees ($500 million annually) would generate nearly $4 billion annually - enough to replace the $3.5 billion in current tolls and subway and bus farebox revenues and still leave an annual revenue stream of $500 million for improving and expanding transit.
• Provide universal no-fare transit with less crowding than today's service. Making transit free will be an enormous boon for all New Yorkers, particularly low-income residents, and lift, once and for all, the specter of fare hikes. The Kheel Plan also includes a strategy for handling the anticipated increase in ridership that will result in less, not more crowded trains and buses.
• Shorten travel time: Enable a one-third (34%) increase in vehicle speeds within the CBD and an average one-tenth (10%) increase in the rest of the city. A typical 12-minute taxi trip in the heart of midtown Manhattan would be trimmed to nine minutes, while five minutes would be shaved from the typical 55-minute ride for a non-CBD trip, say from Bayside to Bensonhurst. Bus travelers would also save time: a fare-free system would eliminate the tedious swiping of MetroCards that leads to frustrating boarding delays, thereby shortening a typical 20-minute bus ride to 15-16 minutes.
• Produce additional, significant benefits: The plan would generate an additional $2 billion in health cost savings and other benefits from reduced pollution, fewer traffic crashes, lower insurance costs, and increased tendencies to walk and bike - all due to diminished traffic levels.

"The PlaNYC proposal, while commendable and courageous, offers little if any relief to endlessly spiraling subway and bus fares," researchers conclude, while "the Kheel Plan banishes fare escalation from the civic horizon by abolishing the fare itself."

While it was developed independent of the Congestion Mitigation Commission process currently underway, its authors say the Kheel Plan "takes Mayor Bloomberg's visionary congestion pricing proposal to its logical conclusion." As Commission chairman Marc Shaw noted at yesterday's meeting, however, that logical conclusion is going to have to be something that "works in the real world" -- a world filled with term-limited City Council members, parking garage industry-funded lobbyists, a debt-laden MTA and various other challenges. Logical or not, one thing is for certain: With the Commission's aggressive timeline set to deliver an Implementation Plan to City Council by January 31 and Council scheduled to vote by March 28, a conclusion will be reached shortly.

Congestion pricing advocate Carolyn Konheim and consulting partner Brian Ketcham are advising the Bloomberg administration to drop its resistance to a congestion pricing Environmental Impact Study.

The two say a study is needed to head off "likely 11th hour litigation" aimed at stopping the three-year pilot program from taking effect, a possibility Streetsblog alluded to following the first meeting of the Traffic Congestion Mitigation Commission late last month.

"[D]ecision-makers need to know that the selection of the system to be tested has considered all reasonable alternatives to achieve the Mayor's admirable goals," reads a press release announcing Konheim and Ketcham's open letter to Mayor Bloomberg.

The most promising alternative to be examined in an environmental assessment is "charging at the real chokepoints in roadway capacity -- our river crossings and highways," according to Ketcham, a traffic engineer who has regarded bridge tolls as the premier congestion pricing strategy since he introduced them in his landmark Clean Air plan for New York City in 1973. Tolling the four free East River bridges equal to all MTA crossings and across 60th Street, river to river, he calculates "would be at least as effective as PlaNYC in reducing congestion and would generate far more funding for transit."

The independent Brooklyn-based planners estimate that a pricing cordon that crosses bridge and tunnel spans and 60th Street would require E-ZPass monitors on about 50 inbound lanes, whereas the charging network necessitated by PlaNYC's complex avoidance of tolls could require detectors and cameras on1,000 to 2,000 lanes. Based on London's operating costs for a simpler single cordon, they foresee that the charging grid in PlaNYC would consume most of the congestion pricing revenue, leaving little funding for transit -- a major goal of the mayor's plan and the long-term aim of transit advocates.

Mr. Ketcham and Ms. Konheim suggest numerous strategies as alternatives to or companions of congestion pricing, particularly, the kind of comprehensive parking control and parking pricing program instituted in London before road pricing, and measures to reduce taxi cruising, a "major source of New York's congestion."

The full text of the letter appears after the jump.

Hon. Michael Bloomberg

Mayor

City Hall

New York, NY 10007

Re: Congestion Pricing Pilot Test Must Undergo Environmental Review

As long time advocates of congestion pricing in New York City, we fear that your entire plan could be in self-imposed jeopardy. Some of your PlaNYC team wrongly assert that compliance with the State Environmental Quality Review Act need not occur until after the three-year pilot test. It is a mistake to dismiss this clear legal mandate as a delaying tactic of opponents of congestion pricing. Their call for an EIS now is a sure signal that they will see you in court if you have not taken some defensible action to comply with SEQRA, described further in the enclosure. The SEQR process may be inconvenient and is certainly imperfect, but it is mandatory in New York State for all discretionary actions of government that have the potential for causing a significant impact -- as, indeed, is your intent. The virtue of your program's goals does not exempt compliance with the SEQR process. Nor does virtue protect your proposal from 11th hour litigation that could de-rail implementation on the grounds of failing to identify unintended consequences or not adequately evaluating alternatives that further PlaNYC goals.

Your team cannot argue both ways. On one hand, they are saying that the data already collected are adequate to meet the purpose of SEQRA, which is to enable government agencies to make informed decisions. At the same time, they are saying that any SEQR review requires collecting data during the 3-year pilot because the regional model is an imperfect tool for predicting local impacts. If so, they cannot then cite the model to assure communities outside the pricing zone that they would not be adversely affected by commuter parking or over-crowded trains.

Most of all, decision makers need to know that the selection of the system to be tested has considered all reasonable alternatives to achieve your admirable goals: reducing congestion and global warming emissions; generating funds to improve transit; maintaining the city's global economic leadership; and promoting community quality of life and air quality. Thus, the most promising cost-effective alternative must, by definition, be identified in advance of the pilot test.

It is also specious for your team to claim SEQR exemption on the grounds that the Action is reversible and is "not like having to tear down a building." Overhead gantries at hundreds of charging locations would, in fact, be major construction. Last week, the MTA reported that the half-billion dollar cost of transit services to support the pilot period would cause a major reordering of its adopted capital program. The 3-year test will extract well over a billion dollars from the region's motorists. A 3 year change of travel patterns will have long-term effects -- for good or ill -- on the business climate, people's lifestyles and investments across the region. In no way can it be argued that a full scale 3-year "trial" qualifies for the SEQR exemption allowed for feasibility, engineering and planning studies and other purely paper exercises.

Your compelling case for road pricing finally permits rational assessment of closing New York's free bridge loophole, especially in combination with a single charging cordon across Manhattan. Charging at the chokepoints in roadway capacity -- our river crossings and highways -- could be at least as effective as PlaNYC in reducing congestion and would generate far more funding for transit, a major goal. Based on London's costs for operating a ring of street charging monitors, it is evident that administering the more complex charging network in PlaNYC of monitors on 1,000-2000 lanes would consume most of the revenue, leaving little for transit. When your advisors seized on London's street cordon charging system as a way for New York to avoid the historical political stigma of bridge tolls, we think they had no idea of the power of the campaign you would mobilize. Nor did they gauge the latent anti-traffic fervor across the city that now seeks the local traffic relief of bridge tolls, the premier "congestion pricing" strategy in NYC for three decades.

Most promising, but rarely discussed, is the reduction of congestion far beyond the pricing zone that will likely result from reducing trips to the city center and eliminating the distortions of travel due to toll differentials. Our modeling in 2003 shows that tolling the four free East River bridges at the same rate as the MTA crossings would cut more than 9% of the time citywide that motorists, truckers and bus riders now waste stuck in traffic. Most of the travel time savings would be in Brooklyn and Queens where drivers would no longer clog routes to the free bridges. The ripple effect of faster travel would benefit motorists not even using the bridges -- and communities everywhere. Not only would this exceed your goal of 7% less congestion delay in Manhattan, but it could be accomplished virtually overnight with about 25 overhead E-ZPass scanners on the four free East River bridges. Adding another 28 charging points across 60th Street, river to river, would capture the other half of the traffic that now escapes tolls and it would achieve the political equity missing in past tolling proposals. Instituting London-style annual fees for residential parking permits and strict limits for parking in the pricing zone could provide an equitable revenue trade off for eliminating fees for Intra-zonal trips and the costly collection grid.

Our 1995 Four World Cities Study, a milestone comparison of transport in the global financial capitals, revealed strong similarities between London and New York. But important differences must be accounted for in predicting the effects of congestion pricing. In New York, the tolls at most entrances will be deducted from the new charge, lowering its differential impact. Manhattan highways fall far short of London's ring road bypasses with their capacity improvements that smoothed the absorption of traffic diverted from the congestion zone. New York lacks London's comprehensive parking pricing program that prevents long term parking almost everywhere. New York has none of London's initiatives to curtail taxi cruising and erratic maneuvers which are a major cause of congestion. And New York has not created the pervasive pedestrian streetscape, which London First Deputy Mayor Nicky Gavron cites as the real objective of congestion pricing. When you are next in London, get the lowdown on reliance on high-tech charging systems from Deputy Mayor Gavron. Last May at NYU, she confided: If London had New York's bridges and tunnels, it would never have created a street cordon. Why would New York propose multiple cordons-London has enough trouble with one. You've got parking all wrong in New York. Parking pricing should come first or, at least, as a companion to road pricing

Your PlaNYC team cannot continue to validate their public assurances by referring to London without these caveats and without making the PlaNYC model completely transparent, reporting all its underlying data and assumptions. To maintain the momentum of your potential congestion breakthrough, the City should now be preparing at least an EAS to preempt 11th hour litigation. This necessitates gathering and openly analyzing the extensive baseline data, as preceded London's test program. A forthright SEQR/CEQR process will build confidence in the selected outcome by enabling public scrutiny of the analysis of alternatives and their consequences. A full accounting of the societal costs of vehicle travel would also show that the economic benefits of comprehensive congestion reduction are even greater than have been reported to you to date. With a vested interest in your success that goes back 30 years when we first introduced the pricing concept, we stand ready to help you and your team assess what works best for New York.

Sincerely yours,

Carolyn Konheim & Brian Ketcham, P.E.

cc: Traffic Congestion Mitigation Commission; other interested parties

Photo: fabrisalvetti/Flickr

The Observer reported on Wednesday that Walter McCaffrey's Committee to Keep New York City Congestion Tax Free recently solicited UCLA parking policy guru Donald Shoup to do a study of curbside parking policy in New York. Carolyn Konheim, a Brooklyn-based transportation consultant and decades-long congestion pricing advocate, thinks that sounds like a great idea.

As DOT Deputy Commissioner Bruce Schaller pointed out in his 2007 study, Free Parking, Congested Streets, "free or reimbursed parking is an inducement for the majority of motorists who choose to drive to the Manhattan Central Business District rather than use public transportation or other means of travel." Despite this fact, Mayor Bloomberg's PlaNYC 2030 has almost nothing to say on reforming parking policy. Konheim suggests that "we need to price both roads and parking." Perhaps this is something that congestion pricing advocates and opponents might actually be able to agree on.

Here is Konheim's commentary:

The Mayor should extend the offer to Shoup. The California- based consultant concluded years ago that pricing parking can be as effective as pricing roads. The high cost of Manhattan off-street parking proves the point. Bruce Schaller's finding that half the auto entries into the Manhattan Central Business District (CBD) park for free also proves the point.

London has demonstrated that we need to price both roads and parking. Seeing parking as the low hanging fruit, London started curbside pricing first. At an NYU forum on pricing this spring, London's First Deputy Mayor Nicky Gavron, congestion pricing ambassador extraordinaire, whispered away from the microphone: "I hate to be critical, but you've got parking all wrong -- you need to control it first. In London, you can't park for more than 20 minutes without a permit or you'll be clamped. If you can park, it costs 40 quid [~$80]."

Garage rates in central London run $65/day, $1,200 a month. London auto commuters have no local street parking option outside the central pricing zone because all 32 boroughs in the city limit non-resident curbside parking to two hours and deliveries and drop-offs to 20 minutes. In boroughs close to the center, a stay of two hours costs about $8. Spaces are designated in all boroughs for residents who pay a range of $180 to $250 a year for permits for one car and one visitor. Businesses can also get parking permits. Violators' tires are enthusiastically clamped by local wardens who collect fines of $300 or more for their boroughs, which use the revenues for improving roads and traffic calming. The borough of Westminster is developing an automated parking enforcement system. The borough in the center of London nets about $70 million a year in parking revenues.

New York is obviously way behind on parking management. In the core of Manhattan, there are ten times more off-street spaces than in London, and half the drivers into the CBD pay nothing for parking. Many New York neighborhoods are plagued with commuter parking, abuse of agency parking privileges and counterfeit parking permits. Meter feeding is the norm on New York retail streets, which in the boroughs typically adds up to a cost of $8 -- but is not regarded as prohibitive as the proposed $8 congestion fee.

Local civic leaders have expressed fears about the impacts on communities near subway stations that serve the pricing zone, which are not assuaged by Mayoral allusions to -- but no apparent action on -- residential parking permits. Any serious action on resident permits would reveal that they must be just one part of a comprehensive parking program that requires broad public appreciation that street space doesn't come free -- a heavy lift for champions of local parking "rights."

Mayor Bloomberg's bold pricing initiative creates an opportunity to start in Manhattan by properly pricing ALL parking within the pricing zone. The fee would deter free parkers (many on the City payroll). And parking permit fees equal to the $4/day that the Mayor proposes to charge residents for trips within the pricing zone could provide the equity he seeks by charging Manhattan drivers for intra-zone trips. Doing so would eliminate the need for the costly proposed charging network of thousands of charging stations.

As London Deputy Mayor Gavron asked: "Why would you want multiple cordons? We have enough trouble with one." A charging cordon across 60th Street and bridges and tunnels, even simpler than London's, would be far less costly and free up far more congestion revenues for better transit -- the real payoff for all New Yorkers.

Michael Horodniceanu is more progressive than generally appreciated.  He really knows city streets and how they could function better for everyone. His firm's Technical Memo #1 to NYCDOT on Downtown Brooklyn so honestly reported traffic and transit conditions (including the penalty of "free" bridges) that developers' EISs and compliant agencies have been covering up, that the rest of the high level study -- a Mayoral commitment -- has been buried for two years.

Mike was a pioneer traffic calmer. In 1986, as NYCDOT Deputy Commissioner, he offered $600,000 to carry out a community traffic calming plan that would have done 20 years ago what the City's costly sidewalk cosmetics still ignore -- protecting neighborhood streets from through traffic.  He was so far ahead of his time that he took brickbats in a personal appeal to a skeptical community board that now rues the day they voted it down. Today, he uses graphic traffic network models (tools NYCDOT has refused for Brooklyn) to show how innovative pedestrian measures can benefit everyone.  If chosen, he'll know where in the agency to find good people ready to do the right thing.