Comments of NYC Resident Parking Permits Now, Inc.

 

NYC Resident Parking Permits Now, Inc. is a nonprofit organization which advocates for a residential parking permit system similar to that found in virtually every other city in the developed world.

 

We support the proposed Central Business District Tolling Program (CBDTP) only if the proper advance preparations are carried out.

 

As it now stands, however, the proposed program shifts the traffic, parking, and environmental burdens from the lower half of Manhattan to many New York City neighborhoods and streets outside the CBDTP, where parking and driving are already a nightmare.

 

Without a residential parking program, the CBDPT is an irresponsible adventure in fundraising at the expense and on the backs of those who aren’t even using the CBD and are not venturing there by private vehicle.

 

Numerous voices have publicly charged that the proposed CBDTP is a “money grab”.  We believe that in the absence of appropriate preparation—including initiation of a resident parking permit program—the MTA is guilty as charged.

 

The Need for a Residential Parking Permit Program is Widely Acknowledged

 

The history of attempts to initiate a residential parking permit program now extends more than fifteen years. In 2008, when a CBDTP was first proposed by Mayor Michael Bloomberg, that earliest proposal included a residential parking permit program. (NY Times 3/13/2008). It was widely acknowledged that for any CBDTP to be successful, that a residential parking program was required and necessary.

 

The issue was raised again in the City Council in 2011 and again in 2018.  In 2018, then Manhattan Borough President (now Council Member) Gale Brewer commissioned a study of residential parking in four other cities to find out what could be done in New York.  The study basically concluded that while a good idea, such a plan would be difficult to administer. Nothing came of it.

 

As recently as 2022, the New York City Department of Transportation Commissioner Ydanis Rodriguez stated upon taking office in January that a residential parking program was something that would be of great benefit to New York City. Again, there has been no action and no benefit.

 

CBDTP is Not Viable Without a Residential Parking Program

 

Every other city with a CBDTP has a residential parking permit program.  London was the first city to implement restrictions on entering a central business district, but first London had in place a residential parking permit program. Every major city now has such a program, whether or not they have congestion controls in their central business districts.

 

In New York without such a program, drivers will be encouraged to enter the city and access public transport by parking in such areas as Washington Heights, Hamilton Heights, Flushing, Jamaica, and Brooklyn’s transit hubs, not to mention the upper East and West Sides of Manhattan.

 

That is the primary reason that numerous other NYC groups have called for a residential parking permit program, including WE ACT for Environmental Justice. WE ACT performed an in-depth study of the MTA’s CBDTP with particular emphasis on the effects on Northern Manhattan.  This study found extraordinary adverse impacts due to commuters who will park and ride public transit from Northern Manhattan.

 

On Page 16 of the WE ACT study, it cites with approval the London program for congestion pricing, stating:

 

The city used a range of tools to prevent or mitigate potential negative impacts outside the congestion zone. For example, a residential parking permit program discouraged unwanted commuter parking in areas adjacent to the zone.

 

London and Stockholm instituted many other measures designed to make their congestion pricing programs successful. Apart from residential parking programs, they instituted new bus routes and traffic calming measures. In addition, they studied and monitored traffic for years before implementing their programs.  MTA has done nothing of that sort.

 

In each city where congestion pricing has been successful, the monitoring of traffic in affected neighborhoods took place years before implementing the program.  Because MTA appears to be in a hurry for funds to start flowing into its draining coffers, it proposes to study and monitor the effects of its congestion pricing program after its implementation.

 

The MTA’s Own Environmental Assessment Acknowledges Severe Impacts on Parking in Neighborhoods

 

The assessments Executive Summary (ES-22) concedes that ”(a)ll tolling scenarios would result in …increased parking demand at subway and commuter rail stations and park-and-ride facilities outside the Manhattan CBD”

 

The report, which is rife with erroneous and unfounded conclusions, states unequivocally that the CBDTP is “…unlikely to have effect on parking immediately above 60th Street as parking is so hard already”(5B14).

 

We submit this is all the more reason to assure that there is a residential permit parking program in effect before implementing the CBDTP, rather than monitoring the situation to determine the level of chaos which will ensue upon its implementation. Instead, the MTA proposes timing a parking study 18 months after implementation.

 

Considering the many conclusions in the EA that parking will be an increased problem in so many areas already short of parking spaces, it is a callous disregard for residents of those areas to subject them to this chaos for such an extended period.

 

We will not cite the numerous points in the EA where the parking issue is highlighted but suffice to say that MTA has decided to neither address nor mitigate the anticipated issues prior to instituting the CBDTP. As a result, we submit that the charges of this plan being a mere “money grab” are fully confirmed.

The Environmental Assessment is Of Questionable Validity

 

The EA makes only passing reference to the effects the pandemic has wrought on midtown and downtown Manhattan.

 

As recently as August 16, 2022, Bloomberg News reported in “The Rise of the One-Day Workweek for Office Commuters” that, while the length of office visits has increased, the frequency has dropped. More than 50% of workers are in their offices once a week, and only 20% of workers can be found in their offices four or five days a week.  At the same time, 15% of all workers are completely remote.  The sole exceptions to these statistics are in retail, food service, hospitality, and manufacturing.

 

Moreover, The Washington Post stated that as of August 22, 2022, the office occupancy of New York’s business center was a mere 43.5 percent of pre-pandemic levels. (Washington Post, “Bosses want workers back by Labor Day.  They’re not going in without a fight.” August 31, 2022)

One of the important aspects of the depletion of office workers from NYC’s central business district is how it impacts the numbers of other workers employed to support those workers: the cleaners, tech support personnel, lunchtime restaurant workers, and suppliers to the restaurants that serve office workers. The office worker is only the tip of the spear of commerce in any central business district.

 

Traffic may have increased since the early days of the pandemic, but the patterns and nature of that traffic has likely changed dramatically. Moreover, the elasticity of the traffic and its ability to transfer to public transport may also be very different in this new era.

But the EA makes but passing reference to these cataclysmic changes, stating that traffic has almost returned to pre-pandemic levels.  We challenge that conclusion and would relish the opportunity to review the data upon which it is based.

 

Conclusion

The MTA’s proposed CBDTP only shifts the burden of traffic to other areas of New York City.  Most New Yorkers do not use their cars to drive to the southern part of Manhattan; most need those cars to drive to inaccessible places outside of New York City for employment, visiting relatives, and otherwise handle situations requiring such private transport.

 

The MTA fails to allow those New Yorkers the ability to manage the difficulties stemming from its congestion pricing plan—focusing mostly on the plan’s potential revenue. The lack of a residential parking permit program is a clear hole in MTA’s preparation for any congestion pricing program, among other deficiencies.  MTA has failed to research current conditions to ascertain the precise nature of the traffic in Manhattan or whether changes to public transit may be required.

True preparation for a congestion pricing program requires more than simply determining where cameras and sensing devices should be placed and putting up poles to bear them.  The MTA has barely gone beyond that in failing to consider the impact of congestion pricing on the rest of the city.

Respectfully submitted,

Renee Baruch

President, NYC Resident Parking Permits Now, Inc.

www.NYCresidentparking.org