The following are in addition to the concerns we expressed in previous testimony
Though the criteria the State Department of Transportation (SDoT) and the DEIS have articulated for evaluating different options for the 9A corridor are reasonable, the SDoT's interpretation of them is heavily biased towards increasing automobile capacity and auto travel. This bias has produced a DEIS that is flawed by its failure to seriously consider options that do not increase automobile capacity, like light rail, or additional money for existing public transit.
The chief DEIS assumption responsible for producing a narrow range of automobile centered options is that increased capacity is good. Assuming that more capacity is a benefit eliminates consideration of numerous other options intended to get people out of their cars and onto mass transit. The increased capacity assumption is based on the dubious theory that traffic on nearby avenues will be drawn onto 9A, thus reducing avenue traffic, and creating no real increase in automobile trips. Given the ever-increasing number of Manhattan to Manhattan auto trips, and their huge number which is about 400,000 a day, the theory that more capacity on 9A won't accomodate or even induce more car and truck trips is wrong.
The options considered in the 9A DEIS are sharply at odds with the goals articulated by both the New York Metropolitan Transportation Council (NYMTC) in its Long Range Plan and the Federal Clean Air Act, to reduce vehicle miles traveled, and to reduce the incentive for single occupancy vehicle travel. Adding capacity to an area already afflicted by severe ozone pollution is a mistake and probably illegal.
On page 2-6 of the DEIS the "first goal" of the 9A project is described as "providing effective safe transportation service." Yet the DEIS only includes comparisons of various reconfigurations of route 9A's roadway. It does not compare other options for the 9A corridor, such as constructing something like the $50 million dollar Transportation Systems Management option or the No-Build option and using the hundreds of millions saved to add light rail to the corridor, or to provide mass transit improvements.
Indeed, the DEIS doubly fails because it devotes an enormous amount of analysis to options like the Task Force, Modified Task Force, and Enhanced Modified Task Force, that were long ago discarded by 9A project managers, elected officials, and important others, as being too expensive and politically unpalatable. Public meetings and discussion over the last year have focused solely on the $370 million dollar Enhanced Basic Reconstruction, which the 9A project managers have been strongly supporting, and the No-Build option.
The purpose of a DEIS is to
provide policy makers and the public with information and analysis that will
help them choose between alternatives.
The DEIS fails to provide a review of any but an extremely narrow band of options. Indeed, the 9A DEIS is more a tool for the 9A project managers to use to support the Enhanced Basic Reconstruction than to inform the public about the available options.
Unfortunately, the DEIS fails to examine a full range of transportation choices. One such choice is light rail which is summarily dismissed on page 2-3 of the DEIS. The brief discussion of light rail fails to note that a light rail option has become more viable because of the imminent creation of an independently financed 42 light rail.
The essence of our concern is that, if the SDoT gets its way and the Enhanced Basic Reconstruction Plan is chosen, $370 million will be spent adding more traffic to Manhattan. Instead, why not spend $ 50 million on rebuilding 9A as outlined in the No-Build or TSM option, and $320 million building a light rail line, or adding to express bus service from New Jersey, Staten Island, and Brooklyn.
New Yorkers deserve no less then a thorough examination of a full-range of transportation choices. This DEIS does not provide such a range. As a result the ability of citizens and policy makers to make an informed and intelligent decision is reduced. We need an EIS that considers a wider range of options.