Hon. Iris Weinshall
City of New York
40 Worth Street, 10th floor
New York, NY 10013
Dear Commissioner Weinshall:
We write to offer our thoughts
and recommendations on NYC DOT’s truck route management study. We believe this
work holds potential to begin the development of strong controls on truck
movements within the city, and to prepare city agencies and communities for the
higher truck volumes that every available projection reports for the future.
We strongly urge you to ensure
that this study does not recommend half-measures or stop short of developing an
extensive tool-box to help city government and neighborhood leaders cope with
the worsening onslaught of truck-related impacts, including noise and traffic
congestion, safety hazards, damage to buildings and infrastructure, and
disruption of quality of life. If the scale and scope of the present study
contract is insufficient to accomplish this, then the present study should
recommend further analyses and policy steps for DOT and other agencies to take.
The issues related to truck operation in the city are unlikely to diminish, and
are very likely to become more acute over time. Addressing them is going to have
to become a regular part of your Department’s work.
Ensure the study includes key
stakeholder groups and is publicly accessible
1. For the truck study to work,
truckers and truck-dependent businesses must be involved, and there must be a
dialogue between them and concerned citizens. The Port Authority, for instance,
has been able to engage trucking interests over E-ZPass and toll rate issues
during the past five years. Study recommendations will be easier to implement if
they are endorsed by both truckers and the concerned public.
2. The study provides an ideal
opportunity to fully exploit the World Wide Web. Study findings, data,
presentations, public handouts, press releases, time line, work plan and meeting
information should be posted on the NYC DOT web site Truck Study page. It is
inexpensive and will show the public DOT is serious about making this a
collaborative problem solving effort.
3. The Department should
thoroughly assess environmental justice implications of recommendations that
emerge from this study. The study’s recommendations should not remove the burden
of trucks from some communities at the expense of other communities. Information
to be taken into account should include race, ethnicity, economic status and
existing environmental burdens. The most recent information should be used in
this assessment as many neighborhoods have changed markedly in demographic
composition in recent years. Many communities principally populated by people of
color or lower income citizens lay between manufacturing zones -- DOT should aim
to direct truck traffic around and not through these areas.
As the Department stated in its kick-off meeting for the study, local residents
have extensive knowledge of the problems originating from trucks in their
neighborhoods. Some have even conducted studies or surveys on truck traffic
problems and have developed recommendations for remedies. The Department should
review this information and integrate it into its investigation and policy
deliberations. In addition, the Department should reply in writing to
communities’ concerns and recommendations.
Fully Consider a Range of
Policy Options to Reduce Truck Impacts
1. The Dept. has some
experience with traffic calming installations to discourage truckers from
turning onto residential streets in Hunts Point, The Bronx, and other city
locations. We urge the Department to use the truck route study to refine traffic
calming approaches to keeping trucks on legal and appropriate routes, and to add
traffic calming to the regular toolbox the Department should develop to respond
to community complaints about illegal truck routing. The product here should be
a short manual for community boards and other interested parties that depicts
how sidewalk extensions at corners, mid-block speed humps and other traffic
calming devices may deter inappropriate truck routing.
2. DOT should develop uniform
criteria for using “No Truck” signage based on the volume of illegal truck use,
proximity to designated truck routes and other objective measures. DOT has made
the point that the signs do not seem effective in discouraging illegal truck
traffic. But NYPD officials have told us that the signs encourage police
enforcement and make summonses easier to uphold in court.
3. The lack of effective police
enforcement of existing truck routes and regulations is a huge problem. Clearly,
the police department needs to be invested in the Truck Route Management Study
if enforcement is to improve. The police need to consider themselves project
partners instead of observers andamong other things that means they should be
encouraged to sit alongside DOT officials at public meetings instead of in the
back of the room. The goal of the study should be to understand how police
enforcement currently works and doesn’t work, and determine what best practices
should be replicated and how truck enforcement can be institutionalized. This
may warrant hiring a separate consultant with expertise in assessing police
Enforcement-related issues the study should examine include an analysis of data
showing where and what kind of truck summonses are given and how they are
adjudicated. This examination should include a listing and maps that show the
last three years of truck summonses by type, location and police command.
It should also assess how to use TrafficStat to improve truck enforcement,
including what the best measures may be for assessing truck enforcement efforts,
number and type of summonses, public complaints, DOT vehicle counts, etc.
The city has had great success with red light cameras. It should be a relatively
easy matter technically to modify a camera to be triggered by the weight of a
truck. Truck enforcement cameras mounted in vans could be temporarily stationed
at trouble spots. The MTA has completed testing bus-mounted enforcement cameras
as a prelude to seeking legislation enabling their use. DOT should do the same
with truck cameras.
Within its look at enforcement, the study should also consider the implications
of the new state statute imposing higher fines and the assignment of license
points for driving off of designated routes.
4. Double parking and other
congestion problems along truck routes encourages diversion to illegal routes.
The Truck Route Study should examine the extension of parking policies to create
adequate turn-over of on-street parking supply spaces to ensure truck access to
the curb along legal truck routes. Truckers stand to gain immensely from this.
Elements to be examined should include expansion of the commercial vehicle
congestion pricing program beyond Midtown, increasing on-street parking fees in
high volume areas like Midtown Manhattan and downtown Brooklyn and
identification of areas where city-issued parking permits cause parking scarcity
and promote double parking.
5. Current city rules bar
trucks over 33 feet in length (unless given a special permit by the Dept.) at
various times of day from three congested areas in Manhattan. In Midtown between
34th and 42nd Streets, larger trucks are prohibited from 8-10 a.m. and for the
entire afternoon. In upper Midtown (42nd to 59th) the afternoon ban is also in
effect. In the Financial District, larger trucks are not permitted from 11 a.m.
to 2 p.m.
We would like the study to examine the efficacy of these rules in reducing
infrastructure damage, traffic congestion and other impacts, consider whether
the time frames and the truck size threshold for the restrictions continue to be
appropriate, and consider whether there are other heavily impacted areas like
downtown Brooklyn that similar rules should be extended to. Additionally, we
urge that the study examine the issuance of special permits to exempt big trucks
from these rules. Are permits issued so routinely that the rules are irrelevant?
Are permits denied for any reason? Have the rules led shippers to use smaller
6. A major focus of the study
should be an investigation of options for re-routing as much truck traffic as
possible from city avenues and streets to the limited-access highway network.
The mid-20th Century notion of “parkways” as idyllic greenways for motorists has
long been rendered obsolete by the sheer volume of New York City traffic, and by
changes to those roads over time that have made them little different than the
city’s “expressways.” The Department’s decision last winter to allow some trucks
on part of the Grand Central Parkway adjoining the Triborough Bridge is a
positive example in this regard. It should be followed with more ambitious steps
to re-route trucks from streets to highways. Of course, allowing trucks on
highways from which they are now prohibited should be done along with imposition
of greater truck restrictions on parallel avenues and streets. The study should
identify more cases where trucks should be allowed on currently restricted
highways, and the “tradeoffs” of tighter truck access rules to nearby local
streets such highway access could facilitate.
7. Discussions about truck
impacts in lower Manhattan invariably direct a good deal of attention to the
impact of Verrazano Narrows Bridge one-way tolls on truck traffic patterns.
One-way tolls were initially implemented to mitigate backups at the bridge that
spilled back along the Staten Island Expressway. Critics say the arrangement
causes extra truck traffic to cross Manhattan because they favor free west-bound
Port Authority crossings over the double west-bound Verrazano toll. Today, the
metropolitan region has the technology to make the one-way vs. two-way toll
debate obsolete. The Port Authority and other toll agencies in the region are
developing “open-road tolling” facilities that will dramatically increase
vehicle throughput at toll plazas. The MTA could do this at the Verrazano and
end the one-way vs. two-way argument. After examining the issue in the study, we
hope the city would recommend that the MTA begin work on a Verrazano two-way
toll “open road tolling” program.
Thank you for your attention.
We look forward to working with the Department on these important issues.
New York City Environmental Justice Alliance