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Transportation & Environment

Penn Station Expansion Alternatives Scope

At the regularly scheduled monthly Community Board Five meeting on Thursday, March 10, 2022, the following resolution passed with a vote of 37 in favor; 0 opposed; 1 abstaining; 1 present not entitled to vote:

WHEREAS, Empire State Development (ESD) has introduced a General Project Plan (GPP) which combines a land use action to upzone and redevelop the neighborhood around Penn Station along with a preferred alternative to expand Penn Station through a southern expansion, and Community Board Five officially opposed this GPP, construed with this preferred alternative as a foregone conclusion, in December 2021 after over a year of review and analysis; and

WHEREAS, The next likely step after the GPP is a required Federal National Environmental Policy Act (NEPA) review of the preferred expansion alternative and other alternatives to meet similar capacity expansion goals; and

WHEREAS, Community Board Five supports the goals of capacity expansion at Penn Station and increased density through upzoning around Penn Station, though the GPP’s specific land use action and preferred alternative did not satisfactorily and comprehensively evaluate alternative approaches; therefore, be it

RESOLVED, Community Board Five adopts and transmits to relevant agencies the position contained in the following letter, regarding the scope of the coming NEPA review and the criteria that should be considered in evaluating each alternative, including collective costs of upgrading the Northeast Corridor, transit benefits beyond the borders of New York City, construction timelines, and effects of regional rail cooperation on moving passengers throughout the region in each alternative; and be it further

RESOLVED, Community Board Five adopts and transmits the insistence contained in the following letter that specific alternatives be among those evaluated in the coming NEPA review’s scope, including 1) an alternative that adopts expanded through-running through Penn Station, both by using existing platforms with expanded regional coordination, as well as by widening platforms at Penn Station; 2) an alternative that evaluates maximum improvement of existing tracks and amenities within the current station footprint, alongside and in addition to any “no action” alternative; and 3) an alternative that evaluates a connecting tunnel between Penn Station and Grand Central Terminal.

March 10, 2022

Re: Expansion Alternatives Scope for Penn Station Expansion

Dear Governor Hochul, Chairman Lieber, etc.

In December 2021, Manhattan Community Board Five unanimously opposed the current General Project Plan for the Penn Station area, also known as the Empire Station Complex. Manhattan Community Board Five urges you to take the opportunity of the coming federal NEPA review of Penn Station capacity expansion  - as well as the NEPA review of Penn Station reconstruction, also known as the Penn Station master Plan - to rigorously and comprehensively explore alternatives that have not yet seen a full, federal engineering assessment. The following recommendations were adopted unanimously [pending adoption] by Community Board Five on March 10, 2022.

The current GPP proposed by the State combines a land use action with a specific preferred expansion alternative for Penn Station: a southern expansion with new tracks and platforms. Community Board Five rejected this GPP as essentially structured backwards: proposing a funding structure for a specific alternative, before even formally assessing all alternatives and determining the best functional future for Penn Station.

Community Board Five embraces both the goals of expanding Penn Station’s capacity, which will be direly needed over the coming decades, as well as the goal of increased density around transit hubs, an approach known as transit-oriented development. Indeed, the pending construction of the critical Gateway Program and its new trans-Hudson tunnels will add redundancy and ultimately doubled capacity for trains-per-hour crossing the Hudson River, and this new capacity demands a commensurate capacity expansion at Penn Station to take advantage and set the region up for expansion. But we insist that planning for this development must follow from a rigorous evaluation of the right expansion mechanism for the station.

Penn Station capacity expansion and Penn Station reconstruction will require a federal NEPA review, including a formal assessment of alternatives. As with all federal reviews, the process will start with a draft scoping document, which has not yet been produced; we strongly insist that the scope of this review be drafted from the beginning to include both broad evaluation criteria for each alternative assessed that we lay out below, and the inclusion of certain specific alternatives that we detail.


A train station is fundamentally about moving people. The goal of Penn Station expansion, on which we believe all involved parties inherently agree, is to increase the daily capacity both of Penn Station as a rail hub and to meet the growing transit needs of the entire Tri-State Region for the coming century. Community Board Five truly believes this is a service worthy of providing to the entire region, and so our goals are not just limited to the effects on our own neighborhood, or narrow measures like Penn Station’s daily ridership. Our goal, and the stated goal of all associated agencies and rail networks, is the modern, efficient, growing transportation of people through the entire region.

For this reason, the evaluative scope of each expansion alternative assessed in the federal review must not be limited to the narrow “development borders” within the neighborhood of Midtown Manhattan, nor just the transit impacts on riders, pedestrians, daily trips, or per-hour train measurements through the station; the scope of evaluating each alternative and weighing the benefits of each alternative against the others must be broadly-defined, to include network effects of each alternative on the whole region. The criteria for evaluating each alternative must be broadly-drawn—literally, in terms of geographic borders—and also broadly-drawn quantitatively in terms of the metrics, costs, and benefits measured.

Various alternatives are designed, with deceptively cost-effective improvements, to enable wide-ranging logistical and service improvements in other parts of the system, with commensurate logistical coordination between rail systems and infrastructure upgrades in other parts of the region. The costs of these other improvements should be factored in, to be sure, but assessment of the specific improvement at Penn Station must similarly measure the capacity and passenger benefit across the whole region, if it has enabled such improvements.

Time-to-build and construction timelines, including the phased effects of each alternative as components are brought online and the effects on transportation access to various regions in intervening years, must also be a factor of evaluation. An alternative that enables characteristics like “through-running” but delays its availability or construction for decades longer than other alternatives must be evaluated in that context, and the costs/lost benefits that are “left on the table” must likewise be compared to the timely benefits of other alternatives. Alternatives must be able to be compared in terms of utility to the "travelability” of entire region.


Using the above broad criteria to evaluate alternatives, we also believe that certain alternatives must be included in the scope of the review to fully evaluate certain proposals that are credibly raised as viable alternatives to the GPP, so that they can be rigorously discounted once and for all, or otherwise considered as real and viable alternatives. The federal environmental review must evaluate multiple alternatives, but at times the process has been criticized for pro-forma evaluations while only promoting and considering the preferred alternative. Some alternatives have never received a formal federal engineering review, and they must receive a genuine, honest, independent review before the community can ever accept a development plan for a single alternative.

We know that certain existing and prior proposals are very likely to already be analyzed in any NEPA review as alternatives, including: the southern expansion preferred by the GPP; a northern station adjacent to Penn Station as proposed in the Access to the Region’s Core (ARC) project in 2003; and a new station built below the current one by excavating deep into Manhattan’s bedrock, modeled on the East Side Access project under Grand Central Terminal. As with all NEPA reviews, we anticipate a “no action” alternative will evaluate doing nothing, as well.

In addition to the obvious alternatives above, we urge the following proposals to be included in the scope of the review and evaluated in their own rights, so that the full cost, benefit, regional effect, and necessary alteration to Penn Station of each can be weighed in a comprehensive comparison. The following three alternatives are not reflected in any of the likely alternatives just mentioned, but are viable options that are yet to receive comprehensive assessment in the context of expanding Penn Station’s capacity in conjunction with the Gateway Program. Any course of action for Penn Station would be incomplete and deficient without analysis that would allow these three alternatives, that have been proposed for decades, from being thoroughly established as viable or dismissed as verifiably infeasible.


Today, a small number of commuter trains are indeed capable of using Penn Station as a through-running station, such as originating in New Jersey and continuing through the station to points east. But the legacy infrastructure of Penn Station, and the bureaucratic realities of different agencies running commuter rail lines in different regions, severely limit how this capacity is used today.

An evaluation of through-running as a viable capacity expansion alternative must consider two different possible situations for Penn, as well as all the potential benefit of better interagency coordination between rail networks and improved infrastructure in the regions beyond New York City. Only then can we know the full potential of through-running and the full benefit of reconfiguring Penn Station in a specific manner.

The first variant should evaluate the possibilities of through-running using Penn Station’s current track and platform configuration. As some trains do already, more trains could through-run with the current tracks and platforms, particularly if rail networks like New Jersey Transit, Long Island Railroad, and Metro-North Railroad are able to adopt improvements throughout the region like a combined fare system, dual-mode catenary/third rail/diesel trainsets, improved interlockings and rail equipment, and the design of new routes and lines. These improvements will have costs outside of Midtown Manhattan, to be sure, but evaluating the full cost of this alternative, and its benefits, will be critical to weighing the total cost against dramatic expansion of Penn Station’s footprint.

The second variant should then combine these through-running regional improvements with a proposed widening of the platforms in the current Penn Station. Through-running has been shown globally to provide the greatest capacity when train riders can rapidly alight on one side of the train and embark on the other near-simultaneously. This would require a reconfiguring of Penn Stations tracks and a widening of their platforms, which will increase safety and decrease loading times. This variant should be evaluated in combination with the improvements from the variant above, so that the region can assess once and for all the true potential and need for a platform reconfiguration, or whether similar benefits can be gained without such a disruptive transformation.

Through-running achieved with these regional improvements, either with or without reconfiguration of the platforms at Penn, has never received a comprehensive engineering review at the federal level. We urge that now is the time for that review of both options.

Maximal Improvement within Current Footprint

While a “no action” alternative is required in a federal impact assessment, this is likely to leave out evaluation of a series of improvements which would increase the capabilities of the current footprint of Penn Station, but without the expense and disruption of new track or tunnel construction. It is worthy of evaluation to determine exactly what capacity improvement could be achieved by judicious improvement to the current tracks and platforms of the station and its concourses.

An assessment of an “improved-to-the-max” Penn Station within the current footprint would include a set of improvements to current amenities to increase capacity modestly. These include lengthening Tracks 1–4 so that they are capable of full-sized trainsets as the other tracks currently are, which would then enable additional passenger circulation options including the extension of the Central Corridor to reach Tracks 1–4, as well as extension of the West End Concourse to reach Tracks 1–4.

Evaluation must also take into account updated forecasts of peak hour demand, including changes as the East Side Access project at Grand Central Terminal comes online, taking travelers to East Midtown and not through Penn Station. A focus on the station improvements, passenger projection adjustments, and improved logistical planning for bringing trains-per-hour on existing New Jersey Transit and Amtrak tracks into line with the rate of Long Island Railroad trains-per-hour should be factored in. Similarly, the effects of COVID-19 on passenger growth projections must be taken into account, to determine whether in-footprint improvements allow capacity growth to meet projected passenger demand, or whether more dramatic capacity expansion is truly required for the region.

Rail Connection Tunnel to Grand Central Terminal

In the 2003 Access to the Region’s Core project proposal, an alternative given cursory evaluation was a proposal for a short regional rail connection between Penn Station and Grand Central Terminal. Though elements of this alternative were not given rigorous evaluation at a federal level, the potential benefits that may far exceed the smaller costs of a short connection make it worthy of comprehensive evaluation.

The connector proposal envisions a single new 1.2-mile, two-track tunnel under 31st Street and Park Avenue, connecting the current tracks of Penn Station to the original track level of Grand Central Terminal, via a right-of-way that remains largely available and unobstructed.

The envisioned benefits of such a connector would be to unlock the economic and regional potential of routes and single-seat rides with vastly expanded combinations far into the outer reaches of three different commuter services. Trans-Hudson passengers with the East Side as their destination could potentially remain on train as it runs through to Grand Central directly, as well as vice-versa: Bronx, Westchester, and Connecticut residents would reach West Midtown directly as well without transfers. This could alleviate stress on the subway system as well.

Regional savings and logistics should be evaluated as potentially activated by this connector: the cost of a 1.2-mile tunnel is potentially much lower than more expansive alternatives, and as with other alternatives, the potential of cooperation and unification of the commuter rail systems via a single fare system or “central fare zone” could create people-moving efficiencies far beyond Midtown Manhattan. In addition, the added effects of in-situ improvements such as lengthening Tracks 1–4, as in other alternatives, should be evaluated as well.

As with all the alternatives mentioned, the cost savings, timeframe, and enabled regional rail efficiencies would all need to contribute to the ability to comprehensively weigh this alternative against the others.


Community Board Five firmly believes that Penn Station must be modernized and expanded to meet the needs of the coming century. Community Board Five also believes it is sensible to increase density around transit rich areas.

In fact, Community Board Five believes that it is to the State’s benefit to see these alternatives thoroughly evaluated with this broad scope and criteria alongside the GPP. These alternatives could bring more flexibility, more rail capability, and ultimately more benefit to the city and region at less cost than the GPP’s current preferred alternative. It is of course to the benefit of the State and the city to see those options evaluated.

Finally, a rigorous federal evaluation of these oft-mentioned proposals would alternately provide the data and evidence about which are viable and which are not. The State has often dismissed alternatives to their preferred path, but never with a rigorous engineering review taking into account the proposed development methods and regional effects. It’s again in the State’s interest to see these proposals given a full hearing.

Penn Station has been the pedestrian center of its neighborhood, the commuter center of Manhattan, the regional center of the Tri-State Area, and the rail hub of the entire Northeast Corridor since it was built in 1910. That’s a lot of roles to play. The fundamental role of a train station is to move people, and that’s exactly what Community Board Five wants redevelopment to focus on, to ensure success and capacity for yet another century: moving people in a modern, expansive, comfortable, and appropriately-grand fashion. It’s for this reason that every viable alternative for capacity expansion of Penn Station should be comprehensively evaluated for the benefit of the entire eastern seaboard before committing development effort and taxpayer treasure to a single path. We implore you to direct your respective state and federal agencies to scope this review appropriately. 

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