<< Back
Transportation & Environment
Transit Mobility Review Board (TMRB) Congestion Pricing Toll and Exemption Recommendation
At the regularly scheduled monthly Community Board Five meeting on Thursday, January 11, 2024, the following resolution passed with a vote of 29 in favor; 6 opposed; 1 abstaining:
WHEREAS, Community Board Five reviewed and analyzed the toll structure recommended by the Transit Mobility Review Board (TMRB) for the Central Business District Tolling Program (otherwise known as congestion pricing), held a hearing for members of the public, and discussed the merits and implications of the toll recommendation on the neighborhood of Community Board Five; therefore be it
RESOLVED, Community Board Five submits the following comment and testimony to the Metropolitan Transportation Authority (MTA) in regards to the implementation of toll rates, the initiation of the program, and, critically, next steps following the program’s start.
Transit Mobility Review Board (TMRB) Congestion Toll Structure Recommendation
CB5 Response
Introduction
Manhattan Community Board Five appreciates the opportunity to submit comment and testimony on the base toll and exemption recommendation of the TMRB prior to the MTA’s final adoption of rates, as well as to, crucially, provide testimony on steps and considerations that the MTA can take into account during and after the start of the program and its execution.
Community Board Five strongly supports the goals of the Central Business District Tolling Program, including the reduction of congestion on the streets of the Central Business District, as well as the funding of improved and expanded transit infrastructure and options. As Community Board Five’s district sits entirely within the CBD, the intended goals of reduced congestion and improved transit options in the zone would considerably benefit our neighborhood and its residents.
We support accommodation in the final TMRB recommendation for low-income drivers in addition to the State’s full tax credit equal to tolls paid by low-income residents of the congestion zone, including a 50% discount for all low-income drivers, regardless of their place of residence, after the first 10 trips in a calendar month.
Burden
With the understanding that the TMRB recommendation prioritized simplicity, minimized the number of different exemptions, and represents only the initial rates under which the toll program will operate, Community Board Five has serious concerns that the disproportionate burden of the toll structure will fall on residents living inside the zone. While modeling has been presented by the TMRB to predict effects on traffic, to identify the demographics that will bear the costs, and to enumerate externalities of the toll, these are merely predictions, and the full effects will of course not be known until the experiment of congestion pricing is being run. Community Board Five has significant concerns about a variety of effects and implications that remain uncertain.
First, residents of the zone are likely to be impacted by the toll in unexpected ways based on their unique proximity to the boundary of the zone. A resident who happens to live near the boundary, work near the boundary, have a neighbor or family member just a few blocks away over the boundary, or have services or a place of business to attend just a few blocks away over the boundary could incur the maximum toll per day by this proximity, while conversely, a resident living deeper within the zone could drive to work, family, or business every day without incurring the toll to cross the boundary at all. This particular inequity is not yet fully understood.
Additionally, residents and businesses of the zone will absorb and primarily feel any unexpected externalities of the pricing. It is not known whether the added cost on deliveries and businesses will impact the prices of goods and services offered by businesses in the zone. Any inflationary costs passed by businesses onto consumers will be directly borne by residents of the zone as well. It is similarly uncertain how property values in the zone may be eventually affected by these increased costs. It is unknown how this kind of inflationary pressure may affect the availability of services in the zone — such as hospital services, for example, which are already closing under immense financial operating pressure, as well as other pressures that congestion tolls may exacerbate, like the availability of employees for emergency services.
Live Metrics
Understanding that these effects will not be fully understood until congestion pricing is in effect, it is critical that these practical effects are studied immediately and transparently after the program begins collecting its toll. We call on the MTA to collect and transparently publish all applicable live data about the impact of the program on its intended goals in the district, as well as the impact of side effects on the district.
The MTA should publish live data via a publicly-available dashboard on a regular basis from the start of the program on whether congestion is truly being reduced within the zone, and whether this congestion reduction is evenly distributed between vehicles from inside and outside the zone; for example, if the residents of the zone are not able to elastically reduce their daily trips over the boundary, as the program purports to induce on drivers from outside the zone, then the cost of the toll will be inelastically borne by residents of the zone, and this must be measurable and identifiable from the data.
Similarly, monitoring must be able to establish the specific effect of the toll program on block-by-block air quality, and this data collection and publication must be started prior to the initiation of the program, to establish baseline measurements. We call on the MTA to begin measuring and publishing this data immediately, in the months prior to the program going live, so that all residents will be able to transparently understand the status quo before the program and to follow the effects and impacts of the program in real time when it begins.
Flexibility
With the understanding that the TMRB prioritized simplicity in its final toll recommendations, we were nevertheless disappointed, perhaps because of parameters provided to the TMRB, not to see more dynamic pricing schemes evaluated for comparative purposes. Cities such as Singapore and Stockholm provide examples of dynamic pricing schemes that can be adjusted on a block-by-block basis, while the TMRB assumed from the start that a single flat toll would be leveraged on any car that enters anywhere in the zone. As the above data is evaluated, the MTA must widen its study and evaluate alternative dynamic pricing schemes to compare the potential effects and benefits to the initial effects of a flat fee.
Similarly, as the initial toll rates and exemptions go into effect, the MTA must continue to project and comparatively evaluate the potential effects of further improvements and adjustment to the pricing scheme if they are needed, if the scheme is not accomplishing all desired goals or is causing unanticipated side effects. The MTA must be prepared to adjust not only the rates in the TMRB recommendation but be prepared, when adequately studied and if demonstrably advantageous, to adjust the principles of a simplistic flat fee and minimal exemptions. The TMRB initial recommendation imagines the program starting with a bare minimum of exemptions, but based on data and monitoring, it may be advantageous to explore further exemptions in the future, such as based on vehicular air quality.
Community Board Five is similarly clear-headed about the need for prices potentially to be adjusted upward, if the MTA’s monitoring indicates that goals such as reduced congestion are not being achieved. The TMRB’s recommendation is a baseline, and realizing the goals of the program in practice will necessitate flexibility, openness to adjustment, and transparency in success metrics.
Conclusion
Community Board Five is fully aware that congestion pricing in New York City is an experiment; the effects of the Central Business District Tolling Program can be modeled and predicted but cannot actually be known until the program begins. The TMRB’s recommended rates and exemptions are a starting point, but in a practical sense, the success of the program and achievement of its goals of reducing congestion and raising revenue for transit investment will depend not on a perfect initial guess at rates, but on smart, data-driven adjustment and flexibility after the program begins. The legacy of congestion pricing will rest not on its starting rate, but on publication and study of its effect and iterative, flexible adjustment after its start.
This transparent monitoring and a commitment to iteration and flexibility will ultimately define the program. Iteration from starting the program and then observing it may be the only way to make sure the rates become and remain equitable and effective.
We call on the MTA to commit now, prior to the start of the program, to a regime of transparent measurement and publication so that the MTA and the communities around the CBD can assess the success of the program together. We thank you for your close attention to these concerns of the residents and parties living within the congestion zone as you roll out the program, and as we all work towards the same goals of decreased congestion and improved transit.