Ritchie Torres submitted the following comment to the MTA, the Federal Highway Administration, and the Traffic Mobility Review Board:
"Dear Chairman Weisbrod, Chairman Lieber and Administrator Marquis:
I am writing to express concerns about the environmental impact of the MTA's Central Business Tolling Program upon the Bronx. Even though I have long been a principled proponent of congestion pricing, I strenuously object to any plan that would divert diesel truck traffic from Manhattan to the Bronx, particularly the Cross Bronx Expressway. The Bronx cannot and will not be a sacrificial lamb on the altar of the Central Business District.
William Faulkner once said: "the past is not dead. It is not even past." Nowhere do these words resonate more powerfully than in the South Bronx, which continues to be haunted by the ghost of Robert Moses. A lethal legacy of the infamous Moses, the Cross Bronx Expressway is, both literally and metaphorically, a structure of racism. It has left in its wake decades of displacement, disinvestment, and environmental degradation from which the Bronx has since been struggling to recover.
Every day in the South Bronx, there are 15,000 diesel truck trips to and from the Hunts Point Food Distribution Center. Those diesel trucks, as well as tens of thousands more, create extensive congestion on the Cross Bronx Expressway and unleash massive quantities of air pollution and greenhouse gas emissions. Children who bear the misfortune of living near the Cross Bronx or attending school nearby are, through no fault of their own, breathing in pollutants that cause them respiratory diseases like asthma.
It is no accident that the South Bronx has been persistently plagued by the highest rates of asthma hospitalization in the city. Simply put, the air we breathe in the Bronx is different from and worse than everyone else's--not by accident, but by virtue of the structures we have built and the inertia that keeps them in place.
When it comes to the public health of the Bronx, those charged with voting upon a congestion pricing plan must observe the Hippocratic Oath: Do no harm. Yet harm is precisely what will befall the Bronx if the environmental impacts projected by the MTA's own modeling are left unmitigated.
The MTA's Environmental Assessment contains no tolling scenario that would produce either a beneficial or neutral impact on congestion on the Cross Bronx Expressway. All the scenarios--from A to G--would lead to increased diesel truck traffic on the Cross Bronx, with increases ranging from 50 to 704. Even 50 is 50 too many.
Both the Traffic Mobility Review Board, which must vote on a congestion pricing plan, and the MTA Board, which must approve it, must confront a critical question. Is it fair to create less congestion, pollution, and greenhouse gas emissions in Manhattan at the cost of creating more in the Bronx? Is it fair to treat the Bronx as little more than a dumping ground for Manhattan's diesel truck traffic? If you believe, as I do, that the public health of the Bronx should be a priority rather than an afterthought, then the MTA has an obligation to find a congestion pricing model that has a beneficial or neutral impact on the Bronx in general and the Cross Bronx in particular. According to Schedule G, tolling personal vehicles and commercial trucks at the same rate could minimize truck diversions. Crediting drivers crossing the Lincoln Tunnel could reverse the incentive to drive through the Cross Bronx. Trucks should get a full credit when using the Lincoln Tunnel or Midtown Tunnel to enter the Central Business District so that there is no cash incentive to divert to the Cross Bronx.
The burden of bringing environmental justice to the Bronx cannot, however, fall solely on the shoulders of the MTA. The whole of New York State government must do its part. Capping the Cross Bronx Expressway to prevent air pollution; greening the Hunts Point Terminal Market to retire 1000 diesel powered Refrigeration Truck Units; prioritizing the South Bronx for EV charging stations; closing fossil fuel peaker plants upon the completion of Tier 4; and preventing the concentration of last mile delivery warehouses at the Harlem River Yards, a state-owned site. These are but a few initiatives the State could champion concretely to address the public health and environmental needs of the Bronx.
The State should adopt mitigation measures, conduct continuous air quality monitoring to evaluate the efficacy of those measures, and establish an enforcement mechanism that enables the State to be held accountable in the event the mitigation measures fail. The enforcement mechanism could take the form of a toll agreement with the Federal Highway Administration (FHWA) that imposes on NYSDOT, NYCDOT, and the MTA a contractual obligation to mitigate the environmental harms in the Bronx and on the Cross Bronx. In addition to mitigating the impact of congestion pricing, the State should prioritize the capping of the Cross Bronx in the capital plan of the New York Metropolitan Transportation Council (NYMTC), which makes decisions about how and where to deploy federal transportation funds.
The people of the Bronx need something more tangible than feel-good rhetoric about racial equity and environmental justice. We need real investments that offer a clean and green break from the environmental racism of the past. We need congestion pricing to be not part of the problem, but instead part of a solution that finally brings breathable air to the Bronx."