Hon. Iris Weinshall
Transportation Commissioner
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.
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 vehicles?

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.

Sincerely,

Christina Hemphill
Transportation Director
New York City Environmental Justice Alliance

John Kaehny
Executive Director
Transportation Alternatives

Jon Orcutt
Associate Director
Tri-State Transportation Campaign

NYC Environmental Justice Alliance
115 West 31st Street #709
New York, NY 10010 212-239-8882

Transportation Alternatives
115 West 31st Street, 12th floor
New York, NY 10010 212-629-8080

Tri-State Transportation Campaign
350 West 31st Street #802
New York, NY 10001 212-268-7474