Transportation Alternatives (T.A.) is a 4,500 member New York City citizens group. More than 800 of our members live within two miles of the Gowanus Expressway. The course the State Department of Transportation has set on with the Gowanus Expressway is short-sighted and a misuse of scarce tax dollars. Rarely does $1 billion become available to invest in our transportation network. With the goal of making a more intelligent decision, T.A. calls on the New York State Department of Transportation to:

• Perform a Major Investment Study for the entire corridor, merged with the Staten Island MIS.
• Fund a Community Engineer and provide a budget to hire consultants in other fields on a needed basis. All data and models should be available to the community engineer.
• Evaluate the possibility of using combinations of non-elevated highway and mass transit alternatives to maximize broad-scale benefit. Prepare scenarios for each highway alternative that include mass transit improvements.
• Evaluate the impact of other proposed projects in the corridor, including but not limited to: the Staten Island Expressway, the Nadler/Giuliani proposed harbor rail-freight tunnel, light-rail transit proposals on Staten Island and in Brooklyn, the Goethals Bridge, reconstruction of the Brooklyn Heights Promenade and reconstruction of the Brooklyn Queens Expressway Viaduct between Sands Street and the Williamsburg Bridge interchange.
• Examine the demand for any alternative in conjunction with time-of-day variable congestion pricing on the Verrazzano Narrows Bridge and Brooklyn Battery tunnel. Do the same with the no-build scenario and Alternative Two.
• Given that the life span of tunnel options is more than twice that of elevated highway options, discount costs and benefits based upon the projected life cycle of each alternative. Based on experience with the existing elevated highway and New York underwater tunnels, develop a maintenance schedule for the lifespan of alternatives and include it in present-value estimates of project costs. In addition, the costs and benefits of each alternative should be presented on 30 year, 50 year and 100 year scales.
• Develop traffic and pollution models for each alternative. Compare each alternative to both current standards and EPA's proposed new standards. Include induced demand estimates for alternatives that provide capacity improvements and reduced demand estimates for alternatives that reduce capacity, demand, or provide additional transit or rail freight service. The data that you collect should be shared with the public. Provide concrete examples where similar projects in other cities have led to impacts similar to those you forecast. Explain the model you use to reach your conclusions, and provide the assumptions and data. The Community Engineer should have a regular role in overseeing development of these models.
• Use the pollution and VMT models to estimate the effect of different alternatives on public health, and on pedestrian and bicyclist deaths and injuries. Explain the model you use to reach your conclusions, and provide the assumptions and data.
• Show the impact of differing alternatives on future land use in both the local area and the metropolitan region. Explain the model you use to reach your conclusions, and provide the assumptions and data.
• Estimate the effect of alternatives on the business community and on tax revenue to the city from the different land uses that will inevitably result from the different alternatives. Specify the value of taxable land added by teardown options, and increased project area property values and economic activity as a result of a teardown. Explain the model you use to reach your conclusions, and provide the assumptions and data.
• In alternatives where transit improvements or road pricing are considered, make explicit the effect of these improvements on traffic demand and show how they extend the time available before highway and local road level of service decreases compared to roadway-only options.
• Explain in detail how you have reduced the project schedule while at the same time reducing costs from initial estimates. Address the issue of whether long-term (more than six months) projects in other places have been able to work more than 10 hour days without worker fatigue and turnover.
• Make sure that all models study the effects on Prospect Park. Specify whether the park will be used by any alternate routes. Will any alternative remove the current need to use the park for rush-hour traffic relief, allowing more car-free hours?

Effect of Increasing Capacity
Throughout the draft Environmental Assessment and elsewhere, the State DOT refers to the desirability of "improving the operational characteristics" and the car carrying capacity of the Gowanus Expressway. The State's analysis in the Draft EA examines the effects of a capacity increase in a "snap-shot" fashion ¾ by which they assume that traffic levels on an expanded Gowanus would only increase at the same rate as they are on the current decrepit structure. Indeed, the State assumes that an add-on HOV lane would result in a reduction in vehicle trips. Substantial published evidence demonstrates that additional HOV lanes result in a total increase in vehicle trips and simply remove two passenger vehicles from the existing traffic flow, thus creating more space for single occupant vehicles to occupy. (See British Trunk Roads Report, 1995; and Chesapeake Bay Foundation Report, 1996 among other sources.) The net result is that the State's ultra-short term analysis fails to consider the "induced demand" or additional trips that added capacity Produces. Thus, the full potential increase in vehicle trips produced over time is not revealed, which is extremely significant given the number of Brooklyn to Brooklyn trips made on the Gowanus. More trips on the Gowanus Expressway, means more car trips on the local streets from which these trips originate and end.

Any scoping study or environmental review of different Gowanus Expressway alternatives must consider the trip induction or reduction potential of that alternative. Current land use changes, in particular the increase in Gowanus corridor automobile trip magnets like mega-stores, means that the potential feedback effect of more highway capacity leading to more auto-dependent land uses, in-turn leading to more car trips, must be examined. Additionally, the State must make its assumptions and calculations regarding induced demand explicit to the public. Thus, the State scoping/study should include:

• An assessment of car trips added or subtracted to the Gowanus corridor and I-278 corridor from the Goethals Bridge to the Grand Concourse, by each alternative at 1 year, 2 year, 5 year, 10 year, 20 year and 50 year intervals.
• The State must include an induced demand calculation in their modeling that conforms with accepted assumptions as established by the Transportation Research Board and in consultation with the Community Engineer.
• The effect of land-use on the various alternatives and vice-versa (including estimated trends over 1,5 and 20 year periods) need to be examined.
• A baseline "true cost" or externality cost of existing Gowanus corridor auto use on air pollution, crash deaths and injuries, noise, building damage and real estate value must be established. (Brian Ketcham P.E. has issued a draft study of this issue that should serve as the basis for the State.)
• The various alternatives and their effect on car trips, and land use should be assessed and their external and direct costs compared with the baseline externality costs.

Alternatives
T.A. calls on DOT to evaluate the effects of other possible projects in the Koscousko to Goethals corridor on all alternatives and study all alternatives to an equal depth. Each alternative should be explored to the same depth as Alternative Two has been studied. For example, if there are engineering problems with an alternative, you should ask engineering firms to develop innovative solutions. SDOT should prepare a cost/benefit analysis for each alternative. We propose four fundamental alternatives, but we are explicitly stating the possible permutations that should be considered. DOT should be able to establish sub-models that show the effect on each alternative of transit improvements, road pricing, and freight modal-shift to rail. DOT should also make a good-faith effort to develop LRT routes that serve the most people while minimizing travel time and costs. DOT should examine LRT proposals put forth by Councilman John Fusco and Staten Island Borough President Guy Molinari. The following bulleted concepts should be added to the scoping document list:

1. The RPA's tunnel proposal:

1)by itself
2)combined with a light rail transit (LRT) system over the Verrazzano Bridge, following the current right-of-way and then up Third Avenue to an underground terminus connected to the Atlantic Terminal complex.
3)combined with a similar LRT system through the Brooklyn Battery Tunnel, terminating at the Battery Garage.
4)combined with a cross-harbor rail freight tunnel
5)combined with a doubling of frequency and off-peak discounts on the N,R,B and F lines. Explore extending the G line to Ditmas Avenue while restoring F express service. Net cost for transit improvements should be met by SDOT.
6)combined with roadway congestion pricing, set at a level where the marginal social cost of each additional driver begins to exceed the driver's marginal private cost.
7)combined with development of a more extensive express bus network in the areas that feed into the Gowanus, combined with guided busway technology to replace two general purpose lanes on the new highway
8)The possibility of a tunnel under Downtown Brooklyn, to replace the BQE north of the Battery tunnel
9)Option 8 combined with the above mass transit options

2. Use of expanded mass transit, combined with a cross-harbor rail-freight tunnel, to replace the highway with a restored third avenue:
1)with a light rail transit (LRT) system over the Verrazzano Bridge, following the current right-of-way and then up Third Avenue to an underground terminus connected to the Atlantic Terminal complex.
2)with a similar LRT system through the Brooklyn Battery Tunnel, terminating at the Battery Garage.
3)via a doubling of frequency and off-peak discounts on the N,R,B and F lines. Explore extending the G line to Ditmas Avenue while restoring F express service. Net cost for transit improvements should be met by SDOT
4)combined with roadway congestion pricing, set at a level where the marginal social cost of each additional driver begins to exceed the driver's marginal private cost.
5)combined with development of a more extensive express bus network in the areas that feed into the Gowanus, combined with guided busway technology up Third Avenue.
6)The possibility of a tunnel under Downtown Brooklyn, to replace the BQE north of the Battery tunnel

3. Pricing and parking policy to reduce automobile travel demand. DOT should provide a list of current taxes that could be eliminated with the revenue, including but not limited to sales tax
1)combined with a light rail transit (LRT) system over the Verrazzano Bridge, following the current right-of-way and then up Third Avenue to an underground terminus connected to the Atlantic Terminal complex.
2)combined with a similar LRT system through the Brooklyn Battery Tunnel, terminating at the Battery Garage.
3)combined with a cross-harbor rail freight tunnel
4) combined with a doubling of frequency and off-peak discounts on the N,R,B and F lines. Explore extending the G line to Ditmas Avenue while restoring F express service. Net cost for transit improvements should be met by SDOT.
5)combined with roadway congestion pricing, set at a level where the marginal social cost of each additional driver begins to exceed the driver's marginal private cost.
6)combined with development of a more extensive express bus network in the areas that feed into the Gowanus, combined with guided busway technology to replace two general purpose lanes
7)The possibility of a tunnel under Downtown Brooklyn, to replace the BQE north of the Battery tunnel
8)Option 7 combined with the above mass transit options

4. Alternative Two;
1)by itself
2)combined with a light rail transit (LRT) system over the Verrazzano Bridge, following the current right-of-way and then up Third Avenue to an underground terminus connected to the Atlantic Terminal complex.
3)combined with a similar LRT system through the Brooklyn Battery Tunnel, terminating at the Battery Garage.
4)combined with a cross-harbor rail freight tunnel
5) combined with a doubling of frequency and off-peak discounts on the N,R,B and F lines. Explore extending the G line to Ditmas Avenue while restoring F express service. Net cost for transit improvements should be met by SDOT.
6)combined with roadway congestion pricing, set at a level where the marginal social cost of each additional driver begins to exceed the driver's marginal private cost.
7)combined with development of a more extensive express bus network in the areas that feed into the Gowanus, combined with guided busway technology to replace two general purpose lanes
8)The possibility of a tunnel under Downtown Brooklyn, to replace the BQE north of the Battery tunnel
9)Option 8 combined with the above mass transit options

The system you build will directly affect how New York develops in the next century. Portland, Oregon has developed a model, called LUTRAQ, that shows the relationship between land use, transportation and other government policies. The U.S. District Court in Will County, Illinois ruled in January, 1997 that the Illinois DOT would have to develop a separate set of socioeconomic and land use forecasts based upon what would likely occur with or without their preferred alternative. These forecasts alter traffic demand assumptions significantly. New York State DOT must do the same with its alternatives. Otherwise, the State DOT would do a disservice to the businesses and residents of Brooklyn and the region and their children, who must live with the decisions made today.