NARP Testifies against current design of new Hudson River Tunnels
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NARP Testifies against current design of new Hudson River Tunnels
Ross B. Capon, Executive Director
National Association of Railroad Passengers
Before
Supplemental Draft Environmental Impact Statement Hearing
Access to the Region’s Core (ARC) –
April 1, 2008
Thank you for this opportunity to comment on the current ARC plans. We appreciate that New Jersey Transit is attempting to address a serious problem—existing and anticipated growth in demand for rail service between North Jersey and Manhattan.
However, we strongly oppose the tunnel project as currently planned and join with other organizations in underlining the need for new Hudson River tunnels that will perform, as outlined below, functions consistent with needs for interstate service (including within the New York City region), security and redundancy, and the ability to provide reasonable service and opportunities for track maintenance.
It is essential that New York City’s existing Pennsylvania Station (NYP) be accessible from the new tunnels. This was a key feature of Alternative G in the 2003 Major Investment Study. In a June, 2007 redesign, NJT jettisoned this capability. That is unacceptable. It means the new tunnels would lead only to a new terminal near NYP, under 34th Street, dramatically reducing flexibility for NJT, Amtrak and potentially Metro-North. It ensures that the new tunnel could be used only by NJT trains dead-ending at their new terminal, and that any future, regional run-through service, such as Trenton-Stamford, would have to use the existing Amtrak tunnels.
The reasons why the new tunnel must provide access to NYP, and the
arguments against the planned, new “deep cavern” station 175 feet under
34th Street are formidable.
- Today’s security-conscious world cries out for the redundancy and operational flexibility that NJT’s pre-June, 2007 design offered. Consider the implications of having the existing Amtrak-owned tunnels (used by both Amtrak and NJT trains) disabled either temporarily (should, for example, a train derail or be otherwise immovable) or, heaven forbid, for days or months. Under the present plan, it would be impossible to maintain any kind of run-through service—either existing intercity service, or the inter-regional services (such as Trenton-Stamford) which should be part of any solid future planning for the region.
- It is important to be able to maintain the railroad adequately and efficiently with minimum negative impact on service. Today, maintenance is basically limited to 55-hour weekend windows, yet growing demand for weekend service—both commuter rail and intercity—is bumping up against those windows. Thus, connecting the new tunnels with NYP would offer maintenance/service benefits both for NJT and Amtrak trains using NYP and for NJT trains using any new terminal.
- We understand the pressure on NJT from FTA criteria which focus on travel minutes saved: anything increasing project costs without saving more minutes makes the project weaker when measured against FTA criteria. But the FTA criteria are wholly inappropriate when applied in a post-9/11 world to a key strategic asset in such a densely populated area.
- The current plan is incompatible with interstate service needs. It is inconceivable that a project of this magnitude would be built when it provides no redundancy or capacity benefits for interstate service. “Interstate” means not just the Amtrak’s existing Boston-Washington trains, but also—as noted above—inter-regional services that must be on the agendas of NJT, Metro-North and the Long Island Rail Road. All of these services would have to be developed within the limits of the two existing tracks under the Hudson.
- There is general agreement that New York City is the number one market in the country where expanded intercity train service would help address demands for air service that are bumping up against airport and airspace capacity limits. By failing to connect the new tunnels with NYP, this project not only does not provide any new intercity slots at NYP, it is our understanding that it also precludes future investments aimed at providing such slots.
A process issue also demands comment. New Jersey Transit has failed to release anything more than a 31-page “Summary Report” of the 2003 Major Investment Study (MIS), even though the longer report is alleged to contain justification for what we consider to be fatal flaws in the current design. It is imperative that NJT release all of the background data relevant to the finding than the new tunnels cannot access NYP.
At the request of two NARP board members from the New York City region, I set up a meeting at FTA headquarters which took place January 11. At this meeting, we made clear our opinion about the secrecy at issue and were told that FTA would try to help us get the information needed. On March 27, an FTA official who participated in that meeting told me that, as of a few weeks ago, she had checked with the regional administrator and no progress had been made on getting NJT to release the information.
We are left with a weak claim by NJT that their currently favored alternative “does not preclude” extension to Grand Central Terminal of the upper three tracks planned for the new NJT terminal. However, we have found no documentation for this claim, including no engineering drawings of how it would work.
These issues need to be discussed openly. The problems created by restrictions on federal funding do not justify NJT’s secrecy, and do not change the bottom line: a plan is needed which connects new tunnels to NYP and which is compatible with realistic design of a rail connection between NYP and Grand Central Terminal.
It appears that NJT is making meaningful public review of this project impossible because the taxpayer-funded MIS remains largely secret. This is unacceptable, particularly for a project of this magnitude ($7.6 billion of taxpayers’ money, not counting the tax dollars used to produce the thus-far secret document).
In sum, it would be a monstrous failure of public policy to permit implementation of the present design in spite of its major failings as outlined here and in statements by others.