HART Hudson Alliance for Rational Transportation
www.hartwheels.org
email.. Hartwheels@aol.com
July 9, 1999
Roseanne Koberle
Information Officer
North Jersey Transportation Planning Authority
One Newark Center, 17th Fl
Newark NJ 07102
Fax 973-639-1953RE: 2000-2002 NJTPA TIP (Transportation Improvement Plan)
Comments on Bergen Arches (DBNUM 98537 or TPK 113 or "Bergen Arches Transitway") and related projects:
Projects DBNUM 98537 (Bergen Arches), DBNUM 112 (Secaucus Interchange) and DBNUM TPK 9801 (Secaucus Connector) form one proposed continuous transportation corridor. We realize that the irrational does sometimes drive governmental decisions, especially when the private economic stakes are high. But it strains even our jaded credulity to expect us to believe that this project was not conceived from the start as a second turnpike extension to the Jersey City waterfront. We mention this not to be obstreperous, but as people who still insist that legally mandated public review processes be respected. This in spite of those who advise us that this highway is a "done deal" and our efforts are a waste of time.
The three above-mentioned projects must be reviewed for cumulative impact. The notion that the Interchange and the Connector (to what?) were conceived in a vacuum, after which a well meaning highway planner hit upon the clever idea that all of the cars and trucks dumped into Jersey City could be moved a bit further east through the railroad cut is repugnant to reason. All of the foreseeable primary and secondary impacts of the Interchange and Connector should have been articulated at the earliest possible moment, and this should have been folded into a cumulative review of the entire corridor which would yield a more realistic picture. Looks like somebody missed a rather critical impact.
Instead, we are faced with a seemingly fair and impartial Bergen Arches needs assessment grafted onto a highway "connector." This is classic segmentation; the narrowly reviewed segments never raised the hugely important social and environmental questions posed by the entire highway project. It was doubtlessly intended that the "staked out" segments would become the strongest argument for the completion of the highway. The possibility of a less polluting, more efficient rail alternative west of the Arches was also precluded without a serious look. The entire corridor should be re-examined de novo; highway proponents should not be rewarded for their obfuscation.
We can not fail to mention, if only as an aside, our amazement at the number of contradictory, after-the-fact justifications that have recently been offered for the Arches highway project since opposition to it has become known. Hockey rink, baseball stadium, movie theaters. We thought it was for the commuters from Montclair and Mahwah. Or was it for the truckers? Not many years ago, the abandoned Hudson County waterfront was rightly promoted as a redevelopment area. One of the strongest arguments for this redevelopment was the existing transportation infrastructure. PATH. New York subway connections. Ultimately light rail. But now we are informed that all of this isn't good enough. We have to publicly finance private auto competitors to the existing and new public lite rail transit system. It seems that every week a new need is discovered that can only be satisfied by this highway. It looks to us that a bunch of very well connected individuals have, for whatever reason, decided to build this highway. Now they're trying to find a reason why.
At the very least, the needs assessment of the Bergen Arches should spell out the real reason for this project. We would genuinely like to know. We would welcome attempts to refute the arguments we put forward in our February submission, copy attached, to the NJTPA on the matter. To date, all we are hearing is extremely lame, contradictory justifications, coupled with assurances that this project is going to happen-- no matter what. What does this sort of thinking suggest about the role of the Municipal Planning Organizations (MPOs) in transportation planning? Have they been converted to a justification of decisions made elsewhere?
If there are such over-arching motivations for this highway, shouldn't they at least be made public? Isn't this the essence of the review procedure? Shouldn't all primary and secondary impacts of the project (stadiums, cinema complexes, Portway truck routes or whatever) be articulated? Conversely, if this project is simply one more instance of a raid on the pork barrel, isn't it the duty of the MPO to place things in a regional context and inject a note of rationality?
Finally, we think the notion of a "needs assessment" far from self-evident. Whose needs? The waterfront commuter who can easily take a train to work on the Hudson County waterfront, but who prefers to drive, or that of someone living in inland Hudson County without a decent public transit option? We trust that Title 6 of the Civil Rights Act and the (federal) Executive Order on Environmental Justice will be incorporated into any needs analysis. We further trust that the needs of those communities severely disrupted by the last (and, hopefully, final) round of urban freeway incursions will be addressed--not by compounding the problems, but by mitigating them...
We urge the NJTPA to combine all three projects into one for analysis of their combined impact on the local and regional transportation network, environmental health and safety, and the economy in accordance with the above mentioned Civil Rights Act and federal Executive Order on Environmental Justice, as well as NEPA and TEA-21. We also urge the NJTPA to define the project so as not to preclude analysis of all reasonable transportation alternatives. Aggressively promoting modern rail freight is critical to protecting and more rationally using existing highways.
As we compose this document, the national weather channel is informing us that the entire region is under yet another "ozone health advisory." We are informed of the vehicular origin of most smog, and urged to use public transportation--"where available." It's only going to be available if the responsible parties incorporate an awareness of this ongoing crisis into their transportation planning.