ABA Submits Comments on New York City’s Congestion Pricing Plan

The ABA voiced its reservations regarding the proposed toll rate schedule for the Central Business District Tolling Program (CBDTP), as submitted to the Metropolitan Transportation Authority’s (MTA) Bridges and Tunnels public comment period that ended yesterday. The ABA expressed concerns in its seven-page response about the tolling plan’s departure from congestion mitigation principles, stating that the current proposal does not align with the Value Pricing Pilot Program (VPPP) authority. The VPPP is a federal initiative aimed at reducing congestion through tolling strategies, primarily focusing on congestion relief rather than revenue generation.

“The Schedule does not reflect congestion mitigation,” wrote Brandon Buchanan, ABA’s Director of Regulatory Affairs. “By definition, congestion mitigation would dictate all mass transit providers be exempted from paying a price. There is no credible basis to make a distinction between mass transit operations pursuant to a government contract or privately undertaken.”

One of the central issues raised by the ABA is the lack of exemption for all mass transit operations, regardless of public or private status, in the proposed toll rate schedule. The Association argued that distinguishing between transit providers based on arbitrary criteria undermines the fundamental goal of congestion mitigation. Emphasis was placed on both public and private bus operations playing a vital role in alleviating congestion, with the latter often moving larger numbers of passengers more efficiently. The ABA also highlighted the positive environmental impact of motorcoaches, which can displace up to 35 to 40 cars from roadways, contributing to congestion reduction.

“The TBTA has an opportunity to address this flaw in the Schedule, in line with the other well-established value pricing projects around the world and in the U.S., by ensuring all mass transit operations, regardless of public or private status or type of passenger, are exempted from the tolling scheme described in the Schedule,” wrote Buchanan.

The ABA also urged the TBTA to pause the process and better align with the concurrent Port Authority of New York and New Jersey’s recently released Port Authority Bus Terminal rehabilitation proposal, currently undergoing an environmental assessment process. “Bus operational data from the PABT would have been highly valuable to the development of the CBDTP, and it is surprising the Port Authority is not one of the leading agencies participating in development of the CBDTP. However, if an oversight, the TBTA clearly still has an opportunity to rectify this oversight, gain invaluable data on current and future bus operations, and strengthen the CBDTP.”

Read ABA’s complete submitted public comment