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Comments Regarding the Hudson River Project Environmental Impact Statement Scoping Document

May 31, 2016

Ms. Amishi Castelli, Ph.D.
Environmental Protection Specialist
Office of Railroad Policy and Development
USDOT Federal Railroad Administration
One Bowling Green, Suite 429
New York, NY 10004

Mr. RJ Palladino, AICP, PP
Senior Project Manager
NJ Transit Capital Planning
One Penn Plaza East – 8th Floor
Newark, NJ 07105

RE: Comments Regarding the Hudson River Project Environmental Impact Statement Scoping Document

Dear Ms. Castelli and Mr. Palladino,

The Municipal Art Society of New York (MAS) welcomes the opportunity to provide comments on the Scoping Document for the Hudson River Project (Project) Environmental Impact Statement (EIS) being prepared by the Federal Railroad Administration and New Jersey Transit.

The North River Tunnels into New York Penn Station – which moves a workforce that annually contributes more than $50 billion to the U.S. economy – are crucial to the entire Northeast Corridor. The Hudson River Project plan to repair damage in the existing tunnels from Superstorm Sandy and construct two additional tunnels to improve resiliency is critical to the future of New York City and the surrounding region. Thus, MAS strongly supports the Hudson River Project.

For many years, MAS has been the leading advocate for a new Penn Station and a comprehensive district and infrastructure plan for West Midtown. As such, MAS makes the following recommendations for the Project:

  1. Tunnel Alignment Alternatives – Although the primary purpose is to rehabilitate the existing Hudson River tunnels, the Project is undeniably connected to the future expansion of Penn Station and a number of long-range infrastructural improvements that would affect area transportation for generations. The EIS needs to evaluate tunnel alignments that provide optimal connections to local subway and bus lines, while also accommodating potential through-running service for commuter rail lines (i.e., NJ Transit and LIRR). Further, we encourage the analysis of tunnel alignments that do not solely align with the Right of Way at Hudson Yards or those proposed under the Penn Station South project, to comprehensively assess a wider range of potential local and regional connections.
  2. Coordination with Other Planning Efforts: MAS has long called on elected officials to develop a long-term vision for both trans-Hudson transportation capacity and a forward looking vision for West Midtown. We therefore request that the EIS carefully and comprehensively evaluate how best to coordinate the Project with other related planning efforts, including:
  3. Empire Station Complex Proposal – We believe that Governor Cuomo’s ongoing solicitation for the Empire Station Complex could result in a series of worthwhile efforts to ease congestion and improve public spaces and amenities at Penn Station. Although the Hudson River Project is primarily focused on restoring the North River tunnels, tunnel alignment alternatives must incorporate Governor Cuomo’s planned improvements to the station, while not foreclosing opportunities for additional and more substantial transit capacity, life safety, circulation and public space improvements in the future.
  4. Penn Station South Project / Block 780 – MAS understands that in an effort to expedite the construction of the tunnels, other elements of Amtrak’s Gateway Project, including the expansion of Penn Station south to Manhattan’s Block 780, are not included in the scope of the current Project. However, in order to maximize the return on the proposed investments, the EIS should evaluate the proposed tunnel and existing tunnel repairs in coordination with platform area enlargements and improvements anticipated for the planned expansion of Penn Station or Amtrak’s Block 780 project.
  5. Port Authority Bus Terminal Master Plan – Like Penn Station, the Port Authority Bus Terminal (PABT) is in dire need of rehabilitation and increased capacity. The Port Authority’s planning efforts for the site should be incorporated into the EIS as part of a comprehensive look at how best to add new trans-Hudson capacity to the region. The EIS should disclose an estimated range of new capacity for the rehabilitated tunnels, as well as the new tunnels. This information will allow for better planning for future improvements at the PABT, as well as Penn Station.
  6. Cost Effectiveness – Although the Hudson River Tunnel Project, as stated, will not directly increase rail capacity, the EIS should also evaluate alternatives that utilize the analyses and findings from the Northeast Corridor (NEC) Future Study EIS that provide the highest level of capacity improvements balanced with the most feasible costs.

Thank you for the opportunity to provide comments on this critically important project.

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