Congestion Pricing. Let's Clear the Air.

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If the goal is to clear the air as the mayor says other mechanisms of the plan should address this. Taxis are a sensible place to start. We think it borders on lunacy that in 2007 the vehicles that we use as Taxis are predominately Ford Crown Victoria's equipped with gas guzzling and emission spewing V8 engines. These vehicles are dinosaurs that have no place in New York-or any city for that matter. The average life of a NYC taxi is 5 years and the Mayor has already required that all taxis be hybrids by 2012. We are suggestion that we jump-start this conversion by requiring that any exempt taxi vehicle be a hybrid vehicle. Furthermore we see no reason why Black Cars (radio cars) should be exempted from congestion charges. They should either be merged with the Yellow Fleet so that the public can benefit from their presence and have the ability to hail them or be treated as the private cars that they are.

We also think that delivery companies such as FedEx, UPS & DHL, etc should be exempt from charges for delivering packages within the zone. These companies are crucial for large and small business and although they are private companies, in many ways they play the public role of mail carrier and this should be recognized. ConEd vehicles should also be exempt for obvious reasons.

Car sharing companies such as Zip Car, and rental companies such as Hertz, Avis, etc, having vehicles starting trips within the zone should also be exempt. The reason for this is that these services decrease the need for car ownership while increasing mobility options and thus deserve preferential treatment.

Another exemption we think is worth suggesting is for local farmers coming to farmers markets or making deliveries. The connection between food and the environment and living more sustainably is an obvious one that isn't made often enough. New York is surrounded by farms that are under severe pressure from low cost overseas producers, difficult growing conditions, and land development pressure. Our thinking is that anything that can be done to help the people that grow food we eat near us should be done.

Speaking of exemptions the city should use Congestion Pricing to not only reduce cars but also reduce dangerous drivers from our streets. It's not a secret that two demographics are responsible for a disproportionate amount of fatal crashes. Elderly drivers and younger drivers. So we propose that any resident over the age of 60 and all full time students be given free transit passes which when coupled with the congestion charges, will act to further incentivize these two groups to leave their cars at home.

Not all congestors are created equal. Let's close the SUV loophole.

Another issue that we think needs clarification is the term "automobiles" and "trucks". The plan as we all know calls for charging cars $8 dollars and trucks $21 but yet doesn't define cars or trucks.

All SUV's are classified as trucks to benefit from a federal loophole that exempts them from fuel and emissions standards. While we see a need for some cars in our city, we don't see a need for 8,000 lb. behemoths that guzzle gasoline and spew emissions. There is no reason for SUV's to be driven in Manhattan and thus we think congestion pricing is an opportunity to close this loophole that has a negative impact on NY. Since SUV's are legally classified as trucks we think they should be charged the higher truck rate, even if their steering wheels and cup holders are padded with leather.

And what about trucks carrying goods? Why is a gasoline sipping Sprinter van with a modern exhaust system and car like handling abilities considered the same as a diesel-belching semi pulling a tractor? They are not the same thing and should not be classed the same way. If the goal is to clear the air then lets adjust congestion charges of trucks to include, size, weight, engine type, emissions system. The range of possible trucks is just too large for them to fall under one classification so we need more than one.

This is good opportunity to get the ridiculous super stretch limousines that have started proliferating in recent years off our streets too. We suggest charging those by the inch.

One thing we can learn from London: a plan for the people has to include the people.

With any policy there are winners and losers. The winners out number the users and if possible the losers should somehow be made whole for their losses. Three obvious losers of the plan are Manhattan residents who own cars, businesses owners that keep delivery vehicles in Manhattan, and owners of parking garages. The residents lose because they have to pay to be in the zone even if they are just leaving New York, as they live here and have no choice so this just doesn't seem fair. The business owners in Manhattan already have much higher operating costs and are already paying a premium to be in Manhattan. And as so few Manhattan residents own cars and as Manhattan residents and business owners are not the cause of congestion, rather the cause is the vehicles that pour into the city everyday we think that they should be exempt. Exempting Manhattan residents an business owners who keep vehicles in the zone will benefit garage owners.

What we do like very much about the London plan has unfortunately not been included in our plan. Recently, at a talk titled "Learning Lessons from London on Congestion Pricing" At the Rudin Center for Transportation sponsored by The Drum Major Institute I heard first hand Nicky Gavon the Deputy Mayor of London and the Point Person on Londonís plan speak talk about Londons comprehensive, transparent and public planning process.

London recognized that there are winners and losers took a bottoms up approach to talking to people. What that means is that met with people, in an organized planning process to learn what different constituents needs where and then they tried to address them in the fairest way possible to all people. The New York approach on the other hand has been a top down approach, with no public dialogue or input. New York really needs to have that dialogue before we move forward.

Congestion Pricing is a good idea, the Mayor is right the time is now, The plan however needs work.

Overall we're pleased with the proposal to try a pilot of Congestion Pricing and are excited to see ideas that can reduce the negative impacts of automobiles in our city implemented. We however think that as the plan was funded by powerful business interests that there are some built in biases and the plan should be adjusted to benefit the most amount of New Yorkers as possible. Congestion pricing is a sophisticated policy tool and this plan feels more like a hammer to us than a precise instrument. We have offered a number of suggestions that we think can improve the plan and also think that there needs to be an open and inclusive planning process so that all stake holders can have a voice in shaping the plan prior to it being implemented. We fully agree with the mayor that time is now for Congestion Pricing is now and are also cognizant that a larger setback to not than not having a plan to reduce congestion would be to implement the wrong plan. And whether the plan is approved in Albany or not, we should move forward with clarity, purpose and urgency to achieve the goals of congestion pricing. As part of the next phase we would like to see thinking that goes beyond limiting cars by thinking about our infrastructure in new ways to encourage and incubate new mobility ideas. It's important to realize that our goal is not to just limit cars but to design a modern mobility system that allows us move around in a way that is healthier for environment, that is also safe, affordable, easy, reliable-and of course the envy of the world.

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