NJSC Submits Comments Opposing NJ Turnpike Auth Capital Plan

For Immediate Release
April 3, 2020

Today, the New Jersey Sierra Club submitted comments opposing the New Jersey Turnpike Authority proposed 2020 Capital Improvement Program. The $24 billion capital plan will widen major segments of the NJ Turnpike and GS Parkway. There are a total of 15 highway widening or bridge replacement projects, totaling at least $15.635 billion, although the final costs will be much higher due to budget adjustments and cost overruns.

“The NJ Turnpike Authority’s proposed capital plan is irresponsible, and so are their actions. They held public hearings during the coronavirus outbreak to deliberately limit public participation, which was in direct violation of Governor Murphy’s orders to limit statewide gatherings and stay home. The plan itself will add hundreds of miles of lanes, knocking down homes and promoting overdevelopment and sprawl. What’s worse is that they haven’t demonstrated need or looked at alternatives, and no environmental analysis or EIS have been performed,” said Jeff Tittel, Director of the New Jersey Sierra Club. “This rogue and arrogant authority is out of control. They are being undemocratic, unsafe, and unfair to commuters.”

These projects will add a total of at least 454 lane miles, increasing capacity by 998,800 cars per hour or more, even though research shows that increasing highway capacity does not eliminate traffic congestion. A recent report by Transportation for America shows that although freeway capacity has increased faster than the population in America (42% compared to 32%), traffic delays have increased by 144% since 1993. Some of the projects included in the plan:

In the Meadowlands, they want to widen 9 miles between Newark and East Rutherford, which will cost $4.2 billion and result in 108 total added lane miles. This project will cut through environmentally sensitive wetlands, increasing flooding and resuspending toxic sediment.

They want to widen the GS Parkway between Wall Township and Sayreville for both the Express and Local highway, which will add 108 lane miles and cost $1.35 billion. They will have to build right up against people’s homes, and may end up cutting through hundreds of acres of forests and wetlands.

In South Jersey, they plan to widen the NJ Turnpike between Carneys Point and Mt. Laurel, which will cost $1.1 billion and add 68 lane miles. This will promote development and sprawl in the middle of environmentally sensitive farm fields, bringing in more shopping centers and warehouses in these undeveloped areas.

“The Sierra Club opposes this capital plan because it is the biggest fossil fuel subsidy in the history of the state. Governor Murphy says that he wants to be a national leader in reducing greenhouse gases, but that will be hot air if this proposal is approved. This will increase greenhouse gas emissions and climate impacts exponentially. Vehicle Miles Traveled will increase dramatically, and more sprawl and development from these projects means more cars on the road. Cement and asphalt are some of the biggest contributors to greenhouse gases,” said Tittel. “Many of these projects are in extremely flood-prone areas, especially in the Meadowlands and coast parts of South Jersey. As sea levels continue to rise, these projects will go underwater or be subject to chronic flooding.”

Many of the projects in the capital plan are located in Environmental Justice communities. This means more traffic and pollution in areas that already receive a disproportionate amount of pollution. This undermines Governor Murphy’s Executive Order 23, which states that “all Executive branch departments and agencies should consider the issue of Environmental Justice and make evaluations and assessments with that guidance.” Some of the projects in EJ communities include:

In Jersey City, they want to widen the NJ Turnpike between exits 14 and 14C, which will cost $4.3 billion and add 32 total lane miles. They will be cutting through Environmental Justice communities and increasing traffic and pollution in these areas.

They want to widen sections of the GS Parkway from Woodbridge to Hillside, Hillside to Clifton, and Clifton to Paramus. These projects will cost a total of $4.05 billion and will add a total of 116 lane miles. They will have to tear down homes and apartment buildings in Environmental Justice communities like Hillside, Irvington, Newark, and East Orange, which means mass disruptions. This will also cause traffic jams along one of the most traveled areas on the Parkway.

“This is like the ghost of Robert Moses, a wish list of every bad project that the highway lobby wants. They want to bulldoze communities and open areas up for sprawl and overdevelopment while undercutting the need to expand mass transit in NJ. They’ll have to tear down homes and apartment buildings in Environmental Justice communities like Hillside, Irvington, Newark, and East Orange, which means mass disruptions in those areas. These funds would be better spent helping these communities by putting in a light rail system along the Parkway,” said Tittel. “This is more about Pay to Pave than getting people to work. In Jersey City, they want to spend $4.3 billion to cut through Environmental Justice communities. This means that traffic will back up as people get off onto Route 440 and Columbus Ave and will bottleneck at the Holland Tunnel.”

In March, the NJTA went forward with two public hearings about this capital plan, despite the COVID-19 public health emergency. The Sierra Club asked them to postpone hearings and extend the public comment period because of Governor Murphy’s Executive Order 103.

“Governor Murphy needs to hold the Turnpike Authority accountable and stop this capital plan from going forward. This money would be better spent improving and expanding NJ Transit. Light rail and bus riders should be outraged that this money is going toward building and widening highways instead of fixing our transit system. Out of the hundreds of miles they are adding, not one mile will be for Bus Rapid Transit (BRT) or dedicated carpool lanes. Many of these projects are in flood-prone areas, which means the money spent on them will just wash away with the next storm. The Governor needs to step in and stop this out of control agency from moving ahead with their plan despite the coronavirus outbreak,” said Jeff Tittel, Director of the New Jersey Sierra Club. “These projects will change the shape of New Jersey for decades and will do nothing to fix our traffic problems. If you build them, they will come.”

New Jersey Sierra Club Comments Below:
_______________________________________________

John M. Keller, P.E.
Executive Director
New Jersey Turnpike Authority
1 Turnpike Plaza
P.O. Box 5042
Woodbridge, NJ, 07095
March 30, 2020

Re: NJ Turnpike Authority Proposed 2020 Capital Improvement Program and Toll Adjustment

Dear Mr. John Keller,

These are trying and unprecedented times. The people and environment of New Jersey are facing both the COVID-19 pandemic as well as the longer-term threat of climate change. The U.N. Climate Report warns of a global tipping point by 20301, so it is critical to reduce greenhouse gas emissions as quickly as we can. The 2018 IPCC Report recommends reducing greenhouse gas emissions by 45% by 2030, compared to 2010 levels, and reaching zero emissions by 20502. New Jersey’s Global Warming Response Act calls for 80% reductions by 2050, and Governor Murphy’s Executive Order 100 calls for 100% clean energy by 20503.

In New Jersey, the transportation sector is responsible for 45% of the state’s net greenhouse gas emissions. The 2019 New Jersey Energy Master Plan states that “mobile sources are … the largest cause of ozone precursors in New Jersey and are responsible for 71% of the state’s nitrogen oxides (NOx) emissions, as well as particulate matter”4. In order to reach New Jersey’s clean energy goals of 100% by 2050, as set out by Governor Murphy’s Executive Order 100, it is imperative to reduce the greenhouse gas emissions of the transportation sector as quickly as possible. Unfortunately, the proposed 2020 Capital Improvement Program does the opposite.

The proposed capital program includes road widening projects on both the NJ Turnpike and Garden State Parkway that will increase greenhouse gas emissions and climate impacts exponentially. Increasing highway capacity will mean more traffic and air pollution in a state with some of the worst air quality in the nation. Many of these projects are in Environmental Justice communities, increasing pollutants that are most responsible for smog and ground-level ozone, like NOx, and disrupting communities that should be protected under Governor Murphy’s Executive Order 23. Vehicle Miles Traveled will increase dramatically, and additional sprawl and development from these projects will mean even more cars on the road. This capital plan will undermine the objectives of New Jersey’s Energy Master Plan, which includes drastically reducing New Jersey’s demand for fossil fuels, reducing Vehicle Miles Traveled, and “making the building, transportation, and electricity sectors more efficient”5.

Many of these projects, especially in the Meadowlands and coastal parts of South Jersey, will go underwater or be subject to chronic flooding as sea levels continue to rise. Even though these projects will have drastic environmental impacts, no environmental analysis or Environmental Impact Statement (EIS) have been performed. This plan could be carried out using federal money, but that would require the National Environmental Policy Act (NEPA) process. Instead, toll money will be used to fund these projects as a way to side-step the NEPA process and avoid any environmental reviews. The 2020 capital improvement plan is speeding us backwards into 1950’s traffic jams. This is like the ghost of Robert Moses, paving over open space and Environmental Justice communities to make way for the automobile.

There is no demonstrated need for these projects, and no alternatives have been considered. None of these widening projects will be for Bus Rapid Transit (BRT) or dedicated carpool lanes along the NJ Turnpike and the GS Parkway. New Jersey has not looked at implementing traffic calming measures that have been used successfully in other states, like metered merges on entrance ramps. Other alternatives to highway widening projects include using existing roads for flex lanes to avoid unnecessary highway expansion. These funds could also go toward transit alternatives like expanding freight or regular rail lines across New Jersey to help connect people to jobs and services more effectively. Instead of reducing traffic, this capital plan will increase traffic and air pollution while undermining New Jersey’s progress when it comes to mass transit, electric vehicles and clean energy.

There are fifteen projects in the capital plan that will increase highway capacity by widening sections of the NJ Turnpike and GS Parkway or by widening and replacing bridges. These projects account for $15.635 billion, 65% of the total $24.14 billion capital improvement program budget. They will add at least 454 lane miles which will increase capacity by at least 998,800 cars/hour during optimal times, based on the national average of 2,200 cars/mile/hour6.

The 2020 capital improvement program will add hundreds of lane miles even though research shows that increasing highway capacity does not eliminate traffic congestion. A recent report by Transportation for America shows that although freeway capacity has increased faster than the population in America (42% compared to 32%), traffic delays have increased by 144% since 19937. According to the report, “we are spending billions and we are growing our freeway network – often at a faster pace than population growth – but we aren’t making a dent in congestion”. Similarly, a 2017 paper published by the Transportation Research Record found that for every 1% increase in highway capacity, traffic increases by 0.29 – 1.1% in about five years8. It is clear that instead of reducing traffic congestion and delays, adding highway capacity only moves bottlenecks and overwhelms the roads that the highway feeds into.

These projects will increase air pollution at a time when our country is facing the outbreak of a respiratory disease. Cement and asphalt are some of the biggest contributors to greenhouse gases, and increasing highway capacity will increase air pollution from traffic as well. Assuming that flow rate is 2,400 cars/hour/lane during rush hour and 1,900 cars/hour/lane during optimal times9, these projects will attract 1,089,600 cars/hour during rush hour and 862,600 cars/hour during off-peak times. The average passenger vehicle emits 4.6 metric tons of CO2/year10. This means that the added capacity from these projects will bring in approximately 67,902,376.75 lbs CO2 every hour during rush hour and 53,792,791.97 lbs CO2 per hour during off-peak times.

These projects would increase air pollution in New Jersey by approximately 376,990.5 metric tons CO2 every weekday or 100,535,024.3 metric tons CO2 each year. This is only a narrow snapshot of the impacts of these projects. It doesn’t include the impacts of all of these cars driving on other roads on their way to or from the expanded sections of the NJ Turnpike or GS Parkway. This only accounts for passenger vehicles, and doesn’t include trucks or buses. It also doesn’t include the dozens of smaller projects like extending lanes and fixing interchanges that are also in the capital plan. The projects in the capital improvement program will increase pollutants that are most responsible for smog and ground-level ozone, like nitrogen oxides (NOx), sulfur oxides (SOx), and various types of volatile organic compounds (VOC), all of which are present in gas vehicle tailpipe emissions.

Many of the projects in the capital plan are located in Environmental Justice communities. This means more traffic and pollution in areas that already receive a disproportionate amount of pollution. Governor Murphy’s Executive Order 23 on Environmental Justice states that the DEP “shall take the lead in developing guidance for all Executive branch departments and agencies for the consideration of Environmental Justice in implementing their statutory and regulatory responsibilities” and that “all Executive branch departments and agencies shall consider the issue of Environmental Justice and make evaluations and assessments with that guidance”11. The current proposed capital improvement program will disproportionately affect Environmental Justice communities, and therefore goes against EO 23.

Highway widenings in communities like Hillside, Irvington, Newark, and East Orange will mean that homes and apartment buildings will have to be torn down. Construction will mean more traffic jams and ground-level ozone along one of the most traveled parts of the Parkway. New Jersey already has some of the worst air quality in the nation. The New Jersey Energy Master Plan states that “according to the U.S. EPA’s National Ambient Air Quality Standards (NAAQS), all 21 counties in New Jersey are in moderate or marginal nonattainment of ground-level ozone standards”12. In the 2019 State of the Air report by the American Lung Association, ten counties in the state have ‘F’ designations13. This capital improvement program will widen highways and increase air pollution in counties that already have failing grades, including Monmouth, Middlesex, and Essex County.

The funds allocated for increasing highway capacity would be better spent fixing dilapidated bridges and other parts of the system. They would also be better spent improving and expanding mass transit in New Jersey, especially at a time when ridership is down. These funds could help expand the Hudson-Bergen Light Rail Line, the Monmouth Ocean Middlesex Light Rail Line, and the South Jersey Light Rail Line. These funds could also go toward smart transportation planning like using existing roads for reverse and flexible lanes, fixing interchanges and off ramps, and other ways to improve traffic flow without major highway expansions.

Some of the impacts of specific projects included in the 2020 capital improvement program include:

TPK Mainline Widening Between Interchanges 1 – 2, TPK Mainline Widening Between Interchanges 2 – 3, and TPK Mainline Widening Between Interchanges 3 – 4
In South Jersey, there are three projects that will add a total 34 lane miles to the NJ Turnpike between Carneys Point and Mt. Laurel. These projects will cost $1.1 billion and will pave over environmentally sensitive farm fields, wetlands and streams. This will result in more water pollution, oil runoff, as well as more sprawl in this area. More housing developments and warehouses will be built in the middle of undeveloped farmland because of the increased highway capacity. These projects will mean more truck traffic and air pollution. We believe that instead of reducing traffic, these projects will result in massive traffic delays as cars get to the Delaware Memorial Bridge, creating a bottleneck there.

TPK Westerly Alignment Mainline Widening Between Southern Mixing Bowl – 15W and Replacement of Laderman Bridge and TPK Westerly Alignment Mainline Widening Between Interchanges 15W – 16W.
These projects will widen 9 miles of the NJ Turnpike between Newark and East Rutherford in the Meadowlands. This area is an oasis of nature in the middle of one of the most densely populated areas in the country. We are concerned that these projects will mean more development and pollution in the middle of extremely flood-prone and environmentally sensitive wetlands. The money spent on these projects could wash away with the next storm. According to the Rising Seas and Changing Coastal Storms study, commissioned by NJDEP and prepared by Rutgers University and experts, sea levels in New Jersey could rise as much as 2.6 feet by 205014. With this projected sea level rise, all of these roads will be underwater within decades. These projects will mean more flooding and resuspending toxic sediment, as well as bottlenecks as traffic squeezes onto Route 3 or I-80, through the Lincoln Tunnel or over the George Washington Bridge.

TPK Newark Bay – Hudson County Extension Mainline Widening Between Interchanges 14 – 14A and TPK Newark Bay – Hudson County Extension Mainline Widening Between Interchanges 14A – 14C
There are two projects between Newark and Jersey City that will add 32 total lane miles and will mean replacing or widening 30 bridges. This section of the NJ Turnpike is surrounded by Environmental Justice communities. These projects will mean more traffic and pollution in areas that already received a disproportionate amount of pollution. Instead of reducing traffic congestion, we believe that these projects will cause more congestion as cars exit the Turnpike on Route 440 and Columbus Avenue and will create a bottleneck at the Holland Tunnel.

GSP Mainline Widening Between Interchanges 98-125
In Monmouth and Middlesex Counties, this 27-mile project will add lanes to both the Express and Local sections of the GS Parkway. This will add 108 lane miles and will include replacing or widening 65 bridges. This project will cause major disruptions between Wall Township and Sayreville, cutting through neighborhoods and paving over open space. The construction will have to be right up against peoples’ homes in some areas, and may end up cutting through forests and wetlands in these counties.

GSP Mainline Widening Between Interchanges 129 – 142, GSP Mainline Widening Between Interchanges 142 – 154, and GSP Mainline Widening Between Interchanges 154 – 163
The proposed capital program includes three consecutive projects that will widen 34 miles of the GS Parkway. The first project from Woodbridge to Hillside will add 26 lane miles, the second project from Hillside to Clifton will add 72 lane miles, and the third project from Clifton to Paramus will add 18 lane miles. In order to make space for these projects, the concrete walls on either side of the Parkway in areas like East Orange will have to be moved back at least 45 feet on either side. Homes and apartment buildings will have to be torn down in Environmental Justice communities like Hillside, Irvington, Newark, and East Orange, causing mass disruptions. These projects will take at least 10-20 years to complete, if not longer. Construction from these projects will cause traffic jams along one of the most traveled parts of the Parkway and increase pollution in areas that already suffer from a disproportionate amount of pollution. We believe that the funds from these projects would be better spent helping these communities by putting in a light rail system along the Parkway.

We are concerned that no environmental analysis or Environmental Impact Statement (EIS) have been performed for these projects. We believe that an EIS should be performed for the proposed 2020 capital improvement program because these projects will directly affect the environment in many ways. Hundreds of acres of wetlands, forests, streams and rivers will have to be destroyed. Projects in South Jersey and Monmouth County will promote overdevelopment, which means more shopping centers and warehouses. Projects in the Meadowlands will destroy environmentally sensitive wetlands while increasing flooding and resuspending toxic sediment.

We are also concerned that the public has not had a fair chance to participate in this process. Public hearings were held in the midst of the COVID-19 outbreak. Prior to the hearings, Governor Murphy declared a State of Emergency and a Public Health Emergency in New Jersey and a statewide curfew was put in place from 8pm to 5am. Hearings were live streamed, but this did not allow for public comments. Many people don’t have access to computers or are busy taking care of their families during this public health emergency. It is not possible to do the public’s business when the public are not able to participate.

We believe that the proposed capital improvement program will waste billions of dollars and increase air pollution and traffic in New Jersey. Highway widenings have been proven to be ineffective at reducing traffic congestion. Instead, we believe that this money would be better spent on expanding and improving mass transit in New Jersey. These funds could also go toward smart transportation planning like reverse and flexible lanes and better traffic management. We also believe that this process was unfair to commuters and to the people of New Jersey. Holding public hearings during the coronavirus pandemic did not allow for full public participation.

If you have any questions, or if there is any additional information that I can provide, please feel free to call me at (609) 558-9100.

Sincerely,

Jeff Tittel
Director of the New Jersey Sierra Club

______________________________
1 U.N. Environment Programme. Emissions Gap Report 2019. November 2019. https://www.unenvironment.org/resources/emissions-gap-report-2019
2 Intergovernmental Panel on Climate Change. Global Warming of 1.5°C. October 2018. https://report.ipcc.ch/sr15/pdf/sr15_spm_final.pdf
3 New Jersey Executive Order 100, January 2020. https://nj.gov/infobank/eo/056murphy/pdf/EO-100.pdf
4 The State of New Jersey. 2019 New Jersey Energy Master Plan: Pathway to 2050. January 2020. https://nj.gov/emp/docs/pdf/2020_NJBPU_EMP.pdf
5 The State of New Jersey. 2019 New Jersey Energy Master Plan: Pathway to 2050. January 2020. https://nj.gov/emp/docs/pdf/2020_NJBPU_EMP.pdf
6 Transportation Research Board, National Research Council. Highway Capacity Manual. October 2000.
7 Transportation for America, The Congestion Con. March 2020. http://t4america.org/wp-content/uploads/2020/03/Congestion-Report-2020-FINAL.pdf
8 Milam, R et al. Closing the Induced Vehicle Travel Gap Between Research and Practice. Transportation Research Record: Journal of the Transportation Research Board. January 2017. https://doi.org/10.3141/2653-02
9 Transportation Research Board, National Research Council. Highway Capacity Manual. October 2000.
10 U.S. Environmental Protection Agency, Greenhouse Gas Emissions from a Typical Passenger Vehicle. March 2018. https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100U8YT.pdf
11 New Jersey Executive Order 23, April 2018. https://nj.gov/infobank/eo/056murphy/pdf/EO-23.pdf
12 The State of New Jersey. 2019 New Jersey Energy Master Plan: Pathway to 2050. January 2020. https://nj.gov/emp/docs/pdf/2020_NJBPU_EMP.pdf
13 American Lung Association, 2019 State of the Air. April 2019. http://www.stateoftheair.org/
14 Kopp, R.E., C. Andrews, A. Broccoli, A. Garner, D. Kreeger, R. Leichenko, N. Lin, C. Little, J.A. Miller, J.K. Miller, K.G. Miller, R. Moss, P. Orton, A. Parris, D. Robinson, W. Sweet, J. Walker, C.P. Weaver, K. White, M. Campo, M. Kaplan, J. Herb, and L. Auermuller. New Jersey’s Rising Seas and Changing Coastal Storms: Report of the 2019 Science and Technical Advisory Panel. Rutgers, The State University of New Jersey. Prepared for the New Jersey Department of Environmental Protection. Trenton, New Jersey.

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