STATEMENT OF GREG MEYER,
Tri-State Transportation Campaign

On Amendments to 1998-2002 NJTPA Transportation Improvement Program

February 3, 1999

North Jersey Transportation Planning Authority
Newark, New Jersey

Re. DBNUM 98537, "Proposed renovation of rail tunnels beneath Jersey City into motor vehicle tunnels which will enhance access to the Jersey City Waterfront."

Tri-State Transportation Campaign expresses its opposition to project description and amendment to the TIP for the following reasons:

1) Rather than explore general cross-county mobility and congestion issues in Hudson County, the project description in both the TEA-21 eannark statement specifies "roadway," and the proposed TIP description specifies "motor vehicle tunnels," as key elements of the project. The NJDOT general scope of work for the project phrases the project in such a way that private motor vehicles are the implicit users of the right-of-way. Transit and rail freight, both of which have been studied as part of corridor revival in the past, are mentioned only as afterthoughts. In an area with such a high-transit mode split as Hudson County, with massively growing rail freight needs, and with consistently non-attaining air quality, this a regrettable constriction of the project description. The project description and study scope of work should reflect all modal alternatives as equally viable options. "Roadway" and "motor vehicle" should be removed from the project description.

2) The TIP project description lacks the term "study" as the present scope of the project. That the project is in "Study" should be explicit in the project description; without it, an air-quality conformity determination should be performed before the project is amended into the TIP.

3) Because the project is in study, there is no reason why it should be amended to the TIP at this time. It would be better suited to be amended to the candidate study and development pool given its present status. Amending the project to the TIP at this stage risks "grandfathering" it into the TIP so that it will not be forced to undergo air quality conformity analysis at a later date.

Re: DBNUM 53B and 53C: Route 139 rescoping and design.

1) The major rescoping and design work proposed for these projects have potentially major conformity impacts that must be assessed and considered exempt before they are amended to the TIP. Without such an exemption determination, these amendments should not be allowed to proceed.