Could Sustainability Become Unsustainable?

The New York City Economic Development Corporation (NYC-EDC) is soliciting expressions of interest from vendors and consultants regarding provision of services for NYC’s intended Congestion Pricing Electronic Toll Collection (ETC) system.

The assumed, but apparently not absolutely fixed, technological approach for the system is the E-ZPass tag and beacon system that has operated for some years regionally in the New York area and other U.S. regions. This would be complemented with license plate recognition (LPR) cameras to enforce payment from motorists that elect not to use E-ZPass.

At first, this approach this makes some sense:

• E-ZPass is already installed in more than 70% of vehicles that enter Manhattan; hence motorists are familiar with it.
• LPR cameras work with relative accuracy in London, Stockholm, Toronto and other pricing applications.

On the other hand, the E-ZPass approach has drawbacks:

• It is infrastructure heavy. This means high capital expense, intrusion on NYC’s urbanscape, and exposure to vandalism – all of which are acknowledged in the RFEI.
• It is expensive. The costs of such infrastructure will leave less money to fund much-needed transit additions. In London, it cost £2.40 to collect £5; this led to an increase in the congestion charge to £8. (The two congestion zones in London use a similar number of camera gantries as is suggested in the NYC RFEI; we cannot point to a comparison to Stockholm, since this peninsular island required only 18 gantries, less than 10% of what the NYC RFEI suggests.)
• It is complex. The complexity of performing partial tolling in an area that is already partially tolled will require a system of physical, social and monetary exceptions (plus a rebate scheme), whose complexity far exceeds anything in either London or Stockholm.
• It is unambitious. The RFEI traffic reduction goal of 6.3% within the charging zone will do little to ease congestion in NYC. The goal needs to be at least twice that in order to meaningfully impact bus congestion, bike safety and air quality. Without a significant drop in bus congestion and bus delays, congestion charging would not have worked in London and may not work in New York.
• It is inflexible. Once the system is in place, changing the zone boundaries – i.e., adding or removing a street or new area – will be prohibitively expensive. While no system can be perfect, designing-in inflexibility at the start diminishes the value of the investment.
• It is not extensible. When the time comes to congestion-price part of the boroughs, new gantries would have to be installed at a similar, new expense. This is in clear evidence in London where the first zone cost a little under $300M and the second zone cost the same.
• It is not scalable. The NYC system, slated to serve 1.4M vehicles, will serve 9 times more customers then the original London system on an equivalent number of gantries. Hence a gantry failure (say, due to vandalism) will generate 9 times the loss-volume as would a similar failure in London.
• It risks evidentiary gaps. If an enterprising citizen set up a website to report failed gates, motorists without tags may be able to evade charges more readily.

We need to find a better solution.