Fraudulent Data Used in Goethals Bridge DEIS

Commander
First Coast Guard District
Building 135 A
Governors Island NY 10004

Dear Commander:

The following letter and attached table are my official comments on the Staten Island Bridges Program Modernization and Capacity Enhancement Project Draft Environmental Impact Statement and Draft Section 4(f) Statement. I oppose the expansion of the Goethals Bridge because it provides more highway capacity.

Roadway enlargements have several negative impacts, such as:

• increasing dependence on motor vehicles makes it harder for non-drivers to travel,
• increasing air pollution,
• increasing congestion in other locations, which raises the cost of doing business in the region and further exacerbates air quality problems.

Please note, the transportation and air quality analyses in the DEIS are fraudulent. I analyzed the DEIS's 2020 estimates of peak hour traffic using the Port Authority's Staten Island bridges (see attached table). Volumes in the No Build scenario would increase only 1% under the Build alternative and decrease up to 6% under the HOV Build alternative. This is impossible. First, the volume estimates for the new facility are too low and/or the traffic projections for the No Build option are too high. Second, the DEIS's hypothesizes that traffic using the Bayonne and Outerbridge will switch to the Goethals. While some shifts are likely, the space freed on the other bridges will be filled by new trips.

I urge you to reject this project.

Sincerely,

Daniel Convissor

A .wk1 spreadsheet of this table is available

Change in Bridges' Peak Hour Vehicle Volumes
Note: "Totals" represent the change in total capacity and volume on all Port Authority Staten Island bridges. (vph) = Vehicles Per Hour. Vol/Cap = Volume/Capacity
Morning Peak Hour
Build Alternative in 2020 from No Build Alternative in 2020
	Westbound (Northbound)				Eastbound (Southbound)
	Capacity (vph)	Peak Hour (vph)	Vol/Cap		Capacity (vph)	Peak Hour (vph)	Vol/Cap
Goethals	75%	32%	-24%		50%	3%	-32%
Outerbridge	0%	-12%	-12%		0%	-0%	-0%
Bayonne	0%	-21%	-21%		0%	-0%	-0%
Total	24%	1%	-19%		16%	1%	-13%
HOV Build Alternative in 2020 from No Build Alternative in 2020
	Westbound (Northbound)				Eastbound (Southbound)
	Capacity (vph)	Peak Hour (vph)	Vol/Cap		Capacity (vph)	Peak Hour (vph)	Vol/Cap
Goethals	57%	31%	-16%		71%	-2%	-42%
Outerbridge	0%	-14%	-14%		0%	-4%	-4%
Bayonne	0%	-27%	-27%		0%	24%	24%
Total	18%	-2%	-17%		23%	-0%	-19%
Evening Peak Hour
Build Alternative in 2020 from No Build Alternative in 2020
	Westbound (Northbound)				Eastbound (Southbound)
	Capacity (vph)	Peak Hour (vph)	Vol/Cap		Capacity (vph)	Peak Hour (vph)	Vol/Cap
Goethals	60%	1%	-37%		69%	17%	-30%
Outerbridge	0%	-0%	-0%		0%	-5%	-5%
Bayonne	0%	1%	1%		0%	-15%	-15%
Total	19%	1%	-15%		23%	1%	-18%
HOV Build Alternative in 2020 from No Build Alternative in 2020
	Westbound (Northbound)				Eastbound (Southbound)
	Capacity (vph)	Peak Hour (vph)	Vol/Cap		Capacity (vph)	Peak Hour (vph)	Vol/Cap
Goethals	57%	-6%	-40%		53%	16%	-24%
Outerbridge	0%	-5%	-5%		0%	-5%	-5%
Bayonne	0%	-4%	-4%		0%	-15%	-15%
Total	18%	-6%	-20%		18%	0%	-15%

These calculations are based on volumes in Tables 6B-23 and 6B-24.
Staten Island Bridges Program Modernization and Capacity Enhancement Project
Draft Environmental Impact Statement and Draft Section 4(f) Statement.
Coast Guard, US Department of Transportation. May, 1995.