Amit Bose, Administrator
Federal Railroad Administration
U.S. Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590
October 20, 2024
Dear Administrator Bose:
On October 2nd, 2024, the railroads (Amtrak, MTA, and NJ Transit), issued a feasibility study related to capacity expansion at Penn Station. The City Club of New York respectfully challenges the conclusions of the recently released "Doubling Trans-Hudson Train Capacity at New York Penn Station" feasibility study, which, despite its depth, prematurely dismisses through-running and other innovative alternatives as infeasible without significantly expanding Penn Station’s physical footprint. We believe this conclusion is unsupported by a full exploration of modern engineering, operational innovations, and community- sensitive construction methods.
Rebuttal of Key Points:
1. Through-Running and Operational Feasibility
The study dismisses through-running based on a flawed analysis of operational and safety constraints, ignoring its successful implementation in cities like Paris and London. Through-running has effectively doubled train capacity in these global cities without the need for large-scale demolition or expansion. The ability to front-load platforms, reduce dwell times, and facilitate efficient train turnover is precisely why through-running remains an optimal solution.
In Penn Station, many of the logistical and operational challenges outlined in the study—such as track reconfiguration or the need to stagger arriving and departing trains—could be mitigated by incorporating phased implementation. The study overlooks smaller-scale, phased redesigns that could modernize existing infrastructure, enhance signaling, and integrate platform-level design solutions. These incremental improvements would enable connection of New Jersey Transit, Long Island Rail Road, and Amtrak services without drastic alterations to the station's footprint.
2. Platform Reconstruction and Track Utilization
The study's assumption that Penn Station requires extensive demolition for wider platforms overlooks proven solutions in comparable high-traffic stations globally. While decommissioning the station for extended periods of time is impossible, construction could be staggered. For example, currently, Track 3 is decommissioned for construction. This has been ongoing for some time, without significant impact to service. Platform reconfiguration would provide a better and safer passenger experience, a critical step as the station, including the platforms, are currently not in compliance with NFPA130. Front-loading platforms—whereby train doors are better aligned with platform edges to enable faster boarding and alighting—would drastically reduce dwell times and improve the station's overall throughput capacity without expanding the physical footprint. Introducing advanced signal systems and track-switching technology could increase track utilization efficiency, addressing many of the bottlenecks the study cites as critical reasons for platform expansion.
3. Constructability Challenges
While the study outlines constructability and safety challenges as major roadblocks for many of the proposed through-running designs, it does not fully explore modern construction techniques that could overcome these challenges. Phased construction approaches, similar to those employed in high-traffic stations around the world, could incrementally upgrade Penn Station’s capacity without large-scale disruption. Using cut-and-cover methods, prefabricated structural components, and carefully sequenced phased construction, it is possible to upgrade platforms and tracks while minimizing disruption to daily operations. This approach could allow Penn Station to increase capacity without large-scale demolition and displacement, especially in critical areas that hold cultural significance, such as the Block 780 neighborhood (the city block immediately south of Penn Station, bounded by Seventh and Eighth Avenues and West 31st and 30th streets).
4. Economic Benefits and Induced Growth of Through-Running
Through-running offers numerous advantages that extend beyond mere operational improvements. Economically, through-running would generate induced growth by significantly increasing connectivity and economic potential of the greater New York metropolitan area. Environmentally, it contributes to reducing carbon emissions by encouraging higher transit ridership and alleviating congestion, aligning with the region's sustainability and climate objectives. Furthermore, it presents significant cost savings compared to large-scale demolition and expansion. By leveraging existing infrastructure and integrating modern rail technologies, through-running allows for more efficient capital investments focused on platform reconfiguration and operational upgrades, making the process less disruptive than a complete station rebuild.
In addition to environmental and financial benefits, through-running enhances
regional connectivity and transit equity. It supports the long-term vision for the
Northeast Corridor by fostering seamless connections across the network and
preparing it for future demand increases. As cities worldwide embrace integrated, high-capacity transit systems, New York must remain competitive. Moreover, through-running improves accessibility for historically underserved communities, ensuring that the advantages of increased capacity are distributed more equitably. Given the urgency of addressing congestion and operational challenges, implementing through-running is essential for maintaining New York’s leadership in transit innovation and ensuring long-term mobility and economic competitiveness.
5. Community Engagement and Transparency: A Call for Inclusivity
The process of public engagement around the southern expansion has, unfortunately, fallen short of the inclusive and transparent approach that such a significant project demands. The exclusion of representative voices calls into question the fairness and transparency of the engagement effort. The members of the recently-formed Station Working Advisory Group [SWAG] does not include an adequate representation of all stakeholders, particularly neglecting to consult/ include those who hold opposing views on the expansion. Most concerning is the absence of any representation from residents and owners whose homes and businesses are directly threatened by the proposed demolition.
The lack of meaningful representation for the residents of Block 780, many of whom face the threat of displacement, is particularly egregious. Block 780, for example, houses rent regulated seniors, and tenants. It is also the home of small businesses and cultural spaces like music rehearsal studios. This lack of inclusion undermines the integrity of the decision-making process and diminishes the voices of those most impacted. In a redevelopment of this scale, it is essential to ensure that the people who are most affected have a meaningful role in shaping the outcomes. A truly democratic process requires that diverse perspectives, especially from local residents, be actively sought out and considered.
The only path forward is through cross-acceptance, where all perspectives—especially those at risk—are genuinely considered and incorporated. Moving forward, we need a process that engages the public in a meaningful way and places community input at the forefront of decision-making. A redevelopment of this magnitude should not be guided by predetermined outcomes but rather informed by the needs, concerns, and aspirations of those who will live with its consequences. A more transparent and inclusive process is not just preferable—it is essential.
6. Gateway Program Alignment
The study correctly identifies the importance of the Gateway Program in enhancing regional mobility but fails to align Penn Station capacity expansion efforts with other existing regional rail improvements. The Trans-Hudson Tunnel was conceived as a project for redundancy, resiliency, and reliability, rather than addressing capacity needs, missing the opportunity for a more comprehensive approach. The projects (Hudson River Tunnel, PennR, PennX), segmented into smaller but entirely interdependent parts, do not allow for comprehensive planning. A more integrated approach, in which through-running is prioritized across the Northeast Corridor, would help meet the Gateway Program’s long-term goal of doubling capacity between New York and New Jersey without necessitating major footprint expansion.
7. Through-Running Must Be Included in the NEPA Process
The exclusion of through-running from the National Environmental Policy Act (NEPA) framework not only undermines the study’s legitimacy but also deprives the public of a fair, legally mandated comparison of all viable alternatives. The study in question was conducted outside the NEPA framework. Therefore, it lacks the legal standing to disqualify through-running from further consideration. It is essential that any decision-making process adheres to NEPA’S codified standards, ensuring transparency, public input, and a thorough assessment of all viable alternatives. We therefore formally request that through-running be included and thoroughly evaluated as a core alternative in the Environmental Impact Statement (EIS) process. This will allow for a fair comparison of options and will ensure that the most effective, sustainable, and forward-thinking solution is chosen.
Conclusion
We urge USDOT to reject the premise that expanding Penn Station's footprint
is the only solution. Through-running, coupled with platform reconfigurations, phased construction, and advanced rail technology, represents a more sustainable alternative to large-scale demolition.
Furthermore, the study was conducted outside the NEPA framework and cannot be used to disqualify through-running from further evaluation. We formally request that through-running be evaluated as a core alternative in the NEPA Environmental Impact Statement (EIS) process. This alternative, along with platform reconfigurations and phased construction, would meet the region's long-term transit needs without destroying residential communities and small businesses, and without significantly expanding Penn Station’s footprint. Any proposal that endangers local communities or displaces residents and businesses should be met with caution. We also call for a more inclusive public engagement process that gives a voice to the residents and businesses most affected by these plans. We urge USDOT to ensure that these issues are addressed fully in the EIS (Environmental Impact Statement) process, safeguarding both Penn Station’s future and the communities that surround it.
We appreciate your consideration of our concerns and stand ready to work with
USDOT, Amtrak, and the Railroad Partners to ensure that Penn Station becomes the world-class transportation hub the northeast corridor deserves—without compromising the integrity of the communities that surround it.
Sincerely,
Layla Law-Gisiko Liam Blank
President Chair Transportation Committee
The City Club of New York The City Club of New York
CC:
Hon. Pete Buttigieg, Secretary, U.S. Department of Transportation
Hon. Charles Schumer, Senate Majority Leader
Hon. Jerrold Nadler, Congressman, NY CD12
Hon. Liz Krueger, Finance Committee Chair, NY State Senate
Hon. Leroy Comrie, Chair Corporations Committee, NY State Senate
Hon. Tony Simone, Assembly Member AD75
Hon. Steven Otis, PACB Representative, Assembly Member
Hon. Erik Botcher, Council Member CD3
Marlys Osterhues, Federal Railroad Administration
Stephen Gardner, AMTRAK
Tony Coscia, Amtrak
Janno Lieber, CEO, MTA
Kevin Corbett, CEO, NJ Transit
Alicia Glen Co-Chair Gateway Commission
Balpreet Grewal-Virk Co-Chair Gateway Commission
Full Letter