New York City Congestion Pricing is Needed – But Only if Equity Concerns are Taken Seriously

By Sophia Nelson

If the Federal Highway Administration (FHWA) approves the Central Business District Program’s Environmental Assessment, New York City will be the first in the nation to implement a congestion pricing program, something it desperately needs to minimize congestion in Manhattan and to raise revenue for overdue transit improvements, but it must help make transportation easier for those it aims to serve – not harder.

The Metropolitan Transportation Authority (MTA) Reform and Traffic Mobility Act, approved in April 2019, included a tolling program to be facilitated by the MTA’s Triborough Bridge and Tunnel Authority (TBTA).[i] Revenue will be used to fund the MTA’s capital program, which is in dire need of funding for system modernization improvements. While the program has been criticized by certain residents for unfair tolling, the MTA assures the public that the program is necessary for reducing congestion, decreasing travel times, and improving air quality.[ii] However, the success and overall acceptability of the program relies on the MTA’s ability to adequately address real or perceived concerns about inequitable impacts.

According to the MTA, 95 percent of trips to the Manhattan CBD by low-income populations are made using public transit. Further, fewer than one percent of commuters to Manhattan’s CBD are low-income individuals who drive,[iii] meaning only a very small portion of low-income commuters will be directly burdened by the toll.

The program still must consider the effects on low-income car users from the outer boroughs, however. In 2008, FHWA produced a report titled Lessons Learned from International Experience in Congestion Pricing, which summarizes some successes and failures of other congestion pricing programs. This report found that low-income car users are most likely to be negatively affected by congestion pricing.[iv]

To address this, the MTA plans to provide discounts on commuter rail to New York City residents of up to 20 percent. It also agreed to commit funds to improve bus service from Queens to Midtown, which would improve transportation options for car-reliant households.[v] To take it a step further, a portion of the toll revenue could even be used to subsidize taxis or ride-hailing services for first/last mile connections, thereby providing even more mobility for commuters from areas with poor bus or subway access.

The FHWA also notes that the distribution of toll revenues is important for ensuring equitable results. Since all the revenue will be directed towards public transportation expenses – 80% for New York City Transit, 10% for the Long Island Rail Road, and 10% for Metro-North Railroad – the resulting improvements will be directly benefitting lower-income residents and public transportation customers.[vi]

Once the program begins operation, the TBTA is required to collaborate with the City Department of Transportation to produce biannual reports on topics such as impacts to traffic congestion, changes in traffic patterns, and environmental improvements.[vii] However, there is no specific plan to evaluate equity impacts after the program is implemented. The FHWA report notes that, while some cities have designed their policies with equity in mind, post-implementation equity analysis is lacking. Though New York City is completing the required amount of public engagement, planners could take the lead on collaborative planning and on integrating equity into the process. If the public is only engaged before the program has started, how will the city know how it impacts residents’ day-to-day lives down the road?

Another important question about the congestion pricing program: who is going to be exempt? Who is going to be eligible for a tax credit? Who is going to pay the $23 toll every day? As expected, many residents are already attending the public engagement meetings to advocate for exemption. The MTA Reform and Traffic Mobility Act exempts emergency vehicles and vehicles transporting those with disabilities, but who else will be exempt is yet to be decided.[viii] Some say that just residents of the congestion zone should be exempt; others say that suburban commuters or even off-duty police should be exempt. With equity at the forefront, the MTA must listen to these concerns and re-evaluate who should bear the burden of congestion tolls.

If the congestion pricing program is rejected, the MTA would need to cover increased capital costs somehow – which would most likely result in a fare increase. This policy would hurt most New Yorkers who utilize public transit, but especially low-income individuals who are disproportionately burdened by transportation costs. Clearly, New York City needs a congestion pricing program now more than ever. But if New York City wants their program to be a successful model for other cities, equity concerns must be seriously addressed as the details of the program become finalized.


[i]MTA Reform and Traffic Mobility Act,” Pub. L. No. S01509C (2019).

[ii]Central Business District Tolling Program,” MTA, accessed February 17, 2022.

[iii] Ibid.

[iv] K.T. Analytics, Inc., “Lessons Learned from International Experience in Congestion Pricing” (Federal Highway Administration, August 2008).

[v] Matthew W. Daus, “NYC Congestion Pricing Primer: Plans, Policies, Pandemic Impacts & Ideas to Make It Work Better!,” Black Car News (blog), November 2, 2021.

[vi] “Central Business District Tolling Program.”

[vii] MTA Reform and Traffic Mobility Act.

[viii] Ibid.


Sophia Nelson is a first-year Master’s student in City and Regional Planning. Specializing in Transportation Planning, she is particularly interested in urban public transit systems and equitable community engagement. Sophia received her undergraduate degree from the University of Washington, where she studied urban planning and geography. Besides her interests in planning, she loves hanging with her cat, cooking, and tending to her houseplants.


Edited by James Hamilton

Featured image courtesy of Curbed NY

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