I’ve wanted to write an essay for a while on the ongoing plot to spend a billion dollars or more to convert the pollution-spewing Kensington Expressway through Buffalo’s east side into a pollution-spewing tunnel with some grass and tree plantings on top (the so-called “capping” plan), but I never found the time to get it done. Since then, the Buffalo Rising blog has posted a very good three-part series by Edward Marriott on the state DOT’s disastrous plan, which has now been fast-tracked and dressed up in social justice platitudes in the aftermath of last year’s racist mass murder at the Jefferson Avenue Tops. So, instead of the essay I had been thinking of, what I’m posting here is an adapted version of the comment I submitted to the NYS DOT.
While at this point it seems like the 33 tunnel is a done deal – local politicians are firmly behind the plan to continue polluting the east side with highway effluent and the neighborhood groups that have advocated removing the 33 for decades have been beaten into acquiescence by the state government’s refusal to consider any option that would reduce the number of vehicle miles traveled – it is still worthwhile to speak out against what is shaping up to be a generation-defining failure of governance. You can (and should) submit a comment opposing the 33 tunnel plan here.
The comment I submitted (edited to replace footnotes with hyperlinks) is as follows:
The Department of Transportation must give complete and fair consideration of removing the Kensington Expressway (Route 33) entirely and restoring the street grid that was destroyed in order to construct it.
The objectives of the Kensington Expressway project must be modified to also include improving the air quality and health outcomes in the neighborhoods that have been harmed by the Kensington Expressway since its construction, especially since advocates of the Department of Transportation plan have repeatedly made misleading public comments suggesting that turning the expressway into a tunnel will reduce pollution in the surrounding neighborhoods, when that assertion is not supported by any studies or reports that have been made public. It is entirely inadequate that project objectives be limited into “enhanc[ing] the visual and aesthetic environment of the transportation corridor” and “maintain[ing] the vehicular capacity of the existing transportation corridor” and not include improving the air quality and reducing pollution for people living adjacent to the expressway.
Further, removal of the expressway and re-establishment of the former parkway must be studied as an alternative in comparison to no-build and tunnel options when the lead agency completes an environmental review for this state action and such review should include the public health impacts of removing the highway compared to converting highway into a tunnel as well as the no-build option.
Removing the Kensington Expressway and re-establishing the former parkway deserves to be seriously considered – including and especially during environmental review and through participatory public hearings – for a number of reasons:
Removing the expressway is the only way to reduce automobile pollution and attendant disease in the neighborhoods on both sides of the expressway;
The Kensington Expressway was built for a city of twice the population that Buffalo currently has and maintaining its level of capacity is unnecessary;
Removing the expressway and restoring the former parkway is in far better alignment with state climate goals than preserving an urban highway for generations to come; and
Removing the expressway and restoring the former parkway will cost significantly less than constructing a tunnel, especially if air filtration is to be installed.
Removing the expressway is the only way to reduce automobile pollution and attendant disease in the neighborhoods on both sides of the expressway
First, removing the Kensington Expressway is the only option of any of the 10 presented by the DOT that will reduce automobile pollution and the disease that it causes in the neighborhoods impacted by the expressway.
In her January 2022 State of the State address, Governor Hochul declared her intent to “reverse the damage that was done more than half a century ago” by the construction of the Kensington Expressway. Beyond its aesthetic and mobility impacts, the Kensington Expressway has been a major source of damage to the health of people living nearby. The health impacts of the highway have driven activism in the neighborhood for decades and has been acknowledged by elected officials as well as by Department of Transportation studies.
In a May 2022 press conference about the expressway, Rep Brian Higgins referenced “environmental injustices that have negatively impacted low-income communities nationwide by way of increased traffic and pollution which led to many health complications (cancers, lupus, asthma).” State Assembly Majority Leader Crystal Peoples-Stokes announced environmental health as a priority for the redesign of the expressway at the same press conference.
A 2014 study on the expressway prepared by the UB Regional Institute funded by the Department of Transportation, researchers noted (internal citations omitted):
To date there has been several studies that point to the adverse impacts of highways on nearby residents’ health. Road traffic is a major source of air pollutants such as nitrogen dioxide, carbon monoxide, particulate matter and volatile organic compounds which have major negative impacts on the health of children and adults who live in close proximity to them. There is also considerable epidemiologic evidence on the relationship between ambient air pollution, morbidity due to respiratory diseases, and chronic respiratory disease in school aged children.
[...]
Locally, a study was carried out in Erie County that has linked asthma and other breathing disorders of children and adults to the effect of highways near residential areas. The results of this study also estimated that children living within 200 meters of roads with heavy truck traffic or a high density of automobile traffic have a higher risk of asthma hospitalization.
Because of the documented harm from automobile pollution and policymakers stated intent to “reverse the damage” (emphasis added) done by the construction of the Kensington Expressway, removing the expressway must be considered as an option.
Merely constructing air filtration systems while retaining the highway is not adequate. Beyond the expense (discussed below), according to Slide 16 in the Department of Transportation’s presentation, filtration systems will remove some carbon monoxide and nitrogen oxides from the pollution ventilated from the highway, but these are not the only pollutants that cause harmful health impacts. Volatile organic compounds and particulate matter, as acknowledged in the DOT’s 2014 expressway study, also cause significant health problems and would be better mitigated by removing the expressway than by converting it into a tunnel whose effluent will still pollute the neighborhood.
Further, as acknowledged in the DOT’s 2022 presentation, the air filtration technology that is under consideration has never been deployed in the United States and will require significant energy inputs as well as traffic and upkeep to maintain and to haul away waste. The health of generations of neighborhood residents now and into the future should not be gambled on unproven and expensive technologies that, even if successful, will require even more resource and traffic inputs to operate.
The simpler option of removing the highway must be studied and given a fair hearing.
The Kensington Expressway was built for a city of twice the population that Buffalo currently has and maintaining its level of capacity is unnecessary
According to US Census Bureau data, Buffalo’s population was 532,759 in 1960, two years after construction on the Kensington Expressway began. In 2020, the population of Buffalo was 278,302, less than 53% of the population of the time when the highway was built. The population of Erie County has also declined, though not as much, from 1,064,688 to 954,236. As Buffalo has shrunk at a faster rate than Erie County, local jobs have shifted out to the suburbs, reducing the need for a high-speed expressway to bring commuters into the city.
All of these facts render the Kensington Expressway overbuilt for the population we have. Whether there ever was a need for the expressway in the first place considering the enormous costs it has imposed is debatable, however the fact that currently there is not such a need is not. With far fewer people to use it, maintaining the current vehicular capacity of the Kensington Expressway is not a legitimate goal in the first place and certainly does not override other public policy objectives, especially public health.
Just as it is well-established that building new highways and adding additional traffic capacity creates new demand and causes more vehicle miles to be traveled, so does removing urban highways actually reduce the number of vehicle miles traveled.
In sum, there is no need for a highway of the size of the Kensington Expressway cutting through the heart of Buffalo. It is overbuilt for our population and is causing more car trips to be made, which in turn cause increased pollution, worse climate change, and more motor vehicle accidents.
Removing the expressway and restoring the former parkway is in far better alignment with state climate goals than preserving an urban highway for generations to come
New York State passed one of the most ambitious climate change laws in the United States in 2019 with the passage of the Climate Leadership and Community Protection Act. While that act is focused primarily on carbon pollution from the electrical generation and transmission sector, it is unambiguously the intent of voters and policymakers to use public resources to slow and mitigate climate change.
With that in mind, it is inexplicable that slowing and mitigating climate change – like reducing other pollutants – has been omitted as an objective of the Kensington Expressway redesign project.
The Department of Transportation, in its environmental impact study as well as in its holistic consideration of options for redesigning the expressway, must consider the climate impacts of removing the expressway in addition to studying the impacts of concealing the expressway under a tunnel and of doing nothing.
There is considerable reason to believe that removing the highway will be the best option from a climate perspective.
As mentioned above, a reduction in vehicular capacity will likely induce a reduction in demand and thus a reduction in overall vehicle miles traveled, which will result in reduced carbon emissions.
Further, removing the highway and restoring the original parkway and street grid that existed prior to highway construction will be far more conducive to an expansion of public transit, especially critically needed crosstown public transit in Buffalo, which will further drive down the number of vehicle miles traveled and the carbon and other pollution that accompanies increased auto travel.
Finally, even in an hypothetical future scenario where all internal-combustion automobiles have been replaced with electric cars, reducing the number of vehicle miles traveled and demand for personal automobiles will still be of critical importance. Building and maintaining roads and manufacturing cars all rely on fossil fuel inputs beyond just the fuel burned for propulsion: asphalt and plastic are both derived from petroleum, and cars still move on rubber tires that create particulate pollution that is a health hazard.
From the long-term perspective and considering the social imperative to mitigate climate change, removing the expressway when there is the money and political will to invest in redesign is clearly the best option and must be seriously considered alongside tunnel options.
Removing the expressway and restoring the former parkway will cost significantly less than constructing a tunnel, especially if air filtration is to be installed
Finally, judging from the costs of other highway removal projects and cost estimates for proposed tunnel conversion options, removing the Kensington Expressway appears to be far more fiscally prudent than preserving it.
The cost of converting the Kensington Expressway redesign has ranged from an estimated $600 million in a 2012 Department of Transportation study to $560 million in the 2014 UB Regional Institute study to the proposed $725 million for a tunnel with air filtration in the most recent public documents.
By comparison, removing a 0.67-mile segment of Rochester’s Inner Loop cost only $22 million, just 3% of the $725 million projected cost of converting a slightly longer segment of the Kensington Expressway into a tunnel with air filtration.
From a financial standpoint, this would be what is commonly referred to as a “no-brainer”. By removing the highway rather than building an enormously expensive tunnel, hundreds of millions of dollars of the $1 billion allocated for the project could instead be used for rebuilding homes and businesses lost to the construction of the expressway, establishing new public transportation routes, creating jobs to maintain new trees and greenscapes, or any number of other valuable public investments.
For all of the above-stated reasons, it would be a blunder of astronomical proportion to continue pursuing a tunnel project for the Kensington Expressway without giving serious study to removing the highway altogether. Removing urban highways has proven to improve communities in the past, and it has been a major error to pre-emptively remove this option from the table in the case of the Kensington Expressway. The interests of public health, New York’s climate goals, and sound public investment all demand that the Department of Transportation give highway removal a fair hearing.
To do otherwise would constitute (another) deep betrayal of east Buffalo, belie the statements of the public officials who have declared their intent to remedy the harms that have been inflicted by the expressway over the past three generations, and consign future generations to more disease and poor climate.
The NYS DOT’s comment form about the Kensington Expressway project is available here. You can also email a comment to Kensingtonexpressway@dot.ny.gov.