To Mr. Mark Tiano, PE and Paul Lo Gallo, PE, New York State Department of Transportation: 

The Route 17 Transportation Corridor Planning and Environment Linkages Study (Route 17 PEL)—is based on unevaluated assumptions and contains some serious defects. The New York State Department of Transportation should not finalize the PEL until these deficiencies are addressed:

• NYSDOT did not take into account the well-documented traffic phenomenon known as “induced demand”—if NYSDOT widens Route 17, it’s likely that traffic will increase. In addition to adding more cars, widening the highway is likely to cause more traffic, create congestion, contribute to urban sprawl, spur the release of millions of tons of CO2 emissions, and result in a six-lane highway running straight through the heart of the Catskill Mountains.
• NYSDOT did not evaluate the impact of additional traffic on climate pollution as required under the Climate Leadership and Community Protection Act (CLCPA), New York’s landmark climate law. While a thorough analysis may not be required at this stage in the process, failing to address this early and thoroughly sets the entire review on the wrong path. We are in a climate crisis—New York needs to turn away from fossil-fuel dependent projects;
• The Route 17 PEL study did not sufficiently analyze alternatives to widening Route 17, and therefore takes consideration of other approaches to traffic management off the board. The alternatives analysis must be revisited and redrafted to include a robust consideration of other options.

Please revise the present draft to address these issues from the start—the region and the state deserve a more thorough analysis before a project with this scope and cost is advanced.

Sincerely,