Steven Woods Operations Fellow, The Center for Post Carbon Logistics.
Andrew Willner Executive Director, The Center for Post Carbon Logistics,
Abstract
There are few, if any, reasonable arguments for continuing Manhattan’s Pier 6 operation as a primarily recreational and non-water dependent facility given the direct and indirect benefits of its conversion to a hub for low-carbon maritime freight. In light of the New York City Economic Development Corporation’s Request for Proposals for operation of the Downtown Manhattan Heliport for up to the next 20 years, it is critical to look at this waterfront and water-dependent infrastructure in the context of future maritime and multi-modal transport systems for the City of New York. With the City’s imperative to face the climate crisis and reduce the social harms of the current truck-based delivery systems of the New York Metro Area, it makes little sense to continue the present conventional rotary-wing flights from this facility which could be put to far better use as a maritime and cargo transport hub for Lower Manhattan. This policy brief covers the major points of this argument, including impacts from carbon emissions and other sources of water and air pollution, public health and safety, economics, transport systems capacity, and public trust doctrine and working waterfront considerations.
Keywords: Climate Policy; Sustainable Transportation; Urban Aviation; Urban Planning; Transportation Systems; Public Trust Doctrine; Working Waterfront.
The NYCEDC plays a leading role in planning for and determining the sustainability and efficiency of New York City’s transportation infrastructure, energy systems, and buildings. The City and NYCEDC’s interest in addressing the City’s aging and overburdened freight system, including through the activation of a marine freight distribution network across the City’s waterways, has been documented extensively across various strategic plans, including Delivering Green, Delivering NY, Freight NYC, Blue Highways RFEI, DockNYC RFEI, and the City’s long-term strategic climate plan, PlaNYC. Throughout these plans, the City has committed to creating opportunities for marine freight by “modernizing its marine terminals, expanding waterfront access to maritime shippers, and supporting private sector marine highway initiatives.”
In November 2023, the City released a Request for Proposals (RFP), through the NYCEDC and Department of Small Business Services (SBS), seeking an “Operator” for the Downtown Manhattan Heliport (“DMH” or “JRB”)[1] at Pier 6 for one five-year term, with up to three options for five-year conditional renewals at the discretion of the NYCEDC and the City. The RFP specifically seeks proposals that will “(i) support aerial use of the site, including but not limited to electric vertical take-off and landing (eVTOL) aircraft and helicopters, subject to Federal Aviation Administration (FAA) regulations and the City’s efforts to maintain quality of life for its residents, (ii) invest, install, and activate the necessary support infrastructure to facilitate eVTOL use, and (iii) build out, activate and support secondary maritime freight usage and micro-distribution at the site to advance the City’s programs.” Altogether, NYCEDC intends to realize the City’s vision for Pier 6 as a “first-of-its-kind hub for sustainable transportation and deliveries.”
This RFP marks a critical opportunity for NYCEDC to transform Pier 6, a coveted piece of City-owned waterfront real estate, to better align with the City’s objectives for marine freight, sustainability, and equity. As one of the last working piers in Lower Manhattan, Pier 6 is a crucial maritime asset in the City’s efforts to revitalize its working waterfronts and decaying freight system. While the 2023 RFP for Pier 6 includes provisions for some marine freight usage at the site, the service is secondary to existing heliport operations.[2] In pursuing this vision the City is foregoing the opportunity to realize Pier 6’s full potential as a marine freight terminal while still preserving heliport capacity for essential flight operations. This plan is a perilous departure from the City’s purported green freight and sustainability objectives.
Pier 6, or DMH, is a critical piece of public waterfront infrastructure in Manhattan. The City’s proposed use for which starkly deviates from its expressed freight system and sustainability goals. This misalignment is a result of the City’s oversight of 1) negative externalities produced by each potential use-case of City assets, particularly those rooted in the status-quo; 2) the economic potential of alternative use-cases that reduce or eliminate negative externalities for all New Yorkers; and 3) the potential positive externalities experienced by all New Yorkers as a result of these alternative use-cases of City assets.
Understanding of two critical concepts are required in this discussion: “Path Dependency” and “Leverage Points”. “Path Dependency” refers to the idea that decisions made today will continue to have an effect for many years to come (up to 20 in the case of this RFP), and may prevent more beneficial actions. “Leverage Points” for change are generally acknowledged to be more effective the more fundamental their effects. An example leverage point may be a regulation encouraging fuel efficiency. This is a shallow leverage point, because it affects only the efficiency of a vehicle, and does not address many other consequences of using cars and trucks, such as roadway congestion, fossil fuel dependence, and so on. A ban on ICE vehicles is a deeper leverage point, because it eliminates many of the consequences of vehicle emissions. The deeper a leverage point, the bigger its effect on both behaviors and outcomes, but the more fundamentally it must affect the system it is intended to change. Changing the use of the Pier 6 to a maritime hub is a far deeper leverage point for a sustainable transportation transition than adopting eVTOL operations, as it completely changes the incentives and mindset for the use of the space toward more sustainable and impactful uses.
The analogy of the “Futures Cone” ties both of these concepts together somewhat more coherently. If a cone from this point in time is imagined extending out to a given horizon, for example, the year 2050, there are various possibilities currently open, ranging from the absurdly improbable at the outside of the cone, to the planned path at the centerline. Somewhere on the wide, and distant end of the cone (2050) is a place which is a desired future, where the planet remains habitable, New York City is not below sea-level, and persistent issues of justice have been addressed. Every decision made from here to the end of the cone points the ship to a different point in that future, and as the ship is moving forward, there will be a point where the desirable future cannot be reached by turning anymore. By navigating within that cone of possibilities, one reaches the future, but must be careful to point their decisions on the limited number of paths which can lead to the desired outcome. This is similar to the probability and possibility trees in the game of chess narrowing as each move is made.
It must be remembered that we are playing chess, not checkers in the climate crisis. What resources are committed, and how, in the immediate future affect the remainder of the game. Every move made closes off future options which, if the player is not paying attention, may be far more important than the move chosen. An intelligent chess player does not throw their queen away capturing a pawn if they can avoid it. However, that is exactly what the City’s current plans do by committing Pier 6 to continued helicopter operations when a far better use is available.
The decision for the next five years will create Path Dependency on uses of Pier 6 through the full potential 20-year term of the new concession agreement. Alternatively, if a decision is made to depart from the harmful patterns of Pier 6’s past 64 years as a heliport, the door is opened to a far more sustainable, economical, and environmentally just future for the City’s freight system. By departing from a socially harmful use, toward an inherently quieter, less polluting (i.e., carbon emissions),, and safer use of Pier 6 with more job creation, the City can claim meaningful leadership on the climate crisis, while improving quality of life for New Yorkers.
Freight System Challenges
New York City’s freight system handles 365 million tons of cargo entering, leaving, or passing through the City, approximately 90% of which is carried by truck. By 2045, local freight volumes are expected to grow 68% due to population and demand growth. The roads, bridges, and highways that carry freight into the City are at or over capacity.
Roadway congestion problems are endemic in the New York Metropolitan Area (NYMA): four of the top 50 congestion hotspots in the United States are in the NYMA. Taking the lead as the worst truck bottleneck in the U.S. is I-95 at SR 4 in Fort Lee, NJ–the stretch of highway leading into the George Washington Bridge from New Jersey. This is followed by the I-278 Belt Parkway in Brooklyn, NY in 27th place, I-495 in Queens, NY in 36th place, and I-678 in the Bronx, NY at 46th place. Cargo trucks conveying freight to and from NYC are left with little choice but to accept these congestion bottlenecks as an additional cost of doing business. These costs take the form of delayed deliveries, wasted fuel, and extra labor costs.
The City is not only facing surging cargo volumes, existing transportation infrastructure is in a state of severe disrepair. Most of the freight infrastructure in New York City today was developed in the early 20th century and is increasingly obsolete. The City’s outdated infrastructure is in dire need of renovation beyond routine maintenance and repair. For example, a 2019 study conducted by TRIP, a national transportation research nonprofit, found that only 28% of New York City’s bridges were in “good” or “better” condition, while 64% warranted ratings of “fair” condition and the remaining 8% were deemed “poor/structurally deficient.”[3]
The City is tasked with a triple mandate to meet this challenge: increase freight capacity, repair existing transportation infrastructure, and transition the entire system to a net-zero greenhouse gas (GHG) emissions operation. The City must tackle the tremendous challenge ahead of rising freight volumes within the effectively fixed capacity of existing land-side transportation infrastructure. These urgent freight system issues are well known and form a central pillar of the City’s policy programs and NYCEDC’s strategic initiatives. The City’s stated freight system goals are heavily geared towards prioritizing a modal shift to maritime channels on the City’s Blue Highways, supported by micro-distribution services and micro-hubs. In this vision, zero-emissions vessels will convey freight directly to the shorelines in all five New York City boroughs. This modal shift can significantly reduce the number of trucks needed to convey freight into and around the City.
The Working Waterfront: Marine Freight
The City has taken a number of steps to realize its freight vision. New York City’s Working Waterfront contains a range of water-dependent uses including maritime and maritime support operations, marinas, waterborne transportation, and commercial and recreational boating. It also contains industrial and municipal uses many of which do not use or depend upon the water for their operation. Although reduced in size and economic significance, these working waterfront activities still play an important part in the City’s economy. New York City’s Comprehensive Waterfront Plan seeks to promote water-dependent and industrial waterfront uses in areas that are well-suited to them. Specifically, the working waterfront goals are to:
- retain sufficient waterfront land to accommodate existing, and attract future industrial, maritime, municipal, and other working waterfront uses;
- identify infrastructure improvements and other investments necessary to sustain these uses;
- identify opportunities to encourage ferries, excursion boats, marinas and other water-dependent uses;
- encourage waterborne transportation of goods and people, and maximize intermodal linkages;
- ensure that working waterfront uses are developed in an environmentally sound manner; and,
- provide public access where appropriate and feasible.
The plan for the working waterfront classifies working waterfront uses, analyzes their geographic concentration and dispersion, and projects future needs. The Pier 6 DMH facility is included in a Priority Marine Activity Zone (PMAZ), which reinforces its role as a key working waterfront site.[4] Pier 6 is a critical site for NYC’s future marine highway system. It is one of the few piers in Manhattan that is both well-located and can be immediately converted to support marine freight and micro-distribution use at scale. Historically, Pier 6 was built by the City’s Department of Marine and Aviation as a cargo pier, but was converted to a heliport in 1960, servicing the major international airports in the NYC area.
To create a more “sustainable, equitable, resilient, and efficient freight delivery system,” NYCEDC was awarded a $5.16 million grant by the U.S. Department of Transportation Maritime Administration (MARAD) under its “Marine Highway” program in October 2022. The funds will go towards “upgrad[ing] and improv[ing] six harbor landings [to] strengthen critical freight movement on waterways by enabling these landings to dock watercraft and prepare cargo for local delivery.” Pier 6 in Lower Manhattan is one of the harbor landings covered by this grant.
Pier 6 services up to 29,651 non-essential helicopter flights annually, representing over 95% of the facility’s total annual flight volume. Heliport operations at Pier 6 have become increasingly problematic for the City’s residents in recent years due to the significant negative externalities produced by conventional helicopters, including incessant noise pollution, GHG emissions, and harmful air pollution. Because the majority of Pier 6 flight volumes are for non-essential tour flights, the negative externalities produced by these flights are indefensible. The 2023 RFP for Pier 6 relies on technological advancements in sustainable aviation, namely eVTOL aircraft, to deliver significant improvements to noise and air pollution generated at the site. This strategy insufficiently addresses the negative impacts of the heliport on surrounding communities and fails to capture the benefits of marine freight services. The plan for Pier 6 expressed in the RFP prioritizes status quo helicopter operations, portraying the pier exclusively as a primary heliport facility, ceding a limited area to secondary maritime freight capabilities subordinated to heliport activities.[5] It is a clear demonstration of the fundamental disconnect between the NYCEDC’s stated strategies and goals and its deployment of City assets.
Development Objectives for the Deployment of City-Owned Assets
NYCEDC is dedicated to strengthening the City’s economy to promote equity, sustainability, andinnovation. These guiding objectives serve the greater responsibility of NYC’s government to prioritize improving the quality of life of all New Yorkers. NYCEDC is the City’s largest landlord and bears responsibility for ensuring it leverages the City’s properties and assets to optimize gains for the benefit of New York’s Citizens and the City’s bottom line.
This larger public service duty and NYCEDC’s specific objectives should govern the City’s decisions and actions, including those made when acting through NYCEDC. Accordingly, this logic would dictate that the City pursues innovation opportunities which promote the following Development Objectives:
- Greater equity across the NYC community
- Generate benefits for many people over benefits for few;
- Improve the quality of life for disadvantaged communities over wealthy, privileged communities and populations;
- Are accessible to everyone, with few barriers to entry over accessible to few, with high barriers to entry;
- Are less expensive and thus affordable for many over expensive and thus inaccessible to most, except for the wealthy;
- Environmental sustainability and the transition to a carbon-constrained future, positioning NYC as a global Climate Leader
- Prioritize energy efficiency over energy intensity;
- Prioritize low infrastructure intensity techniques over high infrastructure intensity techniques
- Generate certain and immediate GHG emissions reductions over speculative and long-term emissions reductions;
- Generate annual revenue while maximizing (a) and (b)
These Development Objectives are the basis for assessing NYCEDC’s current plans for Pier 6 in the 2023 RFP and the maximal maritime use of Pier 6. NYC cannot continue delaying real opportunities to achieve large-scale emissions reductions and equity improvements. Cities around the globe have already surpassed critical climate tipping points–New York City is no exception. In order for the City to emerge as a global climate leader, it must take immediate and widespread action to align critical decisions with existentially imperative climate, equity, and economic goals.
The current vision laid out for Pier 6 in the 2023 DMH RFP exhibits a staunch adherence to the site’s existing condition as a heliport predominantly used for non-essential flights. It is only through the active inclusion of externalized impacts in scenario valuation methods that the City can bring real innovation and success of its overarching priorities.
Helicopter flights at pier 6 can be broken down into essential and non-essential flights. Essential flights include police or fire department helicopters, emergency medical aircraft transporting organs or injured people, and Marine One landings for the President of the United States or other high-security diplomats. Non-essential flights include private charter flights to nearby airports or Long Island and tourists on 15-30 minute sightseeing loops around Manhattan. Most estimates place the number of essential flights around three each day, or less than 5% of total flight volumes, leaving the other 95% of flights at Pier 6 for non-essential tourist flights. The City allows no more than 29,651 tourist flight operations (TFO) at Pier 6 annually, which includes a breakdown of volume caps by month, due to public complaint and discontent with helicopter operations.
Non-essential tourist flights have been the main point of contention for New Yorkers forced to face incessant noise disruptions from these flights. Despite the strong and enduring opposition the helicopter tourism industry has faced in the City and surrounding communities from aggrieved residents and politicians, the City has been slow to engage in real solutions to control non-essential helicopter traffic.
Industry lobbyists contend the revenue received from tourism and other nonessential flights is critical for the survival of the overall heliport operation. Provided discussion of other possible alternatives is excluded A Priori, this logic may pass a cursory examination. As a result of this critically flawed argument, non-essential flights have remained, despite the overwhelming and unnecessary harms caused to New Yorkers and the environment. This is a false dilemma, as there are other ways of maintaining access for essential helicopter flights, and has led to a failure of imagination on the future of Pier 6. Essential helicopter flights could be incorporated into the design of marine freight operations at the site without a significant challenge, or the cost of maintaining facilities for essential flights could be taken on by the City as a necessary public service while non-essential flights are banned.
Potential benefits outside direct payments to the City which Pier 6 heliport operations might bring to the NYC economy–employment opportunities, drawing in more tourists, or contributing to growth in local manufacturing–actual gains in these areas are minimal. The NYC helicopter industry contributes a negligible amount of jobs to the city’s labor market. Even estimates from helicopter lobbies are unimpressive: In one example, it is estimated NYC’s heliports create employment opportunities for approximately 150 pilots, 80 mechanics, and additional staff working with tourist companies. In a more conservative estimate from an industry report, the helicopter sightseeing industry (which exclusively operates at Pier 6) directly employs approximately 70 people in NYC. These employment estimates pre-date the implementation of a 50% reduction (cap) of tourist flight operations at Pier 6 from 2015 volumes, so current employment numbers are likely much lower. Regardless of which estimate is more accurate, they both pale in comparison to the whole of NYC’s labor market: private sector jobs in New York City reached more than four million jobs (4,181,500 total) in 2023. It cannot be argued in good faith that helicopter tourism is critical to the NYC tourist market. Approximately 30,000 flights with an average of four passengers can only carry 120,000 passengers per year, a mere 0.21% of the over 56 million tourists who visited the City in 2022. Overall, it is clear the most material benefit the City incurs from the current operation of Pier 6 is the revenue it earns as a concession payment from the current heliport Operator and any amount the City earns from these operations should be greater than the cost of these operations to the City and its citizens.[6]
The current Pier 6 flight cap of 29,651 tourist flights per year, at an all-in average of one engine-hour each,[7] using an EC-130B4 helicopter as typical gives: 53 gallons/hour = 201 liters x 3.5 kg CO2/liter = 0.7035 metric tons CO2 (tCO2)/flight x 29,651 flights = 20,859 tCO2 per year. The New York State Department of Environmental Conservation (NYS DEC) publishes a guidance document to provide “damages-based values [of carbon] as a tool to aid state agencies in the consideration of [GHG] emissions and climate change in their decision-making.” At the NYS DEC’s estimated $2,200 social cost per tCO2 emitted, estimated emissions from DMH amount to a social cost of approximately $46 million each year for the current use of Pier 6 from carbon emissions alone. If the City is netting less than $1,548 per helicopter landing, the City/NYCEDC is subsidizing social harm to the City (and planet) for an extremely small economic benefit to the wealthiest tourists and residents. This alone should be enough to invalidate the City’s standing appraisal of the heliport’s value as Pier 6’s primary use, as no contractor would be able to profitably operate a heliport while paying over $126,000 per day in rent.
Noise pollution from conventional helicopter activity at Pier 6 is indisputably the most disruptive to New York’s citizens. A decade ago, public complaints filed through the City’s 311 hotline regarding excessive helicopter noise rarely surpassed 1,000 complaints annually. Due in part to an increase in commuter services to the Hamptons and JFK airport, public complaints about helicopter noise have spiked in recent years. In 2021 NYC residents filed approximately 26,000 noise complaints against helicopters, a significant departure from the previous decade’s relatively stable volume of complaints.
Mounting tensions between the NYC public and the helicopter industry has garnered the attention of representatives in the New York City Council and New York State Senate. Most successfully, public grievances against helicopter noise resulted in a 2016 agreement to limit flights by 50%–or a reduction of tour flights to 29,651 or under annually at Pier 6–and severely limited operating hours and possible routes, as acknowledged in the RFP (Pp 7). Despite these concessions, robust public opposition persists.
New York City’s Environmental justice (EJ) communities, defined as “low-income or minority communities located in the City of New York,” are disproportionately located near major road and rail transportation infrastructure. As a result, these vulnerable communities suffer from disproportionately high levels of noise and air pollution and the resulting chronic health impacts from a fossil fuel-dependent transportation system. Reducing helicopter flights at Pier 6 will reduce the heavy burden of incessant helicopter-related noise pollution for New Yorkers, especially those living in EJ communities. The additional freight trucks taken off the roads with marine freight operations will further contribute to reducing negative impacts in EJ communities by decreasing road traffic noise. The well-documented health impacts from noise pollution, along with the rising level of public opposition to non-essential flights at Pier 6 indicate the direct social harm from helicopter activities at Pier 6.
NYC’s Future Vision for Pier 6: A “Hub for Sustainable Transportation & Local Deliveries”
In November 2023, NYC.gov issued a press release detailing the RFP for the operations of Pier 6. The press release includes the following comments from NYC Mayor Eric Adams:
“Our vision for the Downtown Manhattan Heliport will create the world’s first heliport with infrastructure for electric-powered aircraft and put this public asset to work for New Yorkers as a hub for sustainable transportation and local deliveries. We will not only put New York City at the cutting edge of sustainable flight technology while addressing a persistent quality-of-life issue with helicopter noise, but also get trucks off the road and make our streets safer.”
This statement advances a vision for Pier 6 that overstates the potential for eVTOL technology, and subsidiary maritime freight operations, to be a silver-bullet solution to the numerous challenges the City faces related to helicopter tourism. It reflects a broader sentiment that the vision put forth by NYCEDC is firmly aligned with the City and NYCEDC’s responsibility to deploy City-owned assets to optimize public benefit. However, the RFP and ancillary commentary from NYC public officials represent the City’s strategy to ameliorate the negative impact from conventional helicopters and capture some of the benefits of marine freight operations.[8]
According to the RFP and associated sources, the City plans to continue operating Pier 6 at full-capacity as a public-use heliport, accommodating non-essential sightseeing and essential flights alike. Noise pollution from conventional helicopters is acknowledged as an urgent problem, placing responsibility on the selected Operator of Pier 6 to incentivize the transition to eVTOL and quieter stage aircraft, upon FAA certification, such that these newer technologies gradually capture an increasing portion of total allowable tourist flight operations (TFO). The Operator is required to invest in, install, and activate the necessary infrastructure to facilitate eVTOL use, including electric charging infrastructure, no later than the fifth anniversary of the concession agreement. Overall, proposals are “required to include plans to further reduce take-offs and landings of non-eVTOL tour and corporate and/or personal chartered flights at JRB while maintaining a competitive return through the activation of diversified revenue streams. (Pp 7)” EVTOLs form the crux of the City’s vision for Pier 6 and are the source of anticipated improvements compared to current operations at Pier 6.
EVTOLs are battery-powered and, thus, a presumably zero-emissions alternative to conventional rotorcrafts. Still, as a “sustainable transportation” vehicle,[9] eVTOLs may not be the most sustainable and efficient. Further, EVTOLs are at an early stage of development, with existing research yielding conflicting conclusions regarding the extent of noise improvements achievable through a transition to eVTOL aircraft from conventional helicopters. One eVTOL company, Joby Aviation, published promising results from a 2022 study conducted in partnership with the National Aeronautics and Space Administration (NASA) as part of its Advanced Air Mobility National Campaign. According to the study, Joby’s S4 prototype measured noise levels “somewhere between [a] refrigerator’ and ‘moderate rainfall’ on a decibel chart” (45.2 dBA) when flying overhead at an airspeed of 100 knots and an altitude of 500 m. Despite these encouraging measurements, other researchers remain skeptical.
Most helicopter noise is generated by the rotors, not by propulsion engines, so little change can be expected from the adoption of eVTOL aircraft. The most socially harmful aspects of helicopter noise could be mitigated through routing plans, but most of this work has already been completed and will not see a significant change simply by transitioning to electrically powered helicopters. Only slowing down and flying higher will to assist in reducing noise in a meaningful way. It is doubtful either of these options will be acceptable to tour operators.
Marine Freight Provisions
Alongside heliport activities at Pier 6, the City plans to launch secondary “low-impact marine cargo” operations paired with last-mile green delivery options (Pp 1,8). This “Proposed Project is a key initiative for Freight NYC to shift freight from truck deliveries to the City’s waterways and bike facilities to improve street user safety, reduce truck traffic congestion, improve air quality, and fight climate change.” While the City champions this marine freight provision as a bold action towards greening NYC’s freight system, its actual plans for marine micro-distribution services at Pier 6 are underwhelming and statistically insignificant compared to the problem.
In early 2023, NYCEDC undertook an environmental assessment statement (EAS), as required by City Environmental Quality Review (CEQR), to assess the environmental impacts of the planned low-impact marine cargo usage and last-mile green delivery operations at Pier 6.[10] The City’s initial designs for this project anticipate the installment of one landing barge for marine freight on the north side of the existing pier, which will accommodate a maximum of three marine freight vessel landings per day, conveying a small volume of cargo through the pier. The planned daily throughput for marine freight at Pier 6 is only capable of moving up to 5,400 cubic feet of small packages or parcels (90 total pre-loaded cargo bikes/day x 60 cubic feet of storage/bike = 5,400 cubic feet of cargo/day) if loaded to full capacity. This is only equivalent to seven 16 foot box trucks per day displaced from New York’s roadways.
To put these numbers into perspective, 2017 saw an average of 125,621 trucks cross into Manhattan each day, with over 30,000 trucks crossing over the George Washington Bridge alone. The potential displacement of only five box trucks each day from marine freight use at Pier 6 is statistically insignificant for the City’s freight system goals. The City’s plan for the JRB Marine Infrastructure Project ultimately emerges as a red herring, promising innovative improvements to quality of life and climate leadership, while meant to disguise the perpetuation of the status quo.[11]
DMH RFP Vision: Still Incompatible with the City’s Policy Priorities and Objectives
In its plan for Pier 6, the City allocates minimal space and capacity for marine freight, capturing barely nominal benefits from this service for the City’s freight system and community. The plan prioritizes eVTOLs and helicopter tourism over l marine freight, despite the fact that eVTOLs and air freight have never formed part of the City’s policy plans. At its core, an eVTOL-centric strategy for Pier 6 operations is a stop-gap measure to perpetuate existing operations. This strategy exhibits path dependence due to prioritizing heliport uses in the past, and is a strategy that appeals to tradition instead of relying on innovation and forethought. Moreover, it signals a problematic priority misalignment with the City’s broader objectives, moral imperatives, and policy priorities.
As highlighted, non-essential helicopter flights provide an important source of revenue for the heliport, and without them (in the existing model), it would be close to impossible to sustain Pier 6 operations to support essential helicopter flights. Under these circumstances, the path dependence of the City’s past Pier 6 strategy is a logical consequence of the City’s unimaginative and narrow policy appraisal model. Regardless of how hard the City tries, truly optimal results are impossible if the City holds steadfast to a decision-making model that omits the social costs and benefits which are not captured in a simple Revenue-And-Expense sheet.
“Increasing the use of the city’s waterways will spur the transformation of commercial transport—resulting in a greener city with reduced congestion and pollution. NYCEDC and NYCDOT’s Blue Highways pilot program encourages the use of sustainable water freight and last-mile delivery solutions—an effort recently funded by the federal government.”
– Delivering Sustainable Infrastructure | NYCEDC
The 2023 RFP vision for Pier 6 is opposed to realizing the full benefits of marine freight activity at this site. Pier 6 is one of the few piers in Manhattan capable of supporting marine freight at scale with approximately 71,900 square feet of existing barge and pier space, in addition to a 6,300 square foot terminal building. Water depths at Pier 6 are approximately 12 to 15 feet, which mitigates the need for costly dredging. Further, Pier 6 is close to key roadways and freight transfer locations (e.g., distribution, delivery, and fulfillment centers or warehouses) which serve the City, especially Lower Manhattan.
The continued use of Pier 6 as a helipad does not realize any of the aforementioned Priority Maritime Activity Zone (PMAZ)goals, despite taking up a prime location along what could be a working waterfront. The PMAZ designation for this stretch of the Lower Manhattan waterfront is also not being given primacy in the Lower Manhattan Coastal Resilience Project plans to date (e.g., former Piers 13 and 14 are not being reconstituted as green shipping incubator piers or other sites of waterborne commerce). This oversight is another reason to take advantage of the full maritime commerce potential of Pier 6.
Establishing a marine freight terminal and micro-distribution operation at Pier 6 would accommodate an array of last-mile delivery vehicles, including electric and non-electric bikes and electric quads (collectively “cargo bikes”) that can carry an average of 60 cubic feet of cargo each and electric cargo vans that can carry an average of 400 cubic feet of cargo each. As Pier 6 marine freight operations expand, non-essential flights from heliport operations should be phased out, especially those using conventional helicopters. Ultimately, the only remaining heliport operations at Pier 6 should be essential flights–including primarily Marine One, emergency, and medical service flights.
The potential jobs impact of replacing delivery trucks with a cross-harbor marine freight system operating from Pier 6 is significant, especially when supplemented by microdistribution arrangements. The most significant employment impact is from the microdistribution operations completing last mile delivery. Using last-mile micro-mobility vehicles, each cargo bike-and-trailer combination operates at effectively zero carbon and transports up to 0.5 tons at a time. Assuming an effective speed the same as a truck in New York City traffic, it will take approximately 5 to 10 bike-and-trailer trips to do the job of one 16 foot box truck driver, while reducing congestion for the entire roadway system. This may result in a surge of un-exportable jobs for the City in a range of up to eight bike couriers per box truck removed. In addition, the longshore, staging, and vehicle loading crews may amount to hundreds of employees, depending on hours of operation and cargo volume handled.
Conclusion
To date, the City has failed to recognize the major potential marine freight holds as an alternative use for Pier 6. It is clear that the City is actively choosing to devote Pier 6 to leisure helicopter activity, despite the widespread social harm this use inflicts on citizens. This decision gravely overlooks the significant gains on multiple City priorities that could be made by pursuing the most logical best use-case of Pier 6: marine freight operations.
The City urgently needs to better align the decisions it makes to deploy vital publicly-owned assets with its stated policies and priorities for sustainability, equity, and innovation. This is achievable by embracing a more holistic assessment of the externalized costs and benefits associated with the possible use-cases for an asset (in this case, Pier 6/DMH). The City’s current plan for Pier 6 in Lower Manhattan critically overlooks these impacts in favor of the status-quo heliport activities at the Site. This plan is made at the expense of the City’s numerous policy goals, freight system plans, and sustainability initiatives in which it promises to invest heavily in maritime freight and revitalizing the working waterfront[12] but includes neither air freight nor sustainable aviation as a strategic goal or policy priority.
The slow retirement and reduction of primarily recreational services with high social cost and high emissions in favor of low-emissions high social benefit infrastructure in Downtown Manhattan is an obvious and important shift which should be prioritized in the course of all climate and economic policy. By limiting the facilities available for activities such as private helicopter tours which are taken up by only a fraction of a percent of tourists annually and substituting socially beneficial infrastructure in their place, significant gains can be made on multiple City, State, and Federal environmental, economic, and social policy goals simultaneously.
In a carbon constrained future, the NYMA will require significantly more dockage for cargo transport, possibly as much as 200 or more berths in Manhattan alone, or about four miles of docks.[13] Unless there is a concerted effort to start including these facilities into planning and development efforts now, the space will not be available once needed. The impact of any emissions-reducing effort is amplified by earlier implementation, as it prevents more emissions over the short remaining timeline to 2050, when the city plans to have reduced its greenhouse gas emissions by 80% compared to a 2005 baseline. The City is already behind plan for these goals, and the longer meaningful action is delayed, the more extreme the remedial measures will have to be: This entails higher costs, more social and political upheaval, and economic pain for everyone involved, before the flooding, storms, and other climate-based damages are accounted for. Unless action is taken now, the tools needed in 20 years will never have been built, and it will be impossible to build them once needed with existing facilities and capabilities. Now is the time to take converting waterfront space to marine uses seriously, for New York City and the United States as a whole.
[1] ‘JRB’ is the Federal Aviation Administration (FAA) location identifier for Downtown Manhattan Heliport (DMH).
[2] Per a 2019 report by the NYC DOT approximately 125,621 trucks cross into Manhattan per day. SEE: NYCDOT, “Improving the Efficiency of Truck Deliveries in NYC.” (April 2019) Pp 3.
[3] The TRIP study’s rating system indicates that a “bridge is rated in poor/structurally deficient condition if there is significant deterioration of the bridge deck, supports or other major components. Bridges that are poor/structurally deficient may be posted for lower weight limits or closed if their condition warrants such action.” The study allocated a fair rating if the “bridge’s structural elements are sound but minor deterioration has occurred to the bridge’s deck, substructure or superstructure.” SEE: TRIP. Preserving New York’s Bridges: The Condition And Funding Needs Of New York’s Aging Bridge System. Washington: TRIP, 2019.
[4] Priority Marine Activity Zones (PMAZs). As defined and mapped in the Waterfront Revitalization Program, PMAZs are special area designation that assist WRP consistency review. The PMAZs are areas with concentrations of waterborne transportation uses and important nodes that support the city’s waterborne transportation and maritime activities. These areas are characterized by shorelines used for vessel docking, berthing, or tie up, and where the maritime infrastructure, such as bulkheads, docks, piers, and fendering, is designed to support such uses.; SEE: NYC Department of City Planning. “Priority Marine Activity Zones” in The New York City Waterfront Revitalization Program New York: NYDCP, 2016. https://www.nyc.gov/assets/planning/download/pdf/planning-level/waterfront/wrp/wrp-2016/nyc-wrp-pmaz.pdf
[5] “The JRB Marine Infrastructure Project… is anticipated to reduce trucking and encourage greener and more efficient last-mile deliveries while still allowing for the use of JRB for its primary aviation operations…. NYCEDC requires that proposals include …Schedules demonstrating no interference with heliport operations.” RFP Pp 8
[6]Stephanie Riegg Cellini, James Edwin Kee. “Cost – Effectiveness And Cost – Benefit Analysis” Handbook of Practical Program Evaluation 3 Ed. San Francisco: John Wiley & Sons, 2010.
[7] The one hour per flight figure is designed to include idle time, preflight and postflight checks, non-revenue flights to and from maintenance facilities, training and pilot currency flights, and other ancillary operations necessary to maintain the aircraft, as there are no indications of maintenance facilities at the DMH location.
[8] “The City specifically seeks proposals which will “(i) support aerial use of the Site, including but not limited to electric vertical take-off and landing (“eVTOL”) aircraft and helicopters, subject to Federal Aviation Administration (“FAA”) regulations and the City’s efforts to maintain quality of life for its residents, (ii) invest, install, and activate the necessary support infrastructure to facilitate eVTOL use, and (iii) build out, activate and support secondary maritime freight usage and micro- distribution at the Site to advance the City’s programs.”; NYCEDC. Request For Proposals: Downtown Manhattan Heliport Pp 1.
[9] A distinction should be made between ‘motion’ and ‘transportation.’ For example, if a flight leaves from, and returns to, the same location (e.g., sightseeing or tourist flight), it is not a means of transportation and should not be treated as such. Transportation requires separate points of origin and destination by definition: “To take or carry (people or goods) from one place to another.”
[10] The ‘Project Description’ for the Downtown Manhattan Heliport Freight NYC Project EAS states:
“The City proposes to establish a last-mile delivery operation on the existing Heliport pier… with no change to the volume or timing of the helicopter operations. The Proposed Project would establish a floating freight barge landing for docking the marine vessel, as well as a gangway to connect the Heliport pier and the barge landing…The last-mile operations would utilize marine vessels to transport pre-loaded zero-emission vehicles (cargo bicycles) to a new permanent floating barge to be installed on the north side of the Heliport pier. The last-mile delivery facility may also use cargo vans… loaded with packages transferred from the vessel… The operations would be limited to up to three marine vessel deliveries per day, tentatively at 7 AM, 12 PM, and 3 PM. [Heliport Operations are] not to be affected by the addition of a last-mile delivery operation and would continue as at present, with uninterrupted use for its primary aviation operations. The Proposed Project is a key initiative for Freight NYC to shift freight from truck deliveries to the City’s waterways and bike facilities to improve street user safety, reduce truck traffic congestion, improve air quality, and fight climate change.”
SEE: NYC City Environmental Quality Review Environmental Assessment Statement (EAS) For Downtown Manhattan Heliport FreightNYC Project. CEQR Reference Number 22SBS006M, 6 Feb 2023. Pp 27
[11] The JRB Marine Infrastructure Project is “anticipated to reduce trucking and encourage greener and more efficient last-mile deliveries while still allowing for the use of JRB for its primary aviation operations.” It is the target of the aforementioned MARAD Marine Highway grant. SEE: NYCEDC. Request For Proposals: Downtown Manhattan Heliport Pp 8
[12] “The City is committed to bold action to make our freight system more sustainable and efficient. NYCDOT and the NYC Economic Development Corporation (NYCEDC) are committed to encouraging greener and more efficient truck deliveries, increasing the share of goods moved by water, rail, and cargo bicycles, and supporting innovation and new technologies to make freight movement more efficient.” NYCDOT. Delivering Green: A Vision For A Sustainable Freight Network Serving New York City. New York: NYCDOT, 2021.
[13] Woods “Sail Freight Revival.” Master’s Thesis. Prescott College, 2021. 21,500 tonnes of supplies arriving in Vessels of 111.25 tons, or about 100 feet in length, requires 3.8 miles of docks without maneuvering room.