Preliminary Statement

This Memorandum of Law is submitted on behalf of the six defendants in the above captioned action in support of their defense that their refusal move out of the South Outer Roadway of the Queensboro Bridg when ordered to do so by members of the New York City Police Department was justified pursuant to § 35.05(2) of the Penal Law.1

QUESTIONS FOR THE NYPD

1. Since motor vehicles annually kill about 300 pedestrians and bicyclists on New York City streets, and collide with about 17,000, why is so much of the police enforcement effort directed to highways? 80% to 90 % of speeding and reckless driving summonses are given on highways instead of city streets.

Good afternoon, my name is John Kaehny. I represent Transportation Alternatives, a group of 2,500 New Yorkers who favor walking, bicycling and mass transit over cars, and encourage others to do the same.

Good afternoon. My name is John Kaehny. I represent Transportation Alternatives, a group of 2,500 New Yorkers who are striving to make our city more livable by improving walking, cycling and mass transit and reducing dependence on the automobile.

Many of us are tired of fighting the West Side Highway. We want the it fixed, we want our riverside park, our walking and cycling path, and more and safer pedestrian crossings. But tired and impatient as we are, we don't want more cars, and that is exactly what we will get if the Enhanced Basic Reconstruction plan is built.

The following are in addition to the concerns we expressed in previous testimony

Though the criteria the State Department of Transportation (SDoT) and the DEIS have articulated for evaluating different options for the 9A corridor are reasonable, the SDoT's interpretation of them is heavily biased towards increasing automobile capacity and auto travel. This bias has produced a DEIS that is flawed by its failure to seriously consider options that do not increase automobile capacity, like light rail, or additional money for existing public transit.

1. First, let me start off by saying that Transportation Alternatives appreciates the goal and determination of Council Member Millard and other Council Members to create a safer environment for pedestrians. Long before Council Member Millard or his bill, Transportation Alternatives has been standing up for pedestrians. Pedestrian rights and safety are a primary goal of our organization.

Council members:

My name is Paul Harrison. I represent Transportation Alternatives, a 3,300 member citizens' group dedicated to a better quality of life through improved and expanded transit, as well as better conditions for cycling and walking.

Good afternoon. My name is Paul Harrison. I represent Transportation Alternatives, New York's 3,300 member citizens group working for a more pedestrian-friendly New York, better conditions for cycling and improved mass transit.

Good afternoon. My name is Paul Harrison, and I represent Transportation Alternatives, New York City's 3,500 member citizens group working for better walking, cycling and mass transit. I am here today to ask for three things:
1. Enforcement of existing traffic laws;
2. A Resolution calling for 15 mph neighborhood streets, and;
3. A resolution supporting community requests for traffic calming.