2-1 June 2021

Chapter 2: Purpose and Need

2.1 INTRODUCTION

The CEQ regulations that implement NEPA require that an Environmental Impact Statement (EIS) 

“briefly specify the underlying purpose and need to which the agency is responding in proposing 

the alternatives including the Proposed Action” (40 CFR 1502.13).

2.2 DESCRIPTION OF THE PROPOSED ACTION

The Proposed Action is the construction and operation of the Platform and Tunnel Encasement in

the Western Rail Yard, including the following: 

• A new approximately 9.8-acre structural steel and concrete Platform spanning the Western 

Rail Yard. Platform construction would also include the replacement and modernization of 

LIRR support services, railroad staff facilities, and rail car cleaning services, associated 

infrastructure, and the construction of a new approximately 20,000 square foot electrical 

substation. 

• A concrete Tunnel Encasement in the southern portion of the site running underground from 

Eleventh Avenue to West 30th Street to preserve right-of-way for a new trans-Hudson 

connection into New York Penn Station.

Chapter 3, “Alternatives,” provides a more detailed description of the Proposed Action (see 

Section 3.4). 

2.3 PURPOSE FOR THE PROPOSED ACTION

The purpose of the Proposed Action is to: 

(1) cover and protect the active railroad tracks and LIRR support facilities in the Western Rail Yard 

so that the Project Sponsor can provide additional new capacity for real estate development 

and house critical life safety and mechanical, electrical, and plumbing support services for the 

yard, including new lighting, sprinklers, and an extensive Platform ventilation system; and 

(2) preserve a right-of-way through the Western Rail Yard to support the future construction of a 

trans-Hudson passenger rail crossing into New York Penn Station. 
June 2021 2-2 

2.4 NEED FOR THE PROPOSED ACTION

Collectively, MTA's operating agencies (Bridges and Tunnels, Construction & Development, Long 

Island Rail Road, Metro-North Railroad, MTA Bus Company, and New York City Transit) serve a 

population of 15.3 million people across a 5,000-square-mile travel area surrounding New York 

City. Consequently, MTA provides over 2.6 billion trips each year, accounting for about one-third 

of the nation’s mass transit users and two-thirds its commuter rail passengers. However, MTA has 

ongoing financial needs as the agency responsible for operating and maintaining North America's 

largest transportation network, which comprises the nation’s largest bus fleet and more subway 

and commuter rail cars than all other U.S. transit systems combined.1

1 http://web.mta.info/mta/network.htm (accessed January 15, 2021)

 

The fares and tolls MTA collects do not solely cover their operating costs. MTA’s revenues typically 

come from a combination of fare and toll revenues, dedicated taxes, revenues generated by MTA’s 

real estate holdings, and state and local subsidies. However, the agency has often faced operating 

budget deficits. For example, after the financial crisis in 2008, MTA faced a $400 million deficit. 

These deficits have become more severe in the face of decreased ridership and toll revenues 

resulting from the COVID-19 public health emergency. At present, MTA faces a $15.9 billion deficit 

through 2024.

2

2 https://www.nytimes.com/2020/11/25/nyregion/mta-budget.html (accessed January 15, 2021) 

,3

3 https://new.mta.info/document/25291 (accessed January 15, 2021) 

,4

4 https://new.mta.info/transparency/financial-information/financial-and-budget-statements (accessed January 

15, 2021) 

As a result of these recurrent deficits, MTA is consistently looking for additional 

revenue streams to sustain the operation, maintenance, expansion, and upgrading of the vast 

public transportation systems it operates.

Use of the air space above the Western Rail Yard has been a long-standing goal of both MTA and 

New York City. MTA has sought to maximize the revenue generation potential of its real estate 

assets, and when TBTA redeveloped Hudson Yards in 1986, the tracks and other facilities were 

reconfigured to accommodate the columns that would be required for a Platform needed to allow 

future private development to occur. In 2015, MTA completed construction on the No. 7 subway 

line extension. MTA NYCT extended service from Times Square (Seventh Avenue and 41st 

Street) to West 34th Street and Eleventh Avenue enabling riders to easily get to the far west side 

of Manhattan and access Hudson Yards. MTA agreed to make the investment to construct, 

operate, and maintain the No. 7 Subway Extension because of the anticipated high-density 

development proposed to take place in Hudson Yards (see Figure 1-3). 

MTA would use the revenue from the lease of the Western Rail Yard property to support issuing 

bonds, the proceeds of which would be used to fund capital infrastructure upgrades, maintenance, 

and other operational needs. The Platform is needed to support the provision of developable land 

area that would generate revenue for the MTA and its subsidiary agencies, to protect the rail yard, 

and to provide modern state-of-the-art life safety systems for the entire Western Rail Yard. 

As the Proposed Action would benefit MTA and New York City, it is also consistent with and 

supports USDOT’s mission to ensure America has the safest, most efficient and modern 

transportation system in the world, which boosts our economic productivity and global 

competitiveness and enhances the quality of life in communities both rural and urban.5

5 https://www.transportation.gov/about (accessed January 15, 2021) 

 
Chapter 2: Purpose and Need

2-3 June 2021

The Tunnel Encasement is needed to maintain the ability to preserve passenger rail service in 

and out of New York Penn Station. As detailed in FRA’s 2013 EA6

6 Amtrak and FRA, Finding of No Significant Impact, Environmental Assessment for Construction of a 

Concrete Casing in the Hudson Yards, New York, New York. May 2013.

and 2014 SEA,

7

7 Amtrak and FRA, Finding of No Significant Impact, Supplemental Environmental Assessment for 

Construction of a Concrete Casing Extension in the Hudson Yards, New York, New York. November 2014.

 studies have 

shown that Hudson Yards is the only clear alignment on the west side of Manhattan that would 

allow a rail tunnel under the Hudson River to fully connect to New York Penn Station from the 

west. If the underground ROW is not preserved prior to private development on the Project Site, 

the use of this location under Hudson Yards would be permanently lost as a possible alignment 

for future expansion of rail service between New York and New Jersey that is dependent on this 

ROW. New rail infrastructure is part of the effort to maintain a functional, resilient, and improved 

trans-Hudson passenger rail crossing into New York Penn Station, maintain existing Amtrak 

intercity and NJ TRANSIT commuter rail service on the Northeast Corridor, and to support future 

increases in the capacity of the regional rail system should they be pursued.

2.5 OBJECTIVES

FRA established objectives consistent with the purpose and need for the Proposed Action. The 

objectives of the Western Rail Yard Infrastructure Project include the following: 

• Maintain safe, continuous, and uninterrupted LIRR operations, construct critical life safety and 

ventilation systems, and modernize operational facilities within Western Rail Yard; 

• Support the ability to meet the revenue-generation goals of the MTA, the owner of the Western 

Rail Yard;

• Provide support for the economic, social, and recreational life of the Hudson Yards area and 

the City; and 

• Preserve opportunities to enable future growth of passenger rail service and to maintain a 

functional, resilient, and improved trans-Hudson passenger rail crossing into New York Penn 

Station. 