Even before the developers of American Dream Meadowlands (formerly “Xanadu“)—a hulking, still-half-built retail development currently lumbering towards completion in North Jersey—announced plans to add a theme park to the project, they had been ignoring a serious issue: how people would get there. TSTC recently pointed this out in a Star-Ledger op-ed and called for American Dream’s developers to fund public transit to the site.

TSTC’s concern comes from the project’s draft supplemental environmental impact statement (DSEIS), which sidesteps the problem of transit access. By relying on the original EIS’ faulty traffic analysis and omitting plans for public transit funding, the revision fails to address the project’s impacts on traffic in the Meadowlands.

The studies were not methodologically sound

For a supplemental EIS to make logical sense, the first EIS must be sound. This is not true in the case of American Dream. In fact, in 2004, a joint government commission found that the project’s initial EIS didn’t investigate the project’s traffic impacts thoroughly enough, since it only examined the roads on the Meadowlands’ grounds:

“In order to properly evaluate the traffic impact [of the development], the applicant is advised to assess all major nodes and links within a regional context (recommended minimum radius of four (4) miles from the proposed project boundaries).”

Seven years later, no such study has been done (despite the opportunity presented by the DSEIS).

The initial and supplemental studies also relied on the Institute for Traffic Engineers’ generic “trip generation rates” in their traffic analyses. ITE trip generation rates’ shortcomings are well-documented, and they may not adequately capture American Dream’s scope and prominence. Instead of using bad, generic numbers, why not analyze consumer behavior at other megamalls and apply that information to Bergen County?

These methodological faults mean that nobody knows what the development could do to traffic in the Meadowlands.

Those same traffic studies assume transit service to the mall, but there is none

As if that weren’t enough, the initial EIS assumed that 10% of visitors would arrive by rail or bus. The developers were depending on public transit to help relieve the traffic that comes with a massive retail/entertainment destination, as it does at their other properties.

But while the supplemental report (DSEIS) relies on these public-transit-dependent traffic estimates, no regular bus lines currently service the site, and commuter rail service only runs during special events.

The developers assume that NJ Transit will add routes once the project is complete, but NJ Transit is already stretched thin, and it’s unrealistic to expect them to expand service without extra funds. The bill for transit to American Dream must be footed by someone, and it shouldn’t be the New Jersey taxpayer (who has already subsidized Triple Five Worldwide, the site’s developer, handsomely). Accordingly, TSTC is calling on Triple Five Worldwide to fund public transit to the site, which would ease traffic and make the destination attractive to those without cars.