Walls, Gates, and Former Toll Barriers in Manhattan
A city can have substantial walls around much of its perimeter and still face a difficult eruv question at the places where roads pass through those walls. Manhattan illustrates the point clearly. Its waterfront structures could serve as real mechitzos, while its bridges and tunnels created openings used by large numbers of people.
The halachic discussion therefore turned to the nature of those openings. Were they repaired by an existing tzuras hapesach? Were there actual partitions or gates? Did toll barriers have the status needed for the opening in question? If a crossing itself was a reshus harabim, were closing doors required?
The Rebbe pointed to existing barriers
In his notes of 15 Iyar 5714 on a proposed Manhattan eruv, the Rebbe questioned an assertion that the streets were unquestionably a Torah-level reshus harabim. He observed that the streets ultimately reached bridges and tunnels that appeared to be closed by a tzuras hapesach, a partition, or “Schranken,” barriers used to collect tolls and the like.
The note was framed as a matter requiring investigation. It identifies a potentially important feature of the Manhattan crossings without treating every toll structure as a halachically sufficient gate.
That distinction matters. A toll plaza may contain booths, overhead structures, arms, fences, and traffic lanes. Hilchos eruvin asks about the dimensions and continuity of the actual boundary, the openings between its components, the passage of the public, and the form of closure required for that type of opening. The ordinary fact that drivers once stopped to pay a toll does not by itself answer those questions.
Rav Moshe distinguished between a tzuras hapesach and doors
Rav Moshe's discussion in Igros Moshe, Orach Chaim I:139, reaches the same physical features from another direction. If the bridge opening is treated as a breach into a lesser domain, there are approaches under which a tzuras hapesach can repair the opening. If the bridge itself has the status of a Torah-level reshus harabim, stricter views require delasos, doors, and Rav Moshe discusses the requirement that they be closed at night.
The six-hundred-thousand calculation becomes part of this issue. Rav Moshe first notes that six hundred thousand people did not pass each individual bridge every day when Manhattan's traffic was spread among thirteen bridges and additional tunnels. He then argues that in a city, shishim ribo may be determined by the population and public use of the city as a whole rather than by requiring the entire number to pass on each street.
If a bridge was part of the city, that broader city count could make the stricter door requirement relevant. If it was an outside road, its own traffic would have to be considered separately. Rav Moshe did not erase that uncertainty by simply pointing to the toll barriers.
Existing walls are different from an ordinary wire enclosure
The Manhattan discussion also explains why halachic authorities may treat two superficially similar eruv maps very differently. A genuine wall, riverbank, retaining structure, or other pre-existing mechitza can give an area a strong physical enclosure. A tzuras hapesach may then be needed only at particular openings. That is a different question from attempting to surround an otherwise open Torah-level public domain with a series of tzuras hapesach structures.
The status of the opening controls what can repair it. The status of the surrounding area controls which opinions must be addressed. The actual geometry of the wall and gate controls whether the pieces form one continuous enclosure.
For Manhattan, the existence of waterfront walls and toll-controlled crossings gave the proposed enclosure serious features to analyze. Rav Moshe nevertheless concluded that he could not permit or assist the eruv. The Rebbe's notes likewise required further clarification of the physical and halachic facts rather than treating the existing barriers as a completed answer.
That is why the former toll barriers belong in the Manhattan discussion. They were part of the strongest physical case for an enclosure, while the responsa show that their presence alone did not resolve the large-city eruv question.