VDOT taking comments on E-ZPass fee structure until 12 June, 2012. Have your say!

The Virginia Department of Transportation is considering enacting a fee on users of the E-ZPass system of transponders that allows you to pay your tolls electronically without having to stop at the toll booths. From the VDOT web site:

E-ZPass Fee Structure Under Consideration

With the anticipated expansion of the E-ZPass program in Virginia due to new toll facilities opening, the Virginia Department of Transportation is considering a new fee structure to provide customer support for the increasing number of accounts, transponders and electronic toll collections.

Various fee structures are under evaluation, including a monthly $1 set fee which was presented to the Commonwealth Transportation Board on Wednesday, April 18. 

VDOT is accepting public comments through 5 p.m., Tuesday, June 12, 2012.  All comments will be reviewed and taken into consideration prior to the final decision on the proposed fee structure. VDOT started taking comments April 19, 2012.

(Emphasis theirs.) They are directing people to send e-mail to vdotinfo@vdot.virginia.gov. Please note that all such comments become part of the public record. I’ve already sent my comments and I’ll repeat them here for the record. If you have an opinion on the matter, please get your comments to them. Please remember to be polite – they’re not trying to be jerks, they’re just making a suggestion.

——– Original Message ——–
Subject:     Proposed E-ZPass fee structure comment
Date:     Thu, 07 Jun 2012 17:41:40 -0400
From:     Ric James
To:     vdotinfo@vdot.virginia.gov, DelBComstock@house.virginia.gov, district33@senate.virginia.gov

Sirs/Madams,

Thank you for soliciting comments from the traveling public with regard to the proposed E-ZPass fee structure announced in April. I appreciate the opportunity to voice my concerns.

It is my understanding that a $1/month/transponder fee is being considered that would go to the purchase of additional transponders, the setup and (presumably) maintenance of a retail program to sell transponders in retail stores, and for the general upgrade of systems that make the E-ZPass program work such as antenna and sensors at the toll booths. I am further given to understand that the fees collected would be applied only to these expenses and that the account accumulating the funds would be monitored for the rate of intake – which would be lowered if it was determined that more funds are coming in than is needed to pay for the activities I’ve mentioned.

I would like to go on record as opposed to such a fee. I drive the Dulles Toll Road every weekday on my way into DC and have a front-row seat, twice daily, to the sheer volume of travelers on that road. The stream of E-ZPass users is constant and I find it absolutely unbelievable that the system is not more than paying for itself in terms of reducing delay on and off the toll road as well as the reduced manpower requirements that not having the E-ZPass in place would require. To suggest that these funds are needed is to imply that the outlay required to handle the traffic flow manually would be, somehow, less. I would require documented and audited proof of such a statement before I gave it the least bit of credence.

To compound that matter is the fact that the systems in place – the transponders themselves, the antenna at the toll booths, the back-end systems that match the transponder signature to the driver account and handle the financial transactions – are not being regularly refreshed and re-installed, not that I have seen.  And even supposing that they are, these systems are not being replaced on a regular enough basis that a separate funding structure should be required.

From a policy standpoint, the notion that these fees would be placed in some kind of “lockbox” and only permitted to be spent on the specific expenses specified is not one that enjoys the support of past performance on the part of Virginia government. Past General Assemblies – and a significant part of the current one – have never let such promises deter them from finding other things on which to spend surplus funds. Additionally, I would be suspicious that any surplus funding would somehow manage to be spent on “extra” transponders or allocated “in advance” for equipment upgrades that might or might not ever actually occur. I am concerned that no matter how much is taken in, it would never rise to the level of triggering a reduction in the fees. Taxes appear to have a tendency to be one-way ratchets and fees of this type seem to suffer the same flaw.

I will not rule out future support of such a program if – and only if – absolute iron-clad safeguards are put into place to guarantee that the funds collected are used only for these purposes and that regular, outside audits take place to present a real picture of the state of things. But at this time, with what is being considered and the current state of the kinds of safeguards to which I refer, I must oppose this fee structure and urge you to decline to enact it.

I am forwarding a copy of this letter to my representation in the General Assembly, Delegate Barbara Comstock and Senator Mark Herring, so they may be aware of the level of opposition that exists.

Thank you again for this opportunity. I will watch this matter with great interest.

Regards,

Ric James

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