Mileage-Based User Fees in a Multi-State Region

I

Grant Application for:

Surface Transportation System Funding Alternatives (DTFH6116RA00013)

Mileage-Based User Fees in a Multi-State Region

Submitted by:

Delaware Department of Transportation

On behalf of:

I-95 Corridor Coalition

Project Name Planning Activities and Initial Pilot Deployments for a

Mileage-Based User Fee (MBUF) System Within the

I-95 Corridor Coalition States

Previously Incurred Project Cost - 0 -

Future Eligible Project Cost $2,980,000

Total Project Cost $2,980,000

STSFA Request $1,490,000

Total Federal Funding $1,490,000

Are matching funds restricted to a

specific project component?

One state is participating only in the planning effort;

while other states have contributed matching funds

for the planning effort and a “focused” MBUF pilot

as part of this initial application

States in which project is located Delaware, Pennsylvania, Connecticut, New

Hampshire, Vermont

Is the project currently programmed

in:

• TIP

• STIP

• MPO LRTP

• State LRTP

No

III

Table of Contents

Introduction .................................................................................................................................................. 1

Project Narrative ........................................................................................................................................... 1

Background—I-95 Corridor Coalition ................................................................................................... 1

Need for Alternative Funding Approaches to Support Transportation ................................................ 3

Previous I-95 Corridor Coalition MBUF Activities ................................................................................. 4

Project Description for Grant ........................................................................................................................ 6

Project Vision, Goals, and Objectives ................................................................................................... 9

Work Scope and Activities .................................................................................................................. 10

Requirements of Section 6020 of the FAST Act ................................................................................ 133

Evaluation and Implementation Plan ................................................................................................ 155

Legislative Support ............................................................................................................................ 166

Staffing Description and Grant Management ............................................................................................. 17

Organizational Information ....................................................................................................................... 232

Appendices

A How the Proposed Scope and Work Activities Address Items in Section 6020 of the FAST Act

B Brief Bios

C Letters of Commitment

Tables

Table 1: Summary of I-95 Corridor Coalition Population and Economic Statistics ....................................... 2

Table 2. Project Goals and Objectives .......................................................................................................... 9

Table 3. High Level Outline of Operational Concept Document for State-Specific Focused MBUF Pilots . 10

Table 4. Operating Parameters for the State-Specific Focused Pilots ...................................................... 111

Table 5. FAST Act Section 6020 Requirements and the I-95 Corridor Corridor’s Approach ..................... 144

Table 6. I-95 Corridor Coalition MBUF Steering Committee Members .................................................... 188

Table 7. Preliminary List of Deliverables for the I-95 Corridor Coalition MBUF Activities ....................... 199

Table 8. Activities and Costs for Multi-State Planning and Pre-Deployment Activities .............................. 21

Table 9. Activities and Costs for Implementing and Managing “Focused” MBUF Pilots ............................ 21

Table 10. Proposed Match .......................................................................................................................... 22

Figures

Figure 1. I-95 Corridor Coalition.................................................................................................................... 1

Figure 2. Electric Vehicles ............................................................................................................................. 3

Figure 3. Fuel Tax Revenue Forecast for Oregon .......................................................................................... 4

Figure 4. New Financing Model for the Region ............................................................................................ 5

Figure 5. High Level Schematic of MBUF System .......................................................................................... 6

Figure 6. Toll Plaza on I-95 Entering Delaware ............................................................................................. 7

Figure 7. Methods for Recording and Reporting Miles ............................................................................. 122

Figure 8. Sample MRD Installation Instructions ........................................................................................ 133

Figure 9. Participating States in Grant ...................................................................................................... 177

Figure 10. Organizational and Management Framework for Grant ........................................................... 18

Figure 11. Preliminary Schedule ................................................................................................................. 20

1

IntroductionIntroductionIntroductionIntroduction

This grant application is being submitted by the Delaware Department of Transportation on

behalf of the I-95 Corridor Coalition in response to the Federal Highway Administration (FHWA)

Notice of Funding Opportunity (NOFO) DTFH6116RA00013. The application includes planning

activities and the deployment of pilots in several states in support of a mileage-based user fee

(MBUF) approach to providing an alternative transportation funding mechanism within the

corridor. The proposed project will be managed and overseen by a Corridor Coalition MBUF

Steering Committee, comprising representatives from the participating states—including staff

from the respective Departments of Transportation (DOTs), Department of Motor Vehicles

(DMVs) and finance agencies—along with other key stakeholders from the tolling industry. The

MBUF Steering Committee will be co-chaired

by Jennifer Cohan, Secretary of Transportation

for Delaware, and Patricia Hendren, Executive

Director of the I-95 Corridor Coalition. Under

the oversight of and as directed by the Steering

Committee, the planning and technical work

will be performed by CH2M HILL Engineers,

Inc. (CH2M), the firm (and many of the same

staff) that was responsible for the success of

the road usage charge systems in Oregon.

Project Project Project Project NarrativeNarrativeNarrativeNarrative

BackgroundBackgroundBackgroundBackground————IIII----95 Corridor Coalition95 Corridor Coalition95 Corridor Coalition95 Corridor Coalition

The I-95 Corridor Coalition region extends

from Maine to Florida and includes the

following 16 states plus the District of

Columbia: Connecticut, Delaware, District of

Columbia, Florida, Georgia, Maine, Maryland,

Massachusetts, New Hampshire, New Jersey,

New York, North Carolina, Pennsylvania,

Rhode Island, South Carolina, Vermont and

Virginia (Figure 1). Member agencies include

all the state DOTs, the major toll and turnpike

authorities within the corridor, and various

agencies of the USDOT (including FHWA).

Affiliate members include many of the

metropolitan planning organizations (MPOs) and transportation planning boards (TPBs) in the

corridor plus several other regional and national organizations (e.g., TRANSCOM, American

Association of Motor Vehicle Administrators [AAMVA], E-Zpass Interagency Group, International

Bridge Tunnel and Turnpike Association (IBTTA), ITS America, and the American Trucking

Associations). A complete list of Coalition members may be found at http://i95coalition.org/the-

coalition-2/member-agencies-2/ .

Figure 1. I-95 Corridor Coalition

MILEAGE-BASED USER FEES (MBUF) IN A MULTI-STATE REGION

2

These 16 states form a massive economic driver for the United States. In essence, if the Coalition

region were a separate country, they would constitute the third largest economy in the world.

Some of the key population and economic statistics for the I-95 Corridor Coalition as a whole are

summarized in Table 1.

Table 1. Summary of I-95 Corridor Coalition Population and Economic Statistics

Population 113.2 million—37 percent of the United States’ population

Population Density 280 people per square mile—more than three times more densely

populated than the United States as a whole

Employment 64 million people—37 percent of all United States’ jobs

GDP $ 5.644 trillion—nearly 40 percent of United States gross domestic

product of $14.6 trillion

The coalition region’s economy depends on the efficiency of its transportation system—the

ability to move people and goods quickly, cost-effectively, and reliably. This network includes

12,058 interstate highway miles (26 percent of the national interstate network), and 907,000

total road miles (23 percent of the national network). These roads serve 103 commercial

service airports and 46 commercial water ports. The value of cargo imported and exported

through the region’s seaport and airport gateways was estimated at $850 billion or 27 percent

of the United States total, in 2010.

Even with the Corridor’s impressive rail and transit

assets—1,111 heavy-rail directional route-miles

(70 percent of the national total) and 4,356

commuter rail directional route-miles (62 percent

of the national total), most of which are used at or

near capacity during peak periods—the Coalition

region’s highways are highly congested, especially

in the 29 major urban areas within the Coalition

region. As a result, the various State DOTs,

transportation authorities, and local agencies within the Corridor have implemented and

continue to expand upon a variety of transportation systems management and operations

(TSM&O) strategies and the supporting ITS infrastructure. Moreover, much of the roadway

infrastructure is severely aging and in need of increased maintenance and rehabilitation.

The Coalition’s 2008 report A 2040 Vision for the I-95 Coalition Region1 formulated and analyzed

an alternative transportation vision for the entire Coalition region—one that accommodates key

values and issues related to a global economy, quality of life, climate change, and energy

consumption while reexamining the traditional modal mix and service options available for

passenger and freight transportation in the corridor. Extrapolation of current land-use, travel

1 Available at http://i95coalition.org/projects/2040-strategic-vision/.

Reliable transportation infrastructure is

vital to the state’s continued economic

prosperity and quality of life. Continued

funding for operating, maintaining and

expanding this critical transportation

network requires an adequate and

sustainable funding method


3

patterns, mode use and vehicle miles traveled (VMT) trends out to 2040 resulted in the following

projections:

• 70 percent increase in VMT.

• 84 percent increase in urban Interstate delay

• Highway fuel consumption and greenhouse gas (GHG) emissions increases of 34 percent due

to the projected VMT increase despite improving fuel economy in line with current corporate

average fuel economy (CAFE) requirements.

• Transit, intercity passenger and freight rail struggle to hold market shares without greater

investment.

• Near doubling of truck volumes, a level that is likely not physically or environmentally

sustainable.

• Constrained interstate commerce and economic productivity as a result of increasing highway

and rail bottlenecks.

A vision-driven scenario was developed that would support regional economic growth while

substantially contributing to emerging energy and GHG emission targets. Components of this

vision include doubling the fuel efficiency of the vehicle fleet and increasing use of alternative

fuels; adding nearly 15,000 lanes of additional highway capacity, much of it being managed

capacity; and deploying aggressive TSM&O, including both in-vehicle and roadside technology

deployment. This 2040 vision and scenario will require that surface transportation investments

within the corridor be more than doubled from $32 billion to $71 billion annually. Seeing this

vision through will require a new sustainable funding source.

Need for Alternative Funding Approaches to Support TransportationNeed for Alternative Funding Approaches to Support TransportationNeed for Alternative Funding Approaches to Support TransportationNeed for Alternative Funding Approaches to Support Transportation

The primary source for surface transportation

revenues—the pay at the pump fuel tax, which

is typically based on a fixed amount per gallon—

is not keeping up with the increasing

infrastructure and operational needs of the

roadway networks, let alone future investment

needs. This is especially true of the Coalition’s

region, where the infrastructure is America’s

oldest. The weakening of revenues has been

caused, in part, by inflation, coupled with the

fact that there has not been an increase in the

federal fuel tax since 1993. Moreover, it is

estimated that nearly two-thirds of the state-

imposed fuel taxes have also not kept up with

inflation for the past two decades. There is also

the issue of increased vehicle fuel efficiency as

a result of CAFE standards and the growing numbers of electric vehicles (EV) and plug-in hybrid-

electric vehicles (PHEV) using the roadways (Figure 2). This means vehicles are travelling farther

for the same amount of gas (and the associated fuel tax), with some vehicles (e.g., EVs) not paying

anything for their use of the roadway.

Figure 2. Electric Vehicles: Good for the

Environment and Less Reliance on Foreign Oil;

Not So Good for Transportation Funding


4

This overall funding gap can only be expected to grow as the average fuel economy of the

American vehicle fleet continues to improve and as the emerging fleet of EVs and PHEVs become

more ubiquitous along the roadways. A fuel tax revenue forecast for one state under multiple

scenarios—with each scenario involving different combinations of average miles per gallon

(MPG) for internal combustion engine vehicles, percentage of EV and PHEV sales each year, and

the range of these vehicles—is shown in Figure 3.2 As shown, regardless of which scenario will

eventually come to pass; the fuel tax revenues will continue to decline. As such, a majority of

policymakers and industry analysts across the nation now agree that the fuel tax can no longer

be solely relied upon to provide sustainable revenues for improving, operating and maintaining

the nation’s roadway infrastructure.

Another concern is that the

widening gap between the

most and least fuel-efficient

vehicles has led to issues of

fairness and equity. Making

those who use the

transportation network pay

for that use (the “user pays”

principle), and thereby

contribute to the

improvement, maintenance

and operation of the

roadways appeals to a

fundamental notion of

fairness widely accepted by consumers for utilities (e.g., electricity, communications, water) and

in other marketplaces.

Several approaches have been suggested for solving this funding gap, including raising the per-

gallon fuel tax (and perhaps indexing it to inflation), increasing vehicle registration fees, and

imposing royalties on EV and PHEV purchases. Some or all of these may be necessary in the short

term; but none of them directly and equitably address the “user pays” principle (nor can they be

completely considered a “user-based alternative revenue mechanism” as stipulated in the NOFO.

As concluded by the National Surface Transportation Infrastructure Financing Commission in

2009 and stated in their Final Report3: “The most viable approach to efficiently fund investment

in surface transportation in the medium to long run will be a user charge system based more

directly on miles driven rather than indirectly on fuel consumed.”

Previous IPrevious IPrevious IPrevious I----95 Corridor Coalition MBUF Activities95 Corridor Coalition MBUF Activities95 Corridor Coalition MBUF Activities95 Corridor Coalition MBUF Activities

The aforementioned 2040 strategic vision notes that achieving the necessary level of

transportation funding will require a new financing model (Figure 4), including a mileage based

user fee (MBUF) to replace the gas tax (called vehicle mileage tax (VMT) in the report), along

with peak period pricing to reduce congestion and carbon pricing to improve the environment.

2 CH2M study for Oregon, 2012 3 Available at http://financecommission.dot.gov/.

Figure 3. Fuel Tax Revenue Forecast for Oregon


5

The Coalition began studying a MBUF approach in 2010. In November of that year, it published

the first of its two studies—Final Research Report: Administrative and Legal Issues Associated

with a Multi-State VMT-Based Charged System.4 Notably, the Coalition chose to focus its efforts

specifically on business models, institutional and administrative arrangements, and legal issues—

both state and federal—critical to real-world application of a MBUF system on a regional or

national scale.

With the interest generated by the first study, the Coalition sponsored a second project and

produced an April 2012 report— Concept of Operations for the Administration of Mileage-Based

User Fees in a Multistate Environment. This report5 describes a long-range vision for a concept of

operations that provides for the following:

• Inclusion of all roads and vehicles

• Cross-state reporting and payment for miles driven within each participating state

• Implementation flexibility in terms of rates and rate structures, user payment methods, and

administrative structures, including outsourcing

• Collection of fees associated with miles accrued by local jurisdiction, priced facility and time

of day to accommodate the potential for collecting MBUF, tolls and congestion-based charges

within a single integrated system

4 Available at http://i95coalition.org/wp-content/uploads/2015/03/Transportation_Financing_PhaseI-ES.pdf?dd650d. 5 Available at http://i95coalition.org/projects/transportation-financing/

Figure 4. New Financing Model for the Region

(Source: A 2040 Vision for the I-95 Coalition Region)


6

It also discusses issues associated with the transition from the current highway tax structure to

this long-term vision, as well as a perspective on MBUF system operating and administration

costs. The information in the report was based on an analysis of the operating environments and

current conditions in three contiguous states (Delaware, Maryland, and Pennsylvania) and the

perspectives gained from an extensive interview process with key personnel in state DOTs, DMVs,

toll authorities, state revenue agencies, and private industry representatives.

Project DescriptionProject DescriptionProject DescriptionProject Description and Scopeand Scopeand Scopeand Scope

A high-level schematic of a mileage-based user fee (MBUF) system, provided in Figure 5, identifies

the key elements, participants (both governmental and private sector, plus vehicle owners),

processes, information flows, and activities. While not explicitly shown in the figure,

superimposed across all these MBUF elements and activities are several critical issues, such as

multiple choices to vehicle owners, privacy concerns, urban – rural equity, and costs.

Only a limited number of states, most notably Oregon, have fully explored and successfully

demonstrated some of these MBUF elements and issues. Moreover, it was shown in the initial

Oregon demonstration that conducting a demonstration with a relatively small number of

targeted and invited participants—focusing on decisions makers such as state legislators,

members of the state transportation commission, DOT executives, local officials, and members

of the press—is an effective outreach and educational endeavor. A “focused” pilot can

demonstrate to a group of state and local decision makers and key stakeholders how MBUF may

work, and that it can be a viable, fair, flexible and sustainable funding source for transportation.

Figure 5. High Level Schematic of MBUF System


7

There are numerous issues associated with a multi-state application of MBUF, of which only a

few have been thoroughly explored. All of these concerns are germane to the I-95 Corridor

Coalition states, and most if not all will have national ramifications as well. For example:

• Cross-state travel and the need, ability, and cost-effectiveness of charging out-of-state

drivers for miles driven in another state. This is a challenge for states along the eastern

seaboard given their relative small geographic size, permitting a driver to cross multiple state

lines in an hour or two. Statistics from the U.S. Census Bureau and other studies bear this out,

indicating significant levels of cross-state traffic along several segments within the corridor.

(Additional information on this is provided in Appendix A).

• Coordination and interoperability with toll

facilities—Most of the Corridor Coalition member

states have toll facilities, many of which serve

major corridors in these states (Figure 6).There

are several potential issues to be addressed in this

regard, including the extent to which mileage on

toll facilities should be subject to a mileage-based

user fee, the potential for synergies and

interoperability between MBUF processing and

tolling back office operations, and the ability to

use electronic toll data (e.g., E-Zpass as one example) to estimate out of state mileage.

• Role of DMVs in the administration of a MBUF system—DMV databases will likely fill a major

role in terms of enrolling participants, compliance efforts, and estimating out-of-state travel.

Moreover, some of the potential approaches for measuring mileage (e.g., manual odometer

readings) would likely result in significant DMV involvement, and may not be appropriate for

some DMVs due to their software capabilities and staffing.

• Various approaches for developing and setting per-mile rates—Previous pilots have used a

single “break even” per-mile rate; for example, the Oregon pilots used 1.56 cents per mile,

which is equivalent to an average fuel efficiency of 19 to 20 MPG with a state fuel tax of 30

cents per gallon. Consideration may be given to using a higher rate to help make up years of

“lost revenues” from the gas tax. There is precedence for higher per mile rates; for example,

toll facilities in the I-95 Corridor charge anywhere from 3.9 cents per mile (i.e., Massachusetts

Turnpike between the New York state line and Route 128 just outside of Boston) to 32.9 cents

per mile (for the section of the Massachusetts Turnpike east of Route 128 into Boston), with

the per-mile rate for toll bridges being even higher. Additionally, different per-mile rates may

be used for different types of vehicles (e.g., charge EV and PHEVs less per mile than gas

guzzlers as an environmental consideration). Varying rates based on location of the vehicle

registration (e.g., urban vs. rural) also needs to be further explored. With a mixture of rural

and urban interests in the I-95 multi-state grant, one possibility to be explored is the

feasibility of charging different rates depending on the classification of the census tract where

the vehicle is registered.

• Administrative costs and impacts on state finances—The I-95 Corridor Coalition grant and

its regional approach is also important in terms of minimizing the administrative and

Figure 6. Toll Plaza on I-95 Entering

Delaware


8

overhead costs associated with a MBUF system. For all of its shortcomings, the current fuel

tax mechanism is relatively inexpensive to administer.6 Administrative costs were examined

as part of the Corridor Coalition’s previous MBUF work, and other states have also examined

this issue. An Oregon study of likely administrative costs associated with a MBUF system

indicated that the cost per vehicle is very dependent on the number of vehicles in the system.

For example, the DOT operating costs were estimated at approximately 10 percent of the

total MBUF revenues with a system comprised of 100,000 vehicles; with the operating costs

decreasing to approximately 4 percent—in the neighborhood of the current gas tax—when

the MBUF system reaches 1 million accounts. Informal discussions with several vendors have

further confirmed this concept. Having multiple states participating in a MBUF system helps

to achieve this desired economy of scale in the fastest time possible. Having the private sector

significantly involved in administering a MBUF system is also an important consideration as

is relying on the existing administrative “structure” of tolling authorities. A related issue is the

effect MBUF may have on “cash flows” into a state’s treasury and the associated agency bond

ratings.

The I-95 Corridor Coalition is ideally situated to address these challenging issues that a regional,

and ultimately national, implementation of alternative

funding scenarios present. The I-95 Corridor Coalition

has a history of success, particularly with respect to

advancing the interoperability of technologies and

operational practices. For example, the Coalition’s

partnership with the Inter-agency Group (IAG) helped

advance the integration of various independent

systems that use the same technology into the E‑ZPass

system. The Coalition also supported the development

of legislation regarding toll enforcement reciprocity

through spurring dialogue across states and sharing

legislative language.

The Coalition’s current program structure, with membership comprised of 16 state DOTs and the

District of Columbia, as well as participation by related transportation agencies, organizations

and other stakeholders participating as affiliates, provides a unique environment to share

information from this project with agencies that, while not directly participating in the effort,

may nonetheless have a keen interest in the project activities and assessing the lessons learned

to enhance their consideration of MBUF. The approach outlined in this grant proposal is

grounded in agencies that have worked together successfully for over 20 years.

6 Per a 2010 I-95 Coalition study of MBUF, and based on information compiled from FHWA’s annual reports of highway

statistics, an average of 0.82 percent of motor fuel tax receipts have been used nationally for administrative or collection

expenses over the past decade. A November 2012 Reason Foundation report (Dispelling the Myths: Toll and Fuel Tax Collection

Costs in the 21st Century) notes that indirect costs, such as losses incurred at several levels of the process and taxes hidden in

the collection of revenues (some are even imposed on those exempt from the fuel tax program), suggest that the costs of

motor fuel tax collections may well be in the vicinity of 5 percent of the revenue collected.

The close proximity of the member

states, numerous toll facilities,

strong DOT and DMV leadership,

and experience with using variable

toll rates, all place the Coalition

member states in a strong position

to tackle MBUF implementation on

a regional basis.


9

Project VisionProject VisionProject VisionProject Vision, , , , GoalsGoalsGoalsGoals,,,, and Objectivesand Objectivesand Objectivesand Objectives

The overall vision for this effort is to lay the foundation for a viable mileage-based MBUF

approach for funding transportation improvements and enable a smooth transition from the

current gas tax to this more sustainable and user-based funding source. For this vision to become

reality, this grant proposes to address the goals and objectives outlined in Table 2. To

demonstrate how this grant aims to lay the foundation for a national MBUF approach, specific

actions are also listed in Table 2 and are further expanded in the next section

Table 2. Project Goals and Objectives

Goals Objectives Actions

• Address regional

issues necessary for

national adoption

and implementation

of MBUF.

• Create a low risk environment

to address cross state-issues.

• Balance the unique needs of

each state within a multi-

state framework.

• Create a multi-state and multi-

disciplinary MBUF Steering

Committee to guide project.

• Identify cost effective approaches

for estimating the out-of-state

mileage.

• Accommodate cross-state fund

transfers.

• Create a MBUF Operational

Concept Document for each

participating state.

• Increase public

acceptance of

MBUF.

• Educate the public about

transportation revenue

challenges and the MBUF

solution.

• Demonstrate the ease of use

and viability of MBUF.

• Address privacy concerns.

• Address equity issues.

• Implement a “focused” pilot in

several states.

• Provide choices for collecting and

reporting mileage data.

• Bring a diverse group of states

together to address various issues

(e.g., urban/rural, environmental,

congestion).

• Create a low-cost

framework to

administer MBUF.

• Identify cost-saving

opportunities (e.g., standards)

through a multi-state

approach.

• Address legislative barriers to

MBUF implementation.

• Include DMV and other key

stakeholders (e.g., tolling).

• Include the private sector.

• Explore potential interoperability

with tolling infrastructure.

• Establish initial standards,

protocols and business rules.

• Develop model legislation.

• Conduct a “vendor day.”

• Examine potential impacts on state

finances.


10

WorkWorkWorkWork Scope and ActivitiesScope and ActivitiesScope and ActivitiesScope and Activities

To achieve the goals and objectives outlined in Table 2, this multi-state grant application includes

two main components: Planning and Pre-Deployment Activities (Component 1) and Focused Pilot

(Component 2). Each are described in more detail below.

Component 1: Planning and Pre-Deployment Activities

These activities will lay the foundation for a state to explore mileage-based user fees in a low risk

environment. The scope of these planning activities will be from a “multi-state” perspective to

promote regional consistency and compatibility. This work will build on previous I-95 Corridor

Coalition activities including the aforementioned 2040 vision that outlines recommendations for

transitioning to a new financing system, and the work documented in the 2012 report— Concept

of Operations for the Administration of MBUF in a Multistate Environment.

Specific activities to be conducted will include the following:

• Develop and analyze potential mechanisms for accurately estimating out-of-state mileage

and accommodating cross-state transfers of MBUF funds.

• Analyze issues and identify potential business rules for optimizing MBUF revenues and

minimizing administration costs (e.g., rate setting, cooperation and interoperability with toll

facilities and DMVs, impacts on state finances and bonding issues). This will include a

comparison of projected net MBUF revenue streams with the likely future revenue streams

under the current gas tax mechanism

• Coordination with potential MBUF vendors and account managers, including a “vendor day”

(or multiple days) where these private sector entities can present their approaches and

services to the Coalition members, who in turn can ask questions.

• Address other key areas impacting

corridor and region wide consistency

and/or interoperability, such as

privacy.

• Develop a corridor-wide outreach

and education plan, and associated

materials.

• Develop Operational Concept

Documents for state-specific

“focused” MBUF pilots. The same

basic format will be used for each

state (Table 3); although specifics will

likely vary depending on needs and

objectives of each state. It is also

possible that some adjoining states

will conduct a single multi-state

focused pilot.

• Develop model state legislation for

advancing MBUF, including authorization for future demonstrations.

Table 3. High Level Outline of Operational Concept

Document for State-Specific Focused MBUF Pilots

• Goals and objectives (from the states’ perspective)

• How the state pilot will help address corridor-wide

issues and needs

• Stakeholders and their responsibilities

• Participants (targeted audience) and associated

agreements

• Mileage rates (perhaps different for each state;

perhaps varied by average EPA MPG rating), and

fuel tax credits

• Choices offered for reporting mileage and for

invoicing and “virtual payments”

• Onboarding and off boarding processes

• Evaluation approach, including potential criteria

• Operational scenarios, including transition to

larger, multi-state pilots in future


11

Component 2: Deployment, Operation and Evaluation State-Specific Focused MBUF Pilots

In addition to the planning effort and pre-deployment activities, the I-95 Corridor Coalition grant

application also includes a number of initial MBUF pilots. These “focused” pilots will be based on

the Operational Concept Document developed as part of the planning effort (Component 1).

Following are activities to be conducted as part of this project aspect:

• Pilot system architecture and requirements

• Request for proposal (RFP) and vendor solicitation, followed by a review of vendor

proposals and costs, selection of vendor(s), and vendor contracts and agreements

• Pre-pilot testing plans, testing, and approval to commence pilot

• Participant onboarding, pilot operations and administration, and participant off-boarding

• Evaluation plan, followed by the evaluation process and Final Report

• Implementation plans for next phase of the pilot

• Public outreach plan and associated materials specific to the pilot (and consistent with the

Corridor-wide outreach activities)

The basic operating parameters for these focused pilots are summarized in Table 4.

Table 4. Operating Parameters for the State-Specific Focused Pilots

• These pilots are “focused” in the respect that each pilot will consist of up to 50 light-duty

vehicles (i.e., passenger cars). The participants will be identified by each state and will likely

include senior DOT, DMV, and finance officials; members of transportation commissions; state

legislators; local officials; and possibly the press. In this manner, the focused pilot will

contribute to the overall education and outreach effort.

• The focused pilot will last for 4 months, with another 4 months following the pilot for

evaluation and a final report.

• Participants will not make any actual payments; although faux invoices, including estimated gas

tax credits, will be sent out on a recurring (e.g., monthly) basis.

• MBUF vendors will be selected by the participating state based on the vendor(s) to satisfy the

requirements and estimated costs.

• Data collected during the pilot (e.g., name, license, vehicle identification number, mileage [total

and/or by state]) will be collected and managed by the selected MBUF vendors and then

purged within 30 days following the completion of the pilot evaluation.

• Mature and proven technology for recording and reporting miles will be used.

With respect to the use of mature MBUF technology, a summary of current and near-term

mileage recording and reporting options is provided in Figure 7, along with the information

collected, the extent to which they might be provided by private entities and government

agencies, and the relative privacy considerations. Nearly all of these have been included in MBUF

pilots in Oregon, California, and Colorado.7

7 The “vehicle telematics” approach has not been included to date, due to reluctance on the part of the automotive industry.

Nevertheless, this approach is viewed as the long-term future for MBUF and will be addressed in subsequent phases of the I-95

Corridor Coalition effort.


12

It is envisioned that the focused pilots will primarily utilize the” mileage counter approach.”

This automated mileage reporting is accomplished via a mileage reporting device (MRD) that

plugs into the vehicle’s on-board diagnostic system (OBD-II) port (Figure 8) and uses the

vehicle’s data to measure mileage and fuel usage, and then transmits the information to the

account manager. Two types of MRD’s will likely be used:

• One with GPS capabilities, to provide location information for differentiating mileage by

state (and possibly by public and private roadways). The location information is also used

for other in-vehicle services (e.g., pay-as-you-drive insurance, driving evaluation, tracking

one’s teenage drivers, concierge-type services) offered by the private sector, such that

MBUF becomes a “value-added” to these other services.

• One with no location capability, only recording total (undifferentiated) mileage.

Both of these MRD-based approaches and the corresponding account management activities

will be provided by one or two private sector vendors, as selected by each participating state.

Moreover, it is assumed that the selected vendors will have already provided these MBUF

services and hardware elsewhere, thereby minimizing costs and risks.

Additional approaches may also be included in a focused pilot depending on the needs of the

state (including the desire to participate in a proof of concept endeavor in some instances) and

the costs involved relative to the budget. Other potential approaches8 to be considered include

the following:

• Smartphone—Automated mileage recording via a driver’s smartphone—and a MBUF

application installed on the phone.

8 Based on initial discussions with participating states and their DMV officials, a manual odometer reading will likely not be

included in the focused pilots

Figure 7. Methods for Recording and Reporting Miles


13

• Flat fee—A time-based (e.g., quarterly, annually) charge with no mileage reporting—in

essence, a fee for driving an unlimited number of miles during a specified time period as a

means to maximize privacy (i.e., no additional information is required other than that

required for vehicle registration).

• Innovative approaches—Technology is continuously evolving, with new concepts and

approaches being introduced seemingly on a daily basis. One potential new approach for

MBUF uses a “pay at the pump” model that utilizes a combination of toll tags (e.g., EZ-Pass)

and smart cards by which the vehicle is identified and several different types of secure,

personal transactions can be conducted via the driver’s smartphone during the typical 4

minutes of refueling time—in essence, a “virtual kiosk.” Potential transactions include retail,

user-based insurance, and DMV-related fees.

Addressing the Addressing the Addressing the Addressing the Requirements of Section 6020 of the FAST ActRequirements of Section 6020 of the FAST ActRequirements of Section 6020 of the FAST ActRequirements of Section 6020 of the FAST Act

Section 6020 of the Fixing America's Surface Transportation (FAST) Act, contains a provision

addressing the use of the grant funds (and these same elements are included in the NOFO). These

are summarized in Table 5. Additional information describing how the I-95 Corridor Coalition

grant addresses these various requirements is provided in Appendix A.

Figure 8. Sample MRD Installation Instructions

(Source: Oregon 2012-2013 pilot; part of the information sent to participants with MRD)


14

Table 5. FAST Act Section 6020 Requirements and the I-95 Corridor Corridor’s Approach

Implementation,

interoperability, public

acceptance, and other

potential hurdles

With respect to public acceptance, outreach and education plans

and the associated materials will be developed for the corridor

as a whole and for the state-specific pilots. The pilots themselves

are also a significant aspect of the public acceptance effort.

Several interoperability issues will be explored, including cross-

state mileage and coordination and compatibility with toll

facilities.

Protection of personal privacy A major issue for a mileage-based user fee system. The Coalition

will build upon the lessons learned from a CH2M study on the

subject of privacy in a MBUF system (e.g., no GPS mandate,

specified protection (including legislation) of personally

identifiable information, provisions on how long data may be

retained, sharing of data, and aggregation.)

Use of independent and

private third-party vendors to

collect fees and operate the

system

Building on the growing private sector interest in MBUF – where

MBUF is a “value-added” to other offered services – the

Coalition will host a “vendor day” during which private sector

providers can present their capabilities to Coalition members. It

is envisioned that all the hardware account management

services for the focused pilots will be provided by private

vendors.

Market-based congestion

mitigation, if appropriate

By not mandating location-based mileage reporting technology

(so as to protect privacy), full congestion pricing may not be

feasible. Varying per-mile rates by time of day will be examined.

Equity concerns, including the

impacts on different income

groups, geographies and the

relative burdens on rural and

urban drivers

The planning phase, and possibly the focused pilots, will examine

the concept of charging different per-mile rates based on

classifications of the census tract where the vehicle is registered

(e.g., urban, rural, mixed), as well as the average MPG (or MPGe)

of the vehicle.

Ease of compliance for

different users of the system

Compliance is a multi-dimensional issue and will be addressed in

the grant application through a combination of activities,

including education and outreach, procedures for auditing and

reconciliation of accounts, and enforcement (using the

Coalition’s experience in guiding toll enforcement reciprocity.)

Reliability and security of the

technology

Another compliance-related consideration, along with privacy.

Selection of pilot vendors will, in part, be based on their proven

record of providing reliable and secure technology.

Flexibility and choices,

including the ability to select

from various technology and

payment options (“may”)

User choice (e.g., providing both a location-based on non-

location based option for automated mileage reporting; possibly

other approaches) will be one of the key elements of the pilots


15

Table 5. FAST Act Section 6020 Requirements and the I-95 Corridor Corridor’s Approach

Cost of administration

(“may”)

The cost of transitioning to and then administering a MBUF

system will be front and center in this project. Having the private

sector significantly involved in administering a MBUF system is

an important consideration, as is relying on the existing

administrative “structure” of tolling authorities. In addition, the

I-95 Coalition grant will explore the effect MBUF may have on

“cash flows” and the associated agency bond ratings.

Ability to audit and enforce

user compliance (“may”)

Refer to discussion on compliance

Geographic diversity This grant will constitute the first MBUF demonstrations along

the eastern seaboard.

Evaluation and Implementation PlanEvaluation and Implementation PlanEvaluation and Implementation PlanEvaluation and Implementation Plan

Evaluation of Component 1 (Planning) will be based on the achievement of the goals and

objectives outlined in Table 2 and the applicable provisions (i.e., the “shalls” and “mays”) of

Section 6020 of the FAST Act.

The evaluation of Component 2 (Focused Pilot) will be based on the pilot-specific goals and

objectives (as defined in the Operational Concept Document) along with the applicable provisions

(i.e., the “shalls” and “mays”) of Section 6020 of the FAST Act. Preliminary evaluation criteria for

the MBUF pilots will be included in the Operational Concept Document, and will subsequently be

further detailed in an Evaluation Plan to be developed and approved prior to the start of the

pilots. Formal evaluations of the state-specific focused pilots will also be conducted by an

independent third party (i.e., an entity not involved in the design, development, or operation of

the pilot system). Potential evaluation activities will likely include the following:

• Participant surveys—before, during, and after the pilot—to ascertain their experience with

the system and any changing attitudes towards the mileage-based concept

• Interviews with the vendors, the consultant team (responsible for developing, testing and

overseeing the pilot) and other stakeholders as to their experiences, challenges encountered,

and lessons learned

• Review of pilot data, including pre-pilot test results, mileages reported and associated faux

invoices, and help desk statistics

• Interviews with other stakeholders from non-participating Coalition member states to

address implementation applicability outside the initial pilot states, which will reflect a key

mantra of the I-95 Corridor Coalition that every project is designed and managed to benefit

ALL Coalition members

The work covered in this application is viewed as a critical starting point laying the foundation for

a viable mileage-based user fee approach for funding transportation improvements. An

Implementation Plan will be developed that addresses the next phase of this endeavor, with the

overall aim of progressing the participant states from planning, expanding “focused” pilots into


16

larger demonstration pilots, and bringing in more states to explore multi-state pilots and

demonstrations.

The intention is to apply for a subsequent grant in next year’s FAST Act 6020 application round.

The Implementation Plan will be developed near the end of Component 1 (planning activities)

and will address the work necessary to translate the results and conclusions from this initial grant

into a broader multi-state pilots. The plan will also identify the associated goals and objectives of

the larger pilot, define the series of activities to be undertaken to develop and implement the

multi-state pilot (including subsequent expansion), identify the participating states and other

stakeholders, estimate the costs and likely match contributions, and provide an initial schedule.

The Implementation Plan will be updated later in the project to reflect the results of the state-

specific pilots, including next steps for the participating and other interested states.

Legislative SupportLegislative SupportLegislative SupportLegislative Support

Currently, there is no explicit legislative support for the MBUF-related work addressed in this

application—although none of the participating states are facing any legislative or executive

obstacles, either. Recognizing that legislative support will be crucial for moving the planning

concepts and focused pilot efforts forward to develop and deploy larger and multi-state MBUF

demonstrations – possibly accommodating the actual payment and cross-state transfer of

monies – and then conceivably moving towards a mandated MBUF system in the longer term,

the I-95 Corridor Coalition’s application addresses legislative support in several ways:

• Legal issues as previously addressed in the 2010 Coalition study

• Deployment of focused state-specific pilots, which may include state legislators and other key

decision makers as participants (as part of the broader education and outreach effort)

• Development of model state legislation addressing and advancing MBUF

The success of a mileage-based user fee demonstration program depends not only on the

technical merits of the system, but also the level of public acceptance. The most effective way to

ensure that the proper choices and protections are in place is to include them in enabling state

legislation. State legislation should lay out specific parameters for the state DOT, DMV, and other

public entities to adhere to in the areas of privacy and user choice. First and foremost, public

acceptance is not possible without protecting personally identifiable information.

In addition to privacy protections, legislation ideally should include the authorization for pilots or

demonstration projects that test the system and technology for reliability, ease of use,

interoperability, cost of administration and the potential for fraud. The legislation must also

clarify that any fee imposed is in lieu of, and not in addition to, the current gas tax. Authorization

of actual MBUF payments being made by participants should also be addressed as a way to truly

test and evaluate the system.

State legislation should also create a task force, advisory committee, or equivalent organization

to manage the specifics of the program and report back to the legislature. The legislation should

stipulate that this group will be a bipartisan-appointed collection of transportation experts who

are willing to attend public meetings. They should have control over how the pilots or

demonstration projects are run and what the rates should be.


17

SSSStaffing Description and Granttaffing Description and Granttaffing Description and Granttaffing Description and Grant ManagementManagementManagementManagement

Delaware DOT and the I-95 Corridor Coalition

will administer the grant funds. The

participating states and their involvement are

shown in Figure 9. The organizational

framework for managing the grant is shown

in Figure 10. As shown, the project will be

managed by Jennifer Cohan, Secretary of

Transportation for Delaware, and Patricia

Hendren, Executive Director of the I-95

Corridor Coalition, as co-chairs of the MBUF

Steering Committee.

Jennifer L. Cohan was appointed in January

2015 to be only the third woman to lead the

Delaware Department of Transportation

after serving as the Director of the Delaware

Division of Motor Vehicles since 2007. Her

state public service career has spanned over

25 years, including working with the

Delaware State Legislature within the Office

of the Controller General. Secretary Cohan

currently serves as the Chair of the I-95

Corridor Coalition's Executive Board.

Patricia (Trish) Hendren has over 18 years of

experience working with a range of State

DOTs, MPOs, and transit agencies. The focus of her career has been turning data into useful

information and demonstrating transportation investment needs to external stakeholders. She

recently served as Director of the Office of Performance at the Washington Metropolitan Area

Transportation Authority (WMATA).

The MBUF Steering Committee will be formed consisting of representatives of the participating

states and other key stakeholders as listed in Table 6. The Steering Committee is designed to

bring together a wide-range of perspectives and expertise to create a robust thoughtful group to

guide the grant activities. Brief bios of the Steering Committee Members are provided in

Appendix B. The MBUF Steering Committee will be responsible for all final decisions and

approvals. The Steering Committee is designed to balance the unique needs of each state with a

multi-state perspectives. It is envisioned that this group will actively discuss and evaluate

solutions to implementing MBUF in a regional context. In addition, an active Steering Committee

will create the venue to keep agencies aware of grant activities as the project progresses. Finally,

representatives from non-participating states will be invited to meetings of the MBUF Steering

Figure 9. Participating States in Grant


18

Committee to learn more about this alternative funding approach and lay the groundwork for

future participation.

Table 6. I-95 Corridor Coalition MBUF Steering Committee Members

• Jennifer Cohan (Co-Chair), Secretary of

Transportation, DelDOT

• David Nicol, Assistant Director for

Engineering Support, DelDOT

• Hugh Curran, Director of Finance, DelDOT

• Scott Vien, Director of the Delaware

Division of Motor Vehicles (DMV)

• Tom Maziarz, Chief – Policy & Planning,

CTDOT

• Bill Seymour, Chief of Staff, CT DMV

• Zachary Hyde, CTDOT

• Patrick Jones, Director & CEO, International

Bridge, Tunnel and Turnpike Association

• Mark F. Muriello, Deputy Director Tunnels,

Bridges and Terminals Department, The

Port Authority of New York and New Jersey

• Patricia Hendren (Co-Chair), Executive

Director, I-95 Corridor Coalition

• Victoria Sheehan, Commissioner, NHDOT

• Richard Bailey, Assistant Commissioner, NH

Department of Safety

• Marie Mullen, Director of Finance, NHDOT

• Scott Shenk, Vehicle Registration Manager,

PennDOT

• Roger Cohen, Policy Director, PennDOT

• Larry Shifflet, Director for the Center for

Program Development and Management,

PennDOT

• Emma Lowe, Special Assistant to PennDOT

Secretary of Transportation (L. Richards)

• Costa Pappis – Vermont Agency of

Transportation

Figure 10. Organizational and Management Framework for Grant


19

CH2M will be responsible for the day-to-day project management and technical activities,

including the planning effort and developing and managing the state-specific focused pilots. The

MBUF pilot vendors will also be managed by CH2M with the vendors being under contract to

CH2M (subject to the selection of vendors by the individual states), CH2M was the lead

consultant conducting similar activities for the successful 2011-2013 pilot in Oregon. The firm is

also conducting a study on approaches for protecting privacy for the western states. CH2M’s

project manager will be Louis G. Neudorff, P.E., who also served as project manager for the

aforementioned Oregon work. Mr. Neudorff is located in Virginia, and will be assisted by other

CH2M staff and consultants located in the corridor as described (with resumes) in Appendix B.

Schedule and DeliverablesSchedule and DeliverablesSchedule and DeliverablesSchedule and Deliverables

A preliminary bar chart schedule is provided in Figure 11. The preliminary list of deliverables is

provided in Table 7 (assuming a start date of October 1, 2016).

Table 7. Preliminary List of Deliverables for the I-95 Corridor Coalition MBUF Activities

Deliverable Approximate Due

Date

508

Compliant?

Program Management Plan (including detailed schedule) October 15, 2016 No

Status Reports (Internal to MBUF Steering Committee) Monthly No

Technical Memorandum—Out-of-State Travel March 1, 2017 No

Technical Memorandum— MBUF Administration (e.g.,

business rules, rate setting, interoperability with toll

facilities, impacts on state finances)

May 1, 2017 No

Technical Memorandum—Other Issues Impacting Corridor-

wide MBUF Consistency (e.g., privacy) January 15, 2017 No

Outreach and Education Plan (Corridor-wide) December 1, 2016 No

Outreach Materials Throughout per plan No

Model State MBUF Legislation July 1, 2017 Yes

Operational Concept Document for State-Specific Pilots February 1, 2017 No

Outreach Plans for Focused Pilots June 1, 2017 No

Outreach Materials for Focused Pilots Throughout per plan No

Pilot System Architecture and Requirements April 1, 2017 No

Vendor RFP and Solicitation May 1, 2017 No

Executed Vendor Contracts July 1, 2017 No

Pilot Testing Plans June 1, 2017 No

Pilot Evaluation Plans July 1, 2017 No

Implementation Plans May 1, 2017, and

March 1, 2018 No

Final Pilot Reports April 1, 2018 Yes

Annual Reports to FHWA October 1, 2017 Yes


20

Funding Description Funding Description Funding Description Funding Description

The activities for the multi-state planning effort and pre-deployment activities (Component 1),

and their associated costs, are listed in Table 8. The activities for the focused MBUF pilots

(Component 2), and their associated costs, are listed in Table 9. The total cost – including the

Component 1 planning activities and focused pilots (Component 2) in multiple states– is

$2,980,000.

Figure 11. Preliminary Schedule


21

Table 8. Activities and Costs for Multi-State Planning and Pre-Deployment Activities

Component 1 Scope Item Cost

Develop and analyze potential mechanisms for accurately estimating out-of-state

mileage and accommodating cross-state transfers of MBUF funds $180K

Analyze issues and identify potential business rules for optimizing MBUF revenues

and minimizing administrative costs (e.g., rate setting, cooperation and

interoperability with toll facilities, impacts on state finances and bonding issues)

$170K

Coordinate with private sector vendors/”Vendor Day” $25K

Address other key areas requiring and/or impacting corridor-wide consistency and/or

interoperability, including privacy approaches. $70K

Conduct corridor-wide outreach and education plan and associated materials $90K

Develop Operational Concept Documents for state-specific “focused” MBUF pilots

(same basic format to be used for each state, although specifics will vary by state) $200K

Develop model state legislation for advancing MBUF $45K

Conduct overall project governance and management $100K

TOTAL $880K

Table 9. Activities and Costs for Implementing and Managing “Focused” MBUF Pilots

Component 2 Scope Item Cost

(per state)

Develop pilot system architecture and requirements. Develop vendor RFP and

solicitation. Review vendor proposals and costs. Develop and enter into vendor

contracts and agreements

$20K

Develop test plan plans, conduct pre-pilot testing, and recommend approval to

commence pilot

$20K

Conduct participant onboarding, pilot operations and administration, and

participant off-boarding.

$180K

Develop evaluation plan, evaluation, and final report $80K

Develop implementation plan for next phase $20K

Conduct Pilot and state-specific public outreach and education plan and materials $50K

Conduct program management $50K

TOTAL per State $420K

TOTAL for 5 States (with one state still to be determined) $2,100K


22

Match Information Match Information Match Information Match Information

Table 10 summarizes how the participating states will provide the remaining 50 percent non-

federal share. Letters of commitment for these state matches are provided in Appendix C9,

along with other letters of support. Based on the proposed state match, $1,490,000 is

requested in federal grant money.

Table 10. Proposed State Match and Federal Share

State Hard Match (non-

federal state funds) Soft Match (Type) Total Match

Delaware $290K -0- $290K

Pennsylvania $290K -0- $290K

Connecticut $300K -0- $300K

New Hampshire -0- $580K (Toll Credits) $580K

Vermont $30K -0- $30K

TOTAL $910K $580K $1490 K

Risk Risk Risk Risk AssessmentAssessmentAssessmentAssessment

It is the I-95 Corridor Coalition’s opinion that the risk of the proposed approach is very low. The

Coalition has a history of successfully addressing multi-state interoperability issues involving

operations and tolling. Additionally, as previous discussed, the Coalition will not be starting this

effort from scratch, building upon 2010 effort and the multi-state MBUF Concept of Operations.

The executive management for this endeavor—specifically, Secretary Cohan and Dr. Hendren—

is thoroughly committed to making this project a success, as are the members of the MBUF

Steering Committee. Additionally, the members of our consultant team are leaders in planning,

developing and managing successful MBUF pilots, including all the various issues associated with

this new funding paradigm. The emphasis on proven MBUF technology and experienced vendors

for the state-specific focused pilots will also help to minimize potential risks.

The only potential risk is that some of the participating states may not be able provide a full

match, thereby reducing the total available funding. Should that occur, the Coalition will simply

reduce the scope, coordinating with FHWA, to match the available funding.

9 The Connecticut amount is documented in an email and confirmed verbally.


23

OOOOrganizational Informationrganizational Informationrganizational Informationrganizational Information

Delaware DOT is submitting this grant application on behalf of the I-95 Corridor Coalition10. The

required standard forms (424 series and Lobbying Form) are attached. Additional information

requested in the NOFO are provided below:

• Exceptions – DelDOT and the Coalition reserve the right to review and negotiate terms and

conditions before accepting an award.

• Intellectual property – It is anticipated that the pilot vendors will utilize pre-existing

intellectual property (e.g., MBUF hardware and software), and that any additional

development or customization included as part of this project will be minimal. . Also, the

previous I-95 Coalition Reports on MBUF (from 2010 – 2012) will be used as a starting point

for this effort.

• A-133 Single Audit and, if so, the date that the last A-133 Single Audit was completed –

Delaware Department of Transportation’s most recent single audit is for FY15. A link may be

found here:

http://auditor.delaware.gov/Reports/FY2016/State%20of%20Delaware%20Fiscal%20Year%

202015%20Single%20Audit%20(OMB%20Circular%20A-133)%20Reporting%20Package.pdf

The University’s most recent single audit is for FY15. There were no finding. A link may be

found here: http://www.usmd.edu/usm/adminfinance/finafair/sar.html

• Conflicts of Interest – There are no actual or potential personal or organization conflicts of

interest in this application.

• Accounting system, purchasing system, and/or property control system – The Delaware

Department of Transportation utilizes the state financial accounting system (First State

Financials) which was implemented in 2010, we have no reason to believe that there are

any control weaknesses or open issues with the accounting system. Responsibility with the

system resides with the State Division of Accounting, review and audit of system controls

resides with the State Auditor of Accounts. The University’s accounting system has not yet

been approved. The University changed accounting systems in 2014. The University’s

purchasing system and property control system have both been reviewed and approved.

• Terminated Contracts – None

10 As with other I-95 Corridor Coalition projects funded with federal and state finds, the contracting

entity will be the University of Maryland. However, the Delaware will be responsible for managing the

grant, including coordinating the matching funds from the participating states.

Required Forms

• Standard Form 424 (Application for Federal Assistance)

• Standard Form 424A (Budget Information for Non-Construction Programs)

• Standard Form 424B (Assurances for Non-Construction Programs)

• Grants.gov Lobbying Form

A-1

Appendix AAppendix AAppendix AAppendix A————How the How the How the How the Proposed Scope and Work Activities Address Items Proposed Scope and Work Activities Address Items Proposed Scope and Work Activities Address Items Proposed Scope and Work Activities Address Items

in Section 6020 of the FAST Act in Section 6020 of the FAST Act in Section 6020 of the FAST Act in Section 6020 of the FAST Act

Section 6020 of the FAST Act contains a provision addressing the use of the grant funds (and

these same elements are included in the NOFO). The proposed scope and work activities included

in the Corridor Coalition’s grant proposal address many of these as summarized below.

The implementation, interoperability, public acceptance, and other potential hurdles to

adoption: This requirement has many dimensions. With respect to public acceptance, outreach

and education are an important component of any paradigm change. As a starting point, it may

be necessary to educate drivers on how the transportation system is currently financed (e.g., the

fact that the gas tax is not a percentage of the fuel price but rather a fixed amount per gallon,

and that the gas tax is typically not indexed to inflation), and the resulting loss of potential

revenues versus highway use over time has negatively impacted the performance of the

transportation network. The outreach effort then can focus on why a mileage-based user fee is

necessary to eliminate these funding shortfalls, while also being fair and accommodating any

privacy concerns. The proposed approach includes the development of an outreach plan – for

both corridor-wide use and for state-specific use in the context of the focused pilots – followed

by the development of education and outreach materials (e.g., web site, brochures, FAQs,

presentations, videos11) The focused pilots are themselves a form of outreach, helping to

overcome potential political and institutional hurdles.

Many of the multi-state planning activities concentrate on interoperability issues in terms of

potential synergies with toll operations, coordination with DMVs, and use of their databases in

support of MBUF, and charging for out-of-state mileage. The last interoperability issue – charging

for out-of-state mileage – is a major one for many of the Coalition member states given the

significant number of cross-state trips in the corridor, as evident from Figure B-1. The U.S Census

statistics also bear this level of cross-state travel out with several of the coalition member states

(Delaware, District of Columbia, Maryland New Hampshire, New Jersey) having greater than 10%

of in-state residents working in other states, and /or in-state workers residing in other states.

A straightforward technical solution for identifying cross-state mileage would be to collect

location data with mileage data, as was assumed in the previous (2010-2012) I-95 Corridor

Coalition Study on MBUF. However, experience in Oregon and recent research has shown a

strong public resistance to having location-based technology mandated for their vehicles12. Given

this, we cannot assume that every vehicle will be equipped with location technology to

differentiate the mileage by state. It will therefore be necessary to estimate the amount of out

of state mileages based on other available data, such as using those GPS-equipped vehicles as a

representative sample, the cooperative agreements and data from the International Registration

Plan (IRP) and the International Fuel Tax agreement (IFTA) (although these only address heavy

vehicles, and may not represent the level of out-of-state mileage for light duty vehicles), data

from toll tags (although not every state has toll plazas, nor are they present along all the

roadways in the states that do have tolls), possibly TRANSMIT data (which uses toll tags for

11 An example of the Oregon video can be found at https://www.youtube.com/watch?v=brkWzWtqdJk 12 NCHRP Synthesis Report – 487: “Public Perception of Mileage-Based User Fees”

APPENDIX A—HOW THE PROPOSED SCOPE AND WORK ACTIVITIES ADDRESS ITEMS IN SECTION 6020 OF THE FAST ACT

A-2

measuring travel times, is present on many roadways in several states, but will likely require

software modifications), or some combination of data sources. A key result of the grant work will

be clearer insights into how to handle out-of-state mileage—a must if MBUF is to be

implemented nationally.

Protection of personal privacy: Privacy is a critical issue for a mileage-based user fee system. A

2016 NCHRP Synthesis Report 487, Public Perception of Mileage-Based User Fees” – analyzed

various sources of information on public opinion about mileage fees, including qualitative

research studies such as focus groups, quantitative public opinion surveys, and media stories

covering mileage fees. Privacy was a prominent theme throughout, with a number of the

summary reports highlighting privacy concerns as one of the participants’ key objections to a

MBUF system. Participants were most alarmed by technology that collected data on the location

or time of travel, but even simple odometer-based systems raised concern. People worried about

Figure B-1. Major Trip Ends Involving Cross-state Travel

(Source: Northeast Corridor Intercity Travel Study, September 2015)


A-3

being “tracked,” and many studies quoted participants using the term “Big Brother.” One fear

was that the government or firm collecting the mileage would use the location data, even if they

were not supposed to. Specific fears were that the police would use the travel data or that the

information would be sold if a private firm was used to administer the system. Some people

worried that the data would not be secured and could be stolen. Others talked about a “slippery

slope” scenario in which the government would initially promise not to track vehicles but would

later change the policy to permit tracking.

Based on recent pilots and research, the Coalition’s approach will be to address privacy from the

following perspectives:

• Not mandating location-based technology and provide choices, including at least one that

does not require location technology. Also consider a flat fee approach that requires no

mileage reporting for those individuals who have significant privacy concerns (and perhaps a

bit of paranoia)

• Control over the types of information collected (e.g., the data collected and processed by the

mileage reporting and data collection functions),

• How this information is used and shared with other entities, both the government and private

sector (e.g., what information is transmitted to account managers and to the government;

under what specific circumstances may Personally Identifiable information (PII) be released)

• How long the data are retained (e.g., by data collectors, account managers, and the

government), and the type of consent required for the data be retained for a longer period

• Levels of data aggregation, and the concern that such information may be de-aggregated

using other available databases

• Security of the information

Such approaches, while motivated mostly by privacy concerns, also help address the “may”

provisions of flexibility and user choice. The recommendations and lessons learned from these

other efforts will be brought to bear during this project (e.g., corridor-wide consistency issues,

model State Legislation, vendor requirements public outreach).

Use of independent and private third-party vendors to collect fees and operate: The 2010

Corridor Coalition study on VMT fees noted the potential role of the private sector, using the

experience of the successful relationships between toll agencies and the private sector for back

office operations and other services. The private sector is showing increasing interest in MBUF,

in part, because they see it as a marginal-cost addition to larger platform offerings such as pay-

as-you-drive insurance and other telematics-related in-vehicle services. Moreover, reliance on

the private sector is likely the optimum approach for minimizing administrative costs. Current

vendors providing MBUF hardware (plug-in mileage reporting devices) and MBUF account

management activities include Azuga, IMS, Sanef, Brisa, and Verizon. Other entities such as

Verdeva and Vehcon also offer MBUF approaches. To enhance understanding of how each

technology approach can work, a key activity under this grant will be the hosting of a “vendor

day” during which private sector providers can present their capabilities to coalition members.

Based on the information provided during the “Vendor Day” and the vendor responses to a

solicitation (including costs), each I-95 agency participating in the “focused” pilot will select which

private sector company (or companies) will provide what services for their state.


A-4

Market-based congestion mitigation if appropriate: Pricing is an effective form of demand

management. In fact, several of the toll facilities in the corridor utilize such an approach (e.g., the

tolls for the Hudson River Crossings operated by the Port Authority of NY/NJ are higher during

peak hours (6-10 AM, 4-8 PM)). However, congestion mitigation will be difficult to implement in

a MBUF system. Congestion pricing generally requires knowledge of the vehicle location,

something that is fairly straightforward with a toll-based system with gantries recording

locations. Location information is possible with a MBUF system; but mandating such a location-

based approach is likely to raise significant privacy concerns and become an insurmountable

obstacle for many states (and possibly the nation) to overcome. A simpler approach could be to

impose varying rates by time of day regardless of where a vehicle is located. Given the demand

management benefits of varying rates, several states involved in this grant application want to

explore how market-based mitigation could be incorporated into a MBUF system. This option will

be further examined in coordination with vendors during the focused pilots.

Equity concerns (urban/rural): Much of the I-95 Corridor is very urban and densely populated,

but there is also a significant rural population in all the member states. Differences in driving

habits (e.g., number of trips, average length of trips) exist between urban and rural residents,

and questions of fairness and equity with a mileage-based user fee in this regard is noted as a

major concern.13 The urban/rural make-up of Pennsylvania and New Hampshire, two states

interested in conducting focused pilots, will provide the “laboratory” to further explore this issue.

Other potential equity issues resulting from a shift to a mileage-based approach from a gas

consumption scheme include income inequality (and some pundits have labeled the current gas

tax as “regressive”) and environmental concerns (i.e., while owners of EVs and other highly fuel

efficient vehicles should be paying for their use of the roadway network; is it fair that they should

pay the same amount as the owners of Hummers that use more gas and have higher emissions).

One possible approach for addressing such issues is to establish and charge different per-mile

rates based on classifications of the census tract where the vehicle is registered, the average MPG

(or MPGe) of the vehicle as determined by the EPA, or some combination. This concept will be

examined as part of the planning effort and possibly in the focused pilots.

Ease of compliance and Reliability and security of technologies: Compliance is a multi-

dimensional issue and will be addressed in the grant application through a combination of several

activities, including:

• Education and Public Outreach – This includes providing information to current and future

users regarding the MBUF system functions and operations (e.g., the necessity for the

mileage-based user fee, per mile rates, choices for complying, frequently asked questions),

and ongoing relationship management. This will help ensure that the public understands the

problems addressed by MBUF and how the system works, thereby promoting transparency.

Public outreach and education is an integral part of the Coalition’s grant application and will

build on successful techniques used in prior demonstration pilots. In addition, the focused

pilot is in itself an effective outreach and educational endeavor that demonstrates to a group

of state and local decision makers and key stakeholders how MBUF may work, and that it can

be a viable, fair, flexible and sustainable funding source for transportation.

13 NCHRP Synthesis Report – 487: “Public Perception of Mileage-Based User Fees”


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• Audit/Reconciliation – It will be essential to provide a clear, traceable reporting structure to

support audit activities, including (but not limited to) comparing road usage data with

revenue collection and checking to ensure the system had correct vehicle data in the

transaction, that the calculated charge was accurate, and that customer accounts were

processed correctly. This issue will be addressed as part of the various coordination efforts

during the project, including toll agencies in the corridor (who regularly do this as a matter of

recourse), state DMVs, and the private sector which has similar compliance and audit

concerns for its in-vehicle / telematics offerings. The Steering Committee is designed to bring

together the stakeholders who are necessary to ensure that satisfactory audit/reconciliation

will occur.

• Enforcement Activities – These may include checking DMV registration information to

identify vehicles subject to MBUF and whether the owners and lessees of these vehicles have

set up an account and are reporting mileage, and monitoring these vehicle owners for

compliance, including charging fees and penalties for noncompliant behavior (e.g., tampering

with the data collection function, false reporting). The I-95 Coalition will bring its experience

guiding toll enforcement reciprocity to the MBUF discussion. In addition, the Steering

Committee is designed to ensure DMVs are actively involved in the MBUF work performed

under this grant.

• Reliability and Security of Technology – Compliance is greatly aided by reliable and secure

(i.e., tamper-proof) hardware and software. Current technology can identify when the MRD

has been removed or otherwise has malfunctioned or has been disconnected. This issue will

be part of the coordination effort with the private sector during the focused pilots. It can also

be assumed that the recommended criteria for selecting MBUF vendors – as determined by

the Steering Committee – will include ensuring reliable and secure hardware and software.

In addition, during the “Vendor Day,” technology providers will be specifically asked to

demonstrate how their approach will address reliability and security. It is important that any

MBUF system make evasion and avoidance difficult, and that it do so in a cost-effective

manner. Vehicle owners and lessees paying the mileage-based user fee will want to ensure

all such individuals pay their fair share. They will not tolerate a system that permits a

substantial number of free riders or scam artists, or a mileage-collection technology that can

be easily tampered with.

Cost of administering the system: The cost of transitioning to and then administering a MBUF

system will be front and center in this project. Previous work has concluded that having at least

1 million vehicles is a tipping point for cost/benefit of a MBUF system. A multi-state pilot has a

solid chance to getting to the 1 million vehicle mark. In the interim period, before a 1-million

person plus system becomes a reality, the proposed planning activities will include looking at the

potential impacts on state finances. Having the private sector significantly involved in

administering a MBUF system is also an important consideration as is relying on the existing

administrative “structure” of tolling authorities. In addition, the I-95 Coalition grant will explore

the effect MBUF may have on “cash flows” and the associated agency bond ratings. The projected

net MBUF revenue streams will also be compared to the project revenues from the current gas

tax mechanism.

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Appendix BAppendix BAppendix BAppendix B————Brief BiosBrief BiosBrief BiosBrief Bios

Jennifer L. Cohan was appointed in January 2015 to be only the third woman to lead the

Delaware Department of Transportation after serving as the Director of the Delaware Division of

Motor Vehicles since 2007. Her state public service career has spanned over 25 years. Jennifer

has worked in the capacity of Financial/Program Manager at the

Department of Natural Resources and Environmental Control (DNREC)

managing the state's Clean Water Program. Jennifer has also worked

with the Delaware State Legislature within the Office of the Controller

General. Ms. Cohan has also held an array of leadership positions

within the Delaware Department of Transportation in the areas of

Planning, Finance, and Motor Carrier Safety. She is an adjunct professor

at Wilmington University, teaching leadership and public policy in the

Master's program. Secretary Cohan currently serves as a member of

the AASHTO Board of Directors, and serves as the Chair of the I-95

Corridor Coalition's Executive Board, the Diamond State Port

Corporation Board of Directors, the Northeast Corridor Commission, the Northeast Association

of State Transportation Officials, Transportation and Climate Initiative, and Transportation

Research Board Executive Committee and is an executive member of the National Transportation

Research Board.

Patricia (Trish) Hendren was recently appointed as the Executive Director of the I-95 Corridor

Coalition. Trish has over 18 years of experience working with a range of State DOTs, MPOs, and

transit agencies. The focus of her career has been turning data into useful information, helping

agencies overcome internal barriers to data-based decision making, and

demonstrating transportation investment needs to external stakeholders.

She recently served as Director of the Office of Performance at the

Washington Metropolitan Area Transportation Authority (WMATA). Prior

to this position, Dr. Hendren developed WMATA’s 10-year $11.4 billion

capital needs inventory and established a cross-agency approach to

prioritize these needs for WMATA’s six year capital program and the

American Recovery and Reinvestment Act. To improve current practice

and stay abreast of national issues, Trish has been actively involved in the

TRB since 2001 chairing or serving on committees, research panels and

conference planning efforts. She recently outlined practical insights to help organizations start

down the performance management path in the TR News article “Moving from Reactive to

Strategic: A Transit Agency Perspective.” Dr. Hendren’s contributions to the field and focus on

mentoring were recognized in her selection as the 2014 WTS -DC Chapter Woman of the Year.

APPENDIX B—BRIEF BIOS

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Victoria Sheehan was sworn in as the Commissioner of the New

Hampshire Department of Transportation on October 19, 2015, where

she oversees Victoria Sheehan oversees a $650 million state agency of

over 1,600 employees dedicated to providing safe and efficient

transportation systems. Ms. Sheehan brings both transportation

engineering and management experience in projects and programs to

her role as Commissioner. In her years as a dedicated public employee,

she has worked as a resident engineer in bridge maintenance and as a

project manager with a record of delivering contracts on-time and on-

budget. She has extensive experience in asset and performance management. In her previous

position as Manager of Strategic Planning and Highway Performance at the Massachusetts

Department of Transportation, Ms. Sheehan was responsible for the Highway Division’s $5 billion

capital plan and annual $600 million operating budget.

Richard C. Bailey, Assistant Commissioner, New Hampshire Department of Safety, is the first

person to be appointed to a newly added Assistant Commissioner position within the

Department of Safety. This position was created in 2015, and is appointed by the Governor, with

the consent of the Executive Council to serve a term of four years. He served as the Chief

Information Officer for the NH Department of Information Technology from 2004 to 2010. In

2010 he was appointed as the Director of the Division of Motor Vehicles within the Department

of Safety where he served until his recent appointment as Assistant Commissioner.

David A. Nicol, PE, is the Assistant Director for Engineering Support at the Delaware Department

of Transportation. In that position, he leads a staff responsible for environmental studies,

stormwater management, hazardous materials, pavement management, and materials sampling

and testing. David previously held engineering, planning, management, and executive positions

in the Federal Highway Administration’s Division offices in Georgia, Delaware, California, and

Colorado, including Chief Operating Officer in California and Division Administrator in Colorado.

He also held the two Senior Executive Service positions as the Director of the Office of Safety

Design and Office of Federal-aid Program Administration for FHWA in Washington, DC.

Hugh Curran has served as the Director of Finance for the Delaware Department of

Transportation since 2013. Mr. Curran has more than 30 years of financial management

experience in both the private and public sectors, advising leadership on strategy, planning,

investments, and risk management. Prior to joining the Department, Mr. Curran held finance

leadership roles at MBNA Corporation, Barclays, Morgan Stanley, and Merrill Lynch. He is a

member of the Finance & Administration Committee for the American Association of State

Highway & Transportation Officials and represents the Department within the Mileage-Based

User Fee Alliance. Mr. Curran is also a Certified Management Accountant.

Scott Vien, Director of the Delaware Division of Motor Vehicles (DMV), joined DMV as a

Management Analyst in April 2006, where he has since served in the capacities of Commercial

Driver License Program Manager, Chief of Driver Services, and Deputy Director. As an active

member of the American Association of Motor Vehicle Administrators (AAMVA), Scott is

currently a Member-at-Large on the AAMVA Region I Board of Directors, and has served as Chair


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of the Card Design Standards (CDS) Committee, Vice-Chair of the e-ID Working Group, and as an

Identity Management Representative for the Driver Standing Committee.

Tom Maziarz is the Bureau Chief for Policy and Planning, where he is responsible for overseeing

all of CT DOT’s planning programs, and data collection activities. Additionally, he oversees the

Highway Safety Office that is responsible for all NHTSA-funded traffic safety programs. In that

role he serves as the Governor’s Highway Safety Representative and works with partner agencies

like DMV and the State Police. Tom was responsible for developing the state’s first strategic plan

to guide investment in CT’s transportation system. The Plan calls for investing $100 billion over

30 years to restore and improve the state’s aging transportation infrastructure. To fund it, the

Governor formed a Transportation Finance Panel to recommend new revenue sources. Among

the sources recommended by the Panel are electronic tolling and mileage-based user fees. The

Panel specifically was recommended that CT DOT seek to participate in a mileage-based user fee

pilot project to test the viability of user fees as a new revenue source.

Scott Shenk has been Pennsylvania Department of Transportation, Driver and Vehicle Services

for over sixteen years. He currently serves as the Vehicle Registration Division Manager. In this

capacity, he oversees the central office operations of vehicle registration, titling and financial

responsibility programs. He previously held division manager positions in the Bureau of Driver

Licensing where he oversaw driver licensing field operations, numerous safety programs, and

research projects. Scott has severed on several AAMVA workgroups, most recently he worked

on the Three Wheel Motorcycle working group.

Roger Cohen has served as PennDOT Policy Director since July, 2015. For eight years, Roger was

at the Port Authority of New York & New Jersey, where he was a policy adviser to the agency’s

Executive Director and Board Chairman, manager of the agency-wide business planning process,

and Deputy Director of the Office of Policy Analysis and Planning. He was a public affairs and issue

management consultant for nine years and the head of communications and media relations at

White & Case, LLP, of the WORLD's leading global law firms. Previously he served as the NJ and

district director for a member of the US House of Representatives, and before that was an award-

winning reporter at the Bergen Record newspaper in New Jersey. He is a graduate of Columbia

University.

Larry Shifflet has been working for the Pennsylvania Department of Transportation for over 24

years, during which time he has worked in the Office of Planning including; the Funds

Management section of the program center, the Departments liaison with the Southwestern

Pennsylvania Metropolitan Planning Organization and is currently the Director for the Center for

Program Development and Management. Larry has participated on several NCHRP panels with

the most recent one focused on performance based planning. He has also been invited and

participated in National Peer Exchanges with Washington Department of Transportation,

Colorado Department of Transportation and West Virginia Department of Transportation.

Emma Lowe has served as Special Assistant to PennDOT Secretary Leslie Richards since January

of 2015. She works on a variety of policy initiatives and special projects. She also serves as a

liaison between Secretary Richards and regional and national transportation organizations,

including AASHTO and NASTO.


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Costa Pappis is a modal planner for the Vermont Agency of Transportation, specializing in

highway, rail, and freight planning. He is responsible for managing the agency’s major planning

studies and assists in coordinating planning activities regionally and with state and federal

partners. He is a Certified Public Manager, and member of the American Institute of Certified

Planners, holding both generalist and transportation planning specialty certifications.

Mark Muriello has thirty-four years of experience in transportation and public finance, covering

bus, rail, marine terminal, bridge, tunnel, and toll operations, as well as the electric utility

industry. As Deputy Director of Tunnels, Bridges and Terminals for The Port Authority of New

York and New Jersey, Mark oversees the operations, maintenance and investment plans for the

agency’s six tunnels and bridges and two interstate bus terminals that connect the New Jersey

and New York City. These facilities collectively serve 1.25 million customers each weekday and

produce nearly $1.8 billion in revenue annually. Mr. Muriello serves in a leadership capacity in a

number of industry and national transportation organizations, including the E-ZPass Group, the

Transportation Research Board, the I-95 Corridor Coalition, the Alliance for Toll Interoperability,

the OmniAir Consortium, and TRANSCOM.

Patrick Jones is Executive Director & CEO of the International Bridge, Tunnel and Turnpike

Association. Since assuming this position in 2002, Jones has built IBTTA into the principal

advocate for toll-financed transportation and the leader in producing high quality educational

experiences for toll industry professionals. Under his leadership, IBTTA revitalized its premier

journal Tollways, created the IBTTA Leadership Academy, and introduced many new programs

including the Transportation Finance Summit, Violation Enforcement Summit, Special Summit on

Open Road Tolling, and its first workshops in South America, Australia and South Africa.

Louis G. Neudorff, P.E. is a Principal Technologist with CH2M, located in the Hampton Roads area

of Virginia. He has more than 35 years of experience as a transportation systems and engineering

consultant, specializing in transportation systems management and operations (TSM&O) and the

supporting ITS technologies, the role of TSM&O in supporting sustainable transportation, and

mileage-based road usage charging. He was the project manager for the Oregon Road Usage

Charge Pilot Project (RUCPP) from 2011 to 2013. In this role, Mr. Neudorff oversaw all activities

associated with developing and implementing a pilot demonstration for Oregon, including the

Concept of Operations, system design, vendor selection, testing, integration, implementation,

and operation of the RUC pilot system, which included participants from the Oregon legislature,

the Transportation Commission, and ODOT. Based on the results of this successful pilot—which

verified the goals (e.g., ease of use, open architecture, user choice, protection of privacy)—

legislation was passed moving to a 5000 person volunteer pilot (OReGO). Mr. Neudorff is active

in TRB and the Mileage Based User Fee Alliance.

Matthew Chiller is the Vice President of Federal Relations for CH2M, located in Washington DC.

Over the last several years Matt has led the effort on a federal policy level, along with Brendan

McCann of SB Capitol Solutions, to create a new federal grant program that would provide

funding to states or groups of states to pursue state-based MBUF programs. This has included

well over 100 lobbying meetings with a variety of policy stakeholders, including Members of

Congress and their staff, state DOT employees and members of the transportation policy

community. The result of our effort was the FAST Act’s Section 6020 and its accompanying new

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$95,000,000 FHWA grant program. Matt has experience building coalitions and working

legislative concepts through the process and into law in other areas as well, including the creation

of a new public-private partnership program for the U.S. Army Corps of Engineers.

Richard Foote is a senior-level Systems Design/Integration and Intelligent Transportation

Systems (ITS)/Tolling professional with CH2M, located in Boston, MA. Rich was responsible for

developing the system requirements, interface protocols, and test plans (followed by testing and

integration) for the 2011-2013 Oregon RUCPP effort.

Gary Euler, consultant and located in Pittsburgh, PA, has 40 years of experience in transportation

systems management in both the public and private sectors. His areas of expertise include

program and project management, ITS planning, systems engineering, development and

provision of technical training and project and program evaluation. After almost 19 years with

the Federal Highway Administration (FHWA), Mr. Euler joined the private sector in January 1996.

Gary led two studies sponsored by the I-95 Corridor Coalition. The first was a research study that

focused on business models, institutional and administrative arrangements and legal issues

critical to application on a regional or national scale. The second produced a concept of

operations and set of user scenarios for a long range vision of a multi-state MBUF system. The

concept reflected extensive input from State DOTs, toll agencies, State Departments of Motor

Vehicles and providers of software and services.

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Appendix CAppendix CAppendix CAppendix C————Letters of Letters of Letters of Letters of CommitmentCommitmentCommitmentCommitment

APPENDIX C—LETTERS OF COMMITMENT

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