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USDOT Resources: Overcoming the Challenges of Congestion Pricing 2011
FHWA Webinar Series

Guidebook and Toolkit on Environmental Justice Analyses in Tolling - Transcript

April 4, 2018

Transcript

[Host]: Good afternoon, and thank you for joining us for today's webinar. I'm Radha Neelakantan from ICF and I will be the moderator. As you heard, all participants are in a listen only mode. Please feel free to enter your questions or comments in the chat pod on the bottom left, and the speakers will address them at the end of the presentations. We encourage you to download and read the NCHRP Research Report 860, Assessing the Environmental Justice Effects of Toll Implementations and Rate Changes Guidebook and Toolbox. You will find links to those in the resources pod on the left side of your screen. The webinar is being recorded and will be made available after the presentation. With that, I would like to turn it over to Angela Jacobs, from USDOT, who will provide an introduction. Thank you.

[Angela Jacobs]: Thank you, Radha. Welcome to today's congestion pricing webinar. This guidebook and toolbox are a valuable resource to the community to help us ensure that pricing projects do not negatively impact minority or low income communities, and to find solutions to help mitigate the effects of tolling on these communities. I'm pretty excited about our webinar today because when you see that guidebook, if you have a hard copy, it looks a little bit intimidating. We think it will be great to have some people talk you through it and show you how you can make it useful because I really don't want it to collect dust on your desk.

Our webinar today will walk you through how to use the guidebook and toolbox and illustrate the concepts with two case studies. One, on the residents' toll relief program in Virginia, and another on the user post implementation surveys in Seattle. I would like to introduce all of our speakers now, so we can dive straight into the presentations. Larry Pesesky and David Aimen, the co-principal investigators of [NCHRP] Research Report 860, will walk us through the guidebook and toolbox. Larry Pesesky is a senior vice president for Louis Berger, U.S., responsible for the firm's planning and economics practice. In addition to being co-principal investigator of this report, he was principal investigator of NCHRP Reports 403 and 456: Guidance for Estimating the Indirect Effects of Proposed Transportation Projects. He's also a member of AICP and received a bachelor's degree in agricultural economics from Cornell University, and masters from Rutgers, the State University of New Jersey. David Aimen is an assistant director for planning and technical assistance at the Alan M. Voorhees Transportation Center at Rutgers University. David is the co-PI for this report and previously served as a principal investigator for NCHRP Report 710, Practical Approaches for Involving Traditionally Underserved Populations in Transportation Decision-Making. David received his graduate degree in city and regional planning from Rutgers and is a member of the TRB Committee on Environmental Justice.

Our first case study on the Elizabeth River Tunnels Toll Relief program will be presented by Grindly Johnson and Shannon Marshall. Grindly Johnson was appointed as Virginia's deputy secretary of transportation by Governor Terry McAullife in 2014, serving in that capacity until the beginning of this year when she was appointed as deputy secretary of administration for the Commonwealth of Virginia by Governor Ralph Northam. Grindly previously served as chief administrator for the Virginia Department of Transportation, the third-largest transportation agency in the nation. Grindly was directed by Governor McAuliffe to lead toll relief, the first program of its kind in the nation that provides much-needed financial assistance to residents most impacted by tolls. Shannon Marshall is VDOT's Communications Director. Shannon leads a team responsible for the planning, development and implementation of the agency's marketing, communications, and public relations strategies. Shannon is a graduate of Virginia Commonwealth University, where she earned a Bachelor's of Science and Master's Degree in strategic public relations. Margaret Petrella will be our final speaker. Margaret is a social scientist and has worked at the Volpe National Transportation System Center since 2001. She has approximately 25 years of experience in the field of survey research, utilizing both quantitative and qualitative methods. Ms. Petrella has managed customer satisfaction surveys as well as panel surveys measuring travel response to federal programs and initiatives. Her other work includes program evaluation and transportation planning studies. Now that you know who will be speaking and presenting to today, I will pass things over to Larry.

[Larry Pesesky]: Thank you Angela. Good afternoon, good morning everybody. I would like to go through a few introductory slides to speed things up before we get into our first case study. NCHRP Report 860 -- the purpose of the guidebook and toolbox. We really want to show how to incorporate environmental justice analysis in the context of tolling. There's a set of tools to measure impact on either implementing tolls or changing toll rates to EJ populations. We apply the tools and toolbox with the framework and provide extensive cross-referencing with the steps in guidebook process framework and application of tools. The process framework corresponds with the typical transportation project planning and development process. Again, this is largely about measuring effects on low income and minority populations. This slide shows the relationship between the guidebook and toolbox. The guidebook is an eight step process that I will get into in more detail after the first case study presentation. Then we have our toolbox which is organized around analytical tools, case examples that in and of themselves show how tools can be applied, checklists, reference tables, public involvement strategies, as well as three scenarios of the hypothetical toll implantation rate change situations that you may actually encounter in your work.

The USDOT's environmental justice strategy identifies three fundamental principles of environmental justice. I will highlight these: (1) to avoid and mitigate disproportionate adverse effects on minority and low-income populations, (2) to ensure full and fair participation by all potentially impacted communities in the transportation decision making process, (3) and to prevent the denial and reduction of benefits received by minority and low-income populations. Hopefully throughout our presentation today we will touch on these points.

Why is there a need for Report 860? Well, as you all know, tolling has become more prevalent as a funding mechanism and operational strategy for managing congestion of transportation facilities, and it is recognized that toll implementation rate changes can cause direct, indirect and cumulative impacts. There are certainly benefits, intended benefits, but in some cases there are some consequences in terms of burdens that have disproportionately high and adverse impacts on low-income and minority populations in certain situations. Therefore, there's a need for tools to really measure these effects and mitigate the effects, and guide project implementation. At this point, I'm going to hand things over to Grindly and Shannon to describe the Elizabeth River Tunnel Toll Relief program. Grindly?

[Grindly Johnson]: Thank you, Larry. Good afternoon. I know you all have anxiously been waiting to hear about the toll relief in Hampton Roads. I want to start off with a little history. And the history that I want to talk about is why is the Commonwealth offering toll relief? And the primary reason why we are doing this is because tolling was new to the Hampton Roads area. It was new to the region. It was implemented in a majority minority setting. Stakeholders in the community were never properly informed. We did communicate, but we did not communicate properly, and if you pick up nothing else from this webinar, please remember that communication is everything. Economics and communication kind of go hand-in-hand, and being in a majority minority setting, Norfolk and Portsmouth Virginia, which is landlocked. They have a lot of federal installations in their area. They have the largest navy yards there. They have the Coast Guard, so their tax base is very, very low, and it is a struggling city. And because this was a new concept, we had tolls on Hampton Roads in the early 70s and 80s, but since then we stopped tolling, around the mid-1980s. And then it started again in 2014, not to have the proper communication, not going out to the stakeholders and talking to the constituents, those who actually use the tunnel. They did not understand the concept and the fact that we were going to start tolling two tunnels that have been there for years, and yet we had not even moved any dirt, put a shovel in the ground, or done anything. We just said hey guys, we are going to start tolls because we need this toll money to finish the construction of this project.

So starting off that way, we sort of put a solid case in the community. When we looked around and we started the tolling, we started the tolls I think maybe like $1.25, a nominal amount, or at least I would say the state thought it was a small amount. And when we started looking at the impact that it was having on the community, the governor, Governor Terry McAuliffe and Secretary of Transportation Aubrey Lane tried to mitigate the impact. We started having people go through the tolls without having an E-ZPass. We never fully explained how E-ZPass worked. We just said "Hey, we are going to start tolls. We want you to pay the tolls, and no, there will not be a toll collector. It's going to be all electronic, this is a way of the future. Take it or leave it." And from that we started having people going through the tunnels, not paying a toll, not worrying about whether they even had an E-ZPass, and just going through the tolls. Then we started having the concessionaire billing those folks for that. We had individuals from the minority community with a $17,000 toll bill, with a $14,000 toll bill, a $12,000 toll bill and the only thing they were doing was trying to leave their cities to go to work.

I'm just trying to give you a little history of why we started the toll relief program. And when I told you about the $17,000 toll bills and the $14,000 toll bills, the majority of that cost was for fees. The tolls were a very small part of that number, but because they were allocating fees, administrative fees, delinquency fees, putting a lien on your registration where you could not get your registration unless you paid your tolls, it was a total fiasco in the cities of Norfolk and Portsmouth. Fortunately, we had good negotiators with the governor and with the secretary of transportation. They worked with the concessionaire, and the concessionaire agreed to give us $500,000 a year for 10 years to help offset the cost of tolls on the users most financially stressed.

When we got that money, $500,000 may sound like a lot, but if you want to give a meaningful toll relief to someone, it has to be more than just $.25 and more than $.50. So with the $500,000, we had to look at the communities that were most impacted, and as I said before, we felt that was Norfolk and Portsmouth, both majority minority cities. So we knew that we could not develop a toll relief program in a vacuum. We knew what fiasco we had with starting the toll program, so what we did was go to the community and the community was made up of VDOT, the NAACP, the Hispanic chamber, military, hospitals, colleges. We have a community college in that area, we also have two universities. We had representatives from these institutions to give us input, to give us guidance on how we could set up a program. And I think this was the most critical step that we could have done: engaging the community and listening to their concerns, and keeping them in the loop. Social services was, I think, the biggest proponent that helped us because they helped us to develop what type of income level we were going to use for our criteria. And the relief had to be something that would give the citizens and constituents some sort of happy medium. The fact that they had to pay the toll to get to work, and the fact that we were actually trying to do something to mitigate and help their situation.

The requirements for the tolls were that you had to reside in Norfolk or Portsmouth, earn $30,000 per year or less, and have a Virginia E-ZPass account - and that was the big thing. As I said, we did not introduce E-ZPass to the community until we started the tolls. That was a big mistake. We had to introduce E-ZPass, the concept of E-ZPass. If you wanted to receive relief, you had to have an E-ZPass account. It is the cheapest and easiest way to travel, and in Virginia, you do not buy your transponder; when you get an E-ZPass you pay $35, and it all goes toward the payment of tolls. There are no additional costs or processing fees.

What are the benefits? Once a participant has an E-ZPass transponder, they will get a one dollar per trip refund credited to his or her Virginia E-ZPass account. We wanted it to be based on frequency. It had to be based on frequency. We did not want it just for people who are just going through the tolls or through the tunnels maybe once or twice a month, but we wanted people who were actually going to use it. We came up with 8 trips: after you make your eighth trip, it would be retroactive to go back to a one dollar per trip refund.

You have to apply for the toll relief program in person. The reason for this is that we didn't want to keep their personal information, so we had two customer service operations, one in Norfolk and one in Portsmouth. We also went around to different malls and set up tables were you could do it there, and we went to a couple of festivals you could sign up for E-ZPass there, but you had to have an in-person application. You also had to have proof of income, and you must present at the time of application.

I told you about the stakeholders group that I had. You had to have a driver's license, utility telephone cable bill, checking savings account. Since it's a military town, a lot of the people that come through are only there for short while, so that is why we wanted to be sure that you can have several means of verifying your income and your proof of residency. Having social services on board, as I said, was key because they were able to help us to come up with a thing that everyone should have and it would not be difficult, and it would be proof of their residency. Let me also say this again, I know I stress communication, but communication along with stakeholder involvement.

Proof of income you show a W-2, 1099, one month of pay stubs, your 1040, self-declaration - these were things that we required. But we did not keep any of this material. We looked at it, verified it, and we gave it back to you. For the toll relief period, we decided that the enrollment period would be December 1 through February 15, and the relief would begin on March 1, and you would receive your first rebate in April. That is how we started the first year, and we knew that by going this way, we may have to do some tweaks, but fortunately, we have not had to tweak anything so far. What I guess I'm saying is that having stakeholders' input, listening to your community, finding something that will be meaningful, and having a concern - you have to have some sort of passion or concern for the community in order to make this work. Because we found when we would go out and talk to people, no one wanted to talk to us about tolls. I went into a 711 store one day, and a lady called me the "toll lady." I wasn't sure if she was saying that in a nice way or bad way, but you have to let people know that when you were working on this program, you are working on it to benefit them, not to benefit you, and that you are not dotting the I or crossing the T, but that you are actually concerned about their well-being. And the team that worked with me had all of that criteria. It was a team effort of citizens, engineers, and technicians because for $500,000, we left that money to go straight to tolls. We did not use it for any implementation or setup, but I will tell you, the administration setup fee was quite expensive, and that was provided by VDOT because you cannot use state money for toll relief, which is one of the reasons why we have only initiated it in one area, and that was the only area we have been able to get the concessionaire to come up with money to do it. If you look at the Northern Virginia area, there's no concessionaire that will participate: Transurban is a little too big, with Cintra, we have talked to them, but we don't know if we can come up with something, but I think there may be a light at the end of the tunnel. But when you look at the Northern Virginia area, and if you look at the diversity of the people there, the income level, then it's going to be pretty hard to initiate a toll relief program in that area. When you have a contained area in Hampton Roads where the impact is really in just two cities, then the likelihood of having a successful program is better. And I think our program was successful, or is successful, because it is a contained area, and it is a needed resource for the community. As I said, it's majority minority, and yes, the income level is low, $30,000, and you would be surprised of the number of people in that area who make $30,000 and have to support a family. So if you are making $30,000 and you have to still support your family and pay a toll, then that is a big hardship. Developing this program, I feel, has been a major benefit. But communicating this information to the citizens and constituents have been very difficult. You have to try different ways. There have to be different mechanisms. And I'm going to turn the program over to Shannon.

[Shannon Marshall]: Thank you, Grindly. As Grindly stated, communications has been critical to not only the development of the program, but to the implementation and success. Grindly mentioned the focus group that met monthly to help develop the program. We also conducted focus groups. We recruited focus groups comprised of residents in the community, residents of Norfolk and Portsmouth. We ensured that they had the income requirements that the program was meant to support. We conducted about three focus groups, and we asked participants about travel patterns: How often did they use the tunnels. Why would they use the tunnels? We found that it varied. Some used tunnels for medical appointments, others needed to use them every day for work. Again, others for school. We also found out that there were some respondents who really tried to avoid them as much as they could because they had very low income or they were really struggling financially, and they really watched every dollar they spent. During the focus groups we asked participants to help us really define what "meaningful" is. What is that amount to you? What does that look like? Believe it or not, they were very vocal on that. We found that some the things we were looking at previously didn't quite make a difference, so we went back to the table and made adjustments. We also asked them, "What is the best way for us to communicate with you?" I remember someone said "Hey, send everything to my phone."

Communications were certainly a big part of implementation and development. We were fortunate enough once we launched the first year of the program that we had kind of a database of participants, and as we embarked on the second year, we e-mailed existing toll relief participants, and we reminded them that every year they need to qualify and sign up. Also, since VDOT maintains the state's E-ZPass program, we had access to E-ZPass customers, and we identified our customers who lived in Norfolk and Portsmouth, and we e-mailed them as well, letting them know about the program, letting them know the enrollment period, what the benefits were, and how the refunds work.

Another fantastic opportunity we had in Hampton Roads was that VDOT has two E-ZPass customer service centers in Norfolk and Portsmouth, so when you have a large community base coming in to the customer service centers, maybe biweekly or weekly when they get paid, our customer service representatives have the opportunity to actually speak with them, ask them if they are aware of the program, and if not, say that there is a table right here on the left you can actually sign up for toll relief. And I think that was a huge, huge benefit. In addition to that, we had a toll-free number and that number is actually staffed all year round, not just during the enrollment period.

We developed a specific website for the toll relief program with information. Again, the toll relief application enrollment process is only in-person, so that pretty much was more of an informative website. We also identified the zip codes in close proximity to both of the tunnels and we sent direct mailers to residents in those areas, just again explaining what the program is, what the requirements are, what the benefits were.

Additionally, one of our consultants had a fantastic idea, and that was on-site enrollment at the local mall. You will see on the previous slide that Grindly went over, that the enrollment period is December 1 through February 15, and December is a very popular time to shop for the holidays. In the local mall in downtown Norfolk, there were two weekends where we had in-person sign-ups, and I think it was a Saturday and Sunday, or Friday and Saturday, that they were two back to back days, and we had two tables: one table for E-ZPass and the other for toll relief. And I think the benefit of having the back-to-back days was that if someone came in and had an interest in signing up for toll relief and they didn't have those required documents that Grindly went over, they could come back the next day and sign up and have those as well.

Social media was another great opportunity for us. We focused on the VDOT social media channels in the Hampton Roads district where Norfolk and Portsmouth are located, and we did a countdown on social media. We tried to drum up excitement and interest. Note that during the enrollment period is when Elizabeth River Tunnels announced every year that they had a toll increase. That made it even more important for those people watching their spending, to do what they could to get some sort of benefit. And additionally, the earned media was certainly a huge benefit as well, not only from the local television station, but also from the daily paper. They really helped us promote the program. Again, as Grindly said earlier, the community was well aware of the troubles a lot of people have had with tolls and anytime you see TV news coverage and newspaper coverage of individuals with tens of thousands of dollars and invoices from a toll facility, we knew people really needed help, and reporters were very fair in their coverage and encouraged people to sign up for toll relief. So Grindly will touch a little bit now on the statistics. Again, we are now in the second year.

[Grindly Johnson]: The first year was 2,094, and we spent about $458,000. For the second year, which starts now, on around April 11 or so, drivers will get their first rebate. The program has 2,909 [users]. One of the things we tell you when you sign up is that we only have $500,000, and when the money runs out, the toll relief runs out, but we do have carryover. Since we did not spend $500,000, the remaining $42,000 will go over to the next year. As I close this program, I would like to reiterate that communication is the best thing you can do. Communicate, talk to your constituents. Talk to the neighborhood. Talk to the people. Communication is the key. I would also like to say that we used an outside consultant, HNTB. There's no way we could have done this program, and be as successful as we have been, without relying on HNTB to help us with the data mining and communication efforts. Larry, back to you.

[Larry Pesesky]: Thank you Grindly and Shannon. Hopefully as we walk you through the guidebook, you will see some of the themes that Grindly and Shannon highlighted shine through. I want to go through step-by-step over the next 15 minutes or so, on the guidebook. I am going to focus primarily on step one, which is framing the project, because I think once you figure out where you are in the universe of tolling actions and how those potentially relate to impacts, things sort of roll from there in subsequent steps.

The first thing we did in Step 1 in the guidebook is come up with a typology of tolling actions. The Elizabeth River Tunnels project accounted for two types of tolling actions. There was an existing tunnel that was fully converted to tolls, and previously did not have tolls or toll collection for a long period of time, and then there was a new toll facility constructed. In this case, you have a mix of two types of tolling actions. Really what we want to do with the tolling action is put you in the universe of whether it's implementation or rate change, and where exactly you are for type of tolling action. Then we go to identifying what are the impact-causing actions associated with various types of tolling actions. If you go to Table 1.1 in the Guidebook portion of the report, you will see where we presented both the type of tolling actions and aspects on two different axes, and identified where you have a cross correlation between a type of action and potential for policy action or a possibility. In some cases, we could say definitively, "yes, you have a correlation," and in other cases, it's possible or requires further investigation. And then in other cases there was no correlation at all. This slide here shows the impact-causing aspect associated with the type of tolling action. You will see for the first several cells here on this axis of the chart, that cost is the factor, and the guidebook and toolbox are primarily oriented towards understanding how cost can change people's behavior, and change mobility, and access, and other factors related to trip-making. That's the primary focus as well in the guidebook and toolbox. Yes, there are more typical capital projects of footprint or encroachment type of impact. We do cover those here and they are touched on in report, but those are pretty well covered - whether it's a footprint type of impact or final role to the right, the proximity impact - those are covered pretty well in the environmental impact literature, whether it is the noise effect, air effect, or footprint effect. So we really focused a lot on the more behavioral, cost-related effects.

Moving on, once you identify your action and type of impact activity, we then look at the potential adverse direct effect to users from the action and impact-causing activity. This slide shows, again, the behavioral effects that people may change and changes to their travel routes they typically take because of the implementation of the toll. They may change trip-making behavior, when they normally would travel, the time of the trip, and how often they travel. These are behavioral effects. Your household income, which we call "disposable income," may change because everybody has a budget and, as Grindly pointed out, many of the toll users or tunnel users in the Hampton Roads area make $30,000 a year or less, so there is a budget associated with transportation in terms of household budget. And a toll change or implementation of a toll can have a financial burden. There's also the time factor. We all know time is money and if you want to avoid the toll by taking an alternative route, then chances are that will take you longer, and that can also have an effect.

Then you look at indirect effects. These are all potential, but they are related to the diversions - whether you change your route, or decide to give up on auto ownership and go with alternative mode of transportation. These are examples of indirect effect. If there is a degradation of level of service from people leaving the toll facility and going to an alternative route that is a free route, then that changes level of service, connections, air quality, and noise impact, for example. And the implementation change can indirectly make changes the quality of life that are outlined here on the slide.

I'm not going to go into detail, but just to give you a sense of walking through step-by-step, here just framing up the project so you understand what you're dealing with whatever implementation or rate change project that you are dealing with. There's context associated with this. There's regional context that we outlined here on the slide, and also a more localized context. The regional transportation system provides access to opportunities. Those opportunities can be employment opportunities, services, educational, religious, recreational, social, shopping, etc., and so the ability for people to access these opportunities by traditional access can be affected by the implementation of tolls or toll rate changes. What we really want to look at is, "Is the project you are assessing creating a potential tipping point for these types of environmental justice effects within this particular context of access to opportunities?"

You frame things up now and should have a pretty good handle on what you're dealing with. We then go in Step 2 to understanding what are the potentially applicable requirements, statutes, regulations, and policy. I'm not going to go through these one-by-one. They are touched on the report, but there are a number of statutes and regulations that may come into play, principally Title VI of the Civil Rights Act of 1964, as well as Executive Order 12898 on environmental justice and a D.O.T. order 5610a. That is first and foremost here, but there are a number of other laws and regulations and policies that can come into play when you're doing the action, so this slide and the next slide provide you the list of what we have identified in the guidebook in terms of potentially applicable requirements. You should understand the grounding once you frame the project, and understand where you lie in terms of the regulatory world or statutory world. That's not to say that you only do environmental justice analysis because it is required. It can be a good policy for your toll agency to consider environmental justice affects whether or not there's a requirement that you do the analysis. It seems to be good practice in public relations in particular because we are talking about your toll system users here.

Step 3. Grindly and Shannon touched on the stakeholders, and we certainly emphasize that step here. There are the decision-makers, the people who decide on the toll implementation or rate changes, there is a regulatory agency governing the fiber optic cables and installations necessary for the project, etc. There are all kinds of decisions that need to be made, but there are of course many stakeholders: the users, the effected community, professionals, the Transportation Department or toll authority, the planning department, the metropolitan planning organization, and professionals with expertise that can be brought in to help guide and inform the process. Then you have your review agency. As Grindly mentioned, communication, communication, and communication. This step addresses not only stakeholders in the reviewer/sponsor side, but also helps ensure that we show full and fair participation by all the potentially affected community.

The next step is to start scoping out the measurement and address the impact. We really build upon what's been done in steps one through three with the framing and where you are with potential direct or indirect and cumulative impact, and then asking, "where are you in terms of statutory requirements?", and then asking, "what are you hearing from the community?" What are you hearing from the affected users and the other stakeholders involved with the tolling project or tolling action? Really again, we focus on a scoping exercise similar to what you would do in a NEPA document scoping that involves really revealing, through a scoping process, what potential effects are, how the effects will be analyzed in working with public and in this case environmental justice populations in particular to identify the potential adverse and beneficial effects of the tolling, and through the analysis, address people's questions, expectations and concerns.

Step 5 is where you could conduct the impact analysis and the measurement of impacts. David will get into the tools in a few minutes, but here is really where you are bringing in the hard analytical tools. Not to say there are not tools for public involvement and other aspects already touched on in the process, but here we look at, as we mentioned at the beginning, that there are mobility and access tools, this is about potential for changing people's access to opportunities and their ability to get to where they need in a timely fashion. It's about change, and therefore we look at a scenario of with-toll versus without-toll, typically. Or if it is a rate change for a toll facility already tolled, then we look at rate change versus without-change analysis. Sort of like your typical NEPA document. We discussed fairly extensively in the guidebook and toolbox about how regional models, which many tolls and management implemented in urbanized areas, take advantage of the regional travel demand model that the MPO maintains, and adapt it to be able to assess potential changes in travel behavior. For example, look at trip conversions from the tolling and changes in people's travel times and trip lengths from potentially diverting of the toll. Once this has been defined and measured, we start mitigation strategies. The program Grindly and Shannon described is just one example mitigation strategy that we highlight in the toolbox portion of the report. You want to look at a system-wide analysis in that context, and we also want to look at project-level or more localized, specific effects here. It is really an opportunity to look at cumulative impacts. If you have been focusing on your project, or you are in an area where there may be toll authorities or other toll facilities, and you are adding a toll facility - and I believe Texas D.O.T. and North Central Texas Council of Governments has done a good job looking cumulatively at the impacts of the toll programs or toll facilities coming online over time - what's the cumulative impact consideration? That is something to highlight here in step six: you do not want to overlook cumulative impacts when you're looking at the potential for mitigation strategies.

We look at that in Step 7, and documenting the results to the decision-makers and to the public. This is just pure reporting for the record of the work that has been done up to this point. After the tolls have been implemented, you want to look at post-implementation monitoring. That is how the toll program that Grindly and Shannon described came into play, because people were doing the monitoring of what was happening and adjustments were made, and I think it is important, especially for new toll facilities, to take a look at post-implementation monitoring.

That wraps up the guidebook portion of the presentation. I want to hand things over to David for the toolbox portion. David?

[David]: Thanks, Larry. Let me walk you through the toolbox elements. The toolbox elements include tools, case examples, checklists, reference tables, and scenarios. The important goal of the toolbox is to reach the practitioner with how-to details on specific methods and approaches, as well as highlight more innovative, inclusive, and comprehensive practices that are being undertaken to address EJ in a tolling context. The toolbox describes appropriate methods, effective practices and case examples on several topics including use of data sources, analytical techniques, proactive public involvement approaches, and evaluation criteria for preparing and documenting and environmental justice assessments, among other topics. Practitioners interested in the toolbox elements may access them in many ways. There are many cross-references with the guidebook that Larry was walking us through. You can see the icons associated with each tool that are displayed in the guidebook. The icons are used to help readers navigate to the tools of interest. The people icon refers to public involvement. This icon image can accompany both the tool or a case example write-up.

The tools and toolbox describe a range of methods and approaches for conducting an EJ analysis of a toll implementation or a rate change. The tools seek to address various challenges and highlight notable practices that stem from our standard practice review that was performed at the beginning of the project. We identified areas where additional technical assistance was needed following an extensive literature review, a content review of environmental justice assessments for tolling projects, interviews with agency representatives and practitioners who have been responsible for preparing EJ studies or tolling related implementation efforts, and getting feedback from our TRB panel.

The tools reflect the express need among practitioners for more sharing of effective practices, both analytical methods and proactive outreach approaches, for addressing EJ in a tolling context. The selected tools cover a broad set of themes including definitions and methods for identifying potentially affected low-income and minority populations, and for defining study areas with excess impact. Data sets that can be used to analyze travel patterns and consider how toll pricing impacts may differ based on the income, ability to pay, and the trip purpose of the traveler. Survey research designs can be instituted to inform travel demand modeling and analysis of base behavior for environment assessment. Practical approaches have been used overcome barriers to public engagement so the impact of toll implementation are explored with low income and minority populations, and potential mitigation strategies instituted by sponsoring agencies. The tools also address the need for greater attention to evaluation and documentation of the adverse effects and benefits in making a determination as to whether a project may have disproportionately high and adverse impacts on low-income and minority populations, and, as Larry mentioned, the need for greater attention to post implementation monitoring, to analyze whether predicted effects deviate from the actual effects after the project begins operation. In particular, whether the observed outcomes may be disproportionately burdensome to low-income minority populations and warrant other mitigating strategies to preserve mobility and access for all populations.

Tools have been developed to assist with various steps in the EJ analysis process framework that Larry outlined. Tools were selected for varying circumstances in which they may be used such as different types of toll implementation projects or rate change actions, different circumstances and resources available for agencies and practitioners.

Each tool contains key definitions and explanations for why it is effective for supporting an environmental justice analysis. Detailed information is provided on the methods, data sources and key considerations for applying the tool for EJ analysis. Potential limitations to applying the tool and types of resources or costs that are likely to be needed to carry out the approach are also disclosed. Specific examples are given to illustrate when and how other agencies or researchers have applied the tool to address environmental justice and equity in a tolling context. Each tool contains a resource section with references and links to other source materials for those that are interested in taking a deeper dive into how the tool has been applied. Practitioners can refer to the text box on the first page of each tool to see the techniques featured in the tool and how it fits within the eight step process framework of the guidebook.

One example of a tool in the toolbox is a detailed discussion of practical approaches for engaging low-income and minority populations and carrying out public involvement for projects. This tool emphasizes the importance of public involvement and planning with a range of techniques to overcome potential barriers to public participation and assessing effectiveness in ensuring the full and fair participation of affected populations including low-income and minority populations. In this tool, a range of techniques are briefly described and shown here.

The tool highlights several examples of how transportation agencies have used these techniques on toll implementation related plans and projects. They include bridge and tunnel projects, HOV to HOT lane congestion pricing, and implementation of all-electronic toll collection among other initiatives. Another tool that is in the toolbox describes how net toll revenues are being recycled to preserve mobility and access including to transit investment and to mitigate the effects of toll pricing policies on eligible low-income travelers. We have already heard today about the Virginia DOT toll program at Elizabeth River Tunnels project and this is one of the examples that is featured in this tool.

We will briefly turn to a separate element of the toolbox: case examples. The toolbox contains 8 case examples that provide another means for conveying effective practice. The case examples are mapped to the eight step process framework that Larry described in the guidebook and feature a range of topics. These examples highlight activities that are conducted in the early planning stages to increase awareness of congestion pricing in regional plan studies, to evaluate tolling's effects and specific project facilities and locations for environmental review. Among the examples are discussions of how public engagement efforts can be targeted to reach potentially affected low-income and minority populations to assess the attitude and likely travel responses due to toll pricing policy. The case examples feature practices that project sponsors and practitioners have undertaken to analyze and compare benefits and burdens of toll implementation and pricing. Examples feature ways that populations that have been surveyed to assess whether there are measurable differences in attitudes and travel behavior by income. Examples also feature strategies being used to avoid and mitigate impacts, from toll credit and transit credit programs to net revenue recycling and reinvestment in multimodal and active transportation projects within affected corridors, to the use of design alternatives to mitigate the adverse effects on local communities.

In telling these stories, the case examples are organized to describe the analytical methods, data sources, and processes that were implemented by sponsors. Case examples are relatively brief write ups that explain how the work is done and what resources and costs may be required to undertake such an effort. They describe why the approach is beneficial for addressing environmental justice considerations and what some of the challenges and lessons that were learned in instituting the approach. Each case study also contains a resources sections with references to other literature and guidance that further describes what was featured in the case examples. One case example in the toolbox is a description of the pre-and post-implementation panel survey research design that was administered in the Atlanta I-85 corridor. Margaret Petrella from the Volpe Center will speak further about this research design and types of equity effects revealed as part of the HOV2 to HOV3 conversion of the I-85 corridor. She will also describe the approach and findings of a new toll implemented on a bridge crossing in Seattle, the SR 520 bridge crossing.

Checklists are another element in the toolbox. In Step 1 of the guidebook, framing the project, the practitioner is encouraged to document criteria, methods, and data maps that have been used or will be used to flag potential issues that could have adverse effects on minority and low-income populations. Project framing checklists that are tied to step one topic are a self-assessment tool to help the practitioner, to identify the type of tolling action under consideration and anticipated impact causing aspects of the action. Consider what kind of potential direct and indirect effects may obtain and understand, as Larry pointed out, the context in which the tolling project is taking place. For example, in what stage of decision-making is the project taking place? Have environmental justice issues been raised already? In what ways are there possible linkages to prior stages of decision-making and prior commitment to address EJ that may require continuing attention? The documentation checklist, a portion of which is shown here, offers a suggested template for tracking the progress of environmental justice analysis and the probable disposition of the assessment for each resource topic carried out. Several reference tables are mapped to steps described in the guidebook. The reference tables contain detailed information which I cannot go into here, but will help provide practitioners with various analytical steps. Earlier Larry had spoken about the applicable requirements governing tolling and environmental justice, and reference Table 2.1 presents this information.

Here is the body of another reference table, the contents of which are too voluminous to share with you today, but Step 3 recognizes the relevant decision-makers and stakeholders. We have three reference tables. Reference tables identify the various types of agencies and stakeholders likely to be encountered at different stages of decision-making. The type of decisions that they make, and the concerns they may have as they relate to making tolling decisions and assessing EJ, are highlighted and differentiated. Separate tables are presented for various decision-making stages of the policy and planning, project design and NEPA, and the implementation stage or the operation stage of the effort. Collectively, the tables reinforce the very important point that EJ is an ongoing responsibility of sponsoring agencies in a tolling context at all stages of decision-making.
In Step 4, reference table 4.1 categorizes the resource topics that are typically considered in an environmental impact analysis from environmental justice perspective. The table lists questions the practitioner may wish to consider for each of the major topic areas: mobility access and safety, which is shown here, but also social and economic, physical and environmental, and cultural and historical topics. Steps 5 and 6 also contain companion reference tables to assist the practitioner with an impact analysis and in making a determination of disproportionately high and adverse impacts.

The scenario section seeks to illustrate how the toolbox, elements, and eight stop process framework fit together. The scenario section illustrates how a practitioner may apply the tools, case examples, checklists, and reference tables using the suggested eight step process framework. In the scenarios, a hypothetical practitioner considers the distinctive impact-causing aspects of toll implementation or rate change actions in Step 1. The practitioner considers the applicable requirements that are in Step 2 and who the relevant decision-makers and stakeholders may be in Step 3 and so on. Three basic scenarios are presented to illustrate why the practitioner uses a particular tool at each step of the process framework to address EJ in a tolling context. Scenario A is an un-tolled bridge transitioning to a tolled bridge where project sponsors are considering using a public-private partnership to design, build, manage and operate the bridge. Scenario B is a high occupancy vehicle facility converting to a high occupancy facility, operated by a state DOT. Scenario C is a rate change operated by a toll road operated by a toll authority, where signal-controlled intersections might experience increased traffic diverting from the toll.

While our primary focus throughout has been the development of the guidebook and the toolbox, the research team identified potential areas for additional research, implementation and guidance beyond the scope of our study. We believe the toolbox and guidebook could be converted to an online resource for practitioners. The toolbox element and guidebook were designed to be reposted as online resources for practitioners. We see the need for clearinghouse of tolling or EJ-related reports, but more attention should be given to survey design and robust sampling plans, so the effect of toll implementation and pricing borne by low-income and minority populations can be meaningfully compared with non-EJ populations. Additional guidance from FHWA on the appropriate analytical methods and documentation requirements for evaluating environmental justice effects and rate changes could also improve the standard of the practice. Guidance standards and methods for analyzing the potential social exclusionary effects of tolling impacts appears to be warranted. Ideally, it could be akin to the FTA Title VI guidance for transit products in the study of service equity. Triggering events for such toll impact studies would need to be defined, but could be tied to a commitment or requirement for periodic monitoring. For example, every 3 to 5 years, or at the time of significant toll rate change. Further study of the analytical and procedural features of each EJ assessment, perhaps as part of a broader implementing audit, may be an appropriate area for future research and practical implementation. At this point, I will turn the webinar over to Margaret Petrella from the Volpe Center. She will speak further to the survey design equity issues revealed in conducting survey research of a full facility pricing in Seattle and changes in a vehicle occupancy level requirements for express lane use in Atlanta.

[Margaret Petrella]: Thank you, David. With that, I'd like to point out that this represents case example 8 from the toolbox, so I will just dive right in. First, a little background: as part of the Urban Partnership Congestion Reduction Demonstration Program, USDOT funded six sites across the country to deploy innovative congestion pricing strategies that included the 4T's: tolling, transit, telecommuting and advanced technology. National evaluations were conducted at all six sites, and FHWA funded traveler surveys at two sites, Seattle and Atlanta. Surveys were conducted specifically because they could provide insight that otherwise would not be measured in the national evaluations, such as insights on the impacts of tolling on individual travel behavior, attitudes, and opinions. These are the study questions that we were interested in focusing on. We sought to measure through the survey, changes in route and mode choice, origin and destination patterns, trip departure times, overall vehicle miles traveled and equity issues.

In terms of our approach, we designed a household panel survey where we would survey the same household both before and after tolling. This included all adult members of the household. We asked respondents to complete a travel diary where they recorded all the details of the trips, including the origin and destination, departure and arrival time, trip purpose, and vehicle occupancy as well. In addition to that travel diary, we also asked respondents to complete an additional survey that asks questions them about typical driving and travel behavior patterns in the area, as well as attitudes and some questions about their typical driving behavior as well as attitudes and opinions. Our sample of core road users included drivers who were sampled via a license plate capture methodology, and then transit users who were intercepted in person, and a small sample of vanpool members as well. This was an online survey, although we did include an option by phone if respondents prefer to take the survey by phone. We offered incentives as well, and we conducted a pilot study to test our method and questionnaire.

This slide is just to give you some sense of the materials that we use. We had advanced notification postcards, invitation package, and reminder e-mails that we sent out as necessary. Overall, we sent out more than 31,000 invitations in Seattle, and our response rate was 10 percent, which was fairly typical with a license plate capture methodology. We were really pleased that we were able to retain across the two waves of the survey - and this is more than a year in length, more like 18 months - and we were able to retain 61 percent of our sample, so we ended up with the final sample size of over 2000 households.

I just wanted to say a word about the corridor. In Seattle, pricing entails full-facility road pricing with all lanes being tolled. There are set toll prices by time of day, so tolls during the peak hours are higher than those during nonpeak hours. Although SR 520 had been previously tolled, at the time of this road pricing deployment, the route had been toll-free for roughly 30 to 40 years. It's important to note that there are two toll-free route alternatives to SR 520. You can see the toll bridge there [on the slide], and I-90 is to the south of SR 520, and we heard from a fair number of people who will use those two routes interchangeably. And then to the north is an arterial, SR 522, which goes around the north side of the lake. Now, as part of this road pricing deployment, in an effort to make transit a more attractive and viable alternative, approximately 90 one-way bus trips were added in the corridor during the weekday peak, and additional park-and-ride spaces were also provided. In terms of technology, an active traffic management strategy was implemented, which included overhead signs to control lane usage and to implement variable speed limits during congested periods.

I did want to point out that there were some changes in external factors that could account for some of the differences that we see and you will see shortly in our data. Gas prices did increase between the two waves from wave 1 to wave 2 of the survey. Transit fares increased very slightly and employment levels also increased slightly. While we do see some of these changes, we by no means think that these explain all of the differences that we saw in our data.

In terms of our sample, this slide provides information for our sample as compared to the census figures for King County. Our sample was higher income, more highly educated, more white, and fewer Hispanics as compared to King County overall. However, the demographic composition of our survey respondents was in line with other surveys of SR 520 users. It is important to note that SR 520 links a number of wealthy suburbs to downtown Seattle. And in addition, we recruited drivers during peak hours, so we did expect our sample to be higher income and more highly educated.

Let's now jump to our finding. As a quick overview, I just wanted to point out that this survey was not designed specifically to assess equity issues. I think in an ideal world we would've had more lower -income respondents in our sample, however, we do have sufficient sample sizes for analysis. Our approach in doing equity analysis was to look at income equity, geographic equity, and modal equity, so I will present findings for each of those three groupings. First, in terms of income equity, in doing our analysis we took both household size and household income into account, creating four income groups that were based off definitions of the federal poverty level. Our lowest income group ranged from below the poverty level to three times the poverty level, with a mean income of $37,399. Then you will see our second income group included households that ranged from three to five times the poverty level. The third income group, which was the largest with 901 households, ranged from 5 to 10 times the poverty level, and finally, our highest income group included households that were more than 10 times above the poverty level. This gives you a sense of the income groupings that we use for analysis.

This table presents data on all individual trips that were reported in the travel diaries, as well as cross-lake trips. Wave 1 refers to pre-tolling and Wave 2 is post tolling data. The first key finding is that there was a decline in trips across all income groups. But as you can see, there is a disproportionate decline within the lowest income group. We see a 20 percent decline in trips overall for the lowest income group, relative to a 13 to 16 percent decline for the other income groupings. In terms of cross-lake trips, you can see there is a 28 percent decline in trips for the lowest income group versus roughly 18 percent decline for other income groups.

Here we take those cross-lake trips and look at them by trip purpose. And again, we see that the lowest income group is disproportionately affected for nearly all trip types, but in particular for discretionary trips - and those include trips such as shopping, recreation - we see there was a 51 percent decline in the number of cross-lake trips for that trip purpose. Even for work, school, childcare trips, which are certainly non-discretionary, we see that the lowest income group was disproportionately affected with 34 percent decline for this trip purpose.

We also wanted to take a look at changes in cross-lake mode share to understand if there were changes in the transit mode share that varied by income. Specifically wanted to see if there were significant increases in the transit mode share among the lowest income group. And while we do see a small increase from 18 to 22 percent in the transit mode share for that lowest income group, interestingly we see even larger shifts for the two middle income groups where there was a seven percentage point increase in their transit mode share.

In terms of attitudes, we asked respondents the extent to which they agreed or disagreed with the statement that tolls are unfair to those with limited income. Before tolling, a majority of respondents across all income groups agreed with the statement, but there are significant differences by income, with the two lower income groups being much more likely to strongly agree with that statement. As you can see, 37 percent of the lowest income group and 29 percent of income group number two, strongly agree that tolls are unfair. This compares to 22 percent of income group three and 15 percent of the highest income group, income group four.

As you look through the two waves so Wave 1 versus Wave 2, we see that individuals in the lowest income group became less intense in their agreement with that statement. We see a decline from 37 percent strongly agreeing that tolls are unfair, to 26 percent strongly agreeing. After a period of experiencing the tolls, there was some shift in attitude among lower income individuals. In fact, other surveys have shown similar shifts with users being somewhat less concerned about the equity issues over time. Still, it is worth noting that even in Wave 2, a majority of respondents do agree with that statement.

We had several open-ended questions in our survey as well, and I just want to highlight the respondents in those open-ended questions did provide comments about equity concerns. I have listed a few here. Interestingly though, equity concerns were less common in Wave 2 than in the Wave 1 comments.

Another equity issue relates to transponder ownership. Here we looked at it by income, and you can see that the higher income groups were significantly more likely to have a transponder than our lower income groups, and by a nearly 2 to 1 majority compared to the very lowest income group. If you look at toll payments by income level, we see that higher income households were paying significantly more tolls than lower income groups. Again, this is not surprising given the data I just showed you on transponder ownership.

Now, turning to geographic equity, we assess geographic equity by looking at trip satisfaction by route. In the trip diaries, we asked respondents which route they used to cross the lake - SR 520, I-90 or SR 522. And then we asked them to rate their satisfaction with various attributes of that trip, including travel time, travel speed, and travel time predictability. A seven point scale was used, and mean scores are presented in this table. So a higher mean score represents greater satisfaction. Before tolling, satisfaction was generally higher for the I-90 trips compared to both the SR 520 and SR 522 trips. However, after tolling, we see that satisfaction on SR 520 increases significantly on all three measures, whereas on I-90 we see that satisfaction has declined somewhat, particularly with travel time predictability. So we do see some geographic equity impacts here. While conditions on SR 520 improved, there was a deterioration of conditions on I-90, as some drivers shifted from SR 520 to I-90 to avoid the toll, thus contributing to greater traffic congestion on I-90. And in focus groups that we conducted we heard respondents talk about this.

In terms of modal equity, we looked at satisfaction with transit trips versus driving trips. Regarding transit trips, this chart shows satisfaction with various aspects of the service including seat availability, service reliability, wait time, and travel time. By and large we see that transit users are satisfied with relatively few citing dissatisfaction with any aspects of the service. The only measure where we see a small drop in satisfaction is in the seat availability, and even that is certainly not a large decrease. But anecdotally, in focus groups that we convened, respondents did tell us that there was increased crowding on transit after the start of tolling. Here we have the driver satisfaction measures, and we can see that from Wave 1 to Wave 2, there was an increase in satisfaction for all of these measures.

Now I want to shift gears for a minute and talk about Atlanta because this survey provides us the opportunity to look at modal equity. In Atlanta, an HOV-2 lane was converted to high occupancy, HOT-3 lane, so vehicles with one or two persons had to pay tolls, but if there were three or more occupants in the vehicle, then they could use the toll lane for free. But it's worth noting that everyone had to have a Peach Pass transponder to use the express lanes regardless of whether you were paying a toll or not. So the modal equity question in Atlanta is, "What happened to the two person carpools who were using the HOV-2 lane, and then could no longer use it for free when it was converted to a HOT-3?" The table on the chart shows the profile of trips for HOV-2 users. We isolated HOV-2 users from the pre-survey and we looked at their behavior for those people in the Wave 1 survey, and then surveyed those same people in Wave 2. We saw some pretty dramatic shifts: in Wave 1, they were making 64 percent of their trips in the HOV lane and only 36 percent in the general purpose lane. But then, in Wave 2, after tolling, we saw this significant shift to the general purpose lanes, so these two person carpools have shifted over to the general purpose lanes. As you can see when, again, we isolate those same HOV-2 users and we looked at their satisfaction, and there was a significant increase in dissatisfaction across the two waves. They weren't very happy to have to leave the HOV-2 lane. I don't present results for the express lane users here, but interestingly, we did a similar analysis looking at express lane users in Wave 2 and saw that their satisfaction increased significantly from Wave 1 to Wave 2.

Just to wrap up quickly, the survey data did show evidence of income equity impacts. The key differences in foregone trips with lower income households reducing their cross-lake travel disproportionately. Transit mode shared did increase a little for the lowest income group, but more so for the two middle income groups. Then we see in terms of equity concerns through the attitudinal questions that there was a slight decline in concern among the lowest income groups, but still, a majority did voice concern. There were geographic impacts; as we saw, I-90 users expressed greater dissatisfaction over the course of the survey, and modal impacts were less clear, certainly in Seattle, but in Atlanta we did see modal impacts with respect to the carpooling.

I just want to wrap up quickly with a few thoughts about using surveys to measure equity impact. Surveys are certainly one tool in the toolbox, and hopefully some of the results I have shared today provide or show you some of the value that surveys can provide. What is really important is that, before you conduct that survey, you really do need to understand the local travel context, the characteristics of the road pricing strategy that is being deployed, and also understand all those potential impacts on EJ populations. This is where I think the guidebook and toolbox are going to be a very useful resource. It's only with the understanding of these different factors that you can then begin to design an approach and a questionnaire that will meet your needs. So you really do need to be very deliberate in your study design. You need to think about the resources - do you have the resources to conduct a panel survey? If you do, then by all means, that provides really valuable data, and if you can conduct more than one post-survey, that is great. I wish that we had the opportunity to conduct another post-survey down the line, but we did not. You need to think about whether your methods will result in sufficient sample sizes, and does the questionnaire have the right questions? These are a few examples, but the initial upfront work that you do in trying to understand the local travel context, the road pricing strategy, and how people are affected - that is what will feed into types of questions that you need to include in the survey. You need to consider whether you need to administer the survey in other languages, and likewise whether you need other methods to supplement your primary data collection methods, such as focus groups, for example, or in-person intercepts. These are just a few thoughts. With that, let me open it up to questions. Thank you very much.

[Host:] Thank you so much for all the informative presentations. We have just a few minutes for questions. We have a lot of questions about the VDOT toll relief programs, so I wanted to start with some of those: "How is the income level selected? What percentage of eligible residents enrolled? And did the participants have to pay the toll first and get reimbursed? If so, what was the timeframe for reimbursement?"

[Grindly Johnson]: I'm going to take the questions that are easy. We came up with that $30,000 figure from social services. We had social service reps from Norfolk and Portsmouth, and they based it on programs that currently were running, so that is how came up with the $30,000. Regarding the next question on did they pay first: no, they do not pay initially. They have an E-ZPass that has $35 on it. Once they hit their eighth trip, a dollar is automatically taken off of their toll and it goes back to the first trip. They are not paying for it upfront. And remind me, what was the next question?

[Host]: What percentage of eligible residents enrolled?

[Grindly Johnson]: I can't answer that. I don't know. Between the two cities it is maybe 180,000 folks between the two cities, but I'm not sure.

[Host]: Okay. We have a question for David and Larry. Do you consider the impact on community and not just on individuals? For example if the toll disincentivizes someone to go from community A to go to community B, are you looking at the impact on community B?

[Larry Pesesky]: You can. That goes to the accessibility measure and regional context. I guess we probably focus more on the user and how the user might be impacted in terms of being able to access employment services, healthcare, etc., but certainly the community where the services lie can also be impacted, and if that community tends to be an EJ community, or let's say, a regional healthcare facility that is supported by serving multiple communities, and then all of a sudden the ability of people from one place to use the services is diminished, then that may diminish the overall financial capability of that particular healthcare facility. So yes, within the context, I guess I would look at it from the accessibility point of view.

[Host]: Great. Another question we had was a general question: "Some people are of the view that you don't need to provide toll release for managed lanes when there are free general purpose lanes available. So we wanted to get the presenters thoughts on that."

[Grindly Johnson]: That doesn't really apply to the downtown-midtown town tunnel project. They had an alternate route, but the alternate route was about 40 miles out of the way, so that would not apply to us. But if you're looking at what we have in Northern Virginia, then that may apply. That is just a personal thought. That is not necessarily the view of our management team. But yes, as long as there are general-purpose lanes, and then you have the option of using a HOT lane, maybe there's no need for toll relief.

[Larry Pesesky]: Yes, I will jump in here. I know that in some states the managed lanes have a requirement that the general purpose lanes achieve a certain performance in terms of the free flow speeds. So let's say there is a requirement for general purpose lanes to maintain an acceptable level of service, speed, and throughput, the perhaps there's not a disproportionate impact on those who cannot afford to use the toll lane. However, let's say there is no sort of performance standard for the general-purpose lane, and if the implementation of the toll managed lanes somehow would make conditions in the general-purpose lane even worse, then I think you have the potential for effects.

[Host]: Okay. Great. Margaret, did you want to weigh in?

[Margaret]: I was just going to jump in. I would agree with that assessment. That is what I was going to say. I think you also need to take a look at what's happening in the general-purpose lanes as well, and if conditions are degraded there to such an extent then you should at least consider some sort of relief.

[Host]: Okay. Thank you once again to all the presenters and participants. We appreciate your time today. This webinar will be recorded. We will send out the link to everyone as soon as it is ready. Thank you so much.

This concludes today's conference for today. We thank you for your participation.

[ Event Concluded]

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