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:

No

TIP

STIP

MPO LRTP

State LRTP

I

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
B
C

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

III

Introduction
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
Figure 1. I-95 Corridor Coalition
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 Narrative
Background—
Background—I-95 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/thecoalition-2/member-agencies-2/ .

1

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

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 Reliable transportation infrastructure is
(70 percent of the national total) and 4,356 vital to the state’s continued economic
commuter rail directional route-miles (62 percent prosperity and quality of life. Continued
of the national total), most of which are used at or funding for operating, maintaining and
near capacity during peak periods—the Coalition
expanding this critical transportation
region’s highways are highly congested, especially
network requires an adequate and
in the 29 major urban areas within the Coalition
region. As a result, the various State DOTs, sustainable funding method
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/.

2

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

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 Transportation
The primary source for surface transportation
Figure 2. Electric Vehicles: Good for the
revenues—the pay at the pump fuel tax, which
Environment and Less Reliance on Foreign Oil;
is typically based on a fixed amount per gallon—
Not So Good for Transportation Funding
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 stateimposed 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 hybridelectric 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.

3

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

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
Figure 3. Fuel Tax Revenue Forecast for Oregon
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 pergallon 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 II-95 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
3

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

4

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

Figure 4. New Financing Model for the Region
(Source: A 2040 Vision for the I-95 Coalition Region)

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
5

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

5

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

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 Description and 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

6

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

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
Figure 6. Toll Plaza on I-95 Entering
facilities—Most of the Corridor Coalition member
Delaware
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

7

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

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 The close proximity of the member
has a history of success, particularly with respect to states, numerous toll facilities,
advancing the interoperability of technologies and strong DOT and DMV leadership,
operational practices. For example, the Coalition’s
and experience with using variable
partnership with the Inter-agency Group (IAG) helped
toll rates, all place the Coalition
advance the integration of various independent
member states in a strong position
systems that use the same technology into the E‑ZPass
system. The Coalition also supported the development to tackle MBUF implementation on
of legislation regarding toll enforcement reciprocity a regional basis.
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.

8

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

Project Vision,
Vision, Goals,
Goals, and 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 multistate framework.

• Create a multi-state and multidisciplinary 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.

• 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.

9

• 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).
• 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.

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

Work Scope 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.

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

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.

10

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

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.

11

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

Figure 7. Methods for Recording and Reporting Miles

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

12

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

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.
Figure 8. Sample MRD Installation Instructions
(Source: Oregon 2012-2013 pilot; part of the information sent to participants with MRD)

Addressing the Requirements 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.

13

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

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 crossstate 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 nonlocation based option for automated mileage reporting; possibly
other approaches) will be one of the key elements of the pilots

14

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

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 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

15

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

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

Legislative 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.

16

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

Staffing Description and Grant Management
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.

Figure 9. Participating States in Grant

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

17

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

Committee to learn more about this alternative funding approach and lay the groundwork for
future participation.
Figure 10. Organizational and Management Framework for Grant

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

18








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

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

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 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
Approximate Due
Date

508
Compliant?

October 15, 2016

No

Monthly

No

March 1, 2017

No

May 1, 2017

No

Technical Memorandum—Other Issues Impacting Corridorwide MBUF Consistency (e.g., privacy)

January 15, 2017

No

Outreach and Education Plan (Corridor-wide)

December 1, 2016

No

Throughout per plan

No

July 1, 2017

Yes

February 1, 2017

No

June 1, 2017

No

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

April 1, 2018

Yes

October 1, 2017

Yes

Deliverable
Program Management Plan (including detailed schedule)
Status Reports (Internal to MBUF Steering Committee)
Technical Memorandum—Out-of-State Travel
Technical Memorandum— MBUF Administration (e.g.,
business rules, rate setting, interoperability with toll
facilities, impacts on state finances)

Outreach Materials
Model State MBUF Legislation
Operational Concept Document for State-Specific Pilots
Outreach Plans for Focused Pilots
Outreach Materials for Focused Pilots

Final Pilot Reports
Annual Reports to FHWA

19

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

Figure 11. Preliminary Schedule

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.

20

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

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)

21

$2,100K

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

Match Information
Table 10 summarizes how the participating states will provide the remaining 50 percent nonfederal 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
Hard Match (nonfederal state funds)

Soft Match (Type)

Total Match

Delaware

$290K

-0-

$290K

Pennsylvania

$290K

-0-

$290K

Connecticut

$300K

-0-

$300K

-0-

$580K (Toll Credits)

$580K

$30K

-0-

$30K

$910K

$580K

$1490 K

State

New Hampshire
Vermont
TOTAL

Risk Assessment
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.

22

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

Organizational 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.

23

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

Appendix A—
A—How the Proposed Scope and Work Activities Address Items
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
12

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

A-1

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

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.
Figure B-1. Major Trip Ends Involving Cross-state Travel
(Source: Northeast Corridor Intercity Travel Study, September 2015)

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

A-2

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

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 payas-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.

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

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 locationbased 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 multidimensional issue and will be addressed in the grant application through a combination of several
activities, including:

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

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

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 B—
B—Brief 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.

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APPENDIX B—BRIEF BIOS

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 onbudget. 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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APPENDIX B—BRIEF BIOS

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 awardwinning 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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APPENDIX B—BRIEF BIOS

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 C—
C—Letters of Commitment

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APPENDIX C—LETTERS OF COMMITMENT

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APPENDIX C—LETTERS OF COMMITMENT

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APPENDIX C—LETTERS OF COMMITMENT

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APPENDIX C—LETTERS OF COMMITMENT

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