September 8, 2011

Mr. Hasan Ikhrata Executive Director Southern California Association of Governments 818 West 7th Street, 12th Floor Los Angeles, CA 90017-3435

Subject: 2012 RTP and Road Pricing Dear Mr. Ikhrata: For more than a century the Automobile Club of Southern California, with six million members, has advocated for better mobility, traffic safety, quality of life, and economic opportunity. The Auto Club consistently supports policies and projects that effectively and efficiently improve roads, public transit, and air quality and that reduce congestion and traffic crashes. We also support reasonable and fair ways of paying for programs that further these objectives. Many of the goals and objectives identified for the 2012 Regional Transportation Plan (RTP) are consistent with our desire for a more mobile and better future for Southern California. And we have been pleased to be able to participate in parts of the RTP development process. This includes our participation on the Express Travel Choices (road pricing) Steering Committee. We believe that it is now time to formally share our thoughts and concerns regarding various road pricing options that are being considered for the RTP. These issues were shared previously with your staff and consultants at a number of meetings. All of our comments are made in recognition of the need for both additional resources for transportation and reforms to ensure people clearly receive real and recognizable benefits from the use of the taxes and other charges they pay for transportation.

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Any road pricing policy, plan, or project must clearly and explicitly meet or include the following fundamental objectives and criteria: 1. The objective and result must be to improve mobility and not to enact punitive measures to reduce driving. Simply reducing driving in most cases will result in reduced mobility, reduced access to employment, commercial activity, services, and recreation, and reduced economic and social opportunities. 2. Road pricing must provide direct, recognizable benefits for motorists paying the charge and not adversely impact those who choose not to or cannot pay the price. The amount to be collected through road pricing must bear a proportionate relationship to the benefits payers would receive. 3. Revenues derived from road pricing must be used exclusively for effective transportation projects and services in the corridor or area in which they are collected and should never result in the transfer of existing or future transportation resources to non-transportation purposes. 4. Credible and independent economic analyses need to be completed to determine the opportunity costs of road pricing proposals. Any individual and regional value derived from road pricing must meet or exceed the total value that would have been derived from other uses (investment and spending) of funds to be collected in tolls or other road charges. Projects that use pricing to help finance the construction of new road capacity (like the SR-91 project in Riverside County) have merit and should be included in the RTP. Pricing can and should be used to complete financing or advance schedules for projects that include new express, toll, and general purpose lanes. These projects improve mobility in the region and provide inherent value to those who pay to use them. Pricing scenarios being considered that connect existing and planned HOV and express lanes into a regional HOT lane network show promise and should be considered for inclusion in the RTP as long they do not degrade traffic speeds and mobility on parallel, un-priced lanes and routes. Implementing this strategy will likely take many years, possibly decades, and should be the primary focus of more ambitious congestion pricing efforts in the RTP. Although implementing these scenarios will be challenging, they represent a realistic, achievable goal that can provide real options for travelers and additional revenues for road and transit improvements. Other, much more ambitious pricing scenarios under consideration are not realistic and should not be included in the RTP. These scenarios include proposals for a regional vehicle miles traveled (VMT) tax or “fee,” adding pricing to existing general purpose lanes, and imposing “cordon pricing” in various areas. The overall impact of these scenarios on mobility, motorists, and others is uncertain at best and negative at worst. There is no credible evidence that these scenarios are understood or supported by the public. All of these scenarios will require federal and state legislative authority, votes of multiple local boards and voters, and will face extreme scrutiny by the media and among the public. As a result, it is very unlikely that these scenarios can be implemented in a way or time-frame to provide meaningful, assured revenues for this RTP cycle. Therefore, these scenarios should fail to meet federal financial conformity tests and should not be included in the RTP.

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Changing HOV occupancy requirements from 2 (the current standard on most lanes) to 3 should be considered only as needed on a case-by-case basis and not region-wide or to artificially create “unused capacity” that can be priced. As HOV lanes become crowded they clearly do not provide any benefit or incentive to carpool (the original purpose for creating the lanes). When this happens there are only two rational options. The lanes can be converted to general–purpose lanes (in accordance with federal requirements) or vehicle occupancy requirements can be increased. We are likely to face a time in the future when this may be needed. However, any such change should be done carefully freeway-by-freeway and with the greatest care to preserve and not degrade mobility in each corridor. The Auto Club recognizes that closing the projected $45 billion revenue shortfall in the RTP is a daunting task that will require innovative transportation planning and financial approaches, and may require some re-prioritizing or scaling back of plans. Pricing can play a role in addressing these issues. But pricing should not be used to reduce mobility and accessibility. Nor should it be relied on in an unrealistic way to show “paper revenues” that artificially close the funding gap in the RTP, but that will not materialize in real revenues for actual transportation investment. Thank you for this opportunity to share our thoughts on road pricing and the RTP. The Auto Club looks forward to continuing our work with SCAG and other transportation and business partners to productively, realistically, and meaningfully address Southern California’s mobility and financial challenges. I would like to speak with you and appropriate members of your staff in person to review these items in more detail and to identify the best path forward for the RTP and for Southern California. I will be in touch to schedule a convenient time. In the meantime, please feel free to contact me at 714-885-2307 or Sincerely,

Stephen Finnegan Manager, Government Affairs and Public Policy

c: SCAG Regional Council Express Travel Choices Study Steering Committee Rich Macias, Director, Transportation Planning Naresh Amatya, Manager, Transportation Annie Nam, Manager, Aviation, Goods Movement and Transportation Finance