i York Toll Plaza Upgrade Options A Realistic Approach All Electronic Tolling Footprint at Mile Marker 6.7 Highway 407 ETR®, Toronto, Ontario Prepared by The eTrans Group, Inc. for The Town of York, Maine The eTrans Group, Inc. April 23, 2010 i Contents Executive Summary ........................................................................................................... 1 1.0 Introduction ............................................................................................................. 3 2.0 Alternative Toll Collection Strategies ......................................................................... 4 3.0 AET is Practicable at the York Toll Plaza ................................................................... 7 3.1 Recognizing AET Success Elsewhere ........................................................................ 7 3.2 Though Dismissed in Phase I - MTA has Already Adopted AET .................................. 9 3.3 AET and ORT Have the Same Operational Challenges .............................................. 10 3.4 Revenue Loss (Leakage) Estimates .......................................................................... 13 3.5 AET’s Concept of Operations -- How AET Really Works .......................................... 16 4.0 Alternative Evaluations .......................................................................................... 18 4.1 Engineering Design Guidelines ............................................................................... 18 4.2 Basic Purpose ........................................................................................................ 19 4.3 Safety and Other Traffic Concerns ........................................................................... 20 4.4 Environmental Impacts ........................................................................................... 24 5.0 Issues Critical to the USACE Review Process ........................................................... 27 Sources ........................................................................................................................... 29 Attachment 1 ................................................................................................................... 32 Attachment 2 ................................................................................................................... 39 Attachment 3 ................................................................................................................... 47 CONTROL SHEET ......................................................................................................... 48 The eTrans Group, Inc. April 23, 2010 ii The eTrans Group, Inc. April 23, 2010 1 Executive Summary All electronic tolling (AET) is the Least Environmentally Damaging Practicable Alternative (LEDPA) for the York Toll Plaza upgrade and must be considered during Phase II evaluations. The minimal footprint required for an AET solution just south of the existing toll plaza is demonstrated in Figure ES-1. Figure ES-1 Possible Footprint for All Electronic Tolling The eTrans Group, Inc. April 23, 2010 2 Even though AET is anticipated to have fewer environmental impacts, the Maine Turnpike Authority (MTA) submitted a Draft Phase I report for review by the U.S. Army Corps of Engineers (USACE or Corps) on March 17, 2010 that recommended the following shortlist of alternatives be considered for more detailed evaluation in Phase 2 of the Corps’ Highway Methodology Evaluation Process: Option 1: Option 2: Option 3: Option 4: Do Nothing Open Road Tolling (ORT) and cash toll collection at Mile Marker 7.3 (aka Option 4A) ORT and cash toll collection at Mile Marker 8.7, and ORT and cash toll collection at Mile Marker 9.1. Table ES-1 Anticipated Environmental Impacts of Practicable Options Option Estimated Impacts \ NRCS Wetland (Ac) Stream (ft) FEMA Flood Plain (Ac) Home Displacements Right-of-Way Meets Eng & Safety Rqts Satisfies Purpose & Need Est’d Construction $ Level of Acceptability: 2/ MM 7.3 28 729 4.3 0 8.1 No No $ 56 m Best 3/ MM 8.7 1.7 939 0.5 0 7.0 Some Yes $ 34 m Neutral 4/ MM 9.1 3.8 1582 0.1 0 7. Some Yes $ 35 m AET / MM 6.7 0 0 0 0 0 Yes Yes $ 6.9 m Worst Sources: Options 2, 3 & 4, Source 7, page 3 and Source 23, Table 4.1; AET Option, The eTrans Group, Inc., except price, Source 23, Appendix E, pg 11. Except for the cash toll option in ORT, AET and ORT require the same roadside technology and, if managed properly, the same back-office functions to collect tolls in the high speed lanes. The relative success of each alternative is a function of how well the back-office is managed. Therefore, AET is the Least Environmentally Damaging Practicable Alternative. The eTrans Group, Inc. April 23, 2010 3 1.0 Introduction The York Toll Plaza, the southernmost toll plaza on the Maine Turnpike, collects over $34 million in revenue each year, nearly 39% of all revenue collected by the Maine Turnpike Authority, from about 16 million vehicles, and slightly over 50% of these vehicles are from out-of-state. Built in 1969 and well beyond its planned useful life, this toll plaza poses a safety risk for motorists and employees of the MTA. (Source 7, page 1) On March 17, 2010, the MTA submitted: “Maine Turnpike Southern Toll Plaza Replacement Study, Draft – Phase I Report”, HNTB Corporation, November 5, 2009, (22) to the Corps. (Sources 7, 23) This work includes an assessment of alternative tolling strategies, an existing site evaluation (ESE), alternative site evaluations (ASE), and a comparative screening analysis and results in a recommended shortlist of alternatives to be considered for more detailed evaluation in Phase 2 of the Corps’ Highway Methodology Evaluation Process. Option 1: Option 2: Option 3: Option 4: Do Nothing Open Road Tolling (ORT) and cash toll collection at Mile Marker 7.3 (immediately north of the existing toll plaza) (aka Option 4A) ORT and cash toll collection at Mile Marker 8.7, and ORT and cash toll collection at Mile Marker 9.1. (Source 23) However, all electronic tolling is a viable option at the York Toll Plaza; and, when compared to the options above, AET is the Least Environmentally Damaging Practicable Alternative. This document demonstrates that AET is the LEDPA and should be considered during Phase II evaluation. The eTrans Group, Inc. April 23, 2010 4 2.0 Alternative Toll Collection Strategies Mechanization was first introduced to the toll collection process with automatic coin machines (ACMs) several decades ago. Though ACMs eliminated the need for a toll collector in the lane motorists still had to stop and pay their toll by putting coins into the ACM. Electronic toll collection (ETC) eliminated the need for motorists to actually stop and pay at the plaza. First deployed in North America on the Coronado Bridge in San Diego, CA in 1983, ETC allowed motorists to pay their toll through a radiofrequency communications link as they ‘rolled through’ the toll plaza. ETC provided a much higher level of service to motorists and, by reducing the revenue collected in cash toll operations, reduced revenue losses (leakage) at the plaza. Therefore, it was an instant success and by the early 1990's several toll authorities in North America had successfully implemented ETC with at least one, the Oklahoma Turnpike, offering ETC service to its patrons in free-flow by-pass lanes adjacent to a toll plaza offering a cash toll option. This mode of ETC operations was also quickly adopted by many authorities and by the mid 1990’s ETC service was being offered in a free-flow, open road environment, without any toll booths or toll collectors, on both the SR-91 Express Lanes in Orange County, CA and the Highway 407 Express Toll Route® (H407 ETR®) in Toronto, Ontario. As ETC operations developed from ‘roll through’ in the toll plaza, to free-flow by-pass lanes with an adjacent toll plaza offering a cash toll option, to collecting tolls in a free-flow, open road environment without any toll booths or toll collectors, the toll industry struggled with (and continues to struggle with) the most appropriate terminology to reference each mode of operation. The eTrans Group, Inc. April 23, 2010 5 Table 1 ETC Operating Modes Mode ETC Operations Terminology / First Installed Roll Thru (1) ETC / Toll Plaza with By-Pass Lanes (2) High Speed Tolling (HST), Open Road Tolling (ORT) / No Toll Plaza No Toll Booths (3) Circa 1983 Circa 1991 Cashless Tolling, Free Flow Tolling, All Electronic Tolling (AET) / Circa 1995 1) Roll Thru, Caguas Norte, Puerto Rico Highways and Transportation Authority, San Juan, Puerto Rico. First Roll Thru ETC installation to collect revenue in North America was on the San Diego Coronado Bridge in 1983. Tolls were removed from this operation in 2002. 2) By-Pass Lanes, Oklahoma Turnpike Authority, photo courtesy of TollRoadsNews.com; and, 3) No Toll Plaza or Booths, SR-91 Express Lanes ®, Orange County, CA. The eTrans Group, Inc. April 23, 2010 6 Therefore, in addition to ETC, a number of other terms have been used to describe the collection of tolls in an automated manner via ETC. What seems to now be conventional use of these terms is presented in Table 1. Note that all references that refer to ETC operations in by-pass lanes or tolling without a toll plaza or toll booths: High speed Tolling (HST) Open Road Tolling (ORT) Cashless Tolling Free Flow Tolling, and All Electronic Tolling (AET) toll vehicles at prevailing speeds in an open road environment. Therefore, all of these modes of toll operations are faced with collecting tolls from vehicles without tags that are not participating in the ETC program. The eTrans Group, Inc. April 23, 2010 7 3.0 AET is Practicable at the York Toll Plaza 3.1 Recognizing AET Success Elsewhere It is important to note that all three modes of ETC operation, including AET, have been implemented successfully on several facilities since the mid ‘90s. However, in a discussion on the H407ETR® in Toronto, the supporting documentation for dismissing AET at the York Toll Plaza in this Phase I submittal states: "Even in the instance of the facility being a high commuter roadway with high ETC tag penetration the system can fail." (Source 23, Appendix E, All Electronic Tolling Report, p 4.) And later in the same discussion on the H407 ETR®: "Currently, there is a significant issue regarding toll collection of non toll tag users such that there is a severe revenue shortfall." (Source 23, Appendix E, All Electronic Tolling Report, p 5.) Granted, most toll facilities, including the MTA, have experienced some decline in revenue recently due to the soft economy. However, to infer that the AET system collecting tolls on the H407ET® has “failed” or that it is the cause of “a severe revenue shortfall” is inappropriate. The H407 ETR® has been successfully collecting tolls via its’ AET system (cover) since 1997, is recognized as one of the most successful toll roads in the world, and has won several prestigious international awards. The number of AET ETC programs successfully operating or currently being implemented in the U.S. is now in the dozens. Toll facilities in the U.S. that have already successfully implemented AET include: The eTrans Group, Inc. April 23, 2010 8 SR-91 Express Lanes, Orange County CA I-15 HOT Lanes, San Diego County, CA Westpark Tollway, Houston, TX I-394MnPass, Minneapolis, MN I-95 Lanes Miami, Florida I-25 Express Lanes, Denver, CO E-470 Tollway, Denver, CO Northwest Parkway, Denver, CO 183A Toll Road, Austin, TX Sam Rayburn Tollway, Dallas, TX President George Bush Turnpike, Dallas, TX SR-167 Lanes, Seattle, WA Lee Roy Selmon Cross Town Expressway, Hillsborough County, FL MN/I-35W, Minneapolis, MN; and, Loop 49, Tyler TX. AET conversions are also well underway at many more facilities, including the Miami-Dade Expressway Authority (5 expressways in total), the North Texas Turnpike Authority in Dallas is implementing AET on its 3 expressways that do not already have it, and Florida Department of Transportation (FDOT) is currently converting its extensive toll road network to AET. Maryland also has an AET conversion underway at the Inter County Connector and the Triangle Expressway under construction in Raleigh will be AET, as will several more toll facilities in the planning stage in North Carolina. The UT/I-15 Express Lanes in Salt Lake, and the MD/I-95 north of the Baltimore Harbor tunnels. (Source 20) All of the High Occupancy/Toll (HOT) lanes that have been implemented throughout the country are already successfully tolling with AET, as will the The eTrans Group, Inc. April 23, 2010 9 ones currently being built. (Sources 14 & 20) A summary of these facilities and the status of their AET operations is presented as Attachment 1. Observation 1: AET has already been successfully adopted by many toll authorities in the U.S. and many other authorities are currently in the process of upgrading their existing roll-thru ETC and ORT systems to AET. Many of these authorities, such as those in Florida, Colorado, Texas, California, Minnesota and Washington state, also experience a significant volume of tourist and other out-of-state travel like that experienced on the Maine Turnpike. 3.2 Though Dismissed in Phase I - MTA has Already Adopted AET The MTA has supported the concept of HST and ORT for at least 5 years. (Sources 32 and 34) During this evaluation period the MTA also researched various tolling strategies with the goal of identifying a more efficient and safer means of tolling for the MTA at this location; and, in July 2006 the MTA reconfirmed that the tolling technology that best serves the MTA at the York Toll Plaza is Open Road Tolling (ORT) (Source 22, page 4, Source 20, slide 20) The reasons cited for this recommendation for ORT are: 1. “E-ZPass® Customers pay tolls at 55-65mph –less congestion –increased capacity –better service 2. Cash customers are physically separated from highway speed customers –increased safety 3. Addresses Existing and Future Traffic Demand –increased capacity –customer service -safety 4. 58% of traffic use E-ZPass at York Plaza 5. Over 80% of York Truck Traffic use E-ZPass 6. Reduced Noise Events A. Engine brakes and heavy acceleration B. Rumble strips C. Similar amount of noise as mainline today” The eTrans Group, Inc. April 23, 2010 10 (Source 21, slide 21) Observation 2: The MTA has adopted ORT (also known as HST). Therefore, MTA has already accepted responsibility for collecting a toll from those vehicles (licensed both in and out-of-state) that are not enrolled in the ETC program and drive through the ORT lanes. Observation 3: Adoption of ORT allows MTA to offer a cash toll option via an adjacent toll plaza. However, once ORT is offered the MTA has to also establish the same back-office functions necessary to collect tolls from those not enrolled in the ETC program that are required to support AET. 3.3 AET and ORT Have the Same Operational Challenges In submitting the Phase I report to the U.S. Army Corps of Engineers on March 17, 2010 the MTA notes in the cover letter that: “The MTA considered all-electronic tolling, but determined that such a system would pose significant financial risks due to its reliance on interstate and international billing and enforcement protocols and compacts that do not exists (sic) today and are uncertain to be established effectively in the future. This reality makes all-electronic tolling extremely risky for the MTA, which collects more than half of its annual revenue from out-of-state and out-of-country vehicles. The MTA was also concerned about other issues as well, including the necessity under an allelectronic tolling system to charge both in-state and out-of-state and out-of-state customers with administrative fees, that could exceed the cost of the toll itself, to pay the cost of processing and mailing bills to millions of video toll customers each year. An analysis of the feasibility of all-electronic tolling at Maine Turnpike’s southern toll plaza is provided in Appendix E of the Phase I report.” (Source 7, page 2) Observation 4: The risks from implementing AET are no greater than the risks from implementing ORT, unless The eTrans Group, Inc. April 23, 2010 11 a) one assumes that providing the cash toll option in an adjacent toll plaza is going to somehow make those who would evade the toll suddenly choose to do the right thing; and, b) all of those that drive through the open lanes without a tag are treated as violators – which would likely result in an interesting and very expensive public relations issue. Observation 5: The MTA is not subject to “reliance on interstate and international billing and enforcement protocols”. Interstate and international billing and enforcement protocols can be preempted in many cases if the authority is pro-active and offers motorists not enrolled in the ETC program another user-friendly option to pay their toll. 1. The MTA could deploy (and should under ORT operations) one or more of the many user-friendly programs successfully implemented by authorities that allow motorists to voluntarily pay their toll (usually with a nominal service fee) via telephone, the internet or at a conveniently located kiosk (such as at the southernmost service plaza on the Pike). These kiosks can be manned or automated and payments can be made anonymously. 2. There are at least 2 commercial services in the U.S. that enroll motorists and their vehicle license plates and warrant tolls for those vehicles enrolled in their programs to authorities that establish a formal agreement with them. In fact, as of April 20, 2010: o the MTA appears to be already enrolled in the PlatePass® program through the Inter-agency Group (IAG); and. o Rent-A-Toll™ had the following testimonial on the front page of their web site on April 20, 2010: "Rent A Toll has the most flexible solution in the marketplace to address this pressing issue within the toll industry" Rick Herrington, National Director of Technology Services, HNTB. The eTrans Group, Inc. April 23, 2010 12 The MTA should, therefore, be aware of these programs, especially since they are also appropriate and a necessary part of a successful ORT program. The eTrans Group, Inc. April 23, 2010 13 In those situations where the MTA finds itself in a position where it needs to notice a motorist through the mail for outstanding tolls and fees (which will happen with both AET and ORT toll options) there are several ways to gather the information necessary to do this, such as contacting the jurisdiction’s DMV (or its equivalent) or commercial services that provide this information. In addition, should enforcement be required other authorities with similar challenges have developed a number of innovative enforcement programs within their purview that have been very successful. 3.4 Revenue Loss (Leakage) Estimates Appendix E of the Phase I report (Source 23) estimated annual revenue ‘leakage’ (losses) for different modes of toll operations at the York Toll Plaza: Table 2 MTA’s Estimates of Annual Revenue Leakage Mode of Toll Ops York Toll Plaza Today ORT & Cash AET Optimistic AET Pessimistic Estimated Annual Revenue Leakage (1) % of Total Revenue $ 560,000 1.6% $ 850,000 2.5% $ 1,500,000 4.4% $ 17,100,000 50.3% 1) Leakage is a term used for toll revenue losses. (Source 23, Appendix E, “Comparison of York Plaza Total Revenue Leakage under Each Scenario,” page 19) The eTrans Group, Inc. April 23, 2010 14 Observation 6: Many out-of-state vehicles are already enrolled in the E-ZPass® program and would be expected to continue to reliably pay their toll automatically through the E-ZPass® system as they do today. Given: The York Toll Plaza collects over $34 million in revenue each year (Source 7, page 1) 58% of all traffic using the York toll plaza was already enrolled in the E-ZPass® program as of November 5, 2009 (Source 21, slide 21), and > 80% of the truck traffic is already enrolled in the E-ZPass® program (traffic which pays a much higher toll and tends to be long distance trips thus benefiting less from the current EZPass® discounts) (Source 21, slide 21, and MTA, Toll Rate Charts effective February 1, 2009) Therefore, even after considering the discounts offered E-ZPass® patrons these data suggest that ~ 50% of all toll revenue at the York Toll Plaza is currently being collected by the E-ZPass® program. Observation 7: The AET pessimistic estimate (above) appears to assume that toll revenue would be collected from only those vehicles already enrolled in the E-ZPass® program. This is pessimistic indeed! Assuming that the current roll-thru E-ZPass® toll operation on the Pike has very little toll revenue leakage, more realistic pessimistic estimate for toll revenue leakage under the AET mode of operation would be based on the Town of York’s success rate for collecting outstanding parking tickets of ~ 88% (i.e. Their revenue loss rate on citations is ~ 12%). Since the Town of York does not have the luxury of collecting any of these tickets via the EZPass® program, a conservative revenue loss rate for the MTA (after enforcement options) would be: The eTrans Group, Inc. April 23, 2010 15 12% Leakage on Non-E-ZPass® Users * ~ 50% of Total Revenue ≤ 6% of Total Toll Revenue Lost However, this estimate does not consider any benefits from the several user friendly toll payment options presented above, which should be substantial. Observation 8: An estimated worst case scenario for Total Revenue Lost at the York Toll Plaza under AET operations is well below 6%. Using MTA data and similar logic to develop an estimate of revenue leakage for cash toll operations: MTA’s estimate of 1.6% total revenue leakage for current toll operations at the York Plaza (Figure 2), and eTrans’ estimate that ~ 50% of the toll revenue collected at the York Toll Plaza is via the E-ZPass® operation (rever to above); and, as above assuming that the current E-ZPass operation encounters only minor revenue leakage. A conservative estimate of revenue leakage at the York Toll Plaza under just cash toll operations is at least: 1.6% Leakage at York Plaza Today / 50% Cash Tolls ≥ 3.2% Leakage for Cash Tolls Observation 9: Estimated current revenue losses for MTA’s cash toll operations at the York Toll Plaza (≥3.2%) is more than half of a realistic pessimistic estimate of revenue losses for AET operations at the York Toll Plaza (well below 6%). Once all things are considered, estimates of MTA’s current revenue losses in cash toll operations may be greater than its actual revenue losses under AET operations. The eTrans Group, Inc. April 23, 2010 16 3.5 AET’s Concept of Operations -- How AET Really Works Motorists without a tag who voluntarily contact the authority to pay their toll are typically charged a nominal service fee to recover the costs of processing their toll for the convenience of not having to actively enroll in the ETC program and put a tag on their vehicle. This can even be done in a manner that the motorist remains anonymous. Motorists who the authority has to mail a notice are assessed a higher service fee to recover the additional costs associated with having to retrieve vehicle ownership information and send them a notice. Motorists who the authority has to process through an enforcement action are assessed a significant penalty that is usually set at a level sufficient to recover the toll, the costs of all violations and enforcement activity and any tolls that may not be recovered. Assessing service fees and penalties in an escalating manner according to the level of difficulty, cost and risk associated with collecting tolls at each level, enables the authority to recover the additional costs associated with collecting tolls from those vehicles. In fact, penalties associated with all violations enforcement processing (VEP) activity are usually set at a level sufficient to recover the costs of all VEP as well as the tolls not recovered. Therefore, a conservative estimate for AET Optimistic revenue losses is zero. In fact, less than a year into initial operations for the H407 ETR® the strategy above resulted in violations enforcement activity being a profit center within their AET operation. (Author was in Responsible Charge.) The eTrans Group, Inc. April 23, 2010 17 Table 3 Estimates of Cash and AET Annual Revenue Leakage on the MTA (1) Mode of Toll Ops Cash AET Optimistic AET Pessimistic MTA’s Estimates (2) n/a eTrans’ Estimates (3) 3.2% 4.4% 0% 50.3% Well below 6.0 % 1) Leakage is revenue loss expressed as % of total revenue that should be collected. 2) Source 23, Appendix E, “Comparison of York Plaza Total Revenue Leakage under Each Scenario,” page 19. 3) Conservatives estimates generated by eTrans above. Observation 10: AET is likely to have less revenue leakage at the York Toll Plaza than cash toll operations when service fees and penalties are assessed in an equitable manner. Appendix E of the Phase I report also provides a summary of both “negative” and “beneficial” impacts of AET. (Source 23, Appendix E, All Electronic Tolling Report, pp 7 to 10) These impacts (with salient observations) are provided as Attachment 2. In summary, most of the recommendations for NOT recommending AET fail to recognize that ORT and AET, if managed properly, require the same back-office functions. Therefore, since the MTA has already committed to provide these back-office functions for ORT (having embraced ORT), AET is, by default, a viable alternative and should continue to be considered as a practicable option in the Phase II evaluation effort. The eTrans Group, Inc. April 23, 2010 18 4.0 Alternative Evaluations The following criteria were used in the Phase I study to establish a baseline for alternative evaluations (Source 23, page 3): 1) Engineering design guidelines 2) Basic Project Purpose 3) Toll collection strategies 4) Safety 5) Capacity and plaza sizing 4.1 Engineering Design Guidelines HNTB established the following nationally recognized engineering guidelines as design criteria for comparisons between alternatives. (Source 21, slide 9): “Geometric Design of Highways and Streets (AASHTO, 2004) “Manual on Uniform Traffic Control Devices” – MUTCD (Federal Highway Administration, 2003) “Roadside Design Guide” (AASHTO, 2006), and “State of the Practice and Recommendations on Traffic Control Strategies at Toll Plazas” (FHWA, 2006) Observation 11: Toll plaza design guidelines are limited. Observation 12: Design criteria for a traditional toll plaza are very different from design criteria for an AET toll gateway since AET does not require a toll plaza or incur their environmental, safety and operational impacts. Use of traditional toll plaza criteria that do not The eTrans Group, Inc. April 23, 2010 19 apply to AET applications can inadvertently bias the analyses when AET is a viable option. The Phase I report also stresses that: “A common theme among these guidelines, as it relates to their purpose, is that uniformity of design practices and procedures is a key factor in the safety of travelers on our Nation’s highways. As well, operational efficiency of our roadway network can be improved through the use of these national guidelines and best practices. Another important result of the application of these guidelines is the efficient use of resources and the positive impact it has on our environment.” (Source 21, slide 11) Observation 13: Over 50% of vehicles using the York Plaza Upgrade are expected to be from out of state (Source 7, page 1). Therefore, uniformity of design among the York Plaza site, Massachusetts Turnpike and other roads in the region is critical to both safety and user acceptance (Sources 10 & 11). 4.2 Basic Purpose On November 9, 2009 the following conditions were cited as reasons to implement the York Plaza upgrade now: 1. Safety Concerns and Issues 2. Booths, Tunnel and Canopy 3. Plaza (Area) Design 4. Operations (Traffic Flow) 5. Tolling Technology (Source 21, slide 17) Observation 14: Regardless of which ORT options described in Phase I might be implemented, a conventional toll plaza in each direction is still required. Many of the problems associated with issues 1 through 4 above would, therefore, merely be transferred to the new toll plaza location. The eTrans Group, Inc. April 23, 2010 20 Observation 15: AET is the only option that solves all 5 concerns identified in the Basic Project Purpose. 4.3 Safety and Other Traffic Concerns The MTA’s stated purpose for conducting this work is: “To replace/rehabilitate the existing barrier toll plaza on the Maine Turnpike at York, Maine incorporating High Speed Tolling (HST) and addressing settling/subsidence and facilities deficiencies, safety deficiencies and existing and projected traffic volumes.” (Source 13, slide 19) Observation 16: AET is the only option that fully meets the stated purpose above. A series of basic design criteria were identified for the initial alternatives analysis to establish a minimum baseline for safety reasons. “Basic Design Criteria for Toll Plazas 1. Separation from Interchanges: A. Minimum 1 mile between interchange and center of toll plaza. 2. Separation from overhead bridges: A. Minimum 2500’ between overhead bridge and center of toll plaza. B. Desirably not within footprint (approx 8000’) 3. Horizontal Tangent: A. Straight stretch of approximately 8,000 feet 4. Crest vertical curve: A. Center of straight stretch (toll plaza) at or near the top of a small gradual hill.” (Source 21, slide 12) The eTrans Group, Inc. April 23, 2010 21 These design criteria are important for the cash toll plazas included in MTA’s ORT alternatives as it is important to: Provide adequate roadway length on all approaches to and departures from a toll plaza to allow motorist to weave between traffic lanes safely, and Reduce the likelihood of and minimize the impact from brake failures and other situations limiting vehicles ability to stop (e.g. rain, snow, ice) on all approaches to the plaza. Being able to adequately sign each toll plaza to minimize the number of conflicts introduced to the traffic stream is also critical to both cash and ORT and cash toll operations. Observation 17: AET is not constrained by these criteria established to avoid safety concerns in traditional toll plaza deployments. The Phase 1 Report identified options for sizing the toll plaza under cash toll operations as well as under ORT and cash toll operations. Under ORT and cash toll operations, the number of lanes that need to be provided for each mode of toll operation is a function of the anticipated split between ORT and cash toll operations over time, as well as any peak period or seasonal factors that could impact ORT and cash toll processing requirements at the toll plaza. All of these options impose a significant lateral footprint on the highway regardless of where they are located. (Refer to Figure 1) Once the longitudinal footprint necessary to accommodate the necessary tapers on both approaches and departures to each toll plaza are considered the land footprint of land required to provide these toll facilities is significant. Observation 18: Since a toll plaza is not required to support AET operations, AET does not incur a significant lateral or longitudinal ‘footprint’ on the roadway. The eTrans Group, Inc. April 23, 2010 22 The eTrans Group, Inc. April 23, 2010 23 Figure 1 Plaza Options Being Considered by the MTA (Source 21, slide 25) Options recommended for further evaluation in the Phase I report are as follows: Option 1: Option 2: Option 3: Option 4: Do Nothing Open Road Tolling (ORT) and cash toll collection at Mile Marker 7.3 (immediately north of the existing toll plaza) (aka Option 4A) ORT and cash toll collection at Mile Marker 8.7, and ORT and cash toll collection at Mile Marker 9.1. (Source 23) The eTrans Group, Inc. April 23, 2010 24 A fifth option currently not being considered is recommended for consideration: All Electronic Tolling. Factors that should be considered in locating an AET toll gateway are minimal and include: Gantries (overhead structures) can be placed so that toll gateway covers all travel lanes. There is sufficient room for an environmentally enclosed cabinet to house electronic equipment and a parking pad for a service vehicle, and Accessibility to electrical power nearby. The AET Option could, therefore, be easily placed at a number of locations without impacting the surrounding areas. Design criteria such as those needed for toll plazas are irrelevant to an AET toll gateway. In addition, AET’s only traffic operations concern is that motorists are properly informed that they are about to drive through a toll gateway. Traffic weaving and merging concerns, major safety issues at toll plaza approaches and departures, are not incurred in AET applications. Observation 19: AET is the safest option. 4.4 Environmental Impacts The AET Option could be easily be installed immediately North of the Connector at Mile Marker 6.7. At this location AET gateways would toll vehicles on both the ramps and the mainline. (Refer to Figure 2) . The AET toll gateway could be placed here without any aquatic impacts and there is already power at this location. Other environmental impacts, such as noise and emissions would also be significantly less for the AET option. Nighttime lighting would also be required. However, the impacts of this lighting an AET gateway are significantly less than those from an ORT and cash toll plaza. The eTrans Group, Inc. April 23, 2010 25 Figure 2 Estimated Footprint for AET Toll Gateway at Mile Marker 6.7 Observation 20: Anticipated Footprint from an AET toll gateway immediately North of the Connector at Mile Marker 6.7. A summary of the anticipated environmental impacts of Options 2 thru 4 as presented in the Phase I report, and the anticipated environmental impacts of AET implemented at a location such similar to that identified in Figure 2 above are presented in Figure 3. The eTrans Group, Inc. April 23, 2010 26 Figure 3 Anticipated Environmental Impacts of Practicable Options Option Estimated Impacts\ NRCS Wetland (Ac) Stream (ft) FEMA Flood Plain (Ac) Home Displacements (1) Right-of-Way (2) Meets Eng & Safety Rqts Satisfies Purpose & Need Est’d Construction $ (4) Level of Acceptability: 2/ MM 7.3 28 729 4.3 0 8.1 No No $ 56 m Best 3/ MM 8.7 1.7 939 0.5 0 7.0 Some Yes $ 34 m Neutral 4/ MM 9.1 3.8 1582 0.1 0 7. Some Yes $ 35 m AET / MM 6.7 0 0 0 0 0 Yes Yes $ 6.9 m Worst Sources: Options 2, 3 & 4, Source 7, page 3 and Source 23, Table 4.1. AET Option, The eTrans Group, Inc., except price which was taken from Source 23, Appendix E, All Electronic Tolling Report, page 11. Notes: 1) Though no home displacements are technically encountered, land near new homes at MM 8.7 and MM 9.1 could be significantly impacted should a new toll plaza be built at these locations. 2) Estimates may not include right-of-way for local access road to main utility building. (An access road is not necessary for AET Option.) 3) AET option at MM 6.7 would allow reclamation of several acres of wetlands. The cost of this reclamation is not included in the estimated cost of providing the AET Option above. 4) AET estimate for construction cost includes roadside systems, structures and civil work. Though front and back-office systems costs will be incurred for all options in Figure 5, they are not included in the AET construction cost estimate as they do not appear to have been included in the estimates for Options 2, 3 or 4. Observation 21: AET is clearly the Least Environmentally Damaging Practicable Alternative. The AET Option also offers environmental benefits in several other areas (e.g. air quality, noise, visual and light intrusion). The eTrans Group, Inc. April 23, 2010 27 5.0 Issues Critical to the USACE Review Process It is our understanding that section 404(b)(1) Guidelines of the Clean Water Act allow the U.S. Army Corps of Engineers to issue a permit only if it has been demonstrated that the project is the Least Environmentally Damaging Practicable Alternative (LEDPA). The U.S. Army Corps of Engineers verifies if the recommended alternative is ‘Practicable’ and ‘Least Environmentally Damaging’; and, “Only the LEDPA may receive a USACE Permit.” (Source 17, slide 11) Observation 21: At least one ‘Practicable’ alternative (AET) has not been recommended for further evaluation at the completion of Phase I of this project. This alternative, if implemented correctly, should have no negative impact on the aquatic environment in this area (unlike the 4 options that have been forwarded for more detailed evaluation). Therefore, the Least Environmentally Damaging Practicable Alternative (LEDPA) cannot possibly be selected for this project if the AET option is not included in the options for further evaluation. MTA’s application is thus incomplete. It is also our understanding that priorities regarding impacts to aquatic resources are to: 1. Avoid impacts if possible 2. Minimize impacts that cannot be avoided, and to 3. Mitigate unavoidable impacts. Therefore, the AET Option is the environmentally friendly option. The AET Option: 1. avoids impacts to the local aquatic environment The eTrans Group, Inc. April 23, 2010 28 2. allows the MTA to reclaim several acres of wetlands from the existing toll plaza site; and 3. offers significant other environmental benefits in the form of reduced fuel consumption and fewer emissions, as well as less noise, visual intrusion and less impact on ambient lighting in nearby neighborhoods. The AET option is also clearly safer than those options that have been recommended for further consideration as it requires no barriers in the roadway to introduce conflict to the traffic stream. In addition, the AET option is, by far, the least expensive option; and, if managed properly can also be the most cost-effective option. Conclusion: The AET Option must be included with other options recommended for further evaluation to make the Phase I MTA application complete and enable selection of the LEDPA. The eTrans Group, Inc. April 23, 2010 29 Sources 1. “E-ZPass Personal Account Terms & Conditions”, April 6, 2010, https://ezpassmaineturnpike.com/EZPass/docs/EZPassPersonalTerms.pdf. 2. “E-ZPass Account Types”, April 6, 2010”, https://ezpassmaineturnpike.com/EZPass/info/accounttypes.jsp;jsessioni d=0000sEWrY_EpWdYZSUFgz5HIoxB:-1 3. “Dallas TX area to go cashless by year's end, Miami HEFT next spring”, Posted on Fri, 2010-04-02 02:43, http://www.tollroadsnews.com/node/4683. 4. “Commuter Automatic Quarter Renewal to be completed April 10th and 11th”, April 1, 2010, https://ezpassmaineturnpike.com/EZPass/News.do;jsessionid=0000s0Dh 74WuL_2Xillk_BX_73o:-1?id=1246459009780. 5. “HNTB Designer, Number 92, 2010”, a publication of the HNTB Corporation, http://www.hntb.com/sites/default/files/issues/Designer92.pdf. 6. “HNTB Viewpoints, 2010”, a publication of the HNTB Corporation, http://www.hntb.com/sites/default/files/issues/TranspNewDay_Finn_011 0.pdf 7. Letter from Conrad W. Welzel, Government Relations Manager, Maine Turnpike Authority, to Jay clement, Senior Project Manager, Maine Project Office, U.S. Army Corps of Engineers, March 17, 2010. (cover to submittal of “Maine Turnpike Southern Toll Plaza Replacement Study”, Draft Phase 1 Report, prepared by HNTB Corporation, November 5, 2010) 8. “MTA Votes to Send First Phase of York Toll Plaza Study to U.S. Army Corps of Engineers”, February 25, 2010, http://www.maineturnpike.com/about/press_release.html?recordid=169. 9. “Maine Turnpike stick to 'fat' toll plaza design, city of York hires AET expert to contest” Posted on Thu, 2010-02-25 00:45, http://www.tollroadsnews.com/node/4623. 10. “Mass Governor to appoint all-electronic toll manager” (MAJOR ADDITIONS), Posted on Tue, 2010-02-16 17:59, http://www.tollroadsnews.com/node/4606. The eTrans Group, Inc. April 23, 2010 30 Sources (cont) 11. “Deval Patrick puts toll takers on notice, Governor eyes electronic booths on Pike“, BostonHerald.com, by Hillary Chabot, February 8, 2010, updated February 9, 2010. 12. “HNTB viewpoints, 2010”, a publication of the HNTB Corporation, http://www.hntb.com/sites/default/files/issues/TranspNewDay_Finn_011 0.pdf 13. “US Army Corps of Engineers, New England District, Regulatory Program and Highway Methodology Overview”, Maine Turnpike Authority, Public Meeting for York Toll Plaza, January 21, 2010. (Presentation) 14. “A Critique of HNTB’s Appendix E Review of All-Electronic Tolling: Point, Counterpoint”, Peter Samuel, Editor of TOLLROADSNews.com, 2010-01-18. (Unpublished) 15. “Maine Turnpike Authority's effort to build a new south-end toll plaza raises issue of all-electronic tolling’, Posted on Thu, 2010-01-07 01:31, http://www.tollroadsnews.com/node/4528. 16. “Maine Turnpike Authority pushes on with fight for big new ORT + cash toll plaza”, Posted on Wed, 2010-01-06 00:06, http://www.tollroadsnews.com/node/4526. 17. “Getting caught in the crossfire of a Maine civil war - TOLLROADSnews takes hits”, Posted on Wed, 2009-11-18 11:57, http://www.tollroadsnews.com/node/4452 18. “Two I-95 toll plaza upgrade efforts - York ME, Newark DE – compared”, Posted on Sun, 2009-11-15 21:29, http://www.tollroadsnews.com/node/4447 19. “HNTB: a clarification”, Posted on Fri, 2009-11-13 11:55, http://www.tollroadsnews.com/node/4443 20. “HNTB provides Maine false & misleading advice on all-electronic tolling” (EDITORIAL), Posted on Tue, 2009-11-10 21:49, http://www.tollroadsnews.com/node/4441 21. “Maine Turnpike Southern Toll Plaza Replacement Study”, Draft Phase One report for submittal to the U.S. Army Corps of Engineers”, HNTB presentation to the Maine Turnpike Authority, November 9, 2009. (Presentation) The eTrans Group, Inc. April 23, 2010 31 Sources (cont) 22. “Engineer Recommends Short-list of Sites for Improved York Toll Plaza, --Smaller Toll Plaza Design Avoids Home Displacements—“, November 5, 2009, http://www.maineturnpike.com/about/press_release.html?recordid=164. 23. “Maine Turnpike Southern Toll Plaza Replacement Study, Draft – Phase I Report”, for submittal to the U.S. Army Corps of Engineers, HNTB Corporation, November 5, 2009. 24. “Ten Year Planning report, prepared for the Maine Turnpike Authority, Prepared by HNTB”, September, 2009, http://www.maineturnpike.com/pdf/2009%2010Year%20Planning%20Report.pdf. 25. “Engineer reports on the feasibility of constructing new toll plaza on site where existing York Toll Plaza stands”, June 16, 2009, http://www.maineturnpike.com/about/press_release.html?recordid=158. 26. “Maine Turnpike, Southern Toll Plaza, Initial All-Electronic Tolling, Feasibility Review,” prepared for Maine Turnpike Authority, HNTB Corporation, February 20, 2009. 27. “Tolls and Other Revenue Sources”, with Dr. Ramon Grijalva, presentation to the Atlantic Provinces Transportation Forum, Fredericton, New Brunswick, February 12, 2009 28. “Maine Turnpike Replaces Automatic Coin Lanes with Dedicated EZPass Lanes”, January 8, 2009, http://www.maineturnpike.com/about/press_release.html?recordid=151. 29. “Maine Turnpike Annual Report”, 2008, http://www.maineturnpike.com/pdf/MTA-Annual_Report_2008.pdf. 30. Letter from Gerard P. Conley, Sr. Chairman, MTA, to Michael L. Estes, Chairman, York Board of Selectmen, October 9, 2008, http://www.maineturnpike.com/pdf/Conley-Estes_100908.pdf. 31. “Congestion Pricing – Is it Real or a Planner’s Pipedream?”, presentation to the Transportation Group at the University of New Brunswick, Fredericton, New Brunswick, March 27, 2008. 32. “Maine Turnpike Annual Report”, 2007, http://www.maineturnpike.com/pdf/MTA-Annual_Report_2007.pdf. The eTrans Group, Inc. April 23, 2010 32 Sources (cont) 33. “Simplicity – The Future of Electronic Toll Collection (ETC)”, paper presented to the 8th Asia-Pacific Intelligent Transportation System Forum and Exhibition, Hong Kong, July 11, 2006. 34. “Maine Turnpike Annual Report”, 2005, http://www.maineturnpike.com/pdf/MTA-Annual_Report_2005.pdf. 35. “Toll Systems & Operations – IT Products Meet Patrons”, Monthly Transportation Trends and Issues Seminar, Steer Davies Gleave Ltd. London, England, April 30, 2005. 36. “Making Technology Work in Transportation”, presentation to the Transportation Group at the University of New Brunswick, Fredericton, New Brunswick, February 17, 2005. 37. “Open Road Toll Collection -- Highway to the Future”, with Dr. Thomas McDaniel, proceedings of the 70th Annual Meeting of ITE, August 2000. 38. “Transponders, Transactions and Other Trends in Transportation”, presentation to the Transportation Group at the University of New Brunswick, Fredericton, New Brunswick, February 4, 1999. 39. "Challenges to Deployment of Automated Toll Collection Systems”, presentation to the Institute of Transportation Engineers Southern District 7th Annual Meeting, April 1995. 40. Implementing Electronic Toll Collection on a New Facility: The GA 400 Experience", with David Burgess, Georgia State Tollway Authority, proceedings of the 61st Annual Meeting of IBTTA, October 1993. 41. "Congestion Management: What are the Real Opportunities?, presentation to the 4th National Conference on Transportation Planning Methods Applications, May 1993. 42. "Integrating Electronic Toll and Traffic Management Systems: Opportunities for Congestion Pricing", proceedings of the MTT 1992 Conference, April 1992. 43. "Laying the Foundation for Congestion Pricing", proceedings of Annual Meeting of ITE, District 6, July 1991. 44. "Electronic Toll Collection: A California Update", proceedings of IBTTA, Spring Workshop, April 1991. The eTrans Group, Inc. April 23, 2010 33 Sources (cont) 45. "Public Relations Issues of Electronic Toll Collection and Traffic Management", presentation to IBTTA Winter Workshop, February 1991. 46. “Electronic Toll Collection: The California Challenge", HNTB's First Annual Toll Road Symposium, September 1990. The eTrans Group, Inc. April 23, 2010 32 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. Abbreviations used on this page: SOV (Single-occupant vehicle); HOV (High-occupancy vehicle); HOT (High occupancy/toll); ETL (Express toll lane). On this page, the word "hybrid" is used to indicate systems that are part HOT and part ETL. Current HOT Lanes The following roads currently use HOT lanes: California free. Interstate 15, San Diego County. SOV toll ($0.50-$8.00); HOV-2+ [1] Colorado Interstate 25 between 20th Street in Downtown Denver and the US-36 interchange. SOV toll ($0.50-$3.50); HOV-2+, motorcycles, buses free.[2] Florida Interstate 95 Northbound and southbound lanes between I-195 and the Golden Glades interchange have been opened. Motorcycles, registered HOV-3, hybrid, vanpool, and buses ride free. SOV toll ($0.25-$2.65).[3] Interstate 394, MnPASS Minneapolis, from I-494 to TH 100.[4] SOV toll ($0.25-$8.00); HOV-2+ free.[5] Minnesota Utah Interstate 15 between 600 N in Salt Lake City, Utah and University Parkway in Orem, Utah. SOV toll ($50/mo.); HOV-2+/clean-fuel free. This is not truly a HOT or ETL project, as it operates by selling permits instead of collecting a toll. There is a maximum of 2,000 permits that will be sold.[6] Washington motorcycles free. SR 167, Auburn to Renton. SOV toll ($0.50-$9.00); HOV-2+ and [7] Current Hybrid Systems California 91 Express Lanes, Orange County, 10 miles. Toll rates are time-based instead of congestion-based. SOV toll ($1.20-$10.00); HOV-3+ 50% discount ($0.60-$5.00).[35][36] The eTrans Group, Inc. April 23, 2010 33 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. (cont) Texas Interstate 10 (Katy Freeway managed lanes) Houston between Texas State Highway 6 and Interstate 610 HOV-2+ free in peak hours; SOV and HOV-2+ nonpeak toll ($0.30-$1.60 per toll plaza; there are 3)[37] Interstate 10 (Katy Freeway - QuickRide), Houston (HOV2 toll/free off-peak, HOV3+ free, SOV prohibited, east of Interstate 610) (HOV-2 toll: $2.00)[38] U.S. Highway 290 (Northwest Freeway), Houston (HOV2 toll/free off-peak, HOV3+ free, SOV prohibited) Future HOT lanes (including studies underway) California San Francisco Bay Area The Bay area is planning an entire network of HOT lanes.[8] Interstate 680 Under construction.[9] Expected to open in 2010.[10] The portion being constructed is the Sunol grade. Interstate 580 Under construction. Expected to open in 2010.[10] The portion being constructed is in the Tri-Valley area. U.S. 101 Planned.[11] The areas to be constructed include the total area of the Metropolitan Transportation Commission (San Francisco Bay Area) (MTC), with the exception of the City of San Francisco, the northern approach to the Golden Gate Bridge, and northern San Mateo County.[12] Interstate 80 Planned. The areas to be constructed include the total MTC area, with the exception of the City of San Francisco, and the approach to the San Francisco – Oakland Bay Bridge.[12] SR 4 Planned, portions fully funded. The areas to be constructed are from the junction with I-680 to Antioch.[12] Interstate 880 Planned, portions fully funded. The areas to be constructed go from the south end of Oakland to the junction with U.S. 101.[12] SR 92 Convert lanes from HOV. The area to be converted is the approach to the San Mateo - Hayward Bridge.[12] SR 84 Convert lanes from HOV. The area to be converted is from the I-880 intersection to the approach to the Dumbarton Bridge.[12] Interstate 280 Planned. The areas to be constructed go from the intersection with I680 in San Jose to past the intersection with SR 85.[12] SR 85 Fully Funded. The area to be constructed is the entire length (both ends connecting with U.S. 101. Expected to open in 2012.[12] The eTrans Group, Inc. April 23, 2010 34 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. (cont) SR 87 Convert lanes from HOV. The area to be converted is its entire length, from U.S. 101 to SR 85.[12] SR 237 Planned. The area to be constructed is practically the entire length, from I880 to SR 85.[12] Riverside County Riverside County is recognized by the California Transportation Commission (CATC) as having a traffic congestion problem second only to Los Angeles.[13] SR 91 Recommended. Two HOT lanes and a mixed-flow lane from the Orange county line to the intersection with I-15.[13] Interstate 15 Recommended. Two HOT lanes and a mixed-flow lane from the San Bernardino county line to the intersection with SR 74. Further, an HOV lane and an eventual HOT lane extension to the San Diego county line.[13] Los Angeles County Los Angeles County has a plan in place that has been approved by the California legislature.[14] They have received a grant for $213.6 million from the USDOT(US Department of Transportation). This plan will be implemented in two phases, although it is currently unknown when those phases will take place.[15] Both phases are for the conversion of HOV lanes to HOT lanes. Interstate 10 Phase 1: Convert the San Bernardino Freeway HOV lanes from Alameda St/Union Station to the intersection with I-605. Phase 2: From I-605 to SR 57: in design; from SR-57 to the San Bernardino county line.[15] Interstate 210 Phase 1: Convert the Foothill Freeway from I-710 to I-605. Phase 2: From I-605 to the San Bernardino county line.[15] Interstate 110 Phase 1: Convert the Harbor Freeway from 182nd St./Artesia Transit Center to Adams Blvd.[15] SR 60 Phase 2: Convert from the intersection with I-605 to Brea Canyon (under construction), and convert from Brea Canyon to the San Bernardino county line.[15] San Diego County Interstate 15 Extension of already-existing HOT lanes. "Stage 3": From SR 163 to SR 56(Ted Williams Pkwy) (under construction). "Middle Stage A&B": from SR 56 to W. Bernardo Dr. (under construction; partially complete). "Stage North": From W. Bernardo Dr. to SR 78 in Escondido.[16] The eTrans Group, Inc. April 23, 2010 35 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. (cont) Florida Interstate 95 will be done in phases. Phase 1A was opened December 2008; Phase 1B opened in January 2010. Currently open are northbound and southbound lanes between the Golden Glades Interchange and I-395. As of February 2010, Phase 2, from the Golden Glades Interchange to I-595 in Broward County is unfunded with no scheduled launch date. However, FDOT has stated that, with proper funding, construction could start as early as September 2010, and be open as early as Spring 2012[3] Georgia Conversion of the existing HOV lanes to HOT lanes on Interstate 85 has been approved to relieve the congestion in the DeKalb County portion of the Northeast Atlanta region. This would be done from Chamblee-Tucker road south of the I-285 junction to Old Peachtree Road in Gwinnett County. HOT lanes on I-85 are expected to be in service by 2011.[17] Illinois Illinois Tollway System "Green Lanes" (really, HOT lanes) are to be added to all roadways in the Illinois Tollway System. The lanes could begin operating as early as 2010. All Chicago-area tollways will have "green lanes" by 2015.[18] Suspended after former Governor Rod Blagojevich, who suggested the idea, was arrested, impeached, and removed.[19] Minnesota Interstate 35W Segment 3: From SR 65/I-94 split to 42nd St. This will be a Priced Dynamic Shoulder Lane (PDSL) (a type of HOT lane). Scheduled to open 9/2009. Segment 2: From 42nd St. to 66th St. This is an HOV to HOT conversion project. Scheduled to open 2010. Segment 1: From 66th St. to Burnsville Parkway (see Burnsville, Minnesota). This is an HOV to HOT conversion project. Scheduled to open 2011.[20] New York/New Jersey Port Authority The Port Authority of New York and New Jersey is studying the concept of merging HOT lanes with the existing XBL (eXclusive Bus Lane) lanes in the Lincoln Tunnel.[21] North Carolina Interstate 77 Charlotte, from I-85 to SH 2158 (Griffith Street) at Davidson, Mecklenburg County. Extend existing HOV Lanes, convert HOV Lanes to HOT Lanes and evaluate shoulder use lanes. Under study.[22] The eTrans Group, Inc. April 23, 2010 36 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. (cont) South Carolina All South Carolina projects are under study. Interstate 77 From the intersection with U.S. 21 to the North Carolina state line. This highway portion is very heavily used, and so HOT lanes is one option being studied to relieve congestion.[23] Interstate 26/Interstate 126/Interstate 20 Projections are that traffic on these interstates will double by the year 2030. A corridor taskforce has been in place to study all the possibilities for managing the anticipated traffic growth. All these could accommodate HOT lanes.[23] o These are the only segments that would support widening for HOT lanes: A 7.22 mile segment of I-26 from the intersection with I-126 to the intersection with U.S. 321. A 6 mile segment of I-20 east of I-77 to the northeast section of Richland County. No funds are currently available. o These segments could not be widened, but are still being considered for HOT lanes: A 9.22 mile segment of the I-26/I-126 corridor from U.S. 176 to U.S. 21. A 14.45 mile segment of I-20 from the northeast section of Richland County to the intersection with U.S. 378. Interstate 385 A 6.45 mile segment of I-385 from east of I-85. This segment could be widened for HOT lanes; however, no construction funds are currently available.[23] Texas Loop 1604 There have been discussions of adding HOT lanes to this road in the future.[24] U.S. 281 There have been discussions of adding HOT lanes to this road in the future.[24] Interstate 10 Extending the I-10 HOT lanes from SH 6 in Harris County to FM 359 in Waller County (under study).[25] Interstate 635 From east of Luna Road to Greenville Avenue (under study).[26] Interstate 35E From south of the Loop 12/I-35E split to south of Valwood Parkway, including the reconstruction of existing facilities, construction of frontage roads and the addition of managed lanes.[26] SH 121/SH 183 (Fort Worth district) Proposed improvements are planned to include three general purpose lanes in each direction with three HOT lanes in each direction for a total of twelve lanes with frontage roads for future traffic volumes. Under study.[27] Interstate 35W From Wautauga Ave. to Meacham St. in Fort Worth. Under study.[28] Interstate 820 From I-35W to SH 121/SH 183. Under study.[29] The eTrans Group, Inc. April 23, 2010 37 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. (cont) Virginia Interstate 495 between Springfield and just north of the Dulles Toll Road in Mclean.[30] Officials of the Virginia Department of Transportation (VDOT) signed an agreement with two private companies in April 2005. A contract was finalized on December 20, 2007, and construction began in the summer of 2008.[31] Interstate 95/Interstate 395 corridor. VDOT signed an interim agreement with a private company on 24 October 2006 to supply HOT lanes between Massaponax and Arlington.[30] A start date has been set for the northern part of this project: mid-2010, pending commercial and financial arrangements. No completion date has been set.[32] The project was put on hold because of locality concerns and the "daunting task" of raising sufficient capital in today's markets.[33] Future ETL lanes (including studies underway) Maryland Under construction. Interstate 95, north of Baltimore from just south of Exit 61 (US 40) to New Forge Road in White Marsh.[34] References 1. ^ HOT Lanes on I-15 in San Diego Retrieved May 29, 2009 2. ^ I-25 HOV/Tolled Express lanes 3. ^ a b 95 Express Retrieved February 6, 2009 4. ^ I-394 Background Retrieved July 13, 2009 5. ^ Mn/PASS I-394 'HOT' Lanes Retrieved May 30, 2009 6. ^ Express Lanes Retrieved May 28, 2009 7. ^ WSDOT - Toll Rates Retrieved May 29, 2009 8. ^ MTC Planning - HOV/HOT Lanes 9. ^ I-680 Express Retrieved May 26, 2009 10. ^ a b 2 HOT Network Update Retrieved May 26, 2009 11. ^ HOT Network Report 12-08 Retrieved May 26, 2009 12. ^ a b c d e f g h i j 2 HOT Network Update PPT Retrieved May 26, 2009 13. ^ a b c HOTLanes Executive Summary Retrieved May 27, 2009 14. ^ LA gets legislative OK to take NYC's $210m for dynamic priced lanes I-10, I-110 Retrieved May 28, 2009 15. ^ a b c d e Los Angeles votes to toll HOV lanes on busiest freeways, gets NYC's US$s Retrieved May 28, 2009 16. ^ Expanding and Extending Interstate 15’s Managed Lanes Retrieved May 28, 2009 17. ^ I-85 HOT Lanes Retrieved May 27, 2009 18. ^ Green Lanes are a go Retrieved May 28, 2009 19. ^ Green Lanes Still a No-Go Retrieved July 27, 2009 20. ^ UPA - Innovative Choices for Congestion Relief Retrieved May 28, 2009 The eTrans Group, Inc. April 23, 2010 38 Attachment 1 High Occupancy/Toll (HOT) Lanes in the U.S. (cont) 21. ^ 12th International HOV Systems Conference: Improving Mobility and Accessibility with Managed Lanes, Pricing, and BRT Retrieved May 28, 2009 22. ^ BOARD OF TRANSPORTATION MEETING November 6, 2008 Retrieved May 31, 2009 23. ^ a b c SCDOT to Study Possible HOV/HOT Lanes Beyond I-26 in the Charleston area Retrieved May 28, 2009 24. ^ a b March 5 Transcript: Texas Department of Transportation Special Commission Meeting Retrieved May 29, 2009 25. ^ Public Meeting - IH 10 Managed Lanes Retrieved May 30, 2009 26. ^ a b I-635 MANAGED LANES PROJECT Retrieved May 30, 2009 27. ^ SH121/SH 183 Study Retrieved May 30, 2009 28. ^ 820 Studymap Retrieved May 30, 2009 29. ^ North Tarrant Express Segment One Retrieved May 30, 2009 30. ^ a b VDOT COMPLETES AGREEMENT FOR CAPITAL BELTWAY HOT LANES Retrieved May 29, 2009 31. ^ Craig, Tim (2007-12-21). "Deals Clinched on HOT Lanes". The Washington Post. p. B01. http://www.washingtonpost.com/wpdyn/content/article/2007/12/20/AR2007122002733.html. Retrieved December 21, 2007. 32. ^ I95/395 Megaproject Information Retrieved July 23, 2009 33. ^ Va. Delays Work on I-395/95 HOT Lanes Retrieved October 7, 2009 34. ^ MTA I-95 Express Toll Lanes Retrieved September 10, 2009 35. ^ SR 91 Case Study Final (effective 1/1/2008) Retrieved May 29, 2009 36. ^ 91 Express Lanes Retrieved May 29, 2009 37. ^ Katy Managed Lanes Toll Schedule Retrieved October 3, 2009 38. ^ Evaluation of Usage Retrieved October 3, 2009 Source: http://en.wikipedia.org/wiki/List_of_HOT_and_ETL_lanes_in_the_United_States, April 20, 2010. The eTrans Group, Inc. April 23, 2010 39 Attachment 2 Maine Turnpike Authority Reasons for Dismissing All Electronic Tolling (Annotated) Appendix E, Phase I Report (Executive Summary) eTrans “Since 2006, a few agencies in the US have either begun implementing or have set policy that future replacement facilities will be AET. A handful of agencies have begun conversion or have set policies that future installations will incorporate AET. A few more agencies have initiated extensive formal studies to evaluate the applicability of AET. Many agencies are mainly waiting to see the results of these agencies activities before conducting extensive assessments. It should be noted that although some agencies have committed to convert to AET, at the time of this review, no existing cash based agency has completed a total conversion to AET. Furthermore, there is very little standardization of reporting of the business impacts of AET and much reluctance on the part of those agencies involved in AET to release documented and audited results of the business impacts.” (page i) “While the potential benefits of AET can be documented, the significant risk associated with the uncertainty behind the business costs of AET make the option of AET for the York Toll Plaza replacement not feasible. The following points elaborate on this risk:” (page i) A “The ability to recover toll revenue from as much as 26 percent of the total traffic at York due to the lack of legislation that would compel payment from out of state patrons weighs significantly in this risk. This inability has perplexed toll agencies for over 10 years and we believe that this issue will not be cured in the next 20 years.” (page ii) The eTrans Group, Inc. 1) ’A few’ typically means a small number (e.g. less than 5), but apparently not here. At the time this report was published ~ 12 AET facilities were successfully operating in the U.S., one for over a decade! 2) Not sure what the reference to ‘no existing cash based agency’ means, as most toll agencies in the U.S. have offered electronic toll collection (ETC) for ~ a decade. 3) ‘Audited results’ of any operation are very difficult to find in the toll industry. Refer to Section 3.5 & Observation 10 above in this report. 1) Losing all such revenue is an extremely pessimistic perspective. (Refer to Section 3.4 & 3.5.) 2) Effective enforcement in this type of situation was proven well over a decade ago. April 23, 2010 40 B C “The traffic mix of the Maine Turnpike is such that a significant number of patrons are non E-ZPass users and from out of state. The extent to which these customers would not migrate to E-ZPass and pre-paid video products is uncertain and these factors greatly influence business costs such as operating costs and revenue losses.” (page ii) These issues have all been successfully managed by others. (Refer to Section 3.4 & 3.5.) “The resulting toll and fee structure for an AET system could result in actual or perceived unfair distribution of payments between Maine and out of state customers. This results when out of state violators do not pay because there is no significant enforcement capability and the structure is set up or perceived to be set up to offset these losses by paying in-state patrons further compelled to pay because of threat of registration hold.” (page ii) 1) MTA can ensure that administrative fees and penalties are equitable. (Refer to Section 3.4 & 3.5.) D “Difficulties attributed to the duplicate license plate numbering system and the ability of video systems to recognize the myriad of different plate types present minor operational challenges.” (page ii) ‘Duplicate license plates’ is a rare and easily managed issue. (Refer to Section 3.5.) E “The current lack of industry data for similar roadways already implementing This is more of a management AET limits the ability to compare potential MTA outcomes makes function than a forecasting function. forecasting difficult to calibrate.” (page ii) (Refer to Section 3.2 to 3.5.) F “The uncertainty relative to how customers will respond to the changes in payment methods and the uncertainty relative to revenue recovery potential for violations pose too broad a range of potential outcomes. These include potentially significant risks to net revenue required to operate the roadway.” (page ii) In several recent annual reports the MTA has applauded the tremendous success of and benefits from motorists embracing ETC on the Pike. G “The MTA may be limited in its ability to allow for certain types of post payment options typical for AET systems. For example, post payments of video tolls by customers are considered an extension of credit and any restrictions on how the MTA operates under these situations would need to MTA must resolve these issues if open road tolling (ORT) on the Pike is to be successful. (Refer to Section 3.2 to 3.5.) The eTrans Group, Inc. 2) As of 2/1/2010 a ME resident w/o E-ZPass® pays a $3.00 toll to travel from York to Kennebunk while a ME resident with E-ZPass® pays a toll of $1.20. April 23, 2010 41 be considered.” H “Greater certainty around the potential impacts to toll operating costs and revenue impacts resulting from AET would be necessary to determine if the range of risks can potentially be mitigated to an acceptable level or if the risks are insurmountable. Based on the cost analyses conducted, the range of risk to the MTA resulting from uncertainties related to AET over 20 years could be as high as $400 million.” (page ii) This is more of a management function than a forecasting function. (Refer to Section 3.2 to 3.5) Appendix E, Phase I Report 0 eTrans “While the benefits and cost considerations for AET are very similar to the decision to incorporate the option of HST, one fundamental difference exists. HST maintains an option for non-ETC customers preferring to use a stop condition form of payment, such as cash. AET is entirely electronic and eliminates the option to stop and pay by cash at the plaza. This distinction provides both benefits and costs worthy of careful consideration: In conjunction with a decision to incorporate AET at future toll plazas, the Maine Turnpike Authority must also consider the following negative impacts:” (page 7) MTA must also resolve many of the issues below if HST / ORT on the Pike is to be implemented successfully and in a cost-effective manner. (Refer to Section 3.2 to 3.5, especially Observation 4.) 1 “AET will measurably increase operational costs for back office and the customer service center due to initial and ongoing customer education, additional post processing of transactions and increased violation image and notice processing.” (Page 7) The total operating costs of ORT (as apparently envisioned) are likely to be significantly more than AET, as is the total revenue lost. (Refer to Sections 3.2 to 3.5.) 2 “Non-payment events at an AET plaza will likely increase due to patron confusion, technology limitations and increased scofflaws. Other toll agencies who have installed highway speed lanes or AET have typically 1) ORT may lead to more motorist confusion than AET. The eTrans Group, Inc. 2) Roadside technology required for April 23, 2010 42 experienced increases after conversion that lessens over time as a result of familiarization and enforcement. The issue of revenue collection has been discussed previously regarding scofflaws. The issue of collecting from patrons who infrequently use the roadway must also be considered as the cost to collect for one or two trips must be weighed against the available tolls and fees that could be charged.” (Page 7) AET and ORT is identical. 3 “Current limitations or lack of interstate agreements to enforce out of state toll violators limit the options for penalizing these violators. Without these agreements or laws, the Turnpike has few options to try to compel these violators to pay.” (Page 7) MTA must resolve this same issue if ORT on the Pike is to be successful. (Refer to Section 3.2 to 3.5, especially Observation 4.) 4 “Improperly structured AET programs could result in a real or perceived subsidization of revenue by certain customers (for example, in-state patrons paying for out of state violators who do not pay). An AET program would need to be structured to minimize subsidization of tolls by certain groups of paying patrons at different points in the payment stream. For example, rates/fees/penalties associated with violations would need to be appropriately assigned to cover losses in that category due to lost revenue rather than having ETC or video rates set to offset a portion of losses due to violations. Global inefficiencies such as unreadable images would need to be distributed given an appropriate traffic assumptions.” (Page 7) Agree. MTA has the responsibility of structuring the rates/fees/penalties so that actual or perceived inequities do not exist. (Refer to Section 3.5.) 3) Successfully collecting tolls in both AET and ORT applications is a function of proper management of the back-office functions. 5 “Privacy concerns may emerge given that AET reduces the anonymous options for driver payments. Currently cash is exchanged with no record of the driver. An AET system may require anonymous account options to satisfy a portion of this concern. However, patrons who do not prepay with an account would be subject to identification via license plate lookup. The actual level of this concern is unknown and would need to be the subject of further understanding of patrons.” (Page 8) A properly managed AET and ORT program offers an anonymous option to motorists. This can and has been accomplished a number of different ways. (Refer to Sections 3.3 & 3.5.) 6 “Regardless of the result of capital, operating maintenance and revenue impact costs and savings comparisons, consideration must be given for the potential equity or ethical concerns that could arise from the initial or Agree that AET offers the MTA a net cost savings / increase in revenue if managed properly. Managing the The eTrans Group, Inc. April 23, 2010 43 sustained increases in non-payments expected under AET. The business case of cost savings would have to be weighed against the policy decision to accept that the potential that fewer patrons will ultimately pay the toll. More specifically, a system that allows higher revenue leakage but results in a net positive revenue over previous tolling regimes could still be viewed as inequitable or unethical since a larger portion of patrons are not actually paying the toll.” (Page 8) operation to ensure that sustained increases in non-payments do not happen and that toll rates/penalties/ fees are assessed equitably so that real or perceived inequities do not exist is the responsibility of the MTA for both AET and ORT operations. (Refer to Sections 3.2 to 3.5.) 7 “The capacity of local judicial processes is a potential concern if the judicial system is not set up to handle the additional cases resulting from AET. Advanced planning and coordination with the appropriate agencies would be necessary to determine costs and considerations needed as part of AET planning and implementation.” (Page 8) Agree. MTA has the responsibility of managing the enforcement program with both AET and ORT so that only a few of the enforcement actions in up in the judiciary process. 8 “Unbanked customers (those without bank or credit card accounts) that prefer to pay cash at the point of tolling will find the cash option of pre or post paying with cash offsite as a burden.” (Page 8) MTA can offer these motorists a cash payment option at the Kennebunk service area, the Maine Welcome Center and several other convenient locations. 9 “AET may result in revenue decreases from increased diversion to local roads (some of which are already congested) as some patrons who perceive a lack of options to pay the toll that suits their preferences, seek alternate routes.” (Page 8) A properly managed AET or ORT toll operation offers motorists a number of convenient and user friendly options for paying their toll. 10 “AET will require additional costs to increase transponder use, develop, market and implement new tolling products, as well as implement a significant public relations campaign to inform the public of the changes initially and ongoing education of future customers. The introduction of video tolling products and the removal of cash payment on the roadway will require significant public communication. Other products may include anonymous accounts to satisfy privacy concerns by some patrons.” (Page A properly managed AET or ORT toll operation will promote of increased transponder use and require: 1) development and implementation of a number of toll payment plans, some that are, by design, anonymous; and, 2) marketing/communications efforts The eTrans Group, Inc. April 23, 2010 44 8) to establish and sustain cost-effective operations. 11 “Weather impacts to equipment are magnified with increasing reliance on video technologies. Significant snow or similar conditions may reduce the quality of images resulting in higher volumes of image rejections resulting in direct revenue losses.” (Page 9) A properly managed AET or ORT toll operation will consider this when it establishes toll rates/penalties/fees in an equitable manner. (Refer to Section 3.5) 12 “AET may violate restrictions associated with existing bond covenants, trust indentures or similar agreements associated with the financing of the Maine Turnpike. For example, where bonds require toll revenues to meet certain thresholds, a higher amount of revenue loss under AET may require higher toll rates either initially or over a sustained period.” (Page 9) This issue is resolved in both AET and ORT operations by establishing equitable penalties/fees to overcome any anticipated shortfall. (Refer to Section 3.5) 13 “Consideration for labor agreements and the impact regarding AET implementation.” (Page 9) 1) In several recent annual reports the MTA has applauded the benefits (including savings in labor costs) from motorists embracing ETC on the Pike. 2) Collectors could be offered the opportunity to support AET back-office efforts through a retraining program. 14 “In some cases, the location for the construction of an AET plaza may not be conducive for the construction of a cash plus highway speed toll plaza given the different site requirements. If for some reason the plaza needed to be converted to add cash collection in the future, some AET plaza sites may restrict this option.” (Page 9) AET site requirements are far less restrictive than those for all other forms of toll collection. The environmental impacts are also significantly less. (Refer so Section 4) 15 “The conversion of only one location on the Maine Turnpike to AET while maintaining cash options at others may present confusion among patrons with regards to where payments options are available. Since cash lanes on the Maine Turnpike do not have enforcement cameras, if patrons assuming MTA could easily resolve this concern by converting all toll collections on the Pike to AET – enabling the MTA and citizens of Maine to benefit from the The eTrans Group, Inc. April 23, 2010 45 AET payment options pass through these lanes without stopping to pay, the Maine Turnpike would not realize this revenue.” (Page 9) 16 “Without fare collection staff at toll plazas, the Maine Turnpike will need to consider alternatives to handling wide load permits, which are currently a function served by fare collection staff.” (Page 9) expected increase in net revenue. (Refer so Section 4) Wide load permits must be processed prior to the trip. Paying the appropriate toll is easily integrated with this process. “With the challenges understood, the following beneficial impacts associated with AET include:” (Page 9) 1 “An AET toll plaza has the potential for greater safety due to the removal of any decisions required of the patron at the toll point. The goal of AET is a transparent roadway that reduces or eliminates any change to the driver’s environment than what is typically encountered on other parts of the facility.” (Page 9) A properly designed and implemented AET toll gateway introduces no conflict to the traffic stream thus is much safer for motorists than all other toll options. The safety of most authority personnel is also greatly enhanced since they no longer need to be pedestrians in an active toll plaza to do their jobs.. 2 “Under AET, all customers of the facility benefit from the convenience of not having to stop to pay the toll. Customers can either sign up for a transponder or opt for other products such as pre-paid or post-paid video tolling options that could be offered by the agency.” (Page 9 & 10) A host of user-friendly payment options should be offered to all motorists wishing to use either AET or ORT tolling options. 3 “AET toll plaza configurations minimize plaza construction capital cost by eliminating the need for toll booths that may require wider right of way and additional infrastructure.” (Page 10) Other toll options also have significant safety and environmental impacts. 4 “AET toll plazas typically require less long term maintenance, since an AET plaza includes significantly less infrastructure.” (Page 10) The eTrans Group, Inc. AET toll gateways have very little civil infrastructure and less equipment to maintain. April 23, 2010 46 5 “AET eliminates the cost of fare collection staffing and support at the toll plaza.” (Page 10) These costs are extensive since it is a 24 hour day/7 day a week operation. 6 “Additional environmental benefits are possible with an AET plaza. By increasing the average speed of vehicles passing through the plaza, the average fuel economy of vehicles will increase. This quantifiable reduction in the use of fuel will not only provide financial benefits to the patrons, but reduce the consumption of nonrenewable resources.“ (Page 10) Less fuel consumption and elimination of stop and go conditions also reduces emissions. Other environmental benefits of AET typically include fewer, if any, aquatic impacts, less noise and less visual and light intrusion into nearby neighborhoods. “An AET plaza would require patrons to either sign up for an E-ZPass account or pay via a pre-paid or post-paid video toll account. The MTA would need to consider pricing of such options would be matched to the frequency of the trip by the customer and cover administrative costs for each product. Pricing considerations can also go further to influence patrons to utilize more cost efficient products. Infrequent users who cannot justify the cost of a transponder would have the option to pay a video toll at a higher rate than the transponder rate but less than the cost of a transponder. Depending on the magnitude of the rate adjustment, larger portions of infrequent users would find the transponder option more financially practical. It may be expected that this adjustment may be as high three or more times the existing transponder rate in cases where patrons delay payment until an invoice or notice is received. While having the positive impact of driving patrons towards more cost efficient pre-payment options, this would likely have significant negative public acceptance issues.” (Page 10) The eTrans Group, Inc. This issue can be resolved in both AET and ORT operations by establishing equitable penalties/fees to overcome any anticipated shortfalls. Penalties, which need to be punitive to establish the deterrence factor, are established at a sufficient level to allow fees to be kept to a minimum for those who voluntarily pay their toll through one of the user-friendly programs offered. (Refer to Section 3.5) April 23, 2010 47 The eTrans Group, Inc. April 23, 2010 47 Attachment 3 Daryl S. Fleming, PhD, PE Principal EDUCATION AND REGISTRATIONS Dr. Fleming holds a BSCE from the University of Maine, Orono, an MScE and PhD in Transportation Planning and Engineering from the University of New Brunswick, Canada. Dr. Fleming is also a registered professional engineer in several states and New Brunswick, Canada. CAREER OVERVIEW Dr. Fleming has nearly 35 years experience in the planning, engineering and management of major transportation infrastructure projects. Dr. Fleming is one the world's leading experts in in the deployment and operation of electronic toll collection (ETC) systems, including all electronic tolling (AET) and automated enforcement systems. Dr. Fleming is also recognized as an expert in traffic and toll road operations, HOT lanes, traffic and revenue projections, revenue collections and enforcement and high-occupancy vehicle (HOV) lanes. Dr. Fleming's ability to establish functional solutions to complex technical and operational problems are evident from his repeated success as part of the senior management team on projects collectively valued at over $10 Billion (US) in current dollars, including the: Orange County Toll Roads -- re-introduction of toll roads to Southern California Long Beach / Los Angeles Light Rail Transit System -- re-introduction of light rail transit to Southern California 407 Express Toll Route™, Toronto, Ontario, the world's first fully automated toll road AutoExpreso™, Puerto Rico Highways and Transportation Authority, one of the world’s first ETC programs with distributed tag purchase and account replenishment capabilities, and, GA 400 Extension -- North America's first fully integrated, electronic toll system. Dr. Fleming’s has also been responsible for developing and implementing successful operating plans for several innovative programs in the transportation industry. The more notable of these include: the initial operations plan for the SR-91 Express Lanes™ in Orange County, California, the world’s first HOT lanes (and currently leading the team providing ETC systems and operations advisory) reversible HOV lanes on the North I-25 Corridor in Denver, Colorado, and, an Itinerary verification system for monitoring trucks hauling debris from the World Trade Center site following September 11, 2001. Dr. Fleming has also managed the operations design of over 50 freeway interchanges, 8 that are freeway-to-freeway junctions. Dr. Fleming has led many projects from inception through to deployment and initial operation. In doing so he has managed all stages of these large, infrastructure development programs. The fact that these projects cover the spectrum of most current major operational technical innovations exemplifies his versatility to meet the unique challenges facing both large and small, innovative infrastructure deployment programs in the transportation industry. The eTrans Group, Inc. April 23, 2010 48 CONTROL SHEET PROJECT: York Toll Plaza Upgrade DOCUMENT TITLE: York Toll Plaza Upgrade Options A Realistic Approach CLIENT CONTACT: Mr. Dean Lessard Director of Public Works Town of York 186 York Street York, Main 03909 (207) 363-1010 ETRANS PROJECT #: P00099 Release: 2.1 AUTHOR: Daryl S. Fleming Daryl S. Fleming SIGNATURE: __________________ Date: April 22, 2010 The eTrans Group, Inc. April 23, 2010