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APPENDIX A Literature Review on Planning for Road Pricing This appendix provides the findings from a literature review of sources addressing road pric- ing and the transportation planning process. Each key source is described below. Domestic Scan of Congestion Pricing and Managed Lanes A Domestic Scan of Congestion Pricing and Managed Lanes. Prepared for the Federal Highway Administration, U.S. Department of Transportation, DKS Associates, with PBSJ and Jack Faucett Associates, February 2009. This recent survey by DKS Associates of selected Metropolitan Planning Organizations (MPOs) and state departments of transportation (state DOTs) in 10 metropolitan areas exam- ined how they are planning for congestion pricing and managed lanes. Important findings for consideration of a road pricing planning framework include: Evolution of road pricing from projects to plans: The study found initiation of congestion pric- ing in eight metropolitan areas with pricing projects "started with individual projects," versus deriving from within regional plans themselves. Specifically, "In most cases, the desirability of a congestion pricing or managed lanes project did not emerge directly from a CMP assessment of options" and "most congestion pricing or managed lanes projects are . . . initiated and advocated for by agencies within the metropolitan area and are incorporated into the MTP and the Trans- portation Improvement Plan (TIP) by the MPO as updates of these documents occur." One example is how HOT lanes gradually developed into the regional plan as a network approach within the San Francisco Bay Area. There, "the initiative for the HOT lane projects came first from the Alameda County CMA and the Santa Clara County CMA (the Santa Clara Valley Transportation Authority)." Thereafter, "The MPO (MTC) took the lead to develop the regional plan for a HOT lane network." Nor did state agencies generally derive congestion pricing proj- ects from within broad or systematic planning efforts but instead derived them from site-specific studies. Specifically, "The state DOT was often the initiator but survey respondents generally did not indicate that the projects proposed were part of the state-wide planning effort." However, the report also finds as interest has moved from individual projects to regional approaches, "integration into the metropolitan planning process has also increased." Specifically, MPOs are making "a greater effort to provide an appropriate interagency collaborative process for identifying the need for the projects, identifying the options and alternatives to be considered, formulating an appropriate evaluation process, seeking public and stakeholder input and identi- fying a preferred approach." To spur continued attention to road pricing, regional approaches and more comprehensive planning, the report recommends the federal government provide 73

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74 Road Pricing: Public Perceptions and Program Development "additional encouragement through guidance documents and descriptions of exemplary prac- tices and also in the form of recommendations as part of the MPO certification reviews. Support should also be in the form of federal grants to support regional planning for congestion pricing and managed lane projects." Exemplary planning approaches: The report identifies some "exemplary approaches" to planning that are useful for consideration in devising the recommended framework. The report points to the Seattle area where the Puget Sound Regional Council (PSRC) has updated its CMP to: Identify the location where congestion is greatest and potential future locations for possible application of congestion pricing Specify pricing, demand management, and system management strategies as specific options Establish a specific evaluation method (in this case, benefitcost analysis model) as well as other more traditional performance measures such as safety, reliability, access, and delay Coordinate with Washington DOT long-range transportation plan, to ensure it incorporates outcomes of the MTP update Policy and plans addressing road pricing revenues: Another important finding relevant to any regional and state planning framework attending to road pricing has to do with revenues. The report finds that in Minnesota a policy position has evolved in the MTP pertaining to road pric- ing revenues. Policy indicates "revenue generated from the managed lanes will be used for the cost of implementation and maintenance. The net revenue from the I-394 MnPASS project has not been sufficiently large to warrant consideration of it in the MTP financial constraint." Likewise in Virginia with the adoption of the I-95/I-395 HOT lane project into the 2007 MTP, policy sets out how revenue obtained will be used to cover the costs of each project and excess revenue will be used to fund transit improvements. Accounting for air quality requirements: The report notes the importance of road pricing plans meeting air quality requirements, suggesting any planning framework for road pricing must take into account air quality requirements and assessment processes. The study found all HOT lane proj- ects reviewed involved assessing air quality impacts and attending to mitigation to meet NEPA and/or CEQA requirements. One MPO in Kansas City, MARC, is attempting to make environmen- tal review and analysis integral to regional planning rather than having analysis done after projects are identified. The initiative is entitled "Linking Environmental and Transportation Planning." Models/analysis procedures: The analysis of congestion pricing among the metropolitan areas sur- veyed relied on the regional travel model for analysis. The model often is supplemented by other tools with added sensitivity to pricing and/or for analysis of costs and benefits. Microsimulation models have been used to assess the travel time and level of service associated with alternative pric- ing scenarios, level of service, traffic impacts on local streets and general purpose lanes, as well as the impacts to lower income travelers. Other common performance measures include vehicle miles traveled, emission volumes, vehicle hours traveled, and individual and network delays savings. Pro- prietary toll revenue models have been used for analyses in some areas. GAO Report on MPOs "Metropolitan Planning Organizations: Options Exist to Enhance Transportation Planning Capacity and Federal Oversight," Government Accountability Office, a report to the Ranking Member, Committee on Environment and Public Works, U.S. Senate, GAO-09-868, September 2009. This report by GAO surveyed all 381 MPOs (with an 86% response rate) and conducted case studies of eight metropolitan areas. This congressionally requested report aimed to determine how the U.S. DOT provides oversight for MPOs in transportation planning and how the over-

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Literature Review on Planning for Road Pricing 75 sight might enhance transportation planning. Some findings important to developing a road pricing planning framework include the following: MPOs cite lack of resources and/or expertise for comprehensive planning: A large proportion of MPO respondents to surveys believe their agencies lack resources and/or expertise to carry out transportation planning. Given road pricing is a relatively new concept compared to, for exam- ple, traditional transit or road improvement strategies, it is likely many MPO planners may feel challenged analyzing and incorporating pricing into regional plans. GAO found about 85% of all MPOs responding "cited the lack of transportation planning funding as a challenge to transporta- tion planning" and "about half of [the] survey respondents stated that the lack of flexibility for using federal planning funds inhibits them from conducting comprehensive transportation plan- ning." Also, "staffing constraints, such as limited number of staff and lack of trained staff, also impact MPOs' ability to conduct transportation planning." Finally, "some MPOs lack the tech- nical capacity and data necessary to conduct the type of complex transportation modeling required to meet their planning needs." MPOs view federal planning requirements as pro forma and more value technical assistance: GAO found MPO oversight from the Federal Transit Administration (FTA) and Federal High- way Administration (FHWA) is "process-oriented" and difficult to assess for improving trans- portation planning. While MPOs representing more than 200,000 in population are subject to federal certification reviews, the certification reviews and planning requirements are viewed as "pro forma in nature" and MPO respondents place a greater value on "informal assistance pro- vided by both federal and state governments." Improved planning may come from performance rather than process requirements, and more support for modeling and data gathering: GAO recommends "making the planning process more performance-based could allow FTA and FHWA to better assess MPOs' progress in achieving specific results." GAO also recommends "increasing federal investment in modeling and data gathering to encourage more reliability and consistency across MPOs to travel demand forecasting." MPO Review on Congestion Policies by Anthony Downs "The Need for Regional Anti-Congestion Policies," Anthony Downs, Center on Urban and Metropolitan Policy, February 2004. Anthony Downs at the Center on Urban and Metropolitan Policy has reviewed the history of MPO development and action to assess whether regional planning can be improved for combat- ing congestion, and considers various organizational options for changing MPO authority and effectiveness. He concludes MPOs as currently structured have a near impossible task assigned to them by Congress. On the one hand, they are charged with developing long- and short-range transportation plans across multiple modes, establishing widespread regional consensus, coor- dinating with multiple agencies, taking into account air quality considerations and numerous federal and state regulations bearing on their operations, carrying out the latest and best mod- eling techniques, and doing all this "without any direct powers to implement the plans it creates, since implementation is left to other agencies." He calls the MPO mission "Herculean." While he supports efforts to build capacity at MPOs for all these functions and references the U.S. DOT 2001 Metropolitan Capacity Building Program (MCB) as one such effort, he is san- guine about how effective such help can be. Instead, he suggests serious attention to institutional reform, in particular, "persons promoting regional anti-congestion strategies should seriously consider developing some type of regional transportation entity with responsibilities that go beyond those currently afforded to MPOs

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76 Road Pricing: Public Perceptions and Program Development and become the regional infrastructure agencies. Creating such an agency would require action by the state government--or governments--concerned. The agency's jurisdiction should ideally include the planning, construction, and operation of the metropolitan area's principal roads, bridges, tunnels, and mass transit systems. It would be able to review and coordinate local land use policies and be able to set pricing schemes for parking and tolls. This could be a newly-created regional authority or it could be a fully-evolved MPO." After reviewing various possible models for a new or revised agency, Downs concludes there is little hope for strong regional governance given current distribution of city, county, state, and spe- cial district institutional arrangements. However, he points to an opportunistic approach for advancing "anti-congestion" strategies, which has implications for a planning framework for encouraging attention to road pricing: Take advantage of unique and relevant authority and powers: Downs cites some regional agen- cies already having authority to implement pricing broadly and urges planners and managers to look for ways to implement road pricing under such authority. He notes, for example, ". . . in San Francisco, the Metropolitan Transportation Commission (MTC) is responsible for setting tolls for the state-owned bridges in the area. Conceivably and with sufficient political courage, the MTC could employ peak-hour tolls on these bridges to dissuade many auto commuters from using the bridges." Downs also points to authority, law, and organizational entities associated with air quality in non-attainment areas as another opportunity for regional action in pricing and other congestion reduction strategies. He cites the California Air Resources Board and its wide author- ity, reach, and proactive actions as an example, noting "it (ARB) has proposed that a significant fraction of all automotive vehicles be powered by fuels other than gasoline by the year 2010. Achieving that goal would require enormous changes both in the automobile and petroleum industries and in household behavior. There are 36 air districts in California charged with carry- ing out these regulations in collaboration with their local MPOs." He suggests ARB-like agencies anywhere working with MPOs could (in theory) implement many of the potentially most effec- tive anti-congestion tactics at regional levels. For example, they could impose peak-hour road pricing and parking charges throughout a metropolitan area. He concludes, "federally rooted anti-pollution agencies represent one of the potentially strongest instruments for carrying out regional anti-congestion tactics." Take advantage of crises: Referring to the unique authority MTC has as a regional agency, Downs notes using such authority for pricing bridges will take "widespread public support." He notes an important impetus for gaining such support is a time of crises where congestion rises to the top of the agenda in a metropolitan area whether due to a booming economy and associated growth or unusual strictures in road development or other causes. Downs says such issues "must pose seri- ous, obvious, and immediate threats to the welfare of a large percentage of the population." Prob- ably the reverse also applies--in times of waning congestion and a poor economy, no matter what authority is available, the impetus for effective action is diminished. MPO Review for TEA-21 Reauthorization by Bruce Katz et al. "TEA-21 Reauthorization: Getting Transportation Right for Metropolitan America," Bruce Katz, Robert Puentes, and Scott Bernstein, Center on Urban and Metropolitan Policy, March 2003. As with Anthony Downs, Katz et al. at the Center on Urban and Metropolitan Policy are not optimistic about the capabilities of MPOs to execute effective regional planning. While acknowl- edging federal statutes have "required transportation planning to move beyond simple mobility concerns and take into account social, economic, and environmental outcomes," he suggests much

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Literature Review on Planning for Road Pricing 77 room for improvement and daunting barriers. Some findings of importance to a road pricing plan- ning framework include: States wield considerable power in planning for congested regions: Katz et al. find, "Although ISTEA and TEA-21 were designed to move transportation decision making out of the back rooms and board rooms of the highway establishment, many state DOTs still wield considerable formal and informal power, and retain authority over substantial state transportation funds." And, "the reality is that the state receives and manages all the federal transportation money, as well as large amounts of state transportation money and the state political leverage is far greater than the MPO's." Katz et al. urge, "Congress should require that financially constrained state transporta- tion plans incorporate locally defined metropolitan priorities." Whatever the balance or imbalance of power between state and regional entities, the Katz et al. conclusion points to the importance of state roles in envisioning, planning, and implementing road pricing in state plans and collabora- tive plans with regions and localities. Planning capacity is uneven across MPOs: As with Downs, Katz et al. find capacity needed to evaluate complex and relatively new concepts such as road pricing may be limited at many MPOs. Katz et al. conclude, "MPOs in places as diverse as Albany, Dallas, Hartford, Minneapolis, San Francisco, and Seattle are strong players in their regions and maximize their responsibilities in an effective way. These entities have built up the expertise of their staff to carry out the responsibili- ties of the new federal law. Yet other MPOs, particularly in smaller areas, struggle. . . . Many lack adequate staff and financial resources. A recent analysis, for example, found that 58 percent of small MPOs (those representing populations of less than 200,000) cannot perform basic trans- portation modeling or forecasting." Planning guidance and support needs to be tailored to such uneven capacity. Planning progress indicators needed: Katz et al. recommend requiring both regional and state planning agencies "maintain information systems that annually measure progress on indicators of national significance. These indicators might include mitigating congestion, improving public health, improving air quality, lowering transportation costs, and expanding transportation options for target groups (such as the elderly or low income workers). The law should also require trans- portation agencies to set annual performance objectives in each of these critical areas. As with dis- closure of spending decisions, agency performance objectives (and progress towards meeting those goals) should be shared with the general public in an accessible manner." The recommendation is general but implies incorporating specific and publicly available performance measures and feed- back systems around planning and implementing road pricing. Continue and enhance support for road pricing planning and implementation: Katz et al. rec- ommend much increased funding for the Value Pricing Program which includes both demon- stration support and technical assistance. Apparently the authors believe local and state planning for road pricing should be augmented by federal assistance not simply left to develop with only federal guidance. Decision-Making Framework for Pricing Decisions "Improved Framework and Tools for Highway Pricing Decisions, Draft Final Report Volume I: Decision-Making Framework for Highway Pricing Decisions," NCHRP Project 08-57, Prepared by Parsons Brinckerhoff, Inc., July 2008. In a review of planning for road pricing projects, Parsons Brinckerhoff, Inc. (PB) recommends four phases in the planning of road pricing projects: (1) exploration, (2) option development, (3) feasibility assessment, and (4) investment or finance study. PB indicates the phases follow

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78 Road Pricing: Public Perceptions and Program Development traditional transportation planning. However, some findings and recommendations of relevance to a road pricing planning framework are: Finance phase of planning deserves special attention: PB indicates the investment and finance phase of study for road pricing while common to many transportation planning activities entails unique tasks. For projects financed by debt-backed proceeds for future tolls, an "Investment Grade Study" is needed to finalize funding arrangements in a "Financial Plan," the formal docu- ment that details a project's cost estimate, revenue structure and financial resources. Projects not relying upon debt finance based on future tolls do not require this step but still require detailed finance analysis. Planning can and should proceed either by project or comprehensively: Echoing the opportunis- tic approach to planning offered by Downs, PB suggests "two broad approaches may be used to initiate and assess tolling and pricing," including a comprehensive approach going through the four phases identified or a project approach focusing on a specific corridor or area. As PB notes, both approaches "are valid" and, "this research effort demonstrates that a flexible decision-making framework is likely to incorporate both approaches, capitalizing on their respective strengths" and tailored to reflect "regional transportation needs, institutional arrangements, and politics." Examples of comprehensive approaches are cited in the San Francisco Bay Area, Washington State, Colorado, Atlanta, and Texas. Road pricing planning tends to evolve from projects to regional assessments with two main agencies leading the way: PB finds, "Many regions begin their experience with pricing as a result of low hanging fruit situations where there is a clear logic behind the use of tolls on a new or exist- ing facility. If pricing is implemented successfully . . . a region may consider embarking on a com- prehensive assessment of pricing in other settings, with subsequent projects moving forward for further assessment as a result." Furthermore, PB finds road pricing planning may be led by a single agency or more, with state DOTs and the MPOs the main players. Planning for pricing should match types of pricing to goals and contexts: PB proposes road pric- ing planning should match up types of pricing options with appropriate goals and contexts. PB suggests HOT conversions, existing tollways, new facilities, and other concepts are best suited to varying goals and conditions and a planning approach needs to select concepts accordingly. Like- wise the exact form of pricing needs to match the congestion problem. Environmental review procedures and timing may vary by location and "significance": PB notes environmental reviews as part of road pricing planning vary with state law and custom, suggesting planning guidance needs to be flexible on the subject. It notes, "In certain cases, the consideration of tolling and pricing may be introduced while the environmental process is underway or even after it has been completed. At a minimum, this change would require a reevaluation of the analyses completed. The level of detail of the reevaluation depends on the circumstances surrounding the particular project. In situations where the introduction of tolling and pricing is determined to be `significant,' a supplemental environmental impact statement must be prepared." Modeling is an important and demanding task in pricing planning: PB finds planning for road pricing is an "intense endeavor" given "behavioral models must consider both tolled and non- tolled alternatives, as well as multiple tolling scenarios. Standards can be particularly high when private sector investment is involved (to meet bonding requirements)." Planning must account for legal and legislative matters: PB notes an important stepping stone in the planning process is assessing legal and legislative requirements. Planning will vary depending in large measure on federal aid to facilities. PB notes, "State and local jurisdictions have the great- est flexibility to implement tolling and pricing on local roads and highways that have been, or will be built without federal funding. Greater restrictions apply when tolling and pricing are used on the Federal Aid Highway System, or on HOV lanes or busways funded with transit monies. As a

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Literature Review on Planning for Road Pricing 79 result of these restrictions, the vast majority of tolling and pricing projects implemented over the past 50 years have involved either new state or county toll roads or the expansion of pre-existing toll facilities that have been incorporated into the Interstate Highway System." Likewise, "Various state and local authorities are also needed to implement tolling and pricing projects. Local legal requirements are dictated by state and local statutes and regulations, as well as pricing and toll col- lection policies and mechanisms used to raise financing. Policy makers interested in pursuing tolling and pricing projects should consult with legal experts to identify the specific requirements that would apply in their regions." Key screening criteria in planning: PB enumerates several planning screening criteria impor- tant to consider in planning road pricing including: Congestion relief potential Consistency with state and regional plan goals Ability to improve the efficiency of the regional transportation network Public acceptance Institutional feasibility Safety impacts Order-of-magnitude construction cost Revenue generation potential Financial viability Federal Interim Guidebooks and Briefing Book "An Interim Guidebook on the Congestion Management Process in Metropolitan Transportation Planning," FHWA and FTA, FHWA-HOP-08-008, February 2008. "Management & Operations in the Metropolitan Transportation Plan: A Guidebook for Creating an Objectives-Driven, Performance- Based Approach," FHWA and FTA, FHWA-HOP-08-007, February 2008. "The Transportation Planning Process: Key Issues, A Briefing Book for Transportation Decision Makers, Officials and Staff," FHWA and FTA, FHWA-HEP-07-039, Updated September 2007. Federal planning regulations and guidance are important to devising any planning framework and directly bear on how regional and state planners conduct transportation planning. FHWA and FTA have developed a briefing book that summarizes the transportation planning process and two interim guidebooks that address the integration of management & operations and the congestion management process in metropolitan transportation planning. FHWA and FTA are currently in the process of developing final guidebooks on advancing planning for operations and the CMP. These guidebooks and resources are intended to help provide assistance in effectively carrying out federal planning requirements. Some key items from existing published materials relevant to a road pricing planning framework are: Planning timelines and agency roles are specified: As the briefing book shows, MPOs handle three plans with specified update terms: The MTP or Metropolitan Transportation Plan has 5-year updates except in non-attainment areas where it is every 4 years. The Transportation Improvement Program or TIP (approved capital or "investment" projects--all projects with federal funds must be in here) is done every 4 years. Likewise, for states, the STIP is updated every 4 years.

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80 Road Pricing: Public Perceptions and Program Development Only the Unified Planning Work Program or UPWP is done annually and it focuses on plan- ning studies, not goals, strategies or investments as the other two plans do. Thus, if a RP proposal arises through the planning process, it will be bound by these timelines to come to fruition. Or if it comes from outside the planning process, say from a demonstration or pilot program application, it may have to get "adopted" into the appropriate plan, which may or may not cause delay in the anticipated project development timing. However, pricing projects as with all projects can enter into regional plans outside these cycles via amendments. The briefing book acknowledges the issue of constant changes in projects getting incorporated into the TIP: "Amendments to the TIP can be common given the frequent changes in engineering practices, environmental issues, contracting issues, project readiness, and other fac- tors that can require adjustments to project schedules and budgets." What is required versus advised: Knowing what is required versus advised in regional and state planning is vital to developing any new planning framework recommendations. One key require- ment is for the MPOs (or CMA in places like California) in TMAs (areas over 200,000 in popula- tion or designated same by a governor) to have a congestion management process involving "travel demand" and "operational strategies." The Secretary of Transportation has authority to hold up 20% of "funds attributable to the MPO" if the metropolitan planning process of an MPO serving as a TMA is not certified. Moreover, MPOs in TMAs classified as non-attainment for ozone and carbon monoxide may not receive funds for any highway project that will result in a significant increase in single-occupant vehicles unless the project was addressed as part of the con- gestion management process. States have latitude in defining some of MPO congestion management planning: States and MPOs are encouraged under federal law to cooperate in planning especially for state facilities within MPO planning areas. States also may legislate their own provisions for congestion man- agement planning, as in California where an entirely separate agency from the MPO can be formed to carry out congestion management planning and perform other functions such as allo- cate local and state funds to projects. Unique state processes are allowed if there is a "finding" by the Secretary of Transportation that the processes are consistent with federal congestion man- agement requirements. Emphasis on process versus system: Under SAFETEA-LU, there is a change in emphasis from a congestion management "system" to a congestion management "process" that is intended to be fully integrated into the metropolitan transportation planning process, rather than a stand-alone data collection and analysis system. As the CMP guidebook states, "The change in name (and acronym) is intended to be a substantive change in perspective and practice, to address conges- tion management through a process that provides for effective management and operations, an enhanced linkage to the planning process, and to the environmental review process, based on cooperatively developed travel demand reduction and operational management strategies as well as capacity increases." The emphasis is on performance-based planning to tackle congestion, with specific goals and performance measures, and an emphasis on management and operations of the system and demand management where road pricing may apply, as opposed to simply capital facility planning. Another goal is to ensure planning dovetails with air quality planning to avoid duplication. All such emphasis should support attention to road pricing. Federal guidance updates are ongoing: The CMP guidebook says, "It is also important to rec- ognize the connections between the development of this guidebook and other, concurrent efforts. FHWA/FTA is also currently undertaking the development of a guidebook for manage- ment and operations in the planning process; documenting and assessing various analysis tools with applications to transportation systems management and operations; and cataloguing resources available for statewide transportation planning."

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Literature Review on Planning for Road Pricing 81 Road pricing mention in guidance: In the CMP guidebook (page 2-3), when "operational strate- gies" are mentioned, they are called "management and operations" and road pricing is not men- tioned as one of them in the upfront discussion. While language appears relevant to road pricing such as "mode shift" and change in "travel time," there is no specific mention of road pricing as there is with "ramp metering" and "traffic signal coordination" and "travel info." However, pric- ing is mentioned in the guidebook on page 3-2: "demand management measures, including growth management and congestion pricing." Road pricing also appears on page 3-8: "congestion pricing strategies, including high occupancy toll (HOT) lanes"; "pricing fees for the use of travel lanes by the number of persons in the vehicle and the time-of-day"; and "pricing fees for parking spaces by the number of persons in the vehicle, the time-of-day or location." While more explicit mention of pricing would aid in attention to it, road pricing certainly fits with example "performance mea- sures" named such as "delay," "person throughput," and "transit on time performance." Likewise, the briefing book mentions "systems management and operations," and road pricing might be deduced from the language "pricing of transportation services" (page 47) under that heading. However, much more play is given to ITS, signal coordination, incident management and other classic "TSM" strategies. Attention to pricing might be boosted by explicit reference here and else- where in the document. Guidance on non-attainment strategies related to road pricing: An obvious nexus between road pricing and air quality planning requirements occurs when new capacity is added in non- attainment areas. As mentioned above, non-attainment areas require special CMP planning, as specified in the guidebook: "SAFETEA-LU requires that `for transportation management areas classified as nonattainment for ozone or carbon monoxide pursuant to the Clean Air Act, Federal funds may not be advanced in such area for any highway project that will result in a significant increase in the carrying capacity for single-occupant vehicles unless the project is addressed through a congestion management process.' While capacity-expanding projects are not prohibited, the CMP requirement means that the MPO must consider alternatives to capacity increases. . . ." Guidance on conformity: The briefing book also makes evident the importance of air quality "con- formity" in regional planning, with mention of transportation control measures (TCMs) as a means to attain conformity. Road pricing planning certainly has a potential in TCM planning. The regulatory process underlying conformity is set out: "Transportation conformity on transporta- tion plans and TIPs is demonstrated when projected regional emissions for the plan and TIP do not exceed the region's motor vehicle emissions budgets. A conformity determination is a finding by the MPO policy board, and subsequently by FHWA and FTA, that the transportation plan and TIP meet the conformity requirements." The conformity finding must be made every 4 years. NEPA guidance and road pricing: The CMP guidebook suggests a linkage between NEPA and CMP strategies, with road pricing potentially included, might occur at the regional level volunta- rily. The guidebook points to MARC in Kansas City where the agency has developed policy ensur- ing NEPA studies incorporate a CMS "Toolbox" developed by the agency. The guidebook states on page 4-7, "MARC adopted a policy that its CMS Toolbox of strategies would be considered when the purpose and need for an environmental study includes congestion management." While the MARC toolbox does not mention road pricing as a distinct strategy, it could be considered under TDM, and parking pricing could appear under parking strategies. Another important con- sideration in NEPA analysis of road pricing is the level of scrutiny required, which depends on the level of impact of a project. A project does not need to have an Environmental Impact Statement prepared if it receives a Categorical Exclusion (CE)--which applies to projects that have no signif- icant environmental impacts--or a Finding of No Significant Impact (FONSI) from an environ- mental assessment. Exemption from conducting a full environmental impact review might be possible for pricing projects on existing facilities with limited impacts on travel patterns or where air quality benefits are very likely.

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82 Road Pricing: Public Perceptions and Program Development Financial planning fit with road pricing: The briefing book makes evident the role of financial plan- ning in the MTP and points to the importance of any planning framework linking road pricing to financial planning requirements and processes. Road pricing could be considered as "user charges" and used as a revenue source to develop the fiscally constrained MTP: "The metropolitan transportation plan, which has a 20-year planning horizon, must include a finan- cial plan that estimates how much funding will be needed to implement recommended improve- ments, as well as operate and maintain the system as a whole, over the life of the plan. This includes information on how the MPO reasonably expects to fund the projects included in the plan, includ- ing anticipated revenues from FHWA and FTA, state government, regional or local sources, the pri- vate sector, and user charges. The metropolitan transportation plan must demonstrate that there is a balance between the expected revenue sources for transportation investments and the estimated costs of the projects and programs described in the plan. In other words, a metropolitan plan must be fiscally (or financially) constrained." The appendix of regulations (page C-2) reiterates the balance point: "The metropolitan trans- portation plan, TIP, and STIP include sufficient financial information for demonstrating that projects in the metropolitan transportation plan, TIP, and STIP can be implemented using com- mitted, available, or reasonably available revenue sources, with reasonable assurance that the Fed- erally supported transportation system is being adequately operated and maintained." Strategic Highway Research Program 2 Project C01 Project C01 under the SHRP 2 "capacity" focus area, being undertaken by ICF International, is devising a collaborative decision-making framework for key decision points in various phases of the transportation decision-making process. The CDMF is useful for identifying possible points for road pricing to enter planning and project-level decision making. The framework is derived from about 25 detailed case studies of transportation projects and the decision-making processes that led to their adoption. For each decision point, detailed information is available regarding the stakeholders involved, roles of government agencies, interactions between actors, issues typically considered, and analytical methods and data used to make decisions. The C01 framework covers four phases of transportation decision making: Long-range transportation planning--with inputs from CMP Programming Corridor planning Environmental review and permitting For purposes of considering a planning framework for this project, some key findings include: Long-range planning points for road pricing: Road pricing may be considered at several steps in the long-range planning process. Early steps lay out the scope of the metropolitan transporta- tion plan including regional objectives such as sustainability, improving system efficiency, air quality, and so on. The congestion management process may be considered a sub-process that feeds into the MTP at steps where transportation deficiencies in the region are acknowledged and where alternatives such as pricing and demand management strategies are considered and prior- itized. The CMP can also be the impetus for initiating corridor studies or major investment stud- ies in areas where congestion is greatest, and for identifying potential congestion-relief solutions such as road pricing. Road pricing can be brought into the MTP at steps where strategies are pro- posed and approved either directly or via the CMP. If road pricing comes up as an opportunity outside of the planning process after an approved MTP is in place, there are two ways to integrate it: (1) hold it until the next plan update, test the strategy, and get approval or (2) issue an amend- ment to the MTP.

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Literature Review on Planning for Road Pricing 83 Programming points for road pricing: Programming involves the commitment of funding to par- ticular projects from the MTP over a period of several years. Road pricing has potential for balanc- ing project needs with funding requirements not only in the development phase but ongoing. Corridor planning points for road pricing: Corridor planning offers good potential for attention to road pricing because it is specific by area and by level of analysis. However, any planning frame- work incorporating points for road pricing needs to take into account that corridor planning is not a legally required process and therefore is less susceptible to required procedures and strong guidance. Another important point for corridor planning is that the level of planning detail is at the level required for environmental review, so that both planning and environmental analysis for a road pricing might be done simultaneously, thereby shortening development and implementa- tion time. Environmental review points for road pricing: The C01 project suggests at least two potential paths for road pricing under environmental review. When a road pricing project involves signif- icant new capacity and thereby the potential for causing significant environmental impacts, an extensive environmental review process may be required via an EIS. The environmental review process could be necessary either for compliance with NEPA at the federal level or for a state-level environmental review required by law in some states. Another path, as the review of federal guid- ance above suggests, may be lesser reviews or an exemption, particularly for pricing projects on existing facilities, where trip reduction and air quality benefits are clear cut and where revenues support auto use alternatives.