June 29, 2020
Delivered via email
The Honorable Peter DeFazio
Committee on Transportation & Infrastructure
United States House of Representatives
The Honorable Same Graves
Committee on Transportation & Infrastructure
United States House of Representatives
RE: Support for Tolling Provisions in Investing in a New Vision for the Environment and Surface Transportation in America (INVEST in America) Act
Dear Chairman DeFazio and Ranking Member Graves:
The Alliance for Toll-Free Interstates (ATFI) is a growing alliance of individuals, businesses and organizations advocating for long-term, sustainable, efficient, equitable, and sensible highway infrastructure funding solutions. ATFI applauds the renewed public emphasis on infrastructure funding coming from Congress, and we are glad to see the House abandoning tolling pilot programs in this proposal. While we fully support efforts to increase the rigor of regulatory review of tolls in the INVEST in America Act, we also want to register our opposition to any policies allowing tolling on existing interstates and believe the proposal’s placing new guardrails on tolls should go further to protect motorists.
Implemented properly, infrastructure funding can provide meaningful employment opportunities to those individuals and communities that need it the most, while also modernizing the transportation system to improve the free flow of people and goods throughout the country. At the same time, poorly conceived infrastructure legislation can be counter-productive, causing unintended impacts that are detrimental to transportation networks, economies and local communities.
Keeping these principles in mind, ATFI strongly supports the repeal of the failed Interstate System Reconstruction and Rehabilitation Pilot Program (ISRRPP) and sunset provision for the Value Pricing Pilot Program. Eliminating these tolling pilots is long overdue. History has shown that, when given full consideration, states recognize what all the affected industries have always known. Tolling interstate lanes that drivers now freely access is not only unpopular, it is an inefficient financing mechanism that is the worst approach available to raising transportation revenue. Imposing tolls on existing interstates will increase shipping costs for goods; suppress consumer activity; waste revenues on bureaucratic administration; double-tax businesses; and divert traffic onto local roads, increasing traffic, accidents and road wear and tear in communities near toll facilities. Efforts to make tolling easier will hurt America’s economic future and reroute prosperity around the communities where tolls are located.
As our nation seeks to recover from the devastating economic impacts of the COVID-19 pandemic, tolls will hurt businesses trying to reopen. Hardest hit by tolls will be America’s small businesses and their employees. Tolls raise business costs for moving goods through the supply chain, hurting the competitiveness of local companies. Restaurants, convenience stores, travel plazas and gas stations operating near the newly tolled interstate will face higher costs from manufacturers and shippers, who will be forced to charge more to transport goods by truck. Every day consumers will be shouldering the burden by paying more for goods, demonstrating the fact that the toll is nothing more than an underhanded tax on the general public.
Tolling existing interstates is double taxation. Since the inception of the Federal Interstate Highway System, the federal gas tax has always been the primary source of revenue for the construction and maintenance of federal interstate lanes. Every time a motorist puts gas in his vehicle, he is upholding his end of the deal for interstate maintenance. Converting non-tolled roads to tolled facilities, even when combined with a congestion relief effort, forces drivers to pay two taxes for that same road: a gas tax and a toll tax.
Tolling is also a highly inefficient form of taxation, to the point of being fiscally irresponsible. Toll gantries cost millions of dollars to build and maintain. Even with the latest technology, collection costs alone are at least 8 to 11 percent of revenue collected, according to the Congressional Budget Office. Toll management, enforcement and operations total a significantly larger portion of revenues that do not go to actual road improvements. In 2018, the all-electronic North Carolina Triangle Expressway spent 36.8 percent of annual revenue on toll operating costs; those are funds that could go toward road improvements with more efficient funding mechanisms. In contrast, nearly 100 percent of fuel tax revenue can go toward infrastructure improvements because the cost of administering the taxes is less than 1 percent, and these registration fees do not increase collection costs. Because tolls are generally upheld as a “user fee” for the roads traveled, diverting these funds from infrastructure improvements violates the public trust. When it comes to tolls, Americans will pay more and get less.
Not only are the financial ramifications of tolls unfair to the public, the social costs are discriminatory. Tolls devour take-home pay for drivers and are especially oppressive to low-income Americans. They would make driving on interstates simply unaffordable for some families, particularly with the new economic reality many face today. Additionally, electronic tolling discriminates against the tens of millions of financially vulnerable Americans who do not have bank accounts. This places the heaviest burden from tolls on the backs of those least able to afford it, who, lacking the financial instruments of a debit or credit card, are sent a bill in the mail charging them the toll plus a fee and a stamp. Unfortunately, cashless tolls are on the rise. For example, the Pennsylvania Turnpike Commission recently announced that the March switch to all-electronic tolling due to the COVID-19 pandemic would become a permanent change, further disenfranchising drivers already suffering from other economic impacts from the novel coronavirus. Tolls are expensive for all drivers, but especially costly for drivers without bank accounts.
Tolls will force drivers to use secondary roads. Studies have shown tolls divert traffic onto secondary roads. Local municipalities are then stuck with increased maintenance costs and new public safety concerns such as higher accident rates on local roads and first responders delayed by toll-driven congestion.
For these reasons, we are glad to see the INVEST in America Act’s requirements that congestion tolling projects assess impacts on roads in the same corridor, impacts on freight movements and economic impacts on businesses. However, the truth about tolls is that the negative impacts outweigh the benefits. To ensure that the interests of the driving public are protected, we urge that Congress eliminate programs for tolling existing interstates, restrict toll bridge projects and further limit how toll revenue is spent.
Voters and state-level policymakers continue to reject tolling existing interstates because they understand tolls are bad public policy with myriad negative consequences, both economic and social. We appreciate you taking into account your constituents’ vocal opposition to tolling existing interstates. As we have seen with the failed ISRRPP, when states learn the true impacts of tolling existing interstates, they reject this option. The reasonable response to that failure is to eliminate it and move on to more viable revenue generation ideas.
As reauthorization is discussed, ATFI’s members – thousands of private citizens and numerous businesses and organizations – urge you to fully reject tolling of existing interstates. Americans need sustainable investment in our infrastructure, not discriminatory, ineffective policies that take more and more money from hardworking motorists and businesses. The needs of America’s transportation network are vast and deserve serious attention without the distraction of tolls.
We appreciate the opportunity to offer these comments and ask they be submitted for the official record. We thank you for your consideration and look forward to working with you to move forward this important legislation and further strengthen motorist protections. Should you have any additional questions, please contact our Director of Membership and Operations, Charlie Kiefer, at firstname.lastname@example.org.
Alabama Trucking Association, Inc.
Alaska Trucking Association, Inc.
American Bakers Association
American Farm Bureau Federation
American Highway Users Alliance
American Motorcyclist Association
American Moving and Storage Association
American Trucking Associations
Arizona Trucking Association
Arkansas Trucking Association
Best Way Express
California Trucking Association
Colorado Motor Carriers Association
Delaware Motor Transport Association, Inc.
Duncan & Sons Lines, Inc.
Florida Trucking Association, Inc.
Georgia Motor Trucking Association, Inc.
Golden Strip Transfer
Hawaii Transportation Association
Idaho Trucking Association
Illinois Trucking Association, Inc.
Indiana Motor Truck Association, Inc.
International Foodservice Distributors Association
International Franchise Association
Iowa Motor Truck Association, Inc.
Kansas Motor Carriers Association
Kentucky Trucking Association
Louisiana Motor Transport Association, Inc.
Maine Motor Transport Association, Inc.
Maryland Motor Truck Association, Inc.
Massachusetts Motor Transp. Assoc., Inc.
Michigan Trucking Association, Inc.
Minnesota Trucking Association
Mississippi Trucking Association
Missouri Trucking Association
Motor Carriers of Montana
Motor Transport Association of Connecticut
Motorcycle Riders Foundation
National Motorists Association
National Private Truck Council
National Shippers Strategic Transportation Council (NASSTRAC)
National Tank Truck Carriers
Nebraska Trucking Association
Nevada Trucking Association, Inc.
New Hampshire Motor Transport Assoc.
New Jersey Motor Truck Association
New Mexico Trucking Association
New York State Motor Truck Assn.
No Tolls I-95 Coalition, Inc.
North Carolina Trucking Association, Inc.
North Dakota Motor Carriers Association
Ohio Trucking Association
Oklahoma Trucking Association
Old Dominion Freight Line, Inc.
Oregon Trucking Associations, Inc.
Owner-Operator Independent Drivers Association (OOIDA)
Pennsylvania Motor Truck Association
Rhode Island Trucking Association, Inc.
South Carolina Trucking Assoc., Inc.
South Dakota Trucking Association
Specialized Carriers & Rigging Association
Tennessee Trucking Association
Texas Trucking Association
Truck Renting and Leasing Association
Truckload Carriers Association
Utah Trucking Association
Vermont Truck and Bus Association, Inc.
Virginia Trucking Association
Washington Trucking Associations
West Virginia Trucking Association, Inc.
Wisconsin Motor Carriers Association
Wyoming Trucking Association, Inc.
To learn more about AFTI and join the Alliance please visit www.tollfreeinterstates.com. In addition to joining ATFI you can stay connected with the Alliance on Twitter at @No2Tolls and Facebook at https://www.facebook.com/TollFreeInterstates.