System Trials to Demonstrate Mileage-Based Road Use Charges (2010)

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82 7. DESIGN OF THE TRIALS The preceding chapter addressed strategic themes and issues that arose during the interviews and workshop, including the development of alternate frameworks for the trials. This chapter focuses on more detailed questions related to the design of the trials, summarizing the input offered by interview and workshop participants in response to specific questions about scoping, structuring, funding, managing, and conducting the trials (Appendix D provides more detailed discussion of the responses to the questions). The set of issues addressed in this chapter is based on the list of questions posed in the interview guide (see Appendix B). In the interest of providing a more logical narrative flow of the material, the questions have been reorganized (and in some cases combined) in this chapter, in the following categories: • Roles in overseeing, managing, and conducting the trials • Organizing, coordinating, and funding the trials • Size, participation, duration, and cost of the trials • Pricing policies to examine in the trials • High priority issues to examine in the trials • Detailed trial implementation strategies For each of the specific issues discussed within these categories, we first outline the relevant question(s) posed to interview and workshop participants (note that the question numbers appearing in the text, e.g. question 1.2, refer to the numbered list of questions in Appendix B). We then synthesize the perspectives that emerged based on the interviews and workshop. For questions that elicited considerable divergence in opinion among stakeholders and subject matter experts, the discussion considers whether the appropriate choice might depend on the selected framework for the trials. Any additional analysis conducted by the research team to supplement the input of interview and workshop participants, where needed, is also reviewed. 7.1. ROLES IN OVERSEEING, MANAGING, AND CONDUCTING THE TRIALS This section summarizes the responses to questions related to the potential roles of various organizations in overseeing, managing, and conducting the trials. 7.1.1. Planning and Overseeing the Trials Questions 4.1 and 4.2 asked about how planning and oversight for the trials should be structured. Specifically, what entity, new or existing, should ideally guide this effort? Many interview and workshop participants suggested that an advisory panel—either in the form of a committee or commission—should be established to oversee the effort to plan and prepare for VMT fees, including trials and related activities. At minimum, respondents indicated that the panel should include representation from Treasury, U.S. DOT, FHWA, AASHTO, and states. A separate entity, acting under guidance of the panel, would be charged with managing the details of implementing the trials along with any parallel planning, analysis, R&D, and education and

83 outreach efforts. Many respondents argued that TRB would be the best candidate to fulfill this research management role, though other organizations (e.g., FHWA) would also be possible. 7.1.2. Soliciting Stakeholder Input for the Trial Program Question 4.3 asked about the best way to accommodate stakeholder input into the design of the trials. Respondents indicated that there should be some type of opportunity for stakeholders to provide input on the design of the trials—for example, a stakeholder advisory council, invited input from stakeholders, an open comment period, or meetings with stakeholders conducted around to the country—but also suggested that the period for input should be constrained to at most 3 to 6 months so as not to delay the trials. 7.1.3. Conducting the Trials Question 5.2 asked about who should be eligible to conduct trials—that is, to bid for and/or receive funding to implement a trial. The three prior U.S. cases provide examples of trials being led by a state (Oregon DOT), by an MPO (Puget Sound Regional Council), and by a university (University of Iowa). It is also conceivable that trials could be conducted by private or non-profit entities. The question posed to interview and workshop participants, then, was which of these options would be the best choice for leading expanded system trials. Respondents recognized that states, cities, counties, private firms, and research institutions could all play important roles in conducting the trials. In terms of who should lead the effort, however, two distinct models emerged. Many respondents argued that states should take a leadership role in structuring teams and conducting the trials, given that states would ultimately need to be integrally involved in any effort to implement VMT fees. A smaller number supported the concept of directly funding the various organizations that would be involved in the trials (so as to ensure their participation) for the specific contributions that each would make—for example, contracting with firms to provide the metering devices and billing services, funding states to examine state-level VMT fees and issues related to administration and enforcement, funding local governments to examine local VMT fees and automated payment of parking fees, funding insurance providers interested in testing out PAYD insurance, and funding research institutions or MPOs for data analysis and evaluation. This latter option was suggested as being appropriate for the market framework because it would directly engage the various parties—service providers, insurers, and cities—that could play an important role in the provision of value-added services, such as PAYD insurance or automated parking payment, to entice voluntary adoption. 7.1.4. Roles for DOTS, DMVs/MVAs, and MPOS Question 7.1 asked about the appropriate roles for state DOTs, DMVs/MVAs, and MPOs within the trials. Participants indicated that general state roles within the trials would involve certain elements of fee and data collection along with enforcement support. Specific state roles would vary depending on certain policy decisions (such as the choice of technology to be examined) and the state’s institutional structure. While many participants did not expect that MPOs would assume a major role in leading the trials, several noted that their participation could be valuable in helping to design certain aspects of the trials (e.g., variable pricing structures), facilitating outreach with local stakeholders, and helping to analyze data and evaluate trial results.

84 7.1.5. State Legislative Requirements Question 7.2 asked about the conditions under which enabling state legislation would be required for states to participate in the trials. The response was that legislation would likely be required for states to collect actual revenue in the context of VMT fee trials, and that the passage of such legislation could be expected to take between one and five years. State legislation might be needed in some states even to conduct a trial. State legislation might also be required in some states to allow PAYD insurance to be examined in the trials. 7.1.6. Engaging Multiple Service Providers within a Trial Questions 8.1 and 8.2 asked about potential strategies for including, within the same trial, metering devices and billing services provided by multiple vendors. The intent would be to examine the concept of implementing an interoperable system in which multiple firms could compete for market share on the basis of cost and value-added services (this would be a critical issue to examine under the market framework; for the other frameworks, it might be viewed as valuable but not essential during the trials). Interview and workshop participants suggested that it would be valuable to involve multiple technology vendors within the trials, and indicated that this could be achieved by setting up the competition to allow for multiple award recipients. They also underscored that the competition should be based on more than just cost—for example, it might seek to include different metering approaches or different value-added features from different vendors. 7.1.7. Encouraging PAYD Insurance within the Trials Question 8.3 asked how the trials might be structured to allow and encourage participation among auto insurance companies, if desired. The underlying premise of the question was that PAYD insurance represents a commonly cited value-added service that might encourage voluntary adoption and help defray the cost of metering devices and collection services. Views were mixed among interview and workshop participants as to whether the inclusion of PAYD insurance within the trials should be viewed as optional or required; it would be most beneficial in the market framework in which the goal would be to offer as many value-added services as possible to increase voluntary adoption. Respondents suggested two factors that could encourage auto insurers to participate, if desired: access to detailed travel data (including claim events) to help them calibrate PAYD insurance rate structures, and/or a cash subsidy (likely on the order of $200 per policy) to cover the costs associated with switching policies. 7.1.8. Role for Auto Manufacturers Question 8.4 asked whether auto manufacturers should be involved in the trials, and, if so, in what capacity. Respondents suggested that the voluntary participation of auto manufactures in the trials at this time would neither be likely nor essential (note, however, that the interviews did not include any representatives of auto manufacturers, and many participants did not comment on this question). 7.2. ORGANIZING AND FUNDING THE TRIALS This section reviews questions related to organizing the trials—determining how many trials there should be, where they should be located, and the required degree of coordination among

85 the trials—and the approach to funding the trials (note that discussion of how much the trials might actually cost is presented in the following section). 7.2.1. Number and Location of Trials Question 2.4 asked whether trials should ideally be conducted in all states or, alternatively, in multiple adjacent states. The majority of interview and workshop participants indicated that the trials should not include all states; rather, there should be several trials (most suggestions fell in the range of three to six trials) in individual states or groups of adjacent states (e.g., the I-95 Corridor Coalition) that are interested in exploring, and potentially implementing, VMT fees. Ideally, based on the comments we received, the set of selected trial locations would span different geographic regions of the country, include both “red” and “blue” states, include major metropolitan regions, and include at least one multi-state trial configuration. 7.2.2. Coordination among the Trials Question 5.1 asked about how the trials should be organized and coordinated. At one end of the spectrum, one could envision a large, carefully coordinated trial that would span multiple states and be designed to gather information on a specific set of issues in order to prepare for subsequent implementation of a national system. At the opposite end, it would be possible to fund a set of largely independent trials in which states would have much greater latitude to explore alternate policy structures and implementation designs. Between these two conceptual endpoints, there could also be some sort of hybrid approach—an attempt to structure the multiple trials to address core national implementation issues while simultaneously allowing for state innovation. Interview and workshop participants favored the hybrid concept; that is, the trials should collectively address any crucial issues needed to plan and implement a national system of VMT fees, but there should still be enough flexibility for states to explore innovative policy options. Several responses also suggested, however, that the organizational structure might depend on the selected framework. Specifically, under the state framework states might be given even broader latitude in terms of technical and institutional approaches considered; the main connecting theme among different trials in the state framework would be to examine interoperability standards and certification processes. States might also choose to examine the possibility of shared revenue collection and distribution systems (akin to the International Registration Plan and International Fuel Tax Agreement) for economies of scale. 7.2.3. Basis for Allocating or Awarding Funding Question 6.3 asked about the most appropriate mechanism for distributing funds to support trials. Potential models included earmarks, competitive grants, and proportional funding available to all states on the basis of population or other factors. Interview and workshop participants indicted that funding for the trials should be allocated on the basis of competition rather than earmarking. Several participants suggested that it might be helpful to first request initial expressions of interest and then invite and provide seed funding for a subset of states to develop more detailed proposals. Another idea that emerged was to set aside a modest amount of funding (in addition to funding for the trials) that would be available to any state, on a non-competitive basis, to begin preliminary exploration of VMT fees (i.e., conducting studies rather than trials).

86 7.2.4. Criteria for Competitive Awards Questions 6.4 and 6.5 asked about the criteria that should be applied if the funding for trials were to be awarded on a competitive basis. Most participants indicated that the trials should involve some required elements (e.g., examining one or more metering options, collection mechanisms, and enforcement strategies of interest and perhaps helping to test out interoperability standards) along with some optional elements. Qualification for trial participation would be based on the former, while competition among qualifying bids would be based on the latter. Suggestions for the potential criteria that might be used to evaluate and rank competing proposals, under the assumption that base requirements had been met, included cost, number of participants, capacity of the proposing entity, innovation, inclusion or simulation of variable pricing, intent to collect actual revenue, and intent to explore use of travel data from the system to support improved planning and operations. 7.2.5. Federal Share of Funding Question 6.2 asked about the share of trial funding that might be provided by the federal government. Some interview and workshop participants indicated that the federal government should pay for the trials in their entirety, while others thought a modest state match of perhaps 10 to 20 percent should be required. While the latter would help to ensure that states that applied for funding were committed to the concept of VMT fees, it might also prevent otherwise interested states from participating given the current state of the economy. 7.2.6. Funding Program Question 6.1 asked whether funding for trials should be channeled through an existing program with related scope (e.g., the Value Pricing Pilot Program) or though a new program. Only a small number of respondents chose to answer this question, but many of those who did felt that the evaluation of VMT fees was important enough, and sufficiently distinct from the scope of existing programs, to merit the creation of a new program. 7.3. SIZE, DURATION, AND COST OF THE TRIALS This section summarizes the responses for questions related to the appropriate size (number of participants) and duration of the trials, what they are likely to cost, and how much the federal government should be willing to invest in trials. 7.3.1. Number of Participants Questions 2.2 and 2.3 asked about the appropriate number of participants to include within the trials, as well as the relative importance of various factors that might influence this number: testing the feasibility and cost of certain implementation options at scale, gathering and assessing data on participant responses to alternate implementation options and fee structures, and building greater awareness of (and ideally support for) distance-based user fees. Interview and workshop participants suggested that it would take thousands of participants to properly assess user perceptions of implementation options and fee structures, tens of thousands to gain greater clarity on the feasibility and cost of various implementation options at scale, and hundreds of thousands of participants to have a strong affect on national awareness of and

87 support for VMT fees. Within the context of trials intended to help plan and prepare for implementation, all of these goals would be valuable. Developing a better understanding of cost and feasibility of alternate implementation options at scale, however, would be especially critical. This suggests that it would be appropriate to aim for at least tens of thousands of participants in the trials, a level that would also provide better understanding of how drivers perceive and respond to the various options. While building broader understanding of and support for VMT fees was also considered important, it was noted that this goal could be achieved at lower cost through more traditional education and outreach activities. Yet if the trials were intended to evolve directly to full-scale implementation featuring an initial period of voluntary adoption, as several respondents argued, scaling the trials to include hundreds of thousands of participants would also create a large base of initial adopters, helping to build momentum for the program. Additionally, it would likely encourage service providers to invest more resources in the development of value-added services to increase market share. These advantages might prove helpful in the state framework, if one or more states pursued trials intended to transition directly to implementation. It would be difficult, however, to predict in advance whether states would elect this path. Moreover, as the state framework would not initially lead to the development of a national system, the case for funding hundreds of thousands of participants from federal dollars would be diminished. It would thus appear reasonable to aim for tens of thousands of participants, rather than hundreds of thousands, under the state framework. In contrast, the explicit goal within the market framework would be to evolve directly to full-scale national implementation, so the inclusion of hundreds of thousands of participants would be valuable in this case. To sum up, under either the state or federal frameworks it would be appropriate to aim for tens of thousands of participants (perhaps 10,000 to 20,000 per trial, and 50,000 to 100,000 across all trials). Under the market framework it would be valuable, if possible, to scale the trials to include hundreds of thousands of participants (perhaps 100,000 to 200,000 per trial, and 500,000 to 1,000,000 across all trials). It is worth noting that the overall cost of funding the trials depends to a significant degree on the number of participants; further analysis of the appropriate number of participants to include would therefore be valuable. 7.3.2. Duration of the Trials Question 2.5 asked about the appropriate duration for the trials. The responses of interviews and workshop participants suggest that the trials should last a total of four to six years, including at least one and possibly two years for planning and preparation (two years would be particularly helpful if the intent were to develop initial interoperability standards and certification processes in advance of the trials), two to three years of in-vehicle trials, and another year for evaluation. This timeframe would allow the trials to examine additional functionality (e.g., collecting actual revenue and preventing evasion) that has not been explored in prior U.S. trials. In two of the frameworks—potentially in the state framework and definitely in the market framework—the trials might evolve directly into full-scale implementation at the end of this period.

88 7.3.3. Cost of Trials Question 10.1 asked about how much it might cost to implement the trials. As context, the scope of the project did not support the development of a detailed model to make this calculation. We were therefore particularly interested in the perspectives or insights of participants who had either (a) conducted trials, or (b) examined the cost structure of other trials or programs. Though several respondents offered ballpark estimates in the range of $1,000 to $2,000 participant, they also suggested reviewing prior trials and recent program implementations to get a better sense of the likely cost. Such analysis suggests that a more realistic estimate of the cost of the trials might fall in the range of $2,000 to $4,000 per participant, including roughly $1,000 to provide the metering devices and billing services over a three year period and another $1,000 to $3,000 for additional trial-related costs—e.g., planning and managing the trials, evaluating the results, and enrolling and interacting with trial participants. One individual who participated in the interviews and workshop suggested that under the market framework, though the per-vehicle costs might be similar, it might be helpful to alter the allocation of the costs. Specifically, more resources might be directed to municipalities (to develop automated parking payment), to auto insurers (to develop and offer PAYD products), and to technology providers for the development of additional value-added services, all with the intent of creating more incentives for voluntary adoption. Fewer resources, in turn, would be needed to pay participants to volunteer (participants would instead be enticed by the value-added services) or for post-trial analysis and evaluation (given that the trials would directly evolve to implementation). Based on these numbers (and regardless of the specific allocation), if the trials included 50,000 to 100,000 participants in total (as in the state or federal frameworks), then the cost would fall in the range of $100 million to $400 million. If the trials included 500,000 to 1,000,000 participants in total (desirable under the market framework to create an initial pool of voluntary adopters as the trials evolve to full-scale implementation), then the cost would fall in the range of $1 billion and $4 billion. It should be stressed that the analysis behind these numbers is limited, and there are numerous cost-related uncertainties that would be difficult to predict in advance; further investigation of this question would therefore be helpful. 7.3.4. Value of Trials Looking at the issue of cost from another perspective, Question 2.1 solicited opinions about how much it would be worth spending on trials, under the assumption that the trials would be needed for, and ultimately lead to, implementation. A common response was that the federal government should be willing to invest as much as needed, within reason, to ensure that the trials address any remaining uncertainties to facilitate informed debate and prepare for implementation. Two arguments for spending significant resources on VMT-fee trials were offered. First, a system of VMT fees might ultimately supplant most road revenue sources at the federal, state, and local levels (e.g., fuel taxes, license and registration fees, heavy vehicle use taxes, dedicated sales taxes, and the like), potentially generating hundreds of billions of dollars annually. Second, switching to VMT fees would prevent the loss of billions of dollars in fuel taxes in the coming decades due to more efficient conventional vehicles and alternative-fuel vehicles. When pressed for a specific amount that the federal government would likely need to invest in the trials in order to achieve the intended aims, most answers varied between $200 million and $500 million, with

89 a few suggesting $1 billion or more (interesting, these dollar figures fall in the same range as the estimates of what the trials might actually cost, as discussed above). 7.4. PRICING POLICIES TO EXAMINE IN THE TRIALS The issues reviewed in this section reviews relate to the types of pricing policies that would be helpful to examine within the trials. 7.4.1. Metering All Mileage vs. Tolling a Subset of the Road Network Question 1.1 asked whether, in addition to the concept of charging for travel on all public roads, an expanded set of VMT-fee trials should also examine the potential for tolling on a partial road network. As context, VMT fees constitute one option for reforming surface transportation finance, but there are others. Another possibility would be to toll just the most heavily traveled segments of the road network (e.g., the Interstate system) using simpler RFID technology. While there are possible drawbacks to this strategy—most notably the potential for significant traffic diversion—it could also prove less costly and less politically controversial. In response to the question, participants confirmed that it would be relatively easy, from a technical perspective, to augment VMT trials to examine the concept of tolling on a limited road network. While opinions were somewhat mixed, many respondents suggested that the trials should only examine tolling on a partial road network if the concept were receiving serious consideration as a potential policy direction among decision makers. Otherwise, the trials should focus solely on VMT fees—that is, fees that cover all miles of travel on all public roads. 7.4.2. VMT Fees for Passenger Cars, Trucks, or Both Question 1.2 asked whether the trials should examine mileage-based fees for passenger cars, for trucks, or both. Many interview and workshop participants agreed that the trials should include both cars and trucks (possibly distinguishing between smaller commercial vehicles and long-haul trucks, given their different travel patterns), possibly in the context of separate trials. 7.4.3. Potential Pricing Structures Question 1.3 asked about the potential pricing structures to examine within the trials. Options included flat fees, fees that vary by jurisdiction, fees that vary by time and location, fees that vary by vehicle weight and potentially by road class (for trucks), and fees that vary by emissions characteristics. This question elicited a broad range of responses. Many agreed that the trials should consider, at minimum, flat fees that vary by jurisdiction (to allow, for example, separate collection of federal, state, and possibly local VMT fees). While participants often viewed other forms of pricing as highly desirable, it was also acknowledged that their inclusion could make the trials more controversial. This led to the suggestion that more sophisticated fee structures be viewed as optional within the trials (for example, those bidding to conduct trials might choose, at their discretion, to examine congestion tolls, but this would not be required in order to qualify for funding).

90 7.5. HIGH PRIORITY ISSUES TO EXAMINE IN THE TRIALS This section summarizes responses for questions related to specific technical, institutional, implementation and transition, and user acceptances issues that the trials might be designed to address. 7.5.1. Technical Issues Question 3.1 asked about the relative importance of different technical issues that the trials might be designed to address. Options included alternate metering configurations, alternate collection mechanisms, alternate means of protecting privacy, alternate enforcement approaches, an open systems technology platform (including relevant interoperability standards and certifications), and the potential use of detailed travel data to support other transportation goals (e.g., providing real-time traffic congestion data, calibrating transportation demand models, and the like). While these are all important issues, the purpose of the question was to elicit from the respondents their sense of which should be viewed with the highest priority, and why. Based on comments from interview and workshop participants, the three technical issues viewed as highest priority included alternate collection mechanisms, alternate privacy mechanisms, and alternate enforcement mechanisms. Under the state framework, if it were envisioned that the trials might evolve directly to implementation, then it would also be important to develop and test interoperability standards as part of the trials to reduce the risk that different states would adopt incompatible systems. Under the market framework, with the explicit goal of evolving directly to an initially voluntary system, then it would be beneficial to examine interoperability standards within the trials as well as the development of value-added services based on detailed travel data. 7.5.2. Institutional Issues Question 3.2 asked about the relative importance of different institutional issues that the trials might examine. The options included actual (rather than simulated) collection and apportionment of revenue, simultaneous collection of federal and state (and possibly local) VMT fees, alternate collection systems for passenger cars and trucks, alternate institutional configurations for billing and account management (e.g., publicly administered, administered by a single vendor, or administered by multiple vendors), and competition among multiple vendors within the same trial. The institutional issues commonly cited as high priority to address in the trials included the simultaneous collection of federal, state, and possibly local VMT fees and multiple institutional configurations for billing and account management. Under the state framework, if it were intended that the trials be designed such that states could transition directly to implementation, then it would be crucial to include actual revenue collection. Under the market framework, collecting actual revenue would be essential, and allowing for competition among multiple firms in the same trials would also be very valuable. 7.5.3. Implementation and Phase-In Issues Question 3.3 asked about the relative importance of examining additional implementation and phase-in issues in the trials, such as integration with existing toll systems, including different

91 classes of vehicles (e.g., older vehicles without the OBD II port that might require distinct metering device configurations), charging foreign vehicles, rebating fuel taxes to those who pay VMT fees (if needed), and incentives for voluntary adoption to speed the transition period. Based on the responses of interview and workshop participants, the two issues that emerged as highest priority for the trials included integration with tolling systems and the exploration of incentives for voluntary adoption. Two additional issues received qualified recommendations. If it were intended that VMT fees replace fuel taxes, then the trials should examine methods for rebating fuel taxes for early adopters. Likewise, if were envisioned that all existing vehicles might at some point be required to install retrofitted metering equipment, then it would also be very helpful to examine multiple vehicle classes (i.e., both newer vehicles and older vehicles without an OBD II port). 7.5.4. User Perceptions and Acceptance Question 3.4 asked about different user perception and acceptance issues that could potentially be examined in the trials. Options included user understanding of and support for distance-based road-use charges, user response to alternate fee structures, user response to alternate privacy protection mechanisms, user response with respect to potential tradeoffs between privacy and ability to audit, and user response to the choice of value-added features. Participants generally viewed user understanding and acceptance of VMT fees and privacy concerns as the highest priority issues to examine in the trials. Other issues were viewed as valuable but not equally essential. 7.6. DETAILED TRIAL IMPLEMENTATION STRATEGIES This section summarizes the responses to more detailed questions about how to implement and conduct the trials successfully—for example, enrolling participants, examining interoperability standards, and probing the effectiveness of approaches for preventing evasion. 7.6.1. Strategies for Enrolling Participants Question 9.1 asked about how to encourage both car and truck drivers to participate in trials. Many respondents felt that the trials would need to offer some form of incentive—likely financial, and on the order of several hundred dollars per participant, but perhaps involving the provision of value-added services—to entice sufficient participation. It was also noted that effective incentives for passenger car drivers would likely differ from those for trucking firms; specifically, the opportunity to provide input on the design of the VMT-fee system and pricing policies might be a stronger incentive to participate among trucking firms. 7.6.2. Groups to Include Question 9.2 asked whether efforts should be made to include specific types of vehicles or groups of users in the trials, such as electric vehicles, older vehicles without OBD-II ports, rental fleets, government fleets, or trucking fleets. Based on responses from interview and workshop participants, it would be valuable for the trials to encompass as many vehicle classes and user groups as possible, but few respondents viewed the inclusion of any specific group as being a critical requirement for the trials.

92 7.6.3. Parallel Education Activities Though the project focused mainly on the trials themselves, question 9.3 asked interview and workshop participants to consider complementary education and outreach activities that might be included before, during, and after the trials. Many respondents indicated that the trials should ideally be accompanied by large-scale public outreach and education (though it was noted that this might be less important in the market framework, where participating firms would be motivated to market their services) and the campaign should start early. Other suggestions included designing the trials based in part on public input, using innovative means of outreach, and working through membership organizations. It was also noted that education and outreach would be a sensitive task and should be approached accordingly. 7.6.4. Interoperability Standards Question 11.1 asked whether the federal government should endorse a set of interoperability standards in advance of the trials and, if so, who should take the lead in developing them. Respondents indicated that the development of interoperability standards, along with a process for certifying vendor products and services as compliant, would be a critical area for federal leadership. Issues to address within the standards would include support for fee collection options, privacy protection options, and enforcement options; data storage, communication, and security protocols; and support for IntelliDrive functions. Interviews and workshop participants expressed varied opinions as to who should lead this effort, but suggestions on who should be involved in developing the standards included representatives from device manufacturers and service providers, related industry consortia, IBTTA, ITS America, the IntelliDrive program, and academic institutions. Several respondents also noted that it would be helpful to reference related standards work, such as ISO/CEN 17575, as a starting point to speed the development process. Opinions were mixed, however, on whether standards should be developed in advance of or following the trials. Seeking to develop an initial set of standards in advance of trials would make it possible to examine how well the interoperability concept works in practice during the course of the trials, but it might also delay the timeframe for initiating the trials. Waiting until after the trials, in contrast, would provide a greater opportunity to apply the lessons learned during the trials to the standards development process. As discussed earlier, developing an initial draft of the standards prior to the trials would be important if it were intended that the trials might evolve directly to implementation—this would be applicable for the market framework and possibly for the state framework. 7.6.5. Accuracy of Metering and Billing Question 11.2 and 11.3 asked about how to test the accuracy of metering devices and billing statements. Respondents indicated that accuracy issues should be tested and verified in advance of the trials; that is, there should be some set of tests to certify minimum accuracy requirements before initiating the trials. It was also noted, though, that the trials would provide the opportunity to further evaluate accuracy over a broader range of situations. 7.6.6. Effectiveness of Privacy Protection Mechanisms Question 11.4 asked about how to verify, and demonstrate to users, the proper functioning of alternate mechanisms for protecting privacy. Interview and workshop participants indicated that it would be beneficial to involve, within the trials, a reputable organization committed to privacy

93 protection to help verify that the adopted privacy mechanisms work at intended. It would also be valuable to engage a firm with telecommunications and data security expertise to identify any potential vulnerabilities in the area of data security. 7.6.7. Effectiveness of Mechanisms for Preventing Evasion Question 11.5 asked about how to test the effectiveness of alternate mechanisms for detecting and preventing fee evasion within the trials. States and the federal government would be understandably reluctant to proceed to implementation unless decision makers were confident that VMT fees could be effectively enforced. Yet within the context of trials, the level of participation might prove insufficient to fully stress the enforcement mechanisms. Additionally, if the trials did not involve the actual collection of revenue, there would be little incentive for participants to try to cheat the system. How, then, might the trials be structured to probe the effectiveness of proposed mechanisms for detecting and prevention evasion? Two suggestions emerged from the interviews and workshop: hiring a firm with relevant expertise to systematically search for weaknesses, and offering cash rewards to individual trial participants that find a way to avoid full payment without being detected. 7.6.8. VMT Fees for Foreign-Owned Vehicles Question 11.6 asked about potential ways to test the application of VMT fees to foreign-owned vehicles in the trials, should that be desired. Interview and workshop participants did not provide any specific suggestions for this question. As discussed earlier in Section 7.5.3, the testing of VMT-fees for foreign-owned vehicles did not emerge as one of the highest priority issues for inclusion within the trials. 7.6.9. Additional Uses of Travel Data Question 11.7 asked about how to evaluate, within the trials, the possibility of using detailed travel data to support other transportation applications—for example, developing real time traffic information or calibrating regional transportation demand models. Several respondents suggested paying a subset of trial participants to share their detailed travel data (perhaps on an anonymous basis) and using it to develop real-time traffic congestion information. 7.6.10. Transition Issues Question 11.8 asked about how the trials might be structured to examine certain issues related to transitioning to VMT fees, including strategies for promoting voluntary adoption, methods for rebating fuel taxes (if VMT fees were to replace rather than augment fuel taxes), and the demonstration of a transition strategy. To examine potential responses to a voluntary opt-in transition strategy, respondents stressed the value of including a set of value-added features on the in-vehicle equipment within the trials. Specific suggestions for issues to probe included distinguishing between participant perceptions of VMT fees and perceptions of the value-added services and exploring whether the value-added services used to encourage participation in the trials would prove sufficient to entice the actual adoption of VMT fees. Interview and workshop participants did not provide specific suggestions on the issues of rebating fuel taxes or demonstrating a transition strategy.