Noll Road Association

Comments surrounding Transportation 2040: Puget Sound Regional Council

Summary of the comments below:

1.)    Funding analysis is inadequate and needs thorough review

2.)    Toll should be used as traffic demand instruments, not as a systemic solution to fund all transportation needs.

3.)    Impact fees should be used for capital transportation expansion

4.)    User fees (Tolls, Gas Tax, and VMT) should be used to support capital investment, not operational expenses

5.)    Transportation should be a shared expense supported by general operating revenues in addition to user fees

6.)    Equity should be established within the 4 county area

7.)    Highway 3/16 at Gorst and Highway 104 from Kingston to Poulsbo needs to be included in the plan.

8.)    POF should be in Kingston, Port Orchard and Suquamish

9.)    Population forecasts do not support BRT in Kitsap County.

While I understand the necessity of establishing a financial constraint for federal submittal, I do have concerns about the nature of the financial model as presented. It is my understanding that the financial concepts (specifically the concept of tolling) came as an off shoot from the analysis of constraints on traffic demand. Tolling sprung from its ability to curb and shape transportation choices, rather than a true financing model for a long term stainable funding mechanism.

We have traditionally under priced our transportation with regards to usage. General subsides have been the rule to build the infrastructure and to provide support for operating costs. Without tying usage to cost there is a tendency to over use the infrastructure: when things are “free” people use more. Therefore, it is appropriate to tie usage to cost with a mechanism such as tolling. This is the nature of congestion management and the use of tolls to curb demand.

But user fees also trigger the experience of price points and decreased traffic demand. I think our dismal experience with the Washington State Ferry System is a crystalline example of price points and demand decline. Simply, when prices increase demand falls. It is concerning to me that a user fee model would be adopted in a global manner as the only additional alternative to fund our transportation choices for the year 2040.  As tolls are placed systemically through our transportation system, users will choose other alternatives thereby decreasing demand, and triggering increased tolls. As tolls increase the demand falls still further. The concept of user fees for transportation is not sustainable as our only additional financing choice.

We need to have different and better funding models. And these models should be built into Transportation 2040. Suggested analysis that should be done:

1.)    Tolls:  We need understand fluctuation in toll amounts on various corridors. It is my understanding that there have not been different prices for different toll locations put into the model. How much revenue does a matrix of tolls bring? What is the decline in demand as the tolls change? As we select tolls on certain corridors and we fluctuate price, what impact will these fluctuations have on the other transportation choices? How does the substitution of transportation choices impact the revenue received from tolls? And most importantly, if we use projected toll revenues to finance long term capital improvement, and we then fluctuate the toll pricing to moderate or influence demand, how do we predictably retire debt? Are tolls used as a revenue mechanism or an influence on demand? Can they do both systematically and systemically?

2.)    We need to do an analysis of how to capture the economic rents of transportation policy. Local jurisdictions do this very well by the use of impact fees. As land use policy is changed (zoning and annexation) land valuation increases, this increase is captured through the use of impact fees when development occurs. As we improve transportation corridors, land value increases as the development occurs and yet, this increase in value is not captured to pay for the transportation improvements that caused the increase in value. This creates an economic windfall to a few that could be captured to offset the cost of the transportation improvements. In Poulsbo, we have an expression: “Growth pays for Growth.” This concept should be expanded to the regional level (state?) so that those that reap the rewards of growth policy (in this case, improvement to transportation infrastructure) should pay their fare share. We need to look at impact fees to fund transportation at the regional and state levels.

3.)    Where is the analysis of VMT taxes? If we are shifting our policy to user based fees to pay for infrastructure, why are we simply looking at tolls and gas tax? Why not an excise tax on vehicle miles traveled?

I think the thing that I find the most troubling about the financial piece of this document is the general shift from the broad based approach by government to pay for services and shifting that policy to a user fee system. What inherently is the responsibility of government? Philosophically, government is supposed to solve the problem of providing those goods and services that are more advantageously shared. We all need to share the burden. We understand that our judicial system, police, fire and all forms of public safety should be shared throughout all society. Why? 2 fold reasons: 1.) it is hard to identify the true benefits to each individual and therefore charge them for services and 2.) the cost of the service provided is so significant, that all must bear the burden rather than those that are in specific need.

I see transportation as one of those basic core services of government and should be borne by all citizens, not just those that “use” the system because inherently we all “use” the system. Therefore I think that it is appropriate to use tolling mechanisms in the following circumstances: 1.) as a demand management tool to control congestion and 2.) to dedicate revenue streams to specific capital improvements. If tolls are used to offset marginal costs, price elasticity will limit that revenue stream as increasing costs are offset by increasing tolls.

For Transportation 2040 we should split the technical nature of the document away from the funding mechanisms. Our land planning policies should dictate the location and nature of the specific improvements that should be made. Then an analysis of the cost that is associated should be applied to these policy decisions. After we have a true picture of the cost structure (including operational costs), then we should look at how we are going finance the decisions that have been made. In this presentation, the cost structures are not well defined and the vetting is not clear.

We need to establish equity throughout the 4 county region. Care must be given to make sure that each community within the counties has equal treatment given the forecasted population increases. Pieces that are missing from the Kitsap County Plan are the following:  Highway 3/16 at Gorst and Highway 104 between Kingston and Poulsbo.  The Gorst segment will be especially troublesome due the current traffic counts on the road (how do we replace it or enlarge it without interrupting the current traffic flow) and the topographical features associated with this area.  Highway 104 will see ever increasing traffic as passenger only ferries arrive in Kingston. This will need to be addressed with increased transit service and highway capacity. I would suggest that this be done as soon as possible to lessen the cost of right of way acquisition. If we wait, ROW might become prohibitively expensive. Highway 104 will see equally high demand as Highway 305 after routine POF service is established. The Highway 104 improvements could be borne by impact fees.

Highway 305 at present carries 23,000 cars daily. We have one road to reach ferry service on Bainbridge Island.  The current population forecasts for north Kitsap County are as follows: (from http://psrc.org/data/forecasts/index.htm )

We need to more centrally locate our ferry service. Passengers only ferry service will be necessary at Kingston, Port Orchard and Suquamish in order to better utilize our existing corridor structures. By expanding passenger only ferry service to Suquamish, we would realize “back flow” off Bainbridge Island and reduce the congestion that already occurs.

 Alternative #5 suggests that we move forward with bus rapid transit across Bainbridge and throughout the length of highway 305. I fear that right of way acquisition, other capital costs and on ongoing operating costs of this system will not be supported by the forecasted population base (at year 2040) and the length of the corridor. This would be like the present day population of Ballard and Lynnwood (100,000) supporting a transit system that stretches from Renton to Kirkland (13 miles). We will not have the population density to support this system.  Better solutions would be to increase existing transit service and concentrate on increased park and ride lots and centralize POF services at Suquamish and Kingston.

I have similar concerns for Kitsap County as a whole regarding alternative #5. With a forecasted population of 356,000 in the year 2040 (about 62% of Seattle’s current population)  in a land area of 395 square miles, and so much of that population being outside defined urban centers, I have great concern that the population density will not support BRT solutions. The capital cost and ongoing operations subsidies may prohibit this solution.  A better solution would be support existing transit solutions, hot lanes on highway 3/16, more park and ride lots, ride shares, van pools, flex time for employment,  and fleet changes to support less carbon emissions.

My comments are reflective of my own opinion and are not necessarily representative of the City of Poulsbo.

Thank you for listening.

Becky Erickson

Councilmember

City of Poulsbo

berickson@cityofpoulsbo.com

360-779-4998