WSDOT wrong about risk of losing Federal Highway Funds

In this Q&A document published by WSDOT, (PDF version) they make several claims which need to be challenged.  A series of articles will be posted addressing those claims that are invalid.  This article will address Question 1:

“Why must we comply with federal standards regarding the performance of 45 mph 90% of peak time? Why are you forcing people (2+ carpools) out of the HOV lane to meet a federal requirement?”

WSDOT response:
The 45 miles per hour requirement is a federal requirement, and the Washington State Legislative direction which authorized express toll lanes on I-405, RCW 47.56.880, also requires that the express toll lanes operate at 45 miles per hour 90 percent of the time. Both federal and state law require WSDOT to report annually on compliance with this standard. The 45 mph requirement is based on the fact that the most efficient speed to maximize vehicle throughput in a lane is between 45 and 50 mph. If the facility does not perform to that standard, federal law requires it be brought into compliance within 180 days or the state could face “program sanctions” amounting to a loss in federal funding.
Due to the heavy use of HOV lanes, they are no longer performing to federal and state required standards. In order to conform to standards, we need to be able to change the carpool definition to 3 or more people all of the time or manage the lanes to allow 2-person carpools into them during off peak hours and allow vehicles with less than 3 persons during peak hours to buy their way into the lanes in such a way as to maintain the 45 mph speed objective. While the standards are important, they exist because of an engineering reality: when a lane operates beyond its capacity, not only are speeds reduced – but fewer vehicles per hour will get through.
WSDOT will manage the demand on the express toll lanes to meet performance standards through pricing. The rates will be set to keep vehicles and people moving through the corridor. When traffic gets to a stop and go situation, which often occurs in the HOV lanes, it takes longer to recover and get lanes moving again. By managing the demand through pricing you can regulate the number of users and keep that lane moving which will ultimately move more cars and people through the corridor. Moving more cars efficiently through the express toll lanes benefits the general purpose lane as well during the peak and shoulder periods – when you need the system to operate as efficiently as possible.
Here is the actual regulation published on the FHWA website: second paragraph of the introduction states:

The purpose of this document is to provide information useful to States as they plan, design, operate, and manage HOV and HOT facilities. It is intended to be non-binding and should not be construed as a rule of general applicability. This document provides examples for States to follow in evaluating proposed significant changes to the operation of an HOV lane, to include conversion of an HOV lane to a High Occupancy Toll (HOT) lane.

There is no misinterpreting that statement.  It is non-binding.  Period.  Further in the document it states that if HOT vehicles are permitted to use an HOV lane, then “operational performance must be consistent with Federal requirements.”  In other words, once solo drivers are allowed to pay a toll to use the lane (HOT) it must then comply with the 45mph minimum rule.  So to be brought into compliance WSDOT has the option to simply disallow HOT use and keep it as HOV only. It is that simple.  An HOV lane overflowing with carpools and moving slower than optimal speed still moves more PEOPLE than an under-utilized HOT lane of solo drivers.

Regarding the heavy use of HOV lanes leading to failed performance, that is not a justification to open the lane to SOVs.  Quite the opposite is true. If you can’t even meet the demand of HOVs, then you certainly should not add SOVs to the HOV lanes.  The purpose of making an HOV lane into an HOT lane is to be able to sell off the surplus HOV capacity to some SOVs and thereby lighten the traffic in the GPLs.  That is the intention of the Federal Highway Administration (FHWA) guidelines.

In the case of I-405, by adding the second HOV lane (in the section south of 160th St), it created enough capacity to carry all of the HOVs. From the WSDOT studies, before the conversion to HOT lanes, there were about 1500 HOV cars/hour during peak traffic (It doesn’t say where that measurement was taken).  As per the graphics in their article, Adding the second lane provides a capacity of 2600. (And see our earlier post here)  Therefore, there is no need to exclude 2-person carpools from the HOV status. There is enough capacity to handle all HOVs without too much degradation of speeds, yet not have too much unused capacity.

As for the section of I-405 north of 160th St, THIS SHOULD NEVER HAVE BEEN OPENED TO HOT lanes.  Again, the purpose of HOT lanes is to sell off the surplus capacity.  On that section of highway, it was already over capacity for HOVs.  No additional capacity was added, so SOVs should never have been allowed access to it.  First serve the needs of the HOVs before opening it to SOVs. That is the intention of the FHWA guidelines.  That half of I-405 has only 3 lanes total where the southern half has 5.  No amount of tolling is going to make those lanes functional. It simply needs more capacity.  We agree with WSDOT that you can’t endlessly “build your way out of congestion”, but that is no excuse to abandon adding capacity altogether.  Adding just 1 more lane to increase from 2 to 3 general purpose lanes would increase capacity by 50%.

By making the HOV lane a HOT lane, that invokes the federal 45MPH requirement.  In WSDOT’s own article, the opening sentence of the 4th paragraph, they state:

The main goal of HOV lanes was (and still is) to maximize the movement of people rather than vehicles team has taken measurements at 195th St overpass.  The vehicle counts of the HOT lane were 77% SOVs, 20% carpools, 3% motorcycle/vanpool/bus.  Prior to HOT lanes it was 97% carpools, 3% motorcycle/vanpool/bus.   By replacing that 77% of carpools with SOVs there is a REDUCTION in PEOPLE capacity of the HOV lane by roughly 40% (while speeds are faster, capacity is underutilized).

a lane full of 2 person carpools, even in a degraded state, gets more PEOPLE through than an underutilized HOT lane full of SOVs.

Posted in Uncategorized
One comment on “WSDOT wrong about risk of losing Federal Highway Funds
  1. […] that prove the assumptions and methods of WSDOT are grossly wrong.  Some of these include: – Truth about federal highway funds and How HOT lanes carry fewer people than HOV lanes – How expensive and inefficient tolls are at collecting revenue – WSDOT Admits Traffic […]


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