testimony to Senate Transportation Committee on SB6152

On behalf of, we offer this testimony in support of SB6152 and the 3 actions it takes:
(Click here to read the bill.)

1. Removal of the double-white lines — Safety
The toll lanes were advertised to increase safety.
Washington State Patrol has reported that accidents have more than doubled since tolling began.  Those accidents are heavily concentrated in the limited transition zones where traffic can move into/out of the toll lanes.
This is caused by what transportation engineers call a “Conflict Point”.  The Iowa State University Institute for Transportation  published this short graphic explaining conflict points: in which it states:
“A conflict point is the point at which a highway user crossing, merging with, or diverging from a road or driveway conflicts with another highway user using the same road or driveway.”

With the introduction of the double-white lines, there is a conflict point at every opening to enter/exit the express toll lanes (ETL).  For shorter transition zones, there is one highly concentrated zone.  For longer transitions, there is a peak at the beginning and end points of the zone, but the zones still exist.
Under the old configuration with open access to the carpool lane,  there was no conflict point.
This bill will remove as many of these conflict points as possible to increase safety.

Motorcyclists have commented on the Internet and in the petition that driving on I-405 is much more dangerous for them now as a result of both the danger of the conflict point described above and the fact that they must travel further in the middle of the general purpose lanes to reach the entry point — in some cases 2 or 3 miles — which is where they are most vulnerable.  Removing the double-white lines allows motorcyclists to enter the carpool lanes as soon as they get on the highway and remain there as long as possible before exiting the highway, increasing their safety.

Different drivers and different vehicles need/want different distances to merge from the ETL across the GPLs and ultimately to their exit ramp.  For example, a truck towing a camper-trailer driven by retired tourists who are not from the area will want enough time to read the signs and make the merge. That may be 2 miles or more, while a motorcycle rider wants to stay in the ETL as long as possible, as little as 0.1 miles before the exit.  The double-white lines do not accommodate either of these, creating dangerous and terrifying experiences for them.

The system must be easily understood by all drivers: old, young, locals, tourists, and foreigners.  This system is so complex that WSDOT has published youtube videos and an interactive map along with multiple blog posts explaining how to use it.  This is a serious safety problem.  It is grossly unrealistic to assume that all drivers have the studied these websites, especially tourists, the poor and the elderly.  With the exception of the variable pricing, the double-white lines and transition points are the most complex and confusing part of this toll system. The fact that WSDOT expects it to take 6 to 18 months for drivers to adapt is overwhelming evidence of this.  Removing the double-white lines will make huge improvements to safety and understanding of the ETLs and make them consistent with all of our existing traffic controls.

The toll lanes were implemented to make travel faster for buses.  But the buses now drive on the shoulder north of NE 195th St because they can’t get into the toll lanes.  This is a by-product of the fact they can’t access the toll lanes using the designated access points.  This is dangerous without proper adjustments to the highway.

In the WSDOT report to the WSTC, they stated that WSP gave 1555 citations for crossing the double-white lines. That is 17 violations cited every single day, which is a small fraction of the actual number of people doing it.  Such high disobedience is an indicator that the design is flawed.  As reported in testimony, even buses are crossing the double-white lines, compelling evidence that the lines are not serving the purpose they were intended or that their intended purpose is not valid.  Consider that prior to the change, cars were permitted to enter/exit at any point and did so with an accident rate less than half of what it is now.

Removal of the double-white lines — Performance
Accommodating Construction and Accidents
WSDOT responded to the following question posted in the comments on their blog at

“Lee said…
Are there exceptions allowing crossing the double white lines in the event of accidents, either into our out of the toll lanes? If so, is it limited to near the site of the incident?
October 3, 2015 at 7:49 AM

WSDOT said…
Hello Lee-
If the Washington State Patrol directs you to cross the double white lines, then you are allowed to do so. Otherwise, it is illegal to cross double white lines. Thanks for your question!
October 5, 2015 at 9:54 AM

Similarly, WSDOT published that the toll lanes would be open for free when the GPLs were closed for construction.  However, in practice the double-white lines and limited notification signs prevent this from being a viable practice.  Multiple times over the past 3 months, scheduled construction reduced the GPL from 3 lanes to 1 at night.  Yet in every case, the ETL were not opened.  Most recently, Jan 14th at 9PM the following incident happened where construction was under way and the lanes were reduced to one lane northbound starting at 124th St and an accident had already occurred at 195th St NE.  The overhead sign read “Accident at 195th St. 4 mile backup”.  Eventually the toll lanes were opened for free.  However, drivers had no entry point into the ETL when they read the sign, so they still couldn’t access the ETL and 6 miles cars were backed up from the sign to the accident because drivers had no way of knowing they could now use the ETL and there were no entry points into the ETL even if they knew they could use them.

Accommodating speed variations and drivers’ needs
Under an open access system like the standard carpool lanes, when one lane gets slowed down or is blocked by a slow driver, cars can easily pass by changing into or out of the carpool lanes without slowing down. (In other regions the carpool lanes are even designated to be used for passing only.)  With the new lane configuration, when drivers in the GPL come up on slow traffic and would like to switch to the ETL, they can’t because there is no entry point to do so, usually for several miles. (thus the large number of Lane violations reported by WSP).  A driver cannot predict if the GPLs are slow until they get to the slow traffic.  Removing the double-white lines will allow more vehicles to use the ETL when they need it most, as they approach a slowdown that they wish to avoid.  This would also increase use of the lanes and increase paid ETL use.

2. Open the lanes to all traffic from 7:00 PM to 5:00 AM
Under the old carpool system, everyone was allowed access to all lanes from 7:00PM to 5:00AM. There was never a problem with congestion in the night time hours after 7PM.
Traffic flowed freely because drivers could use all lanes to pass and be passed without creating slowdowns.  The traffic volumes are light enough that there is no need for congestion management during at that time.  Since the implementation of the ETLs, SOVs are unable to use the toll lanes in this manner.  Drivers aren’t going to pay just to pass another car and the double-white line doesn’t allow for it anyway.  So those lanes are nearly empty while traffic is now slower in the general purpose lanes.
The amount of tolls being collected at night is negligible and the rate is at the minimum during those hours.  So opening them to all cars for free without a pass would improve the overall flow of traffic yet not have significant effect on revenue.

Regarding nighttime construction
If the double-white lines did not exist and the ETL were free to all drivers after 7PM, then drivers could switch lanes very easily and they would know they were permitted to do so without any special message boards.  This was why the old system worked so well.  Construction could freely take a lane or 2 of the GPL knowing that cars could freely enter the carpool lanes where ever the needed.

3. Restoring the fourth GPL Lane
Note the attached photo 520mergeto405n.jpg.  This photo was taken Thursday, Dec 17th at 2:30pm.  This is the merge of SR520 to NB I-405.   Also note that there is no opportunity for drivers to move into the toll lanes in the 3 mile stretch from NE 8th St 1.5 mi before this photo, until near the top of the hill, 1.5 mi past this photo.

The report from WSDOT presented to the WSTC this week showed a photo of it being more open, but that photo is not truly representative of the roadway most days.

While the attached photo happens to be on a wet day, this merge looks similar to this nearly every weekday, regardless of weather, as well as randomly on the weekends which never happened before.  This is due to the removal of the 4th general purpose lane that ran from this merge all the way to NE 70th St.  Removing the lane now forces both lanes from SR520 to merge in a shorter length of roadway, creating a pinch point and forcing cars to merge that otherwise didn’t need to because they exit at NE 70th St.  Combine this with the cars in the general purpose lanes waiting for the transition point so they can get into the ETL and the result is a daily traffic jam at this merge, starting as early in the day as 2:30PM as well as on weekends.


Ramp from 520 onto I-405 NB at 2:30pm Thursday, Dec 17

WSDOT describes that fourth lane as an “auxiliary lane” in this article:
Regardless of the semantics, the fact is those lanes accounted for about 3 miles of the 8 northbound miles that now have 5 lanes including this critical zone from the SR520 merge with I-405 north to 70th St. NE.

This congestion has the unintended affect of acting like a metered ramp.  Traffic beyond that point flows more freely until it reaches the next congestion point.  The same happens to southbound traffic as it goes from 3 lanes to 5 lanes in Bothell.  The reality is that any speed improvements in that section have nothing to do with charging a toll.  It is due simply to the fact that there are 5 contiguous lanes and the pinch points at either end regulate the flow in between.

For these reasons, the team at is in favor of SB6152.

We know this is not a complete fix.  This bill is missing some key parts, namely the carpool requirement should be 2+ at all times and there should be no tolling and no need for a transponder.  A 3+ carpool system is less effective than a 2+ carpool system.  Charging a toll does not increase capacity; it decreases participation in carpooling as proven by research at Texas A&M University Dept of Civil Engineering; and it is a terribly inefficient tool for collecting revenue.  But this is a big step in the right direction.  One corrective step at a time.

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