Letter to WSDOT regarding the 6 month performance report

The following email was sent to WSDOT and WSTC  on June 29th discussing a few of the problems in WSDOT’s report to WSTC (and legislators) regarding the 6 month performance of the #405ETL.  They acknowledged receipt and will be providing a collective response:

This email is in regard to the WSDOT presentation to WSTC regarding the I-405 Performance and Operations Update and the Annual Tolling Report given May 17, 2016.
video archive: http://www.tvw.org/watch/?eventID=2016051059 beginning at 35:23
Presentation materials: http://www.wstc.wa.gov/meetings/agendasminutes/agendas/2016/May17/default.htm

I reviewed the data presented in the 6 month I-405 Performance and Operations Update presented at the Bothell Library and again at the May 2016 WSTC meeting. I have some concerns about the information presented.

The absence of any performance data for midday hours, and nights, and weekends
Errors or misrepresentations in creating, collecting, interpreting, and reporting the survey
The use of youtube videos as a means to educate the public
Success criteria are not clearly defined and do not include important factors

First, Major changes were made to the tolling system when they were eliminated on nights and weekends. Yet there is absolutely no mention of any performance data during midday hours (between peaks), nighttime, and weekends. I would expect this to be relevant and essential in determining the performance of the I-405 corridor with tolls vs without tolls. There should be at least 5 comparisons made for the nighttime and weekend data:
1. Performance before construction began.
2. Performance for the year prior to opening the tolls
3. Performance with tolling operating 24×7
4. Performance after tolls were removed at nights and weekends
5. Performance weekdays from 9:00 AM to 3:00 PM compared to the same time on weekends without tolls.

This data is crucial to determine if tolls are actually reducing congestion or if the cited reduction in congestion is strictly a result of infrastructure improvements and other variables like gas prices, weather, economics, and unemployment. By comparison, this article WSDOT reported how the tolls caused congestion to increase on weekends: http://wsdotblog.blogspot.com/2015/11/i-405-express-toll-lanes-6-week-review.html
The omission of weekend/nighttime performance since tolls were eliminated leaves the public suspicious as to the motives of leadership and it is perpetuating a loss of trust.

The second concern is the method of soliciting responses in the survey and how the data was reported to WSTC and presented to the public. WSDOT sent an email to people who have a GoodToGo pass. (a copy of the email is appended.) In Statistical Science this is referred to as Sample Bias and is the opening topic presented in the book “How to Lie With Statistics” by Darrell Huff. This is not a valid method for getting a representative sample of the entire group of people served by I-405 or even of those people using the toll lanes. This is a tiny fraction of the total users of the highway and selectively avoids people who are likely to give negative responses. In the stop405tolls.org petition with over 30,000 signatures demanding legislature to remove the tolls entirely, many people have passionately commented that they adamantly refuse to buy a pass for the toll system. It also biases the survey by avoiding people who don’t typically access the Internet, such as the poor and the elderly. This is not a random survey.

Here are several examples of how the data was misrepresented:
– The following graph was reported on slide 8 of the Annual Tolling Report:


This graphic implies all income levels favor expanding HOT lanes equally. This is deceptive for several reasons:
It is taken exclusively from people who already pay to use the HOT lanes. As such, they already demonstrated some tolerance. (yet 1/3 of them do not agree to expanding)
It does not identify the actual number of people in each household income category.
The range of income for each category is not equal.
How does the income distribution of pass holders compare to the income distribution of the general population?
So the conclusions this graph attempts to make are feckless.

Senator McAuliffe worked to get an amendment to the transportation budget to provide a study of the demographics of users on I-405 including the income of people paying to use the HOT lanes and how often they used them. WSDOT collected part of this data in the survey, but did so poorly; and what they did collect, they did not report.

– The results of the survey were given as percentages, not total number of responses. Reporting percentages alone is misleading. Actual counts are crucial in validating the statistical relevance of each question. This holds true for all data given in the report. Representative Stanford is a professional if the field of statistics and might give a more expert opinion on this.
– In spite of the fact that the survey only included people who are GoodToGo pass holders, only 53% indicated they are satisfied. This is a horrible customer satisfaction rating, but pales in comparison to what it would likely be if the survey also included the rest of drivers who don’t have a GoodToGo pass..


Third, I am concerned about the need for so many education materials needed and the reliance on youtube videos as a means for educating the public on how the express toll lanes work. In addition to publishing 7 youtube videos posted here:

WSDOT has this interactive map:
and this website with numerous lengthy webpages explaining how to use the toll lanes:
And there is a mobile app to find out what the toll price is right before you use them.

Seattle is a gateway city to the Pacific Rim. You might expect some local residents to put the effort into studying all these materials, but the majority of people don’t know they exist and the people who most need them are least likely to watch them. It is unreasonable to expect the millions of drivers in the Puget Sound region to review all of this. Even more so of infrequent visitors from around the state, around the country, Canada, and other countries. Consider that youtube is blocked in China. Not all people have handy access to the Internet, like low income and elderly people. This creates yet another barrier to widen the social inequity of the Express Toll Lanes. If it takes a series of videos, a set of webpages the length of a small book, and an interactive map just to understand them, then the system is inherently too complicated. With all the problems from distracted drivers, the fact that WSDOT created a mobile app for drivers to check toll prices just before entering the toll lanes is incredible.

Lastly, as the 6 month performance report of the I-405 Express Toll Lanes is reviewed, what are the criteria for determining if the tolls are a success or should be eliminated? In engineering this is referred to as acceptance testing. Does that criteria include public acceptance? Does it include a minimum level of service improvement for congestion across all lanes? Does the service level consider overall traffic or just the ETL? If it only considers the ETL and not overall highway performance, then why? Does the service level improvement measurement differentiate between the gains made by imposing a toll vs. the improvements made by increasing capacity? Since capacity was added at the same time the tolls were introduced (for part of the highway), the added capacity masks the fact that the tolls increased overall congestion. That would be revealed if the data regarding weekends and nights were published along with the data already shown by the section north of 522. The only 2 criteria for determining the degree of success or failure that I have seen are:
1. The toll lanes maintain 45 MPH for 90% of peak hour and
2. The lanes must not operate at a financial loss.
Yet these factors alone do not address the interests of the people.

In summary, the report shows a clear bias to yield positive results in support of the tolls. It avoids contradictory evidence, like the results of eliminating the tolls at night and on weekends and WSDOT used sample bias to influence the survey responses, then used reporting methods to obfuscate, prevaricate, mislead or omit facts entirely.

I am concerned about the impact that the errors and omissions in this report will have on any decisions made by WSTC and the legislature and the potentially harmful consequences of those decisions. WSTC and legislators are making policy decisions based on this data. Errors and misinterpretations in what WSDOT tells them could lead to making decisions that create a more deadly highway, increased congestion, wasted tax money, and heightened public frustration and mistrust. If bonds are sold, it could lock us into those bad decisions; not to mention it could cost elected officials their political office. Given the tenuous balance in both the House and Senate, this could change the party majority and affect policy on many other issues beyond transportation.

Your response to myself and my legislators regarding these issues is appreciated.

David Hablewitz


Invitation email for survey sent to GoodToGo Pass holders:

From: “Washington State Department of Transportation” <wsdot@service.govdelivery.com>
Date: 03/30/2016 11:01 AM
Subject: I-405 Express Toll Lanes Customer Survey
Dear Good To Go! customer,

You are receiving this survey invitation because our records show that you have used the Interstate 405 express toll lanes. We hope you will consider taking a few minutes to answer our questions. Your anonymous answers will help us understand more about how people are using the express toll lanes.

If the link above doesn’t work please copy and paste this address into your browser: https://www.surveymonkey.com/r/JGVw17XJ8Rl1tJSp

If you have any questions or comments about the survey, please contact us at 405carpool@wsdot.wa.gov or 206-464-1230.

This email was sent to davidhablewitz@yahoo.com using GovDelivery, on behalf of: WSDOT
310 Maple Park Ave SE · Olympia, WA 98504

Awaiting a response…

Posted in Uncategorized
5 comments on “Letter to WSDOT regarding the 6 month performance report
  1. BestScenicRoutes.com says:

    It sure seems like a letter to the editor along these lines would get a lot of attention.

    Cheers, Sean McDermott

    Contact me

    Date: Wed, 6 Jul 2016 20:25:47 +0000

    Liked by 1 person

  2. David H. Schlaegel says:

    Excellent work. Thank you for your efforts.

    Liked by 1 person

  3. Bill Popp says:

    Yes, I agree, excellent critique, as usual. Sampling is a scientific endeavor but the science part has been clearly avoided. And then there is the selective analysis problem. It seems as if there are two organizations at work here, the WSDOT engineers and the spin team with the spin team having the upper hand. It is disappointing to me having worked with WSDOT over a 40 year span to see so many issues that taint the agency when I know that most engineers simply want to do objective, meaningful work.

    This is a politically driven problem that started with Representative Clibborn (House Transp Comm Chair) and Senator Mary Margaret Haugen (Senate Transp Comm Chair) deciding to proceed with tolling when they were advised by staff based on a study they had authorized to delay the implementation as the tolling technology was not up to the task. So here we are with the daily lives of some 400,000 daily motorists negatively effected and a plan to extend the same “management” concept to the south and to the entire regional system.

    And that is the worst part — “congestion management” has replaced “congestion relief” as the policy directive from Representative Clibborn et al to WSDOT. Instead of real solutions we get behavioral modification, except for the relatively affluent.

    So in an attempt to bring some engineering sense to the political process I have thrown my hat in the ring and am running for Representative Clibborn’s seat.

    Bill Popp


  4. Kevin says:

    Thank you David for the effort you have and continue to put into this. The implementation, operation, and handling of the toll lanes has been at best unethical and would venture to say probably even borders on illegal in certain circumstances such as fancy paint application to justify taking a promised general purpose lane. In line with my view at least of unethical behavior their report out follows this pattern in that the data presented has been absolutely manipulated to provide a means to maintain support for tolling. I completely agree with all that you said and am frankly blown away by the data presented as it does not even come close to the experience I have had with this mess. Frankly data in the report its self is in conflict; slide 7 states a increase in performance between I-5 and 522 southbound in the morning yet slide 15 clearly shows increased conjestion along this portion of the south bound corridore . Which brings up another point that I think you touched on, but if you want a more apples to apples comparison than this section is the place to analyze as there have been no improvements (i.e lane additions and from slide 15 the conjestion is clearly worse than it was under the original 2+ HOV model. The conjestion might clear out quicker but that has nothing to due with tolling it just means that the down stream bottle neck is less than it used to be. Also traffic comparisons also don’t mention that I-405 has been under major construction prior to ETL with the ETL stealing one of the lanes immediately on completion of this construction so there is absolutely no way to compare pre and post ETL efficiency as there is absolutely no baseline to be compared to or what impact the road construction had within the larger picture of conjestion. Additionally one thing that seems to get little talk time in general is the impact of ETL structure on short trips. WSDOT has admitted that short trips between about 1 and 3 exits have been negatively impacted throughout the corridor and this is per design as their expectations have been that few people would use the lanes for short trips. This is probably a true statement with respect to paying a toll however I can only assume, (no data available to support), that the impact is large for short trip commuters of all HOV capacities such as oh school buses maybe. This is my pain and I know the pain of many parents. I depended on the 2+ HOV model to reliably get my son to school. This is now gone for me and my commute brings him in late at least 1 time a week. There is no level of planning that I can do to support a consistant arrival time and complaints to WSDOT have been pushed back on me to better utilize their tools. Ummm okay let me check that app while driving or before leaving to find out that things just changed with an accident or unexpected shift in rates driving people in or out of the lanes. So without getting to much on my soap box one statistic I would be very interested in is the number of tardy arrivals pre and post ETL. I do know school bus routes and times changed notably following the ETL and that Northshore school district did at some level identify issues to WSDOT but apparently that information is not information that WSDOT wanted to make public as I a potentially impacted parent heard nothing about this and only know what I do from one of the attendance employees at my sons school casually mentioning this during one of my late arrival sign ins.

    Finally one additional general note with regards to political and policy impacts. Tim Eyman is currently hot on the hot lanes. Many people will argue that we are in the place we are today at least in part to some of Eyman’s initiatives. I am sure Tim is well aware of the frustration of these lanes and the general mistrust of WSDOT. He is talking of an initiative to abolish these lanes and also tacking on some additional items. I can honestly say at this pount I am ready to sign anything that comes my way to shut down this racket even at the risk of hurting other programs. I am not an Eyman supporter in any way but I am ready to sign. This is not a hit positive or negative to Tim Eyman or political feelings. What this is to me personally is that I am so frustrated with these toll lanes and the unethical operation and management of them that I am ready to sign an initiative regardless of my feelings on the larger long term impacts just to shut things down.

    Liked by 1 person

    • Excellent points Kevin. I have many more to make, including the contradiction in data they present, but the email was very lengthy as it is.
      As for the initiative by Tim Eyman, we stand in the exact same spot.


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