WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

Transcription

1

2 OVERVIEW AND BACKGROUND This Technical Memorandum documents the results of the project by which members of the Western Road Usage Charging Consortium (WRUCC) were provided the opportunity to examine, evaluate, and comment on several of the key documents developed for Oregon s Road Usage Charge Program (RUCP). The WRUCC was created by adoption of an organizational Charter in Its major purpose is to build public sector organizational capacity and expertise on the topic of mileage-based road usage charging, addressing policy, administrative, and technology issues associated with RUC systems. The Consortium provides a collaborative forum for its members all volunteer state Departments of Transportation to information and best practices, discuss issues, observe and learn from other public agencies that are at various stages of testing or implementation, and facilitate joint research projects among interested member-agencies, thereby achieving economies of scale. WRUCC has been approved as a Transportation Pooled Fund (TPF) project by FHWA. This designation allows participating jurisdictions to earmark a portion of their federal research dollars to fund the Consortium and its work plan. Oregon has been in the forefront not only within the WRUCC, but also for the entire nation in the development of concepts, policies, processes, technologies, and systems to replace the current pay-at-the pump fuel tax with an approach that is based on the number of miles driven. The fuel tax was once an excellent surrogate for a mileage-based approach when all light vehicles basically got the same approximate fuel mileage. However, with the growing market of highly fuel-efficient vehicles that pay little or no fuel taxes, this is no longer the case. A new road usage fee system is necessary to create a sustainable funding source for maintaining and operating the public road system, not only in Oregon, but also other western states and throughout the United States and Canada. Oregon conducted a successful pilot of a mileage-based system the Road Usage Charging Pilot Program (RUCPP), involving participants in Oregon, Washington, and Nevada between November 2012 and February Subsequently, the Oregon Legislature enacted Senate Bill 810 in July 2013 directing the Oregon DOT to establish an operational Road Usage Charge Program ( RUCP ) to launch on July 1, 2015 for 5,000 volunteers. Design of the RUCP (e.g., system and business requirements, technical specifications, contract documents) was completed in 2014 followed by evaluation of vendor proposals, with contracts recently executed with Azuga and Verizon to provide Commercial Account Management (CAM) 1 1 The CAMs are third party companies responsible for providing equipment, customer support, and other services for the RUCP as part of a commercial market establishment. CAMs may provide other vehicle related services (e.g., pay as you drive insurance, vehicle monitoring, other value added ) in addition to their RUC offerings. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

3 services. Sanef was the vendor selected to provide ODOT s Account Management (OAM) 2 as an outsourced service. The Oregon experience and the current RUCP offers a potential model and valuable source of lessons learned for other western states interested in a mileage-based road usage charge. Moreover, possibilities exist for the interoperability of road usage charge systems across multiple western states coupled with the potential benefits associated with a regional RUC approach (e.g., capturing interstate mileage, increased numbers of vehicles in the system resulting in reduced per-vehicle costs for administering the system). At the same time, it is recognized that each state may wish to change or modify its approach beyond the parameters developed for the Oregon RUCP. PROJECT ACTIVITIES This project provided the opportunity for the other WRUCC states to engage in a critical examination and verification of the various concepts, attributes, and components of the Oregon RUCP. The documents listed in Table 1 were made available to members of the WRUCC for their review and comment, with the overall project goal of providing or otherwise identifying the following: Potential sources of lessons learned and examples for other western states interested in a mileage-based road use charging. Aspects of Oregon RUCP that other states may wish to adopt, modify, and /or change for their possible approach to road use charging. Possibilities for the interoperability of road use charging systems across multiple western states for a regional RUC system. Input from other states that may also assist in the evolution of road use charging and development of common ground for a regional approach. These documents were posted on an Oregon DOT FTP site. Brief summaries (1-2 pages) of each of these documents were also prepared and sent out to the WRUCC members, as well as being posted on the FTP site. These summaries included herein as Appendix A included a description of the document, the likely audience of the document (by functional area such as policy, technical, procurement, etc.), a summary of the document contents, and key questions that the reader might consider when reviewing the document. Two interactive webinars were conducted for the WRUCC members as follows: January 7, 2015 Approximately 25 participants January 20, 2015 Approximately 15 participants 2 The OAM is a third party company responsible for providing equipment and customer support for the RUCP on behalf of Oregon DOT. The OAM may only provide basic (i.e., non-location based) RUC capabilities; and no other vehicle related services may be offered. The OAM account management website must be branded for the State of Oregon. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

4 The two webinars were essentially the same in terms of the material covered, and both included time for questions and discussion. Based on the experience from the first webinar, the presentation was updated and revised slightly, a copy of which is included in Appendix B. Table 1: Oregon RUCP Documents Included in the WRUCC Examination Documents The RUCP Program Report (Summary Report of the RUC Pilot Program and Legislation) SB 810 the legislation that authorized a RUC system accommodating up to 5000 volunteers and the associated Policy Framework and law. Concept of Operations (CONOPS) System Requirements Specification (SRS) Interface Control Document (ICD) Contract documents for the Commercial Account Managers (CAM) private industry vendors participating in the RUCP (including associated Work Order Contracts (WOCs), Price Agreements and Service Level Agreements) Contract documents for the Oregon Account Manager (OAM) a private industry vendor participating in the RUCP on behalf of ODOT (including associated Work Order Contracts (WOCs), Price Agreements and Service Level Agreement) Business Rules for the RUCP, describing the business and operational conditions to which the RUCP vendors must adhere Administrative Rules for the RUCP General Orientation Program, fiscal, planning and policy Program, planning and policy Planning and technology Technology Technology Procurement Procurement Operations, fiscal and policy Operations and policy SUMMARY OF COMMENTS WRUCC members were given approximately 5 weeks following the 2 nd webinar to review, ask questions, and provide comments (in addition to any comments and questions during the webinars themselves). A summary of these comments and questions general ones and by document is provided below. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

5 General (No Specific Document) Question / Comment Does ODOT bond against their gas tax revenues? What mechanism exists to collect road usage payments from the public? Is this another system that must be developed to be interface with Account Management subsystem? Response No. The State Treasurer bonds against their Highway Trust Fund, which has multiple revenue sources, including fuels tax (diesel and alternate fuels), gas tax and weight distance taxes from heavy commercial vehicles. The RUC would become another revenue source feeding into the State Highway Trust Fund. The CAMs and OAM are responsible for collecting payments from the RUCP participants, and then remitting the funds to the State of Oregon in a timely manner. Account Managers under contract with ODOT are currently planning to use subcontracted vendors to provide payment processing services for their clients. As a component of the Account Managers system, this does not require direct ODOT management of a separate service provider. CAMs are required to remit payment for net revenue of all RUC taxable miles; the OAM is required to remit payment to ODOT of funds received. The administrative and accounting burden varies widely between these two structures and affects level of effort for state management. The State of Oregon has specific cash management requirements established by law and rule which have bearing on payment collection by the account managers as well as their revenue submittals to Oregon. Some details associated with these state specific requirements may not be applicable to other states and could require modification. Based on several factors, internal activities to establish an ODOT operational management structure for RUC required some unique solutions. Oregon s financial management system is a composite of current and dated technology systems. Interfacing with these systems for tax reporting and remittance is a significant effort. Given these factors and to support on-time project delivery, the solution in Oregon was to develop an administrative database (RUCAS) that accepts all reports to the state as defined in the ICD and to meet financial management and record keeping requirements by adding RUC tax reporting and tax remittance functionality to an existing IT project that was already developing a connection with state WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

6 financial systems. The effort and requirements in other states will depend on their unique situations. The documentation describes several systems that may be deployed to meet the requirements functionality. Has Oregon finalized this for their implementation? RUC Lessons Learned: Oregon has gone through a maturity evolution that has created a good RUC element and system example. Specific operability and interoperability issues have not been addressed due to the Oregonian environment or regional RUC immaturity. Oregon focused exclusively on light duty vehicles and limited the RUC study to address/amend only vehicle impacts to the road. California may wish to address further environmental impacts. Regional RUC development will be critical in the future as each state develops the own RUC system. Key elements like the open architecture will be critical for other states to adopt to facilitate an effective regional system. As noted in the initial section, two CAMs are currently under contract for the RUCP Azuga and Verizon all offering a variety of other in-vehicle services (e.g., Pay- As-You-Drive insurance) in addition to RUC. A regional approach is key to providing RUC in a costeffective manner. One of the questions asked during a vendor panel at the Mileage-Based Usage Fee Alliance (MBUFA) annual meeting last week was: Is there a magic number out there, in terms of number of vehicles at which this really does become economically viable? That the amount of government subsidy for running one of these systems goes to zero; or at least, he said, it goes down to a level that it s no more than what a state is spending today to operate its pay at the pump fuel tax collection system? The answer from all 4 vendors on the panel (Verizon, Azuga, IMS / Sanef, International Telematics) was a resounding yes. What is unknown (or perhaps the vendors are not saying) is what that number is. As to environmental impacts, one of the potential value added services identified by the vendors is to monitor emissions using the Mileage Reporting Device (it is, after all, plugged into the OBD-II port). If a vehicle meets emission standards, there is no need for the owner to drive to the testing station and be tested. RUCP Program Report Question / Comment What sort of load testing was done for the pilot (and what is planned for the RUCP)? A related question - What daily record volumes is Oregon experiencing for each vehicle in their pilot? Response None The bandwidth requirements for the mileage message are very small. The RUCPP was set up and capable of supporting far more vehicles than were involved in the pilot. Moreover, the mileage message is transmitted at most once per day, and only on those days when the car was driven (i.e., mileage accrued). WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

7 SB 810 and the associated Policy Framework and law. Question / Comment Response NONE Concept of Operations Question / Comment How do the collection methods identified in the Washington State ConOps compare to the ODOT system and ConOps? Oregon has done a good job with this CONOPS. The user needs for California are greater and more diverse. The California user needs assessment will be a critical aspect/element of the CONOPS for RUC system operability. Love Oregon s change to an open RUC architecture system that will be acceptable and adaptable to changes in technology, user needs, and other regional systems. Response A Concept of Operations must reflect the specific goals, objectives, needs, approaches, and scenarios for the intended system. The Oregon CONOPS was prepared based on the experiences and lessons learned from the RUCPP, the various system attributes and conditions as identified in (the then) pending legislation, and the general operational environment in Oregon. As such, the Oregon CONOPs focused on automated collection methods using mileage reporting devices that plug into the vehicle s OBD-II port (which also help promote private vendor participation and additional in-vehicle services, with RUC as another value-added service.) The Washington CONOPS includes other methods that were either not specifically addressed in the Oregon legislation or were otherwise deemed inappropriate for Oregon s situation such as a flat fee for an annual maximum number of miles, and manual methods (e.g., reporting of vehicle odometer readings on a periodic basis by an authorized agent.). These other methods are briefly addressed in the Oregon CONOPS, but only in the context of other potential means of collecting mileage. As noted above, a CONOPS must be tailored to the specific needs that the system must address, and address any unique conditions in the area where the system is to be deployed. An open architecture, with specified communication protocols, is essential for having multiple vendors involved in a public-private arrangement for providing RUC and related services. It also supports interoperability and a regional approach in the future. Additional benefits WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

8 of an open architecture and commercial entity involvement is the technology development costs and associated technical risks are born by the private sector, not government. Though it is not stated in this presentation, it looks like Oregon went through a critical analysis of performance measures where certain elements are identified as critical to the program, their performance measured and identified as a minimum requirement. As the CONOPS speaks of the system relationships both internal and external to the state, it might be prudent for the CTC TAC to consider having FHWA involved with a seat on the board, ex-officio; a possible recommendation by Caltrans. USDOT is promoting a performance-based approach for evaluating transportation projects per MAP 21, although none of these are directed to RUC. The RUCPP evaluation used several performance metrics, as summarized in the RUCP Program Report. The CONOPS also identifies several potential performance measures (Table 5 on page 75); but these will have to be vetted and finalized as the RUC system grows and eventually becomes a mandated system. Moreover, additional performance measure will likely be required for a multi-state regional system. The next national transportation bill may provide federal funds for regional RUC pilots; but there are no guarantees that such funding will be included. FHWA involvement in a RUC program depends on the needs and desires of each individual WRUCC state. System Requirements Specification (SRS Question / Comment Is the system/device aware of toll roads? Response There are no toll roads in Oregon; and the current RUC mileage reporting devices identified in the Oregon SRS do not incorporate specifications for any toll road RFID technology (although there is nothing to prevent this addition in the future) Moreover, an Advanced MRD (with location capability) should be able to determine when a vehicle is on toll facility with some degree of accuracy. The issue of RUC and toll facilities is a major consideration for many states throughout the country. One concept to consider since gas taxes are currently paid on toll roads, one could also expect that RUC would be paid on toll roads in the future as well, assuming that RUC is intended as a replacement for gas taxes. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

9 How does Oregon know when an MRD in a vehicle stops working? What is the process to notify driver and get unit repaired. One of the lessons learned from the RUCPP was to update the SRS to include a wellness check, and for the MRD to transmit this information once a day regardless if any mileage was recorded. The CAMs and OAM are responsible for notifying the driver and sending out a replacement unit. There is also a pro-rata process for estimating the mileage driven while the MRD is not functioning or otherwise unplugged. Interface Control Document (ICD) Question / Comment How does this system interface with similar systems in use by commercial trucking system and taxi companies? What interface exists to deliver road mapping coordinates to the system from our GIS systems? Response In Oregon, the weight-distance system for trucks is separate from the proposed RUC, which only addresses light-duty vehicles. The RUC system will not interface with any existing commercial truck fleet management or telematics system or with any taxi fleet management system. However, a taxi fleet would be able to register for the RUC using the same system as is available for passenger cars. As part of the public-private partnership concept in Oregon, the CAMs provide and use their own GIS mapping systems. General accuracy of these vendorprovided GIS systems is addressed as part of the vendor certification process. Contract documents for the Commercial Account Managers (CAM) Question / Comment Service Level Agreement (page 5): Do we have estimates from Oregon on actual costs and staffing level needs for each subsystem that are required for support? Response Vendors are asked to provide minimum levels of service; how they accomplish this is assumed to vary based on their existing business structure and staffing, including use of their already existing call centers in some cases. Except for the additional live phone answering customer service task, a market compensation rate for operations was established. This rate was set at a percentage of the gross road usage charge collected by each vendor. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

10 Contract documents for the Oregon Account Manager (OAM) Question / Comment Response NONE Business Rules for the RUCP Question / Comment NONE Response Administrative Rules for the RUCP Question / Comment NONE Response WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

11 APPENDIX A Document Summaries WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

12 ODOT Road Usage Charge Pilot Program 2013 & Per-Mile Charge Policy in Oregon Description: The summary of the Road Usage Charge Pilot Program (RUCPP) 2013 describes Oregon s development of road usage charging policy from 2007 to 2013 with a focus on results of the RUCPP, passage of SB 810, and review of key issues facing road usage charging programs. Intended audience (by functional area): We recommend review by: Transportation policy makers and advisers in the executive and legislative branches; strategic planning executives; financial planning managers; government affairs and communications managers; accounting officials; and staff that participate in revenue collection activities (vehicle fees, tolls, etc.). Summary: The 45-page report comprises seven key chapters. The contents of each chapter are summarized below. Introduction & History of Road Use Charging in Oregon. This introductory chapter presents an overview of the process Oregon undertook to develop and carry out the RUCPP. This chapter includes a list of the technical information and analysis produced during the new period of development of RUC in Oregon ( ). This chapter also presents how the state of Oregon pioneered the user pays principle in 1919, charging a gas tax to drivers for road maintenance, and the recognition in 2001 by state legislators that hybrid and all-electric vehicles would pay less or no fuel tax, and that these vehicles would see increasing adoption. Given this trend, the state accepted that a gas tax was no longer an equitable means of raising revenue for road maintenance, and that a distance-based road user fee posed a more feasible alternative. The independent Road User Fee Task Force (RUFTF) was established in 2001 to develop recommendations and ultimately a final design for revenue collection for Oregon s roads and highways. In 2003, after considering 28 different funding ideas, the task force recommended a road user fee based on distance traveled as the best funding alternative to the fuel tax. ODOT completed two pilot programs, the first in and the second in , employing evaluation criteria developed by the task force to measure the success of each program. Road Usage Charge Policy Development presents the transition of policy from the first pilot s results in 2007 to creating the second pilot whereby ODOT sought to align its program with public preferences. The RUFTF advocated a program with open architecture, no mandate for location-based technology, motorist choice for reporting mechanism, and private sector involvement. Developing the Road Usage Charge Pilot Program. This chapter presents the foundation, purpose, and development and procurement processes for the RUCPP (the second pilot program). Based on this development, ODOT determined the marketplace had four likely categories of distance data collection technologies: basic reporting, factory installed advanced reporting, aftermarket advanced reporting and switchable reporting. It includes several figures summarizing the RUCPP subsystems and components, and an overview of 4 steps related to capturing miles traveled by a RUC-payer, billing, payment by RUCpayer and remittance of road usage charges by account manager to State of Oregon. Managing the Program explains how Oregon managed and implemented the RUCPP. ODOT sought participants in the pilot program with policy interest in transportation funding as this test was focused on demonstrating to decision-makers that the fundamentals of a future RUC system are sound and WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

13 worthy of legislative actions. A total of 88 drivers from three states participated in the RUCPP, along with two private vendors. This chapter also summarizes how extensive outreach was undertaken to help educate the public on both the reasons for the program and how the pilot worked. Evaluating the Program describes how ODOT measured the performance of the pilot program based on four key categories of interest: policy and public acceptance, technology, operation and costs. This chapter summarizes key findings for the pilot goals aligned with these four categories of interest. The report also directs the reader to the OIPP website which features a final evaluation report which discusses the findings in greater detail. Senate Bill 810 and the Pathway to Implementation presents the options considered and actions undertaken by the Oregon Legislature following successful completion of the RUCPP in March Following hearings on two bills, HB 2453 and SB 810, the state passed legislation (Senate Bill 810) establishing the nation s first mileage-based revenue program for light vehicles. The program, slated for launch in July 2015, will engage up to 5,000 initial participants who will be charged 1.5 cents per mile driven. This chapter also presents the statutory requirements of Senate Bill 810 as well as the path forward for the bill in terms of framework, implementation, and context research (including ODOT s hosting a national RUC summit in November 2013), procurement process, recruitment of volunteers, internal ODOT organization and process and the estimated timeframes. Issues Facing Road Usage Charging Programs presents key issues and concerns identified to date regarding how to make road usage charging policies acceptable. The chapter provides a detailed overview on issues related to privacy protection, administrative costs, how road usage charging is not tolling, costs for compliance and operations, equity for rural drivers/drivers in different regions, treatment of non-resident drivers and summary of alternatives to distance-based charging. Key Questions for Reviewers How can the approach to road usage charging in Oregon and passage of SB810 be applicable to other states addressing funding shortfalls? How can your state best leverage the experience in Oregon? Based on the open architecture platform in Oregon, how do you foresee the market opportunities advancing in your state, if at all? What steps can/should Oregon take to help assist your state to move its RUC agenda forward, if any exists? WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

14 ODOT Road Usage Charge Policy Framework Description: The Policy Framework summarizes the evolution of road usage charging policy in Oregon from , with an emphasis on the actions taken by the 2013 Oregon Legislature and an analysis of SB 810, which set Oregon on course to implement and operate a permanent road usage charging program. Intended Audiences (by functional area): We recommend review by: legal and/or policy experts, to provide a critical analysis of the Policy Framework. Examples of such staff in a state Department of Transportation could include: legislative analysts, public-private partnership executives, general counsel, or legislative liaisons. Summary: During its 2013 session, the Oregon Legislature considered two competing bills related to road usage charging. The first, HB 2453, would have implemented a mandatory road usage charge on all vehicles rated by the EPA at or above 55 miles per gallon (MPG) or MPG-equivalent (MPGe). The second, SB 810, would have implemented a road usage charge program initially for up to 5,000 volunteer motorists with any type of vehicle. The Policy Framework summarizes the committee hearings, testimony given, and actions taken on both bills, including identification of proponent and opposition groups, arguments for and against each bill, and amendments made to each bill throughout the process. Ultimately, SB 810 prevailed. The key content of potential interest to other states is the analysis in Section 5 of the Policy Framework. Section 5 provides a section-by-section breakdown of the contents of SB 810, including interpretations and implications for the Oregon Department of Transportation (the implementing agency) and other stakeholders such as volunteers, commercial account managers, law enforcement, and other states. In particular, Section 5.2 of the policy framework provides interpretations of the SB 810 language for a range of unresolved issues. Section 5.3 lists all of ODOT s rule-making opportunities and obligations emanating from SB 810. Finally, Section 5.4 derives policy objectives from SB 810 that ODOT can use in implementing the legislation. Key Questions for Reviewers: Does the Policy Framework provide a sufficiently detailed analysis of SB 810 such that another state could understand ODOT s basis for moving forward with administrative rules, procurement, and other implementation activities? Are there any aspects of the policy directives and objectives as summarized in the Policy Framework that are cause for concern or conflict for your state, should your state and Oregon attempt to work together in the area of road usage charging? Examples of potentially conflicting areas could include divergent statutes around protection of personally identifiable information or involvement of commercial account managers (also referred to in SB 810 as Certified Service Providers). Can the structure and content of the Policy Framework serve as a useful template for other states that need to translate legislation into action? Less important, but still worth considering: does the Policy Framework correctly interpret the meaning of SB 810, especially as it applies to the key issues (Section 5.2), rule-making opportunities (5.3), and derived policy objectives (5.4)? WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

15 Oregon Road Usage Charge (RUC) System: Pre-Legislative Concept of Operations (CONOPS) June 28, 2013 Description: The purpose of a Concept of Operations (CONOPS) is to provide a narrative and pictorial description of a system s intended use, describing the What, Where, When, Who, Why, and How of the proposed system operations. The CONOPS for the Oregon RUC describes the proposed RUC system as it was viewed during the 2013 legislative session (which resulted in the passing of SB 810, authorizing the implementation of a road usage charge program for up to 5,000 volunteer motorists.) The CONOPS focuses on system needs and related policy directives, RUC objectives, and the proposed operational approaches and strategies for attaining these objectives. Please note that future legislative initiatives anticipate a mandate for some Oregonians to pay RUC. The concepts contained within this CONOPS are based on a mandatory program rather than a voluntary program and should be viewed in that context. Intended Audiences (by functional area): The CONOPS provides a user-oriented view of the proposed RUC system, where a user includes anyone with an interest or a role in the development, design, implementation, and / or operation of the RUC system. Moreover, it was written such that people with a wide range of technical backgrounds may easily understand it. Accordingly, we recommend review by all potential stakeholders decision makers, policy makers, financial staff and accountants, engineers, operators, etc. even if only the 8- page Executive Summary is read. Summary: Following the Executive Summary, the 95-page report dated June 2013 comprises seven chapters as summarized below: 1.0 Scope of Document Describes the purpose of a Concept of Operations and the layout of the document, provides definitions of the various terms, and summarizes the assumptions on which the CONOPS is based. 2.0 References Lists the supporting documents used to prepare the CONOPS and other resources such as current and previous legislation and policy decisions, previous Oregon RUC reports, and other reports on mileage-based user fees that may also be useful in understanding the operations of the RUC system as currently envisioned. 3.0 Background Provides a brief discussion of the highway funding process in Oregon and the need for a mileage-based road usage charge on highly-efficient vehicles; the creation and subsequent activities of the Road User Fee Task Force (RUFTF); the results and lessons learned from the initial pilot test in 2006 and the RUC pilot in ; and the then-current proposed legislation authorizing the implementation of a RUC system in Oregon. 4.0 System Needs and Operational Considerations Summarizes the system needs and associated policy directives as identified by the RUFTF, during stakeholder workshops, and in the 2013 draft legislation. These form the basis for the RUC system vision, goals, and objectives as described in this chapter. 5.0 User-Oriented Operational Description Identifies the RUC system stakeholders; describes the various RUC system functions and processes (e.g., acquire / register vehicle, make choices regarding mileage reporting approach and account management, driving and invoicing, disposal of vehicle, compliance, certification), and the interactions among these functions and stakeholders; and provides summary descriptions of the proposed approaches for measuring WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

16 and reporting the number of vehicle miles traveled on the highway system. How RUC operations may change over time is also addressed. 6.0 Operational and Support Environment Describes the operational and support environment of the RUC system, including the system architecture concepts, likely technologies for measuring and reporting the mileage, invoicing and related account management functions, accounting procedures, the role of the private sector in providing these functions (including certification and other value-added services), system compliance, auditing, privacy considerations, and potential performance measures. The governance and administration of the system are also described. 7.0 Operational Scenarios Discusses representative scenarios for the RUC concept and describes how the system will be used and operated. Each scenario is briefly described, including assumptions, stakeholders and their interactions and information flows, how the scenario may change over time, and potential issues that still need to be addressed. Scenarios include identifying vehicles that are subject to a mandated RUC, acquiring and registering a vehicle in Oregon, driving and mileage collection (in state, out of state, on private property, credits for fuel tax paid), invoicing and payment, disposal of vehicle (sold, moving out of state), compliance activities, and failure conditions. Key Questions for Reviewers: Given the date of the CONOPS (June 2013), does it still accurately reflect the current operational concepts and scenarios for the RUC system; and if not, which concepts, scenarios, stakeholders, etc., are missing or need to be updated? Does the CONOPS provide sufficient information such that another state could understand ODOT s overall RUC concept, including the need, goals, objectives, and approaches for a RUC system? Are there any operational concepts as described in the CONOPS that do not address potential operational concerns and issues in your state? Can the structure and content of the CONOPS document serve as a useful template for other states in developing a Concept of Operations for their RUC systems and / or for a multi-state RUC? WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

17 ODOT Road Usage Charge System Requirement Specifications (SRS) Description: The System Requirement Specifications (SRS) is a document that contains the overall requirements for the Road Usage Charge System and specific subsystem requirements for the ODOT system. The ODOT Road Usage Charge System is defined to be an open system for the reporting of vehicle miles driven and the assessment and payment of road usage charges, allowing participation by any implementer that meets the open system interface specification defined in the Interface Control Document. Accordingly, the SRS describes functional requirements for the system and states precisely what the system components must do, but does not constrain how it is to be implemented. Intended Audiences (by functional area): We recommend review by: technical/it personnel; or anyone who wants a more detailed understanding of the system s technical behavior than is provided by the ConOps. Summary: The System Requirement Specifications is a systems engineering document that describes the system and states precisely what the system components must do, but never how the components must achieve these goals. The SRS is the next step in System Engineering process after the ConOps are developed. It is more detailed than ConOps, in that it states precisely what must be done (outcomes and behaviors). However, the SRS does not state how the required functionality is to be implemented. The Oregon Vehicle Road Usage Charge system includes a Mileage Collection Subsystem, a RUC Processing Subsystem, and a Road Usage Charge Accounting Subsystem, as shown in the diagram below. Each of the three subsystems is described in the SRS. After presenting a system overview, the SRS document presents the full system requirements, followed by the requirements for each of the subsystems. The overall requirements for the Road Usage Charge System, includes requirements for system security, disaster recovery, data retention, and system performance. Specific subsystem requirements for the Mileage Collection subsystem, the RUC Processing (RUCP) subsystem, and the Road Usage Charge Accounting Subsystem (RUCAS) are included, organized by functional components of each subsystem. For each subsystem component, the SRS presents a series of requirements, presented in groups of related requirements called functions. For example the first requirement is presented in this way: WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

18 Subsystem: Mileage Collection Component: Mileage Reporting Device Function 1: Record accumulated Mileage Traveled by day MRD.RMT.1 The On-board Unit shall interface with the vehicle in which it is installed to monitor and collect miles traveled by the vehicle. The functionality of each of the system components included in the Road Usage Charge System are summarized as follows: Mileage Reporting Device component provides the physical hardware and processing functions of the in-vehicle device that records and reports mileage data. Data Collection component provides the data processing functions on the mileage data that must be completed before the data is transmitted to account management. Note that Data Collection functionality may be housed with the Mileage Reporting Device, or may be located in a cloud-accessible server. Transactions Processing component provides the functions related to the reception of the transmitted mileage data and processing of the data for use by the account management system. RUC Payer Account Management component provides the functions of account maintenance, billing, invoicing, and related processes, as well as transmission of data to RUC Accounting. RUC Accounting component provides ODOT s accounting functions based on the data received from the Account Management System. Key Questions for Reviewers: Is the MRD-based RUC collection method described here sufficient for your state, or will your state need other, perhaps manual collection methods? Is the system architecture, which supports an open system, with both public and private account managers to be treated equally, appropriate for your state? Are the requirements related to MRD data transmission frequency appropriate for your state? Are there any other requirements or standards that are problematic for your state? WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

19 Oregon Road Usage Charge Interface Control Document (ICD) Description: The Interface Control Document (ICD) is a document that supports an open system implementation for the Oregon Road Usage Charge System by defining a standard interface for communications of road usage and accounting data between the subsystems defined for the system. The ICD specifies precisely how communications within the RUC system takes place. It includes the specification of three interfaces: the Mileage Message, which is the primary means by which data from vehicles are transmitted to account managers (private or ODOT); the Revenue Reporting interface for submitting formal tax reports to ODOT, and the RUC Processing to RUC Accounting interface between private account managers and ODOT s RUC Accounting for reporting monthly summary reports. Intended Audiences (by functional area): We recommend review by: vendors; technical/it personnel; anyone interested in understanding how data are transmitted within the Road Usage charging system. Summary: The ICD is a systems engineering document that specifies precisely how communications within the RUC system takes place. The ICD begins with an overview of the system interfaces and the project context, and describes the open system objective for the RUC system. Then, the ICD presents the details of the Mileage Message, the Tax Reporting, and the RUC Processing to RUC Accounting interfaces. The first interface specified in the ICD, Mileage Message is a standardized message written in the JSON protocol that specifies mileage traveled by a given vehicle. The mileage message includes both undifferentiated mileage (mileage traveled that is not associated with any location data) and mileage that is located with a specific region or mileage rule ID (MRID). As currently written, there is one MRID for public roads in each state (e.g., one for Oregon, one for Washington, etc.) based upon the Federal Information Processing Standard (FIPS) code for each state, and one for non-chargeable miles (miles driven on private roads or off-road, regardless of state). In addition to the Mileage driven, the Mileage Message also specifies the fuel used (or estimated to have been used) in each MRID. Finally, the Mileage message records information about the health of the mileage reporting device whether it was working correctly, or whether some information might be degraded. The Mileage message is specified so that it can cover a variable length of time so it could include just one day, or a week, or a month, etc. However, mileage is recorded by day so there is an individual record of mileage traveled in each MRID for each day. The second interface specified in the ICD, Tax Reporting interface, includes the Mileage and RUC Revenue Report, which contains the sums all the miles driven by vehicles registered with the given Account Manager for each MRID, as well as the fuel tax credits earned and total revenue obtained from each MRID for the given period. The third interface specified in the ICD, the RUC Processing to RUC Accounting interface, includes several JSON messages that are regularly transmitted from the RUC Processing of each Account Manager to the RUC Accounting. The first message is the VIN Summary report, which contains individual records for each Vehicle registered with the given Account Manager of all the miles driven by that vehicle for the reporting period, listed by MRID. However, it does not contain individual daily records for each vehicle. The second message is the Errors, Events and Adjustments report, which contains all the individual error or event codes recorded by MRD s registered with the Account Manager for the given WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

20 reporting period. The third message is the Account and VIN Update report, which reports all account attribute changes and status updates regarding status in the system. Taken together, these three messages allow the RUC Accounting to audit and verify the amount of roadway usage completed by drivers from each Account Manager, as well as the amount paid by the account manager to the state treasury. Key Questions for Reviewers: Is an Internet transmitted, JSON-coded message the appropriate message encoding for my state? Is the electronic security provided by the ICD JavaScript Object Signing and Encryption (JOSE) with 256-bit AES sufficient for my state? Is the privacy protection supported by the ICD transmission of aggregate miles by MRID for location-based MRDs or transmission of all miles for non-location-based MRDs appropriate for my state? Are there any fields that need to be added to the Mileage message? Is there any information that should be added to the 3-message transmission from the Account Managers to the State Accounting authority? WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

21 Oregon Road Usage Charge Program Commercial Account Manager (CAM) Procurement Documents Description: The Commercial Account Manager (CAM) Procurement Documents are the contractual documents used for procuring RUC equipment and services for the Oregon Road Usage Charge Program (RUCP). These documents provide the terms and conditions, the scope, expected schedule, and other criteria used to establish contractual agreements between agencies and RUC vendors. For the purposes of this review, the CAM Procurement Documents consist of a Master Price Agreement, a Work Order Contract, and a Service Level Agreement (SLA). Intended Audiences (by functional area): We recommend review by: vendors; key decision makers, procurement officials, and state contracting and legal representatives. Summary: The CAM Procurement Documents, consisting of a Master Price Agreement, Work Order Contracts, a Service Level Agreement (SLA), and a series of specific requirements (provided in the SRS, BRD, and the ICD) provide the terms and conditions, scope, expected schedule, and other criteria used to establish contractual agreements between agencies and RUC vendors. The RUC market for hardware and services was envisioned as having two distinct categories: the Government/Oregon Account Manager (OAM) and the Commercial Account Managers (CAMs). There are unique sets of procurement documents for the OAM vendor and the CAM vendors. While there are many similarities in the procurement documents, there are some unique differentiators between the OAM and the CAM: The OAM vendor may only offer a basic (i.e., no location capability such as GPS) mileage reporting device, where the CAM vendors may offer any technology offerings that meet the certification standards. The OAM vendors account management website must be branded for the State of Oregon while the CAM vendors may use their company branding and logos. The OAM may not solicit and recruit RUC Payers while the CAM vendors may conduct their own solicitation and marketing to RUC Payers or may bring their existing clients to the market (in coordination with ODOT). The OAM vendor may not collect and resell motorist driving data, while the CAM vendors may collect and resell this data with expressed motorist approval. The CAM vendors may also retain this data for longer than the legislatively mandated 30-day period (with motorist consent). The OAM vendor must collect and remit RUC payments at prescribed intervals. The CAM vendors can collect RUC at any frequency they choose; however, they must pay the collected RUC to the agency quarterly. The OAM is a single vendor who acts solely on behalf of the State of Oregon and provides limited account management services and offerings for RUC payers who do not wish or cannot contract with a commercial entity. Multiple CAM vendors are envisioned for the RUC. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,

22 The CAMs are considered the foundation of the RUC market and are allowed to offer a myriad of mileage reporting and account management options to RUC payers; often coupling the collection and processing of RUC with other value added services, such as Pay As You Drive (PAYD) insurance, Infotainment, trip planning, and motorist concierge services. The CAM vendors may collect and resell RUC payer driving data with expressed approval from the motorist. CAM Master Price Agreement The CAM Master Price Agreement provides the contractual terms and conditions used to contract with the CAM vendors. This price agreement is a master contractual agreement with a RUC vendor which allows agencies to procure specific tasks and deliverables (established through Work Order Contracts). The specific scopes of services, tasks, and schedules are defined in the Work Order Contract (WOC). There are general task categories defined in the price agreement which are used to shape the general scope of the contract: Certification and Testing of System Components: Complete formal certification and testing using a prescribed set of requirements. Operational Trial Support: Support Agency led operational trials prior to system deployment Ongoing Operations: Provide ongoing account management operations, hardware provisioning, and customer support services for RUC Payers. Additional RUC related activities: Provide additional RUC related activities including (but not limited to): research and development, future systems, pilot testing, support for other states, and other activities which the Agency deems relevant to supporting future RUC initiatives including those stemming from legislative directive and the involvement of other states The terms and conditions defined in the Price Agreement were established and negotiated with vendors at a market level. Simply put, this means that the terms and conditions defined in the price agreement are the same for every vendor. While there are individual price agreements established for each vendor, the terms and conditions defined in the price agreement are the same for all vendors. One item of note, is that the Price Agreement also identifies the capability for the RUC contracts to be used be other states and provinces that are considering deploying RUC programs. Under this condition, other states may establish specific WOCs with vendors to procure RUC hardware and services using the conditions established in the overarching Price Agreement. CAM Work Order Contract The WOC is used to define unique tasks, timeframes, quantities, deliverables, and payment terms with CAM vendors. WOCs are established with each CAM vendor who has an established master price agreement with the agency. To date, one WOC has been established for each vendor for preparing and deploying the Oregon RUCP. This first WOC defined four distinct tasks which CAM vendors are currently undertaking: Task 1 Design and Modification: This task defines the activities for each CAM vendor to modify their existing mileage reporting and account management systems to support the RUCP. The requirements established in the Systems Requirement Specifications (SRS) and the Business Requirements Document (BRD); and the format specifications defined in the Interface Control Document (ICD) are used as the baseline requirements for CAM vendors to modify their systems and processes to support the reporting of RUC payer mileage, the collection of RUC, the processing of accounts, and the reporting of financial information to the agency. WRUCC Critical Examination of Oregon RUCP Final Report - March 22,