Transitioning from Title 21 Protocol to the 6C Electronic Toll Collection Protocol: A Standardized Regulatory Impact Assessment
In California, regulatory changes in 2016 supported a transition from the Title 21 (T21) hard-cased electronic toll collection (ETC) protocol commonly used across the United States, to a newer and cheaper transponder sticker technology identified in ISO Standard 18000-63, also known as the 6C protocol.
Although toll agencies were initially expected to incur additional costs to purchase 6C transponders and related equipment, retrofit ETC systems, and dispose of old equipment, these costs were found to be minimal when compared to the overall savings and benefits of using the new system, and realized savings from the transition were anticipated within one year.
In California, toll agencies that transitioned to the 6C protocol within the first year the regulation was implemented (2016) were estimated to save $10.00 to $14.00 per unit. Consumers using the toll facilities were not expected to be impacted by the new protocol because neither costs nor savings would be passed onto individuals or households (toll payers or subscribers of the toll facilities).
After Caltrans' Economic Analysis Branch gathered, analyzed, and estimated the direct costs and savings to toll agencies, the California Department of Finance (DOF) determined that the proposed change resulted in over $50 million worth of impacts during a 12-month period during implementation. It also determined that additional economic analysis was required to assess impacts during an implementation timeframe from 2019 through 2023 and one year after.
The baseline scenario for the economic analysis is highlighted below:
Direct Cost Estimation Inputs (2015$) – Proposed 6C Regulation
6C Proposed Regulation
|Period||No. of Units Per Year (Millions)||Unit Price||Period||No. of Units Per Year (Million)||Unit Price|
|Equipment Purchases||System Retrofit||2017-18||Statewide Upgrades||$2.4 million||-||-||-|
|Transponder Purchases (Switchable)||2019-24||0.490 - 1.7||$10.00||2019-24||0.440 - 0.730||$20.00|
|Transponder Purchases (Non-switchable)||2018-24||0.960 - 3.3||$1.20||2019-24||0.850 - 1.4||$15.00|
|O&M Costs||Transponder Disposal||2018-24||0 - 3.5||$0.28||2019-24||0.52||$0.28|
|Transponder Shipping||2018-24||1.5 - 4.9||T21: $3.00
6C switchable: $3.00
6C non- switchable: $1.00
|2019-24||1.3 - 2.2||$3.00|