Rhode Island's Truck Tolling System Revived
Rhode Island’s truck tolling system, which has been dormant since a lower court ruling in 2022, has found a new lease of life following a Court of Appeals decision this past Friday.
The First Circuit Court of Appeals' decision is a setback for the American Trucking Associations (ATA), who have been at the forefront of the legal battle against the tolling plan known as RhodeWorks. However, it's not a complete victory for the state, as some provisions of the law remain blocked.
Key Findings
The Court affirmed that applying tolls on bridges exclusively to tractor-trailers does not infringe upon the dormant Commerce Clause. Originally, tolls were intended for class 6, 7, and 8 vehicles, but were revised to apply solely to class 8 vehicles.
However, the court found that capping tolls — in cases where a truck is only charged a limited number of tolls in a day — violated the dormant Commerce Clause. But, this ruling doesn't invalidate the law entirely as the capping provision can be "severed" from it.
Impact and Implications
The toll, applied only to local bridges, impacted 13 bridges within the state without affecting interstate bridges. The ATA and other companies initiated legal proceedings in 2018, challenging the toll system.
The First Circuit’s decision arrives 14 months after oral arguments. This decision implies that Rhode Island's law can resume without the capping provision, keeping its primary structure intact.
Dormant Commerce Clause Analysis
The Court of Appeals noted that for a toll system to comply with the dormant Commerce Clause, it must be based on a fair approximation of the tolled facility’s use, not be excessive relative to benefits conferred, and must not discriminate against interstate commerce.
Our analysis resolved two questions:
- Does RhodeWorks discriminate against interstate commerce?
- Is the burden imposed by the tolls fairly approximating the use of Rhode Island bridges?
A Balanced Approach
The conclusion drawn was succinct. The ATA failed to provide evidence that using tolls on class 8 vehicles only is discriminatory or that other trucks compete similarly within the same market sphere.
The RhodeWorks tolling caps, which are somewhat protective of local companies, were found discriminatory as local trucks disproportionately benefited when compared to out-of-state vehicles.
Next Steps
Although the cap provisions were deemed unconstitutional, this didn’t unravel the law. The Court ruled that RhodeWorks can still stand and be implemented to raise necessary funds for bridge maintenance without the caps.
Closing Remarks
Rhode Island Attorney General Peter Neronha expressed satisfaction, stating confidence in the eventuality of this outcome.
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The journey of the Rhode Island truck tolling system continues, preparing to adapt and overcome legal hurdles while maintaining its core objectives.