E-ZPass chief says "far too early" to declare 6C leading candidate for national interoperability + COMMENT (+PJ Clarification)

September 12, 2012

2012-09-11: PJ Wilkins executive director of the E-ZPass Group (aka IAG) contacted us to express disagreement with our report yesterday on OmniAir's certification of the ISO 18000 6C reader tag combination in which we commented that it was the leading RFID candidate to meet the US Government mandated deadline for electronic toll collection interoperability by 2016.

He says it is "far too early to reach the conclusion" that 6C is the leading candidate.

He has three arguments:

1. We don't yet have details of the requirements of an interoperable system. A survey is being done, he says, but since it has been completed and no one can say what the requirements will be "we certainly can't yet state that the (6C) technology meets the requirements."

2. Second there has been "very limited operational performance testing under adverse conditions" of the 6C system. That testing he says still needs to be done.

3. Finally he argues that since "the technology is in very limited operational use at present," he doesn't see how it can become "the de facto standard."

His conclusion: "We have a lot more work to do before we clearly understand the best options for achieving our goal of interoperability within 4 years!"

Wilkins was responding to a report we ran yesterday on the certification announcement by OmniAir Certification Services of the first set of 6C tags and readers (from 3M/Sirit) as meeting the standards of the 6C Users Group. We said 6C was "the leading candidate for providing transponder-based interoperability."

E-ZPass the elephant

The E-ZPass Group's position on interoperability is of huge importance because of its sheer size in the US toll industry - doing as much toll revenue by transponder as the next three electronic toll blocs combined - Florida's SunPass, Texas TxTag and California's FasTrak.

The E-ZPass Group's support is needed for any interoperability to occur. That makes their collective view as expressed by Mr Wilkins important in its own right.

His view deserves respect also because of his personal background as director of toll operations at the Delaware Turnpike where he was an east coast pioneer of open road tolling on the DE-1 tollroad and more recently on the busy I-95 plaza. And he dealt with tolling's intricacies and issues day by day for some years.

The E-ZPass Group has a webpage titled "Interoperability" in which it provides links to its own interoperability arrangements including:

- operating and reciprocity agreements

- file specifications

-policies, requests for proposals

- test plans

- presentations

The E-ZPass Group's position seems to be that the route to interoperability is for others to join it as Affiliate Members.

A presentation on their new interoperability webpage says:

"The E-ZPass model works, and has been successfully interoperable for 17 years (.)

"Membership opportunities exist that allow for rapid expansion of the interoperable system.
Highly accurate equipment and proven processes in place already that work well.  (There is) (n)o need to reinvent the wheel.

"E-ZPass is not the only path to interoperability, but is the only proven system that meets the needs of the various operators, with proven success of interoperability on a large scale across state boundaries, that can be implemented within the time constraint mandated by congress."

The "new membership opportunities" refers to a "National Affiliate Program" announced in February 2012 which for the first time opens E-ZPass Group membership to toll operators using "different equipment... compatible (with E-ZPass) and meeting E-ZPass accuracy rates (and) utiliz(ing) E-ZPass IAG file specifications and business rules."

OUR COMMENT: In other words the E-ZPass Group expects everyone else - the big electronic toll blocs in Texas, Florida and California and operations in Washington state, Colorado, Oklahoma, North Carolina, Utah, Kansas, Louisiana etc - to adopt E-ZPass IAG protocols for their readers and tags and transition out their existing equipment replacing it with, if not equipment from Kapsch itself, with equipment which works precisely to the Mark IV/Kapsch specifications.

(ADDED NOTE: we think our comment here is a fair representation of the E-ZPass Group position as stated on their webpage devoted to interoperability, but PJ Wilkins says we have read far too much into it. We've added his FOLLOWUP CLARIFICATION at the end of this piece, so please take that into consideration in reading this comment - editor 2012-09-12 11:00)

This puts virtually all the burden of moving to national interoperability on non-E-ZPass toll operators - FL, TX, CA, OK, NC, GA, LA, KS, CO, WA - while E-ZPass operators don't have to make any reader-tag changes at all.

The others have to swap out all of their existing single protocol readers for multiprotocol readers or for Kapsch protocol readers, and adapt to a new RFID system.

Most onerous of all it expects them to transition to transponders that cost four or five times the unit cost of 6C tags and twice the cost of 6B tags in use in Texas and Florida, and which require a windshield box for a finite-life battery to boot.

Technologically it would be a step backwards for Florida and Texas to go to a battery box for every transponder. In a few years time it would add end-of-battery-life to customer service issues.

And it would be way more expensive to implement than 6C tags which are so economical they can be given away free to motorists who want interoperability. To handle 6C, single protocol readers all over the country would have to be swapped out for multiprotocol readers. But readers are being upgraded and swapped out all the time, and that can be accommodated in four years.

And it would spread the burden of the move to interoperability more evenly across the country and across toll operators.

There are other angles to this of course too. OmniAir testing and certification is supposed to have established that 6C works to standard in a varied roadside environment. That's what OmniAir testing and certification is all about.

Maybe more testing is needed, but it is not clear what OmniAir hasn't tested sufficiently about 6C to meet Wilkins' standards. Perhaps he should spell that out. Where exactly did OmniAir fall short in their testing?

The capabilities of 6C are well known. It is an open standard. Its memory size and wake-up and transmission speeds are specified. It is read-write, so it can carry point of entry data to the point of exit to compute a trip, just like the E-ZPass box.

Exactly what requirements does 6C not cater to?

Critics of the new technology shouldn't hold back.

6C has been in use for several years now in Denver on E-470 and in Detroit, Ambassador Bridge and more recently in Washington state, Georgia and Utah to positive reviews.

Colorado, Michigan, Georgia, Utah and Washington state present a wide range of climatic environments where 6C is in use, successfully and doing everything that an E-ZPass system usually does, but at a fraction of the cost, and without the box and without the battery.

For that matter the older standard 6B sticker tags in use now for many years in Texas and Florida, being sticker tags too and manufactured by the same etching processes and using the same packaging film provide a huge reservoir of experience that is pertinent to the performance of 6C.

If the E-ZPass Group had a more lithe procurement procedure than their recent five years' long process they would have been doing their own testing of 6C and had the more advanced sticker tag technology as an option themselves.

Because they are so slow compared to Texas and Florida they now want to drag everyone else back to the expensive older gear their ponderous decisionmaking processes have stuck them with.

That's how we see it anyway.

We welcome other opinions on the subject.

Just email us: editor@tollroadsnews.com

E-ZPass Group's own interoperability specs:


our report of OmniAir certification:


TOLLROADSnews 2012-09-11 midnight

FOLLOWUP CLARIFICATION: PJ Wilkins is out of the country but sends this clarification:

"We, the IAG do not take the position that everyone needs to join us, nor do we expect that our members won't have to make some changes as we attain interoperability nationwide.  

"We fully expect we may need to swap out for multi protocol readers in order to achieve the end goal.  We do however recognize that any interoperable system must meet the needs of all toll operators, and must take into consideration the 23 million toll devices in use by our customers.

"We are presently working with our vendor to better understand the capabilities, and limitations of, these new generation multi protocol systems.  It is important that we continue to utilize technology that is highly accurate and minimizes risk to revenue.  Even a one tenth reduction in accuracy rates has a significant impact on a system that collects almost $6 billion in revenue each year.  

"We look forward to continuing to work with our industry partners in advancing interoperability and are confident we will meet the challenge."

COMMENT-2: Apparently we read too much into the slides from the presentation called "The E-ZPass Group and Interoperability" 2012-07-16 reproduced here.

And statements like this:

"E-ZPass is not the only path to interoperability, but is the only proven system that meets the needs of the various operators, with proven success of interoperability on a large scale across state boundaries, that can be implemented within the time constraint mandated by congress."

Maybe the E-ZPass Group website presentation needs to be revised to reflect the much greater flexibility of the position stated in the clarification we print above? - editor

TOLLROADSnews 2012-09-12: 11:00


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