Written evidence from Cobalt Telephone
Technologies
THE SEVERN CROSSING TOLL—ACCEPTANCE
OF PAYMENT CARDS
EXECUTIVE SUMMARY
This submission assumes tolls will remain in
place for the Severn Crossing for the foreseeable future but their
collection needs to be more efficient. It proposes:
— Coin-only is insufficient. Proven processes
already exist in the UK to allow tolls to be paid by credit and
debit cards whilst retaining a free flow of traffic.
— The various benefits of such an approach
are sufficiently strong that a deployment of such a process could
potentially be structured to avoid any capital outlay or loss
of core toll income.
— If clear intent is there, implementation
is achievable during 2011.
INTRODUCTORY CREDENTIALS
1. I write as founder and Commercial Director
of Cobalt Telephone Technologies. The company is the leading supplier
of web and phone payment solutions to the UK parking industry.
From its two UK data centres it centrally hosts payment collection
processes for TfL, DRDNI and over 100 local authority customers
and holds the highest global accreditation for payment card security
(PCI-DSS Level 1). Cobalt is mainly known in the consumer parking
market for its RingGo brand of phone parking.
MY UNDERSTANDING
OF THE
BUSINESS CONTEXT
2. The two bridges that comprise the Severn
crossing take payments from 13 million Westbound vehicles each
year. This income stream totals more than £90 million with
the toll having three pricing tiers £5.50, £10.90 and
£16.40 depending on vehicle size. Counting and banking such
large amounts of cash and bullion is a process of itself.
3. Currently credit and debit cards are
not accepted as a means of payment (although a TAG system exists
aimed at regular users). It goes without saying that the failure
to take casual card payments has created a growing problem for
many motorists who arrive at the crossing assuming that a solution
other than cash must be in place.
4. This tide of unpreparedness creates a
delay, & triggers a safety issue as vehicles have to be removed
from the main flow or, worse still, take pre-emptive avoiding
action. These "NPTs" (cases of non-payment of tolls)
are subject to a manual roadside business-process by which they
are allowed to continue, providing they undertake to pay the toll
within a period of 14 days and pay an additional administration
charge of £5. Should payment not be received the NPT case
undergoes a progression of stages in which the cost and seriousness
increases.
5. The existing toll booths are all fitted
with cameras that take three pictures of the vehicles passing
through the lanes. The cameras are analogue not digital as would
be preferred and whilst nominally able to be used for Automated
Number Plate Recognition (ANPR) purposes are not connected to
suitable hardware. Each existing kiosk, when it takes cash payment,
produces a standard till receipt which is thermally printed and
passed to the motorist.
A BETTER WAY—THE
ANALOGY WITH
RINGGO
6. RingGo is the UK's leading brand of phone
parking with over 70% market share and two million registered
customers. Cobalt Telephone Technologies, which developed and
exclusively deploys the service, hosts all the data that is collected
onshore and answers all the phone calls from motorists in Hampshire
or Berkshire call centres.
7. RingGo is deployed as an adjunct to conventional
coin-only parking machines. It is offered by local authorities
that wish to provide the convenience of card payments, whilst
avoiding the cost of upgrading their existing street hardware.
This is done by placing signs explaining the service next to,
or on top of, conventional machines.
8. On the occasion of first time use motorists
give their payment card details which are encrypted and stored.
There is no subsequent need to give the full card details again.
9. RingGo is widely deployed nationally
but particularly in the West of England. By the nature of the
service, RingGo has to offer its customers an extremely high level
of uptime. The RingGo service has not had an outage in the last
four years which is testament to the resilience of the twin data
centre architecture that underpins it.
10. RingGo is advanced and allows different
parking tariff rates to be applied to different vehicles based
on their characteristics notably including the vehicle's CO2 emissions.
A 4x4 vehicle can therefore be charged more per hour for parking
in the same bay as would a small-engined city car. This feature
has been deployed by the Borough of Richmond to support its emission-reduction
initiatives, demonstrating that such a system can charge vehicle-specific
tariffs based on number plate information alone.
11. Average transaction values for RingGo
are in the order of £4.20. RingGo can be experienced at most
railway station car parks across the UK.
ANALYSIS
12. The secret to successfully taking credit
and debit card payments for the Severn Crossing is not to impede
the flow of traffic. Any concept that involves actually plugging-in
physical cards and entering PINs is operationally weak. The long
heralded "wave and pay" or "tap and go" card
technologies are now thought unlikely to become ubiquitous and
so can similarly be discounted as a solution path.
13. What is required is a "light touch"
membership system where the motorist's vehicle registration number
is already associated with both their credit card details and
their mobile telephone number. RingGo is the UK's leading example
of such a service.
HOW SUCH
A PAYMENT
SERVICE MIGHT
BE ACHIEVED
IN PRACTICE
14. It would be necessary to create the
option of a "drive through" lane or lanes which are
monitored by digital infra-red ANPR cameras. All cars passing
through the gate-line would be photographed and their registration
plate (VRM) checked to determine the relevant fee. This would
be de-duplicated each night (one day in arrears) in a batch process,
making a comparison against pre-payments and post payments. Vehicles
that had not paid would become subject to a progressive enforcement
process modelled on that used for moving traffic offences under
TMA 2004.
COMPLEMENTARY LEGISLATIVE
ACTIONS REQUIRED
15. It would be necessary to revise the
Severn Bridge Act 1992 to allow payment for crossing Westbound
as follows:
— in advance by electronic payment method,
or at the conventional tolls by cash for the standard price; or
— in arrears (up to midnight on the day
after undertaking the crossing) at the standard price plus a "post-payment
premium"; and also
— put in provisions to allow the issuing
of a penalty charge notice at a suitable existing TMA 2004 charge
notice rate, and then apply the same progressive steps, and the
same appeals procedure conducted by the Traffic Penalty tribunal
(an existing organisation). Marilyn Waldron at DfT, who was central
to the drafting of TMA 2004, can advise on the detail.
TRAFFIC ENGINEERING
ISSUES
16. The creation of drive-through lanes
alongside tolls (both at Rogiet and Aust) would require highways
planning expertise and execution. As with all motorway junctions
requiring cognitive decision-making, generous run-on and run-off
areas, together with clear signage and road markings, would be
vital for safety reasons.
17. Digital ANPR camera technology is sufficiently
advanced to allow near faultless monitoring of such high volume
flows regardless of almost all weather conditions. Such cameras
will require DfT approval and suitable regulations already exist
in the form of the document Civil Traffic Enforcement Certification
of Approved Devices of 28 February 2008.
COMMUNICATION ISSUES
18. Crucial to the success of this approach
is the way that the new process is communicated. The key point
to stress is that charges have not risen for those who pay cash
or pay electronically in advance. The post-payment fee only applies
for those who choose to pay in arrears (and for simplicity this
is in line with the recently revised—more generous—London
Congestion charge policy). The PCN process is simply a necessary
backstop.
SAFETY ISSUES
19. It is paramount that the new process
does not, in any way, encourage drivers to use their mobile phone
or other device to make a payment whilst driving. For this reason
it is proposed that the period in which post-payments are accepted
(up until midnight on the day following the crossing) be deliberately
generous.
EXCEPTIONS
20. Military vehicles and other exemptions
would continue to report to the toll booths.
COMMERCIAL ISSUES
21. Given the two distinct work streams
the project should be awarded in two lots:
— Lot 1: the highway modifications including
removal of existing booths to allow free flow lanes, the installation
of signage and suitable over-gantries, verticals and ductwork
to support the installation of cameras.
— Lot 2: the provision of the ANPR cameras,
hosted technologies and the entire business process to register
motorists, take pre-payments, post-payments and issue enforcement
notices. This lot should be written in terms of outcomes and service
levels rather than being prescriptive about the means and methodologies.
I cannot comment on the first of these but I
am of the view that Lot 2 could be supplied on a zero capital
cost, self-funding basis—that is the contractor should,
with a reasonable contract length of say 5+3 years, be able to
return the full toll price to the Severn Bridge yet still set-up
and run the service, including the enforcement process and inevitable
evasion, on the basis of retaining the post payment premiums and
enforcement revenue alone. Clearly other financial models could
be created.
The speed at which such a process could be implemented,
as ever, will be reliant on bureaucratic process elements such
as procurement and legislative change, not the practicalities
of implementation. Were these constraints not in place this project
could be reasonably achieved in six to eight months from conception
to launch.
BENEFITS
— £90 million per annum in coins represents
not far short of a thousand tonnes of bullion. Reducing the collection,
handling, counting, transport and banking of these coins would
lead to significant savings;
— counterfeit pound coins, which the Royal
Mint estimates comprise 3% of the national stock, cannot be exchanged
or passed-on and are worthless. The crossing company must be subject
to considerable losses in this regard;
— the existing workaround process for non-payment
of tolls could be eliminated;
— useful economies of manning could be
made; and
— millions of motorists would be spared
the obligation of using an archaic process.
SUMMARY
22. Coins are a pre-Christian technology.
We live in a digital age. It is arguably a mild national embarrassment
that the prime gateway to Wales is operated as it is. The solution
is to implement a service in which the credit card, the mobile
phone and the vehicle registration are linked in an easily established
account so that free-flow transit can be made. Analogous and successful
services are already established, secure, familiar to the UK motorist
and operate at the scale and intensity required.
September 2010
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