Improving equity in transportation fees, fines, and fares

Improving equity in

transportation fees,

fines, and fares

Findings and recommendations

for northeastern Illinois

April 2021

Contents

Overview .................................................................................................................................................... 2

Why fees, fines, and fares? .................................................................................................................... 10

Equity and mobility challenges in northeastern Illinois ................................................................ 12

Transportation funding challenges ..................................................................................................... 22

Roadways .................................................................................................................................................. 22

Transit ........................................................................................................................................................ 23

Distribution of the cost of public services and infrastructure ....................................................... 25

Equity of Illinois’ tax system .................................................................................................................. 25

Equity of transportation fees, fines, and fares ..................................................................................... 26

Consequences and outcomes of the impacts of fees, fines, and fares ............................................... 49

Existing fee and fare programs .............................................................................................................. 53

Recommendations ................................................................................................................................... 55

Improve mobility options ....................................................................................................................... 56

Implement progressive tax strategies ................................................................................................... 57

Make transportation fees for households with low income more affordable ................................. 59

Ensure households with low income can access tools that provide lower costs ............................ 62

Pilot initiatives that coordinate fee and fare collection ....................................................................... 63

Make paying for parking more feasible for both residents and delivery drivers ........................... 65

Implement traffic and parking violation fine reform.......................................................................... 66

Next steps.................................................................................................................................................. 71

Methodology ............................................................................................................................................ 73

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Overview

Metropolitan Chicago’s transportation system is a literal route to opportunity for the region’s

residents, connecting them to jobs, education, and services. Unfortunately, these opportunities

are not evenly shared in northeastern Illinois. Persistent transportation inequities exist, many

disproportionately impacting mobility options in communities of color and people with

disabilities. These inequities range from the costs of fees and fines to access to efficient

commutes and the high cost of driving. Beyond individual benefits, improving mobility for

residents currently challenged by transportation inequities will help to promote inclusive

growth. This will require significant investments across modes to increase affordability for

residents with low income and connectivity in communities with limited transit, bicycle, and

pedestrian connections.

To begin addressing these issues, the Chicago Metropolitan Agency for Planning (CMAP)

analyzed how residents pay for the transportation system and how the structure of

transportation fees, fines, and fares fits with the financial realities of many households with low

income. While they are just one piece of a household’s transportation costs and overall tax

burden, residents with low income would benefit from reforms that make transportation fees,

fines, and fares more affordable and the overall tax system less regressive. Northeastern Illinois

residents already have several ways they can lower the fees and fares they pay, such as by using

I-PASS accounts and Ventra cards. However, many residents are unable to access these tools,

particularly those without bank accounts.

Residents of northeastern Illinois must also navigate a multitude of public agencies to pay their

transportation fees, fines, and fares. Residents who fail to pay these costs incur late fees and

fines. Fines have a disproportionately high financial burden for households with low income

that can lead to late fees, high debt levels, and other negative impacts. Moreover, data on traffic

safety enforcement indicate that Black residents are more likely to receive citations, leading to

expensive fines.

However, decades of underfunding the transportation system — particularly the public transit

system — have impeded the region’s ability to achieve its mobility equity goals. To ensure the

system is maintained while providing necessary enhancements and expansions, ON TO 2050

recommends securing growing and stable revenue sources to fully fund the transportation

system. To achieve this, new and increased transportation user fees must be implemented so

that travelers pay according to the benefits they receive from system investments.

ON TO 2050 also recommends that new user fees be implemented carefully to avoid undue

burdens on residents with low income. Affordable and accessible mobility options play a key

role in creating pathways to opportunity for people of color and people with disabilities, who

disproportionately live in poverty.

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Residents with disabilities or who are Black or Latinx disproportionately live in poverty

For households with low income, it can be challenging to meet basic household expenses,

including transportation costs. The cost of vehicle ownership in particular is high, yet many

households with low income and residents of color lack access to transit options that connect

them to jobs within a reasonable travel time. Consumer expenditure data show that those with

low income spend 16 percent of their income on transportation costs, on average, while those

with high income spend just 6 percent.

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Transportation costs are a larger percentage of income for residents with low income

Project development

To work toward the goal of aligning transportation revenue and equity objectives, CMAP

conducted its first comprehensive analysis on impacts of transportation fees, fines, and fares to

residents and households with low income. CMAP used quantitative data and qualitative

research to understand the challenges of balancing inclusive growth with the need for

transportation revenue.

This project sought to:

• Assess the impacts of fees, fines, and fares on residents in the region with low income

• Evaluate strategies to reduce the financial burden

• Understand the tradeoffs between affordability strategies and other goals and

objectives, including ensuring the transportation system generates sufficient revenue,

including from its users

• Recommend policy changes to reduce inequitable financial impacts experienced by

residents with low income

This report was developed with significant contributions from transportation agencies,

researchers, and advocates. In addition to interviewing many experts on these topics, CMAP

convened a group of partners and stakeholders from across the region to provide feedback on

the analysis and identify policy changes.

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Assessing equity

Transportation user fees, fines, and transit fares are part of the tax system as a whole, where

every broad-based fee, fine, or fare imposed without regard to income level has the potential to

be regressive. When these fees, fines, and fares disproportionately impact residents with low

income, residents of color may also be disproportionately affected. The following findings

summarize CMAP’s assessment of the affordability of several transportation fees, fines, and

fares and the impacts on residents and households in northeastern Illinois with low income.

Illinois’ tax system is regressive. Illinois’ overall tax system is regressive, owing to a flat

income tax rate and comparatively low tax exemptions. The 20 percent of non-elderly residents

with the lowest incomes paid 14.4 percent of their income in taxes while the top 1 percent of

taxpayers paid 7.4 percent. States with less regressive structures integrate several features in

their income tax structure to mitigate the impacts of regressive sales and excise taxes like

transportation user fees.

The cost of driving is a burden for households with low income. Driving is the most

expensive mode of travel. This is due to the numerous costs of owning and operating a vehicle,

rather than any associated fees, such as motor fuel taxes or tolls. The larger issue is that

households with low income often lack the money to cover basic household expenses, so any

sort of transportation fee is unaffordable. Depending on where they live, households with low

income may also lack mobility options beyond driving.

Households with low income pay proportionately less in fees associated with driving. The

burden of the state motor fuel tax is borne less by households with low income since they tend

to drive fewer miles. Likewise, households with low income tend to own fewer vehicles, thus

spend less on vehicle registration fees. Tolls are also not a substantial share of transportation

expenses for people with low income.

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Households with low income have fewer vehicles and drive fewer miles than other households

Some drivers experience challenges accessing lower toll options. The tolling system currently

in place presents challenges to residents without bank accounts. Drivers with an I-PASS can pay

tolls at a lower rate, but many households with low income do not have one, particularly

unbanked drivers.

Unpaid fines can be financially devastating. Households with lower income pay a

substantially larger share of weekly wages on a fine than households with higher income.

These fines can compound to become a major source of debt for residents with low income.

When residents with low income cannot pay their fines, they may experience bankruptcy, tax

garnishment, vehicles impoundment, employment prohibition, and credit score damage.

Maintaining affordable fares is necessary so that residents may access economic

opportunities and conduct everyday activities. Residents of all income levels rely on transit.

But transit access is especially crucial for residents with low income, as they tend to own fewer

vehicles because of the high cost of driving. Households with low income take 20 percent more

transit trips than other households. When work commutes are excluded, these households take

twice as many trips — indicating that they are more likely to use transit for trips required to live

their daily lives. The cost of a fare varies by many factors, some of which can result in transit

expenses comprising a relatively high share of earnings for a household with low income.

CMAP estimates that expanding reduced fares to all residents with low income would result in

them taking 15 percent more transit trips.

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Recommendations

Improving mobility for residents with low income will require significant investments in

transit, bicycle, and pedestrian infrastructure, funding to administer programs, and revenues to

recoup losses from reducing fees or fares. CMAP and the resource group considered a variety of

strategies to determine which recommendations would best meet the goals of reducing impacts

on residents with low income, as well as other ON TO 2050 goals. Based on these considerations

and the priorities of the resource group, recommendations are as follows:

• Improve mobility options

• Implement progressive tax strategies

• Make transportation fees more affordable for households with low income

o Expand reduced fare permits

o Expand reduced vehicle registration fees

o Vary state and local vehicle registration fees based on vehicle value

o Ensure any new transportation network company fees support regional

transit goals

• Ensure households with low income can access tools that provide lower costs

o Encourage employers to participate in the Transit Benefit Fare Program

o Bolster efforts that help riders use Ventra

o Develop a lower-cost alternative to I-PASS transponders

o Waive any road usage charge equipment cost

• Pilot initiatives that coordinate fee and fare collection

o Increase availability of I-PASS accounts, including to unbanked households

o Allow local vehicle fees to be paid at the Illinois Secretary of State

o Implement full fare integration across service providers

• Make paying for parking more feasible for both residents and delivery drivers

o Designate short-term loading and standing spaces with reduced transaction

fees

o Ensure multiple payment options for drivers without credit cards

• Implement traffic and parking violation fine reform

o Integrate ability to pay through income-based fines or ability to pay waivers

o Assess appropriateness of fine and late fee amounts

o Report ticketing outcomes and impacts with an equity lens

o Offer alternatives to monetary fines

o Improve repayment plans and collection practices

o End employment prohibitions due to ticket debt

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Agenda for implementation

In recent years, the State of Illinois and the region have made notable progress on improving

equity in fees and fines. The Illinois Tollway substantially reduced fees for missed tolls in 2020

as part of an initiative to first issue invoices rather than violation notices for unpaid tolls. The

Tollway plans to also expand its I-PASS Assist program in 2021 to additional drivers with low

income as part of its plan to stop accepting cash tolls. The recently enacted Public Act 101-0652

includes provisions rescinding holds on license renewal or reinstatement due to failure to pay

traffic violation fines and suspensions due to failure to pay fines from automated speed and red

light cameras.

CMAP and other regional partners will work to implement these recommendations through

legislation, policy changes, new initiatives, and other reforms. These recommendations require

action and investments by policymakers and transportation agencies like the State of Illinois,

the Tollway, the region’s transit agencies, and local governments. Further, CMAP must

continue to conduct further analysis to pursue policies that ensure the transportation system

promotes equitable outcomes for all residents.

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Why fees, fines, and fares?

Metropolitan Chicago’s transportation system, particularly the public transit system, has

experienced decades of underfunding. To ensure the system is maintained while providing

necessary enhancements and expansions, ON TO 2050, the region’s long-range comprehensive

plan, recommends fully funding the region’s transportation system. ON TO 2050 also

recommends that new user fees be implemented carefully to avoid undue burdens on residents

with low income. The funding decisions that policymakers and transportation agencies make

greatly impact residents’ ability to access the system.

A person’s socioeconomic status, race, or ability should not result in disparate mobility options.

Yet many of the region’s residents who are low income and people of color live in communities

where transit connections from home to work are limited. When people have access to a

multimodal transportation system that connects them to their destinations, it increases

opportunities and improves quality of life. ON TO 2050 seeks to promote inclusive growth by

improving mobility options that spur economic opportunity for low-income communities,

people of color, and people with disabilities.

Within northeastern Illinois, CMAP estimates that 22 percent of households have an income less

than 60 percent of the region’s median level.

These households are disproportionately

comprised of Black and Latinx residents. Residents with disabilities also disproportionately

have low income and are less likely to drive alone for commuting to work than residents

without disabilities, presenting unique transportation challenges.

ON TO 2050 recommends that revenues be collected as direct user fees from those who benefit

from the transportation system. While this helps improve horizontal equity — treating system

users similarly in terms of the costs they pay and benefits they receive — it may not support

vertical equity. Vertical equity refers to the distribution of financial burdens based on a person’s

ability to pay. Horizontal and vertical equity goals can conflict. For example, horizontal equity

requires that a driver with low income pay the same toll as every other driver who benefits

from using a toll road, but vertical equity requires that they pay less than a driver with higher

income. Most transportation user fees have been structured with horizontal equity in mind. But

it is important to make sure that vertical equity and issues of affordability are considered so

they do not unduly impede mobility.

Scope: researching questions and topics

This report seeks to explore equity in transportation fees, fines, and fares; specifically:

• Assess the impacts of fees, fines, and fares on residents in the region with low income

• Evaluate strategies to reduce the financial burden

Chicago Metropolitan Agency for Planning analysis of Activity-Based Model results.

American Community Survey 5-year estimates, 2019.

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• Understand the tradeoffs between affordability strategies and other goals and

objectives, including horizontal equity and revenue generation

• Recommend policy changes to reduce the inequitable financial impact experienced by

residents with low income

To undertake this work, CMAP began a process to qualitatively and quantitatively assess the

impacts of several transportation fees, fines, and fares; namely:

• Fees and fines associated with motor vehicle usage:

o Motor fuel tax

o Road usage charges (ON TO

2050 recommendation)

o Motor vehicle registration fees

• Fares on fixed-route public transit

o Priced parking

o Tolling

o Traffic and parking violation fines

o Transportation network company fees

Process: convening partners and stakeholders

This report was developed with significant contributions from transportation agencies,

researchers, and advocates. In addition to interviewing many experts on these topics, CMAP

convened a group of partners and stakeholders from across the region to help provide feedback

on the project. This group met several times between November 2019 and December 2020.

During these meetings, the members discussed and provided feedback on the project’s

objectives and scope; analysis and assessment of the equity of each fee, fine, and fare; evaluation

of strategies to improve vertical equity; recommendations; and priorities for implementation.

The group also discussed gaps in the region’s work on planning-related equity issues, which

CMAP and partners will use to guide future work. The group included representatives from:

• Active Transportation Alliance

• Center for Neighborhood Technology

• City of Chicago, Department of

Transportation

• City of Chicago, Office of Equity and

Racial Justice

• Chicago Jobs Council

• Chicago Transit Authority

• Cook County

• Equiticity

• Equity Institute, YWCA of Evanston

• Heartland Alliance

• Illinois Tollway

• Little Village Environmental Justice

Organization

• Metra

• Metropolitan Planning Council

• Muse Community Design

• Pace

• Regional Transportation Authority

• Union of Concerned Scientists

• University of Chicago Inclusive Economy

Lab

• University of Illinois at Chicago

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Equity and mobility challenges in

northeastern Illinois

Access to mobility options plays a key role in creating pathways to opportunity for low-income

communities, people of color, and people with disabilities. Yet, persistent transportation

inequities exist in metropolitan Chicago. Historically, policymakers and planners have been

complicit in reinforcing inequities for residents with low income and people of color, especially

Black people. Racism and inequitable distribution of resources have shaped the built

environment through housing policy, zoning codes, transportation planning, urban renewal,

and pollution-generating facilities and roadways.

These inequities have caused mobility challenges. Many residents with low income and

residents of color have limited transportation options that would efficiently connect them to

economic and other opportunities. Transportation costs are rising, increasing the financial

burden on all residents, particularly residents with low and moderate incomes. At the same

time, residents nationwide with low income have experienced slow income growth. Between

2000 and 2018, they saw just 1.8 percent growth in median income, while upper income

households experienced 7.9 percent growth.

Black and Latinx residents are especially impacted

by this trend because they are a disproportionate part of the overall population that is low

income. This section will provide an overview of the equity context under which transportation

fees, fines, and fares operate.

Households with low income struggle to pay for basic household needs

Households with low income must use their limited financial resources to meet basic needs.

These expenses include housing, transportation, and food, as well as expenses necessary to

maintain employment like commuting costs and child care. However, national data from the

Federal Reserve indicate that 17 percent of adults were not able to pay their bills in full.

These

financial realities mean that even if transportation fees, fines, and fares are a relatively small

part of household expenses, they remain a noticeable daily expense. As a result, they may cause

some residents undue hardship, leading to less efficient mobility decisions, such as additional

driving to avoid paying for parking or tolls, or taking all transit trips in a single day.

In metropolitan Chicago, 11.8 percent of residents live below the federal poverty level, which is

$25,926 for a household with two adults and two children. Across the larger 15-county

metropolitan area, this equates to 1.1 million residents. Among residents with disabilities, 19

percent live below the federal poverty level, representing a disproportionate share of residents

in the metropolitan area.

Pew Research Center, Most Americans Say There Is Too Much Economic Inequality in the U.S., but Fewer Than Half Call It

a Top Priority, January 9, 2020, https://www.pewsocialtrends.org/2020/01/09/trends-in-income-and-wealth-inequality.

Federal Reserve Board's Division of Consumer and Community Affairs, Report on the Economic Well-Being of U.S.

Households in 2018, May 2019, https://www.federalreserve.gov/publications/2019-economic-well-being-of-us-

households-in-2018-preface.htm

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Figure 1 illustrates the differences in poverty rates across several categories, showing that the

poverty rate of Black residents is nearly four times that of white residents, while the poverty

rates of residents of Hispanic or Latinx origin of any race are greater than the overall rate.

Figure 1.

Finding: Black residents, Hispanic residents, and residents with disabilities are a

disproportionate share of those living in poverty

People of color also disproportionately live in the region’s disinvested communities and

economically disconnected areas.

These communities have seen decades of declining

employment, population, and public and private investment, leading to the erosion of tax bases

and public services. Residents of these communities are often denied access to economic

opportunity, resulting in many households having severe financial constraints.

This report will focus on reducing inequity for households with low income, defined by 60

percent of the median household income for the Chicago metropolitan statistical area (MSA) in

2018 (see Methodology). A primary goal is to ensure fees, fines, and fares are not a barrier to

mobility for households with low income, who are disproportionately people of color.

U.S. Census Bureau, American Community Survey, 2019. Data are for the Chicago-Naperville-Elgin, IL-IN-WI

metropolitan area. Population that is Hispanic or Latino includes people of any race.

See ON TO 2050 Local Strategy Maps of Economically Disconnected and Disinvested Areas,

https://www.cmap.illinois.gov/2050/maps/eda.

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Figure 2 provides an overview of households in each income category used in this report.

Figure 2.

Finding: Among households in northeastern Illinois, 23 percent met CMAP’s definition of low

income

Cost of driving is unaffordable for many households with low income

Consumer expenditure data show that those with low income spend a substantial part of their

incomes on transportation.

Figure 3 illustrates the average proportion of income spent on

transportation costs, including driving and public transit.

CMAP analysis of U.S. Department of Labor Bureau of Labor Statistics 2018 Consumer Expenditure Survey Public-

Use Microdata. In the Consumer Expenditure Survey, a consumer unit consists of all members of a particular

household who are related by blood, marriage, adoption, or other legal arrangements; a person living alone or

sharing a household with others or living as a roomer in a private home or lodging house or in permanent living

quarters in a hotel or motel, but who is financially independent; or two or more persons living together who use their

incomes to make joint expenditure decisions.

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Figure 3.

Finding: Residents with low income spend 16 percent of their income on transportation costs

Figure 4 illustrates the ways that vehicle ownership drives expenditures on vehicle purchases,

fuel and oil, and other vehicle expenses (insurance, financing, maintenance, and other vehicle

charges). The Chicago MSA, with its substantial public transportation assets, has lower

transportation expenditures than the United States as a whole, owing partly to lower vehicle

ownership. Primarily, affordability challenges experienced by households with low income are

driven by the numerous costs of owning and operating a personal vehicle, rather than the

associated fees, fines, and fares. The larger issue is that households with low incomes often lack

the income to cover typical base household expenses, so any sort of transportation fee is

unaffordable.

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Figure 4.

Finding: The costs of owning a vehicle, rather than fees, fines, and fares, account for most

transportation expenditures across income groups

Households with low income spend a substantial proportion of their income on transportation

when they own a vehicle. Households in the low-income group owned an average of one

vehicle, while households in the other income groups owned an average of nearly two vehicles.

However, vehicle ownership rates vary within income groups. Nationally, the Center for

Neighborhood Technology found that Black and Latinx residents living in households with no

vehicles were more likely to be in poverty than white households with no vehicles.

Within the

Chicago MSA, Figure 5 illustrates that households with more vehicles have higher incomes on

average, even within the low-income category.

Center for Neighborhood Technology, Equity and Smart Mobility, 2019,

https://www.cnt.org/sites/default/files/publications/Equity-and-Smart-Mobility-Report.pdf.

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Figure 5.

Finding: Even among households with low income, those with more income own more vehicles,

driving higher expenses on transportation

Vehicle owners also incur costs in the form of time spent on paying fees and other related

activities. Drivers need to interact with a variety of facilities to acquire and renew state vehicle

registrations, get state emissions testing annually if their vehicle is more than four years old,

acquire and renew local vehicle licenses, and obtain an I-PASS account, all in addition to regular

vehicle maintenance and motor fuel.

Mobility impacts access to opportunity for residents in economically

disconnected communities

Daily commutes are longer for many residents with low income and residents of color,

especially Black commuters. These lengthier commutes hinder residents’ ability to connect to

available and attainable employment opportunities and reduce overall productivity and quality

of life. Likewise, many residents with disabilities lack sufficient access to mobility options to

commute to work and conduct their daily lives.

This is particularly true for residents living in economically disconnected areas (EDAs) — parts

of the region with concentrated low incomes, limited English proficiency residents, and/or non-

white residents — where access to transit options does not always ensure access to jobs within a

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reasonable travel time. Many of these residents must commute to jobs located far from frequent

transit service. In part, this is driven by planning and land use decisions that have not

prioritized affordable housing or commercial and industrial development in infill locations with

transit access. At the same time, these same residents tend to have limited employment

opportunities within their own communities. Differences in commutes depend on what part of

the region a worker lives in, with the longest commutes found for residents of the west and

south sides of Chicago as well as parts of the south suburbs, as illustrated in Figure 6.

Additional time spent driving increases transportation costs, including potentially making a

driver more likely to incur fines.

Figure 6.

Finding: Communities with lower income levels have longer average commutes, even among

economically disconnected communities

In 2017, just 55 percent of residents in metropolitan Chicago lived in areas with at least

moderately high transit availability, while just 53 percent of jobs were accessible via at least

moderately high transit availability.

Limited connectivity in the transit network is common in

many of the region’s more rural areas, often making it necessary to own a vehicle. As of 2015,

just 41.5 percent of the region’s population and 38.2 percent of the region’s jobs were located in

areas with “high” or “very high” walkability.

Chicago Metropolitan Agency for Planning, ON TO 2050, Population and Jobs with at Least Moderately High

Transit Availability, https://www.cmap.illinois.gov/2050/indicators/population-jobs-transit-availability. This is based

on a CMAP-created index that considers multiple factors: proximity to transit stops, frequency of service,

destinations reachable without a transfer, and walkability.

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Auto trips represent the vast majority of work trips. Meanwhile, even before the COVID-19

pandemic, transit ridership was declining. Income plays an important role in travelers’ mode

choices for their commutes.

Figure 7 shows how workers on either end of the earnings spectrum are less likely to travel to

work by car and are more likely to travel by transit. Travelers with lower income are the least

likely to drive alone to work and the most likely to walk, likely in part because auto ownership

can be unaffordable for many commuters with lower income.

In the suburbs, commuters earning lower wages are less likely than commuters earning higher

wages to use public transportation. Rather, many carpool to get to industrial and retail job

centers in more diffuse locations in the region that are not well served by transit. Workers in the

highest earning categories also have lower rates of auto commutes. High earners are afforded

more choice in where to live and may live in areas with better access to transit, such as near

transit connections to Chicago’s central business district. For example, high earners in the

suburban parts of the region are the most likely to use transit, given that they use Metra

commuter rail to reach jobs in the city.

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Figure 7.

Finding: Workers on either end of the earnings spectrum are less likely to travel to work by car

and are more likely to travel by transit

Systemic racism creates inequities in transportation safety and enforcement

Equity in fees, fines, and fares is impacted by bias in public safety and law enforcement

systems. Beyond improving the transportation system, parallel work must be done to reduce

inequities in how traffic laws are enforced. Although the enforcement system is not the focus of

this analysis, this report outlines the well-documented challenges faced by people of color in

other related systems.

Drivers incur additional transportation-related costs when they are cited for traffic violations.

Traffic violations straddle both the transportation and law enforcement systems. According to a

2018 report by the U.S. Department of Justice’s Bureau of Justice Statistics, the most common

reason for interaction with the police is being a driver in a traffic stop.

Bureau of Justice Statistics, Contacts Between Police and the Public, 2018 - Statistical Tables, December 2020,

https://www.bjs.gov/index.cfm?ty=tp&tid=702

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Historically, traffic safety enforcement has had an inequitable impact on communities of color,

with data indicating people of color are involved in a disproportionate share of traffic stops.

National surveys show Black adults are about half as likely to have a positive view of local

police performance as white adults.

That Black and Latinx communities are at greater risk for

both discriminatory enforcement and traffic violence is not a coincidence; both challenges are

manifestations of systemic racism that is embedded in the built environment.

The Government

Alliance on Race and Equity has defined systemic racism as “racial bias among interlocking

institutions and across society, causing cumulative and compounding effects that systematically

advantage white people and disadvantage people of color.”

At the same time, higher numbers of pedestrian and bicycle crashes occur in neighborhoods

with greater shares of residents with low income and residents of color.

Solving safety

challenges requires comprehensive and context-sensitive solutions. However, many in the

transportation and planning fields have focused on engineering and have not actively engaged

with the role that traffic safety enforcement can play in perpetuating racial and economic

inequities.

These challenges exist in all kinds of communities across the country. ON TO 2050 recommends

that any enforcement mechanisms that address traffic safety disparities in both low-income

communities and communities of color also avoid disproportionate financial and enforcement

burdens on these same communities. Extensive research conducted by the U.S. Commission on

Civil Rights in 2017 revealed the national scope of racial inequity in court debt, fines, and fees,

many of which are traffic-related.

ON TO 2050 recommends that any enforcement

mechanisms that address traffic safety disparities in both low-income communities and

communities of color also avoid disproportionate financial and enforcement burdens on these

same communities. The region will need to work together to eliminate inequities in the system

and develop processes, practices, and protocols to ensure equity.

Many households with low income are unbanked and under-banked

One challenge faced by households with low income is a lack of access to or ability to use a

bank account, known as unbanked and underbanked, respectively. Having a bank account or

Emma Pierson et al., “A Large-Scale Analysis of Racial Disparities in Police Stops across the United States,” Nature

Human Behaviour 4, no. 7 (July 1, 2020): 736–45, https://doi.org/10.1038/s41562-020-0858-1.

Pew Research Center, The Racial Confidence Gap in Police Performance, September 2016,

https://www.pewsocialtrends.org/2016/09/29/the-racial-confidence-gap-in-police-performance.

Vision Zero Network, Vision Zero Equity Strategies for Practitioners, 2017, http://visionzeronetwork.org/wp-

content/uploads/2017/05/VisionZero_Equity.pdf

Government Alliance on Race and Ethnicity, Advancing Racial Equity and Transforming Government,

https://racialequityalliance.org/wp-content/uploads/2015/02/GARE-Resource_Guide.pdf

Chicago Metropolitan Agency for Planning, ON TO 2050 Recommendation: Improve Travel Safety, 2018,

https://www.cmap.illinois.gov/2050/mobility/safety

U.S. Commission on Civil Rights, Targeted Fines and Fees Against Communities of Color, 2017,

https://www.usccr.gov/pubs/2017/Statutory_Enforcement_Report2017.pdf

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credit card helps facilitate many transactions, including using modern, electronic methods for

paying transportation fees, fines, and fares. Many entities that collect fees, fines, and fares use

cost differences to incent the adoption of these methods by their customers because of their

collection efficiency. However, it is well documented that people with low income are more

likely to be unbanked and therefore unable to achieve these savings. In Illinois, it is estimated

that 41 percent of households with annual income under $30,000 are either unbanked or

underbanked.

With incomes above $75,000, the unbanked rate falls to 1.1 percent of

households and the underbanked rate to 10 percent. From other perspectives, 11.4 percent of

households without a high school diploma were unbanked, while 1.8 percent of households

with a college degree were unbanked.

Among the unbanked, the reliance on cash is significant. Two-thirds of unbanked households

used cash for paying bills in a typical month in 2017. Thirty-nine percent of such households

used nonbank money orders, and 22 percent used prepaid cards. Less than 10 percent of

unbanked households used electronic payments, checks, debit cards, and credit cards.

Transportation funding challenges

The region’s transportation system is funded through a variety of federal, state, regional, and

local revenue sources. However, federal and state revenues are not enough to reach a state of

good repair, and underinvestment in capital maintenance has created a significant backlog of

projects. ON TO 2050 recommends that those who benefit from the transportation system fund

it through direct user fees, but this may result in disproportionate impacts on households with

low income.

Making fees and fares more affordable to residents with low income could potentially result in

lower revenues and may require investments in programs or infrastructure. Further

investments in the system could also improve travel times and reliability and even reduce the

need for vehicle maintenance. Given current revenue constraints, this would drive a need to

increase revenues in other ways or reprioritize existing investments toward strategies to help

residents with low income. This section will provide an overview of the region’s transportation

funding system, as well as funding constraints.

Roadways

The state’s roadway system is primarily funded through both federal and state revenues, such

as the state motor fuel tax revenue and state vehicle registration fee. In 2019, the state increased

“2017 Survey Results for Illinois: Banking Status for Illinois Households,” Federal Deposit Insurance Corporation,

last updated 2017, https://economicinclusion.gov/surveys/place-data.html?where=Illinois&when=2017.

Federal Deposit Insurance Corporation, Division of Depositor and Consumer Protection. 2017 FDIC National

Survey of Unbanked and Underbanked Households, Appendix Tables. October 2018.

https://www.fdic.gov/householdsurvey/2017/2017appendix.pdf

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several transportation revenue sources, such as its motor vehicle registration fee and motor fuel

tax (MFT) rates, as part of the legislation called Rebuild Illinois. The legislation also provides for

indexing the MFT rate to inflation to limit the erosion of the revenue’s purchasing power over

time. Even with these revenues, estimated to increase available funding by more than $2 billion

annually, resources will be insufficient to make needed investments in maintaining, enhancing,

and expanding the system.

Several forces continue to erode the MFT’s long-term viability as an adequate or fair source of

revenue. The tax revenue depends on how much fuel that drivers purchase — directly related to

how far people drive. Increased fuel efficiency and a lack of substantive growth in vehicle travel

will undermine the ability of the MFT, even indexed to inflation, to keep pace with the cost of

operating and maintaining the transportation system over the long term. ON TO 2050

recommends long-term replacement of the MFT with a road usage charge, which would be

collected as a per-mile fee when driving on public roadways. A road usage charge would

provide a more sustainable revenue source, as it would grow with vehicle travel rather than

motor fuel consumed.

At the local level, transportation departments use a mix of state motor fuel tax disbursements

and locally imposed taxes and fees, including motor fuel taxes, vehicle licenses, and priced

parking, as well as property and sales taxes. Local governments may also use fine revenue for

transportation or other purposes, but fine levels should be set to promote safety outcomes and

are not appropriate as a revenue generator.

Transit

The region’s transit system’s operations are funded through transit fares and other operating

revenue, including the Regional Transportation Authority (RTA) sales tax, state assistance, a

portion of Chicago’s real estate transfer tax, and limited federal support.

Revenues collected

through transit fares and other smaller system-generated revenue supported 39.8 percent of

service operations in 2019.

Capital costs are funded primarily through federal sources, as well

as state support from motor fuel tax revenues directed to the RTA and state bonding. Capital

A road usage charge would also prevent a growing horizontal inequity related to electric and hybrid vehicles that

will arise if the state continues with an MFT, even with the supplemental $100 electric vehicle fee. Electric vehicle

drivers, as well as hybrid vehicle drivers, will typically pay less than other drivers. In addition, electric vehicle

drivers who drive few miles will pay as much as those who drive substantially more.

The 2021 Regional Transit Operating Budget includes 2.3 percent from The Coronavirus Aid, Relief, and Economic

Security (CARES) Act and 7.7 percent from other federal relief funding.

Regional Transportation Authority. Adopted 2021 Operating Budget, Two-Year Financial Plan, and Five-Year Capital

Program. December 2020. https://www.rtachicago.org/sites/default/files/documents/aboutus/meeting_documents/12-

17-20/Adopted-RTA-2021-Operating-Budget.pdf. Note that fare revenues in 2020 were significantly lower due to

lower ridership due to the COVID-19 pandemic.

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infrastructure needs are significantly underfunded, with an estimated 34 percent of the region’s

transit assets exceeding their useful life as of 2020.

State of Illinois law requires system-generated revenue to recover at least 50 percent of system

operating expenses for CTA, Metra, and Pace and 10 percent for Pace ADA paratransit. State

statute provides for adjustments to calculating the ratio, which explains why actual fare

revenue comes in below the 50 percent mark. To achieve this requirement, the RTA sets a

unique recovery ratio for each service board during the budget process each year.

Each

agency’s individual recovery ratio reflects projected income from other eligible operating

revenues, as well as estimated ridership, including revenue from the fares, which vary

depending on several factors.

Revenues from these sources vary between the operators, which is why each agency has a

unique recovery ratio. For example, nearly one out of every three trips taken on Pace is paid for

with a free or reduced fare permit, driving down the total collected fare revenue and requiring

the rest of the system to compensate to reach the region’s required mark. Any changes to fare

policies that reduce revenue need to account for the constrained funding environment with new

sources of revenue or an adjustment to the ratio required of the service operators.

The State of Illinois historically funded mandatory free and reduced fare programs at $34

million annually, although the cost of providing these services far exceeds the reimbursement.

Starting in fiscal year 2015 and for each subsequent year, the state reduced the subsidy by

nearly one half, requiring each agency to recoup revenue for these programs elsewhere.

In addition to reduced funding for statutorily required reduced and free ride permits, the

transit agencies have experienced other decreases in state support.

When public funding for

operations decreases, unless there are equal cuts to operating services, the service operators

must compensate with additional system-generated revenues to maintain the region’s recovery

ratio. The State has imposed a 1.5 percent administrative fee for collecting the RTA sales tax, as

well as a 5 percent reduction in state matching funds through the Public Transportation Fund.

In total, these state cuts, in addition to the cuts to the reduced and free fare subsidy, amounted

to a $56 million regional operating reduction in 2019, or 1.8 percent of budgeted revenue, and

were estimated to impact the 2020 operating budgets by $46 million.

Regional Transportation Authority. Adopted 2021 Operating Budget, Two-Year Financial Plan, and Five-Year Capital

Program.

The 2021 operating budget counts CARES Act and other additional federal relief funding as system-generated

revenue. With the inclusion of these funds, for 2021, CTA’s specified recovery ratio is 54.75 percent, Metra’s is 52.5

percent, and Pace’s is 30.3 percent for suburban service and 10 percent for ADA paratransit.

The challenges of insufficient operating funding have recently been compounded by the state’s delinquency on

remitting transit revenues. As of November 2020, the state owed the RTA $193.3 million. Late payments have forced

the agency into short-term borrowing to fill budget gaps, with interest costing $5.2 million in 2019 and $4.6 million

through November 2020.

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Distribution of the cost of public services

and infrastructure

In the United States, people and businesses pay taxes and fees to fund the cost of public goods

and services. At the state and local level, the overall tax burden and distribution across

taxpayers vary depending on the location. Different states and localities have different tax

structures. The variance is based on reliance on income tax, property tax, sales and excise taxes,

or other taxes or fees, as well as the specific structure of those taxes.

In some states, residents with high incomes pay a higher proportion of their income in taxes

than residents with lower incomes. These tax systems are more progressive and promote

vertical equity. They typically feature progressive elements in their income tax, such as

exemptions or graduated rates. In other states, residents with high incomes pay a lower

proportion of their income in taxes than residents with lower incomes. These systems are

considered regressive and typically feature fewer progressive elements in their income tax or a

higher reliance on sales and excise taxes, which are not based on income level.

Equity of Illinois’ tax system

The distribution of the tax burden impacts Illinois’ broader economic vitality. In 2018, the

Institute on Taxation and Economic Policy ranked Illinois’ tax system as the 8

most regressive

structure in the United States.

The 20 percent of non-elderly residents with the lowest incomes

paid 14.4 percent of their income in taxes, while the top 1 percent of taxpayers paid 7.4 percent.

While Illinois relies on sales and excise taxes to a relatively typical degree, these taxes often

have regressive impacts on the overall tax system. States with less regressive structures

integrate several features in their income tax structure to mitigate the impacts of these taxes.

Institute on Taxation and Economy Policy, Who Pays, October 2018,

https://itep.sfo2.digitaloceanspaces.com/whopays-ITEP-2018.pdf

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Figure 8.

Finding: Taxpayers with the lowest income levels pay a higher proportion of their income in

taxes than higher-income taxpayers

However, Illinois’ income tax structure features a flat income tax rate and comparatively low

tax exemptions. Illinois taxes all personal income at the same rate, rather than a graduated

approach where higher incomes are taxed at higher rates.

Currently, Illinois exempts $2,275

per individual from taxable income for filers with income lower than $250,000 ($500,000 for a

joint return). Illinois also provides an Earned Income Tax Credit (EITC) for households with low

to moderate income that are eligible for the federal EITC. The Illinois EITC is currently 18

percent of the federal EITC and is a refundable credit, meaning that it can be greater than the

amount of tax liability.

Equity of transportation fees, fines, and fares

Transportation user fees, fines, and transit fares are one portion of a resident’s overall tax and

fee burden. They function as part of the tax system as a whole, where every broad-based fee,

fine, or fare imposed without basis in income level has the potential to be regressive. Even when

these expenses are not primary parts of the tax burden, many residents perceive outlays like

The Illinois state constitution requires income taxes be at a non-graduated rate. See Constitution of the State of

Illinois, Article IX, Section 3, https://www.ilga.gov/commission/lrb/con9.htm.

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tolls or transit fares as substantial relative to other expenses, because they have to pay them on a

more regular basis, particularly if they have to pay in cash.

Indeed, particularly noticeable fees

like priced parking are often used as a traffic management tool to drive behavior.

The following section will assess the vertical equity of transportation fees, fines, and fares, and

the impacts on residents and households in northeastern Illinois with low income. When these

fees, fines, and fares disproportionately impact residents with low income, residents of color

may also be disproportionately affected.

Policies may not have an overtly racist intent yet

produce inequitable outcomes for people of color.

State motor fuel tax and proposed road usage charge

The State of Illinois imposes a 38.7 cents per gallon tax on motor fuel, with the rate rising with

inflation every July. Only drivers pay MFTs directly and therefore only residents with low

income who drive a car are directly impacted. This would also be true with road usage charges,

when implemented. Current travel patterns and the fuel efficiency of personal vehicles affect

the payments that drivers make in MFT today. Drivers are impacted by the motor fuel tax to the

degree that they use fuel, a function of both miles driven and vehicle efficiency. An average

driver in Illinois pays approximately $200 annually in state MFT and would pay a similar

amount under a potential road usage charge structured to replace the current revenue from

MFT. Drivers would pay a road usage charge solely based on how many miles they drive.

Households with low income incur lower motor fuel tax and likely lower road

usage charge payments

CMAP analysis indicates that communities with median household income under 60 percent of

the region median tend to have lower typical household MFT payments than areas with higher

median household income. These MFT payments totaled approximately $220 per year and $350

per year, respectively, in aggregate for all household vehicles.

These communities with lower

income had lower MFT payments because of varying combinations of fewer vehicles per

household and low annual mileage. Differences in MFT payments across communities of

different income levels were not driven by notable differences in vehicle fuel economy. On the

municipal and community area level, no relationship between median vehicle fuel economy

and median household income exists.

For example, see Amy Finkelstein, “E-ZTAX: Tax Salience and Tax Rates,” The Quarterly Journal of Economics, (2009),

https://economics.mit.edu/files/7878; Raj Chetty, Adam Looney, and Kory Kroft, “Salience and Taxation: Theory and

Evidence,” American Economic Review 99, no. 4 (September 2009),

https://are.berkeley.edu/SGDC/Chetty_Looney_Kroft_AER_2010.pdf.

Where possible, the assessment of transportation fees, fines, and fares that follows provides quantitative analysis

on both income and racial dimensions. However, data limitations did not allow a full analysis of the impact of every

fee, fine, and fare by race or ethnicity.

Chicago Metropolitan Agency for Planning analysis of American Community Survey estimates for 2011-2015;

odometer readings from the Illinois Environmental Protection Agency, 2015-17; and fuel economy estimates from the

U.S. Environmental Protection Agency.

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As a result, shifting from a motor fuel tax to a road usage charge would not impose a greater

burden on typical lower-income households relative to typical higher-income households. To

compare the tax burden of a MFT to a road usage charge, CMAP estimated a revenue neutral

rate for passenger vehicles. Under a $0.0195 per mile rate — chosen because it raises the same

amount of revenue overall as the MFT — areas with lower median household income would

experience an $11 typical increase in annual burden, while areas with higher median household

income would experience a $14 typical increase, on average. The higher change in burden is

partially driven by the fact that households in higher-income communities have higher mileage

on average than households in lower-income communities.

Since aggregating to the community level may obscure household-level characteristics, CMAP’s

Activity-Based Model was also used to investigate relationships between income and driving

patterns. The analysis reflects that lower-income households drive fewer miles on average than

medium- and higher-income households, resulting in lower tax payments for the MFT and a

potential road usage charge. While Table 1 compares modeled miles driven by income group

for all households, the results for households that own one or more vehicles are similar. Ninety

percent of all households in the region have one or more vehicles, while 75 percent of

households with low income have one or more vehicles .

Table 1.

Finding: Households with low income drive fewer miles than other households

Income level of

household

Share of modeled

households

Share of total miles

driven

Average miles

driven per day

Low

22%

11%

20 miles

Medium

36%

37%

42 miles

High

42%

53%

53 miles

All households

100%

42 miles

Source: Chicago Metropolitan Agency for Planning analysis of U.S. Census data and CMAP’s Activity-Based Model

Motor fuel taxes do not represent a major cost burden relative to other costs of

driving

Both motor fuel taxes and road usage charges are fees intended to capture funds based on use

of the roadway network. Because they drive fewer miles, lower-income households pay a

similar share of their income in motor fuel tax as higher-income households — approximately

0.2 percent of income for four-person households across each income group. The rate structures

treat drivers of all incomes the same, resulting in a lack of vertical equity for households that

lack sufficient access to other transportation modes. However, it is mostly other driving costs,

such as vehicle purchase, repairs, insurance, and the price of motor fuel itself, not the MFT or a

road usage charge, that make driving unaffordable for some households.

Chicago Metropolitan Agency for Planning, Activity-Based Model

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Vehicle registration fees

The State of Illinois imposes a vehicle registration fee, and many municipalities impose their

own vehicle license fees. Vehicle registration fee revenue tends to provide the stability

necessary to fund or issue bonds for multi-year transportation programs. The State periodically

raises these fees to ensure that the revenues are sufficient to maintain and improve the

transportation system. The State of Illinois recently increased registration fees, with annual

passenger vehicle rates increasing from $101 to $151.

With 10.8 million registered vehicles,

these fees are the Illinois Department of Transportation’s largest source of state-generated

funding. Nearly 8 million passenger cars are registered in Illinois. Growth in actual passenger

vehicle registrations was just 1.2 percent between 2010 and 2019, which is consistent with

stagnation in the state’s population.

Many municipalities impose annual vehicle fees as well. Within northeastern Illinois, 159

municipalities impose these fees on residents, ranging from $5 to $90. Some municipalities

restrict these revenues for transportation investments, while others use the revenue for general

purposes.

Households with low income own fewer vehicles than other households

State and local vehicle fees are inherently regressive. Because everyone pays the same amount

regardless of income, drivers with low income pay a higher percentage of their income on these

fees than higher-income drivers. Additionally, the annual $151 payments may impose a burden

on low-income households. However, many people with low income are not affected by the fee

because they don’t own a vehicle. Data indicate that households nationwide with less than

$25,000 in annual income account for 13.4 percent of vehicles.

Within northeastern Illinois, lower-income communities tend to have fewer vehicles per

household than higher-income communities.

In addition, results from CMAP’s Activity-Based

Model indicate that households with low income in the region own 1.1 vehicles on average,

while households with medium and high income own 1.7 and 1.9 vehicles on average,

respectively. In the aggregate, households with low income account for 23 percent of

households in the region but own 16 percent of the vehicles. Figure 9 compares vehicle

ownership by income level in the aggregate for the CMAP region.

Electric vehicle registrations were increased from a discounted $35 biennial fee to $251 annually, which is

comprised of the same base registration fee as all vehicle owners, $151, plus an additional $100 fee in lieu of paying

the MFT. As of March 2020, electric vehicles account for 0.3 percent of passenger vehicles in Illinois, with 21,336

active registrations out of nearly 8 million passenger vehicles registered in Illinois.

Federal Highway Administration. National Household Travel Survey, 2017.

Chicago Metropolitan Agency for Planning analysis of American Community Survey data, 2014-18 estimates

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Figure 9.

Finding: Households with low income own fewer vehicles than households with medium and

high income

Indeed, not owning a vehicle allows people with low income to avoid paying vehicle fees.

However, in areas with insufficient transit access to employment and services, or bicycle and

pedestrian facilities, not owning a vehicle may not be a reasonable alternative.

Impact of vehicle registration fees depends on local fees imposed

Across the region, the aggregate effect of state and local vehicle fees varies by both fee levels

and income levels. Figure 10 compares typical household state and local vehicle fees paid, based

on typical household vehicle ownership, to median household income, by municipality or

Chicago Community Area. Although the fees are relatively low compared to income levels,

households with median-level incomes in many Chicago neighborhoods and several suburbs

are paying more than a half a percent of their income annually in state and local registration

fees.

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Figure 10.

Finding: State and local vehicle registration fees reach more than a half a percent of income in

some communities

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However, all communities in the region have residents of varying income levels who own

vehicles. Table 2 compares vehicle fee levels by income level, for a four-person household.

Table 2.

Finding: Higher local vehicle fees drive a higher cost burden

Income level, four-

person household

$151 State fee as a

percent of income

State + $25 local fee as a

percent of income

State + $75 local fee as a

percent of income

60% of median income

($51,350)

0.2% 0.3% 0.4%

140% of median income

($119,818)

0.1% 0.1% 0.2%

Source: Chicago Metropolitan Agency for Planning analysis.

ON TO 2050 encourages municipalities to impose user fees to fund infrastructure that meets

community needs. However, the impact of these fees is greater for drivers in municipalities

with higher fees. While these fees are regressive, they remain a small piece of the overall cost of

vehicle ownership. For typical vehicle costs, these fees represent approximately 2 percent of the

annual cost of owning a vehicle, which can reach $10,000.

Tolling

Tolling allows the high cost of urban expressway construction to be borne by users of those

facilities, rather than the general public. In Illinois, such user fees have allowed Illinois Tollway

facilities to be maintained and improved, while IDOT-maintained expressways have fallen into

disrepair due to a lack of adequate and consistent funding. The need for expanded tolling has

been recognized by ON TO 2050, which recommends IDOT and the Tollway implement tolling

in conjunction with planned reconstruction of existing, untolled facilities. This is meant to

defray the costs of reconstruction and provide a sustainable revenue source for ongoing

maintenance and modernization.

Base charges for the Illinois Tollway vary by facility. The Tri-State Tollway, first constructed

more than 60 years ago, has a price of approximately $0.06 per mile. Newer facilities have

higher rates to cover more of the initial cost of facility construction, rising to approximately

$0.20 per mile on the newly constructed Illinois Route 390.

Likewise, the payment method affects toll rates. The financial viability of toll roads requires that

the cost of collection be substantially lower than the collected revenue. Automated collection via

a transponder costs very little compared to alternative payment methods. As a result, the

Tollway charges more for higher-cost transactions, both to cover costs and, more importantly, to

provide a financial incentive for people to choose payment methods with lower costs to the

Tollway.

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More than 90 percent of the Tollway’s transactions are via the electronic I-PASS transponder,

the second-highest electronic collection percentage among peer U.S. toll agencies.

That is likely

to increase, as cash tolls are being phased out on the Tollway system. Nearly 70 percent of

Chicago Skyway transactions are electronic, but unlike Illinois Tollway facilities that offer a

discount for electronic transponder payment, cash and electronic toll rates are the same. To

obtain an I-PASS transponder, the account holder must pay $30 up front; $20 is credited to the I-

PASS account and $10 is a refundable deposit. The Tollway’s cost of collecting I-PASS tolls is

significantly lower than pay-by-plate online tolling, used by motorists who did not have an I-

PASS transponder in their windshield.

To maximize toll collection efficiencies, the Illinois Tollway has put strong financial incentives

in place to encourage I-PASS use. As compared to I-PASS tolls, a typical toll schedule for

passenger vehicles is double for “pay-by-plate” transactions for 14 days after the toll.

To avoid higher tolls and fees, Tollway customers with I-PASS accounts need to keep funds in

their accounts. For customers with credit, debit, and prepaid cards, this is easy through the I-

PASS auto-replenish program.

Customers with depleted accounts have 14 days to pay by

plate, or an invoice fee occurs. For customers without auto-replenish, cards may be used online

or over the phone to add funds. Customers can also purchase Illinois Tollway gift cards at

Jewel-Osco using any payment method and replenish their account using the gift card online or

over the phone. Cash, checks, and cards are accepted at four suburban service oases or at the

Illinois Tollway headquarters in Downers Grove. Checks may also be mailed to a processing

center.

Existing tolling does not significantly impact households with low income

At this time, on average, tolls do not appear to be a substantial share of transportation costs nor

a primary driver of transportation outlays for people with low income. Consumer Expenditure

Survey data indicate that other vehicle expenses, which include tolls, make up just 3 percent of

transportation expenses for households with low income and 6 percent for other households.

Rather, vehicle ownership overall is the primary driver of transportation expenses.

CDM Smith. Illinois Tollway Comprehensive Study Update. November 2020.

https://www.illinoistollway.com/documents/20184/785978/Traffic+Engs+Rpt+Final+for+IL+Toll+2020A.pdf/5dd2d2ab

-5f65-819d-4eda-c6d4ede75979?t=1610111997297.

Illinois Tollway (Mike Colsch), Video Tolling and Collections, March 2017,

https://www.illinoistollway.com/documents/20184/532181/20170313_CSPVideoTolling.pdf/24556ba4-7001-47e0-ad73-

333b83ec3194?version=1.0. In 2015, the cost of collecting tolls was $0.08 per dollar for I-PASS transponder

transactions, including capital expense (gantries, cameras, etc.). Pay-by-plate online tolling, for motorists who did not

have an I-PASS transponder in their windshield, have higher expenses, $0.20 per dollar collected in 2015. Expenses

per dollar collected for cash transactions, which are being phased out, were $0.43 for coin machines and $0.48 for

manual lanes (with an in-person attendant).

“Tolling Information,” Illinois Tollway, https://www.illinoistollway.com/tolling-information.

“About I-Pass,” Illinois Tollway, accessed March, 2020, https://www.illinoistollway.com/tolling-information/about-

ipass.

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The impact of tolling on people with lower income is dependent on several variables. People

with low income tend to have fewer cars than people with high income. In addition, average

annual household miles traveled by auto are higher for people with higher income.

Households with low income may drive fewer miles to avoid the various costs associated with

driving, representing trips suppressed by financial constraints.

While drivers can avoid driving on the Tollway and paying a toll, doing so can make trips

longer. Thus, drivers with low income still use these facilities because they provide a faster

route. While the Tollway serves low-income areas of south suburban Cook County and its

customer base includes drivers of all income levels, much of the Tollway system is in wealthier

suburban counties. In addition, Illinois Tollway per-mile fees are lower than those of many peer

toll agencies nationally, so impacts on lower-income communities have been limited.

Expanding tolling would primarily impact households with moderate and high

income

ON TO 2050’s recommendation to expand tolling to expressways as they are reconstructed may

impact greater numbers of travelers with low income. Using its Activity-Based Model, CMAP

compared a “baseline” 2015 scenario with a “tolling” 2015 scenario, as if the remainder of the

IDOT expressway system in the CMAP region had been tolled at a rate of $0.20 per mile. Under

this scenario, toll revenues would increase by nearly 400 percent. In aggregate, daily toll

revenues would rise from a baseline of approximately $1.8 million to an estimated $8.8 million.

Table 3 indicates that under the expanded tolling scenario, the highest income group would

continue to pay a majority of the tolls collected — and would pay a slightly increasing share.

Table 3.

Finding: Households with low income would pay more in tolls, but a lower share of overall tolls

under expanded tolling

Estimates for

passenger tolls, CMAP

region, 2015

Low income Medium income High income

Baseline

tolling

Expanded

tolling

Baseline

tolling

Expanded

tolling

Baseline

tolling

Expanded

tolling

Share of daily toll

revenues

34%

33%

58%

61%

Daily cost per resident

$0.08

$0.27

$0.44

$0.71

$0.58

$1.20

Source: CMAP activity-based model

While the expanded tolling scenario would result in higher collections from households with

low income, tolls per resident per day would remain lower than those paid by residents with

higher incomes. These model results indicate both lower mileage on the Tollway by drivers

with low income and a lower increase in mileage than households in other income groups.

Lower tolls through I-PASS are less accessible to unbanked households

The tolling system currently in place presents challenges to unbanked residents with lower

incomes who need to access the tollway system. If tolling is expanded, particularly in low-

income areas, equity calls for people with lower incomes to have access to the lowest-cost toll

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rates. However, households with low income tend to be unbanked or underbanked, making I-

PASS accounts less accessible to them.

While I-PASS use is already high at the Illinois Tollway, expanded tolling would require

channeling an even greater number of customers to I-PASS transponders so that low-income

households can take advantage of the lowest toll rates available. This is an important task to

meet the needs of households with low income, particularly the unbanked.

Priced parking

Priced parking is recommended in ON TO 2050 as one component of developing more walkable

communities. CMAP recommends pricing to manage demand, so the price would be higher in

areas with higher demand and free in areas with low demand. Parking revenue should not be a

goal in and of itself; it should be considered a benefit of a well-managed transportation system.

In places where the demand for parking is high, using pricing to balance demand allows for a

more efficient use of land, improves travel time reliability by ensuring the availability of open

parking spaces, and facilitates business activity by opening up high-demand spaces closest to

businesses.

There are several potential approaches to pricing parking that have been implemented in

Chicago and some suburban communities. Priced parking is generally found at Metra

commuter stations; on-street in high-demand areas in Chicago, Oak Park, Forest Park,

Evanston, and Hinsdale; or in garages in very high-demand locations near a variety of

destinations. Additionally, residential permit parking is a form of priced parking that addresses

high on-street parking demand. From a regional perspective, broader implementation of priced

parking in appropriate locations could have many positive impacts. But it is also important to

consider the potential negative impacts, particularly equity impacts. These policies can impact

drivers with limited income, particularly those without access to transit or with ambulatory

disabilities.

Households pay for parking, regardless of whether they drive or it is priced

When parking is free, everyone pays for it — regardless of whether they use it or not. When

parking is metered or has permits, drivers pay for it directly, although not necessarily at full

cost. A grocery store with a free parking garage, for example, must make up the garage costs

through higher prices for groceries. Since low-income households without cars are paying for

the parking, through the grocery prices, of more affluent driving counterparts, there are

inequities inherent within the current transportation system.

While charging directly for the use of a parking space will increase the financial burden on

some drivers with low income, the current structure is not equitable. A goal of new pricing

should be to reduce existing and future potential inequities. To understand equity as it pertains

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to local priced parking, it is important to evaluate who is driving and the burden that low-

income households might bear with fees, fines, and parking enforcement.

One way to measure the equity of parking fees considers the proportion of an individual’s

income that goes to paid parking. With direct parking fees, this proportion is likely to be higher

for people with low income, particularly in locations where there are no options for free parking

or transit. Recommended locations for priced parking are typically in areas where the costs of

providing parking facilities is particularly high, such as in dense neighborhoods also serviced

by transit. The largest equity barrier is experienced by residents without transit nearby who

work in neighborhoods where pricing would be most appropriate. Areas without a transit

network can still benefit from parking management but most would likely continue to have

mostly free parking.

Approximately 10 percent of the region’s population reports having a disability.

For people

who have difficulty walking, convenient and accessible parking should be available, priced by

demand. Currently, drivers with meter-exempt handicapped parking placards may park for

free at parking meters and publicly-owned parking areas. Previous abuse of the placards led to

passage of a state law in 2013, limiting the people who could park for free with a placard to

those who cannot physically feed the meter.

Publicly subsidized parking can create equity challenges

Building additional parking garages for use by all does not alleviate equity concerns. Since

wealthier households own more cars

and take more trips,

a subsidized parking garage may

mostly benefit households with higher income. Parking garages are expensive to construct, and

when the costs are not covered by users, they encourage more driving — negating the intended

purpose of satisfying the demand for parking. A CMAP study on municipally-constructed

parking garages in metropolitan Chicago found construction costs range from $25,000 per space

to more than $70,000 per space. When drivers pay the full cost to park and demand is still high,

private parking garages will be built to fill the demand. However, this high demand for priced

parking is unlikely to happen outside of Chicago’s central business district, higher-income

neighborhoods with significant density, and locations with large attractions.

Transportation network company fees

In recent years, the rise of transportation network companies (TNCs), such as Uber, Lyft, and

Via, has dramatically altered transportation choices available to residents in the seven-county

Victoria Transport Policy Institute notes that “Because disadvantaged people tend to drive less and rely on non-

automobile modes, anything that increases transportation system diversity and land use accessibility tends to

increase vertical equity.” Evaluating Transportation Equity, June 2020, https://www.vtpi.org/equity.pdf.

United States Census Bureau, American Community Survey, 2018 Summary Table for Chicagoland MSA

Illinois Public Act 97-0845 (passed July 23, 2012).

Federal Highway Administration, National Household Travel Survey, 2017.

Chicago Metropolitan Agency for Planning, Activity-Based Model

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region. In the first two months of 2020, TNCs provided, on average, nearly 300,000 trips a day

that started or ended in the city of Chicago. Although data on trips that take place outside of the

Chicago are not publicly available, it is reasonable to assume a significant number of trips are

provided by TNCs in the rest of the region.

The cost of a TNC trip compared to the total cost

of car ownership — and depending on the trip, the cost of taxis — make them a popular

alternative for trips that would otherwise require owning a vehicle. Additionally, the ease of

using TNCs, which allows for the convenience of door-to-door service, has also led to their use

as an alternative to transit and other active modes. However, transit —where available —

remains the region’s most affordable transportation mode excluding walking and biking.

TNCs’ ability to operate depends on the use of public infrastructure. Fees assessed on these

services should ensure that users pay a fair share for use of public infrastructure and that fees

can help offset the additional costs of air pollution, congestion, and the use of curb space. While

some states levy a statewide tax on rides provided by TNCs, Illinois does not impose such a fee

at the state level. State-implemented TNC fees vary in approach, with some collecting a flat

annual permitting fee per company and others charging a per-trip fee.

Per-trip fees are

typically passed down to the consumer and are visible on a rider’s receipt, whereas the permit

fees are not visible to riders on a per-trip basis.

There is also precedent of regional efforts to regulate and assess TNC fees. In Washington State,

King County coordinates with the City of Seattle and other municipalities through a

cooperative agreement to license and regulate TNC operators. The county levies a $0.23 per-ride

fee for trips starting in unincorporated parts of the county and in municipalities for which it

coordinates TNC licensing. In addition to the county fee, the City of Seattle imposes a separate

$0.75 fee on trips within city limits.

In northeastern Illinois, the cities of Chicago and Evanston and the Village of Skokie impose a

local fee per ride as allowed under the Transportation Network Providers Act (625 ILCS 57). In

Evanston, the rate is $0.20 for a shared ride and $0.45 for solo rides that originate or end in the

municipality. In Skokie, the fee is $0.15 and $0.35, respectively. As of January 1, 2020, the fee

structure for TNC rides originating or ending in the Chicago became more nuanced, using

shared status, time of day, and geography to determine the fee. The fee structure is designed to

encourage ride-sharing and reduce congestion into and out of the central business district

during peak hours.

Chicago Data Portal (object name Transportation Network Providers- Trips; accessed July, 2020),

https://data.cityofchicago.org/Transportation/Transportation-Network-Providers-Trips/m6dm-c72p.

States that collect a flat tax include Arkansas’ $15,000 permit fee and Colorado’s $111,250 annual fee, among others,

while states such as Massachusetts collect a $0.20 per-trip fee. New Jersey and some other states levy both types of

fees, with a $25,000 annual permit, as well as a per-trip fee of $0.50 for solo rides and $0.25 for shared rides. Shared

trips are trips where the rider has authorized the TNC to add an additional rider to the trip. Not all trips where the

rider authorizes sharing are actually shared; however, the lower fee is still assessed so long as the shared

authorization is made. See “Policy Guide: Regulation of Transportation Network Companies.” Washington State

Joint Transportation Committee. 2019.

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In addition, within Chicago, trips that start or end at O’Hare International Airport, Midway

International Airport, Navy Pier, or McCormick Place are charged an additional Special Venues

Surcharge of $5.00 per trip.

Chicago also levies a $10,000 annual fee per transportation

network company that operates in the city. The city takes a different approach for taxi cabs,

charging a $98 monthly fee per vehicle in operation and a $3.50 daily fee to suburban taxis.

Other municipalities may impose a fee on taxis if they choose, but taxi services are not included

in Illinois’ sales tax base. Wheelchair-accessible vehicles are not subject to these fees.

A scan of other state and local fees collected on TNC trips shows little variation in how fees are

imposed. With the exception of New York City, which, like Chicago, has a designated

congestion zone with higher fees, most state and local units of government impose either a flat

fee or a fee calculated as a percentage of the trip fare, such as New York State’s 4 percent fee

levied on the gross trip fare.

In northeastern Illinois, TNC fee revenue is used for both transportation and non-transportation

purposes. In years prior to 2020, the City of Chicago has remitted a portion of revenues

collected to the Chicago Transit Authority (CTA) for capital projects. The 2020 budget estimated

that the new fee structure would raise an additional $40 million in 2020, of which $2 million

would be set aside for the Chicago Department of Transportation to make bus improvements,

such as Bus Priority Zones. However, the COVID-19 pandemic has significantly reduced actual

revenue collected. All revenue collected by both the City of Evanston and the Village of Skokie

is deposited in their general funds.

Impact of a TNC fee on residents with low income would be unclear

The extent to which TNC fees impact residents with low income is dependent on how much

they use TNCs, similar to other transportation fees like the motor fuel tax or priced parking.

Existing research is inconclusive on the extent to which people with low income use TNCs for

transportation. Preliminary findings from CMAP’s My Daily Travel Survey conducted between

August 2018 and April 2019 show that riders with annual income less than $25,000 take more

than 20 percent of all TNC rides in the region.

These findings are contrary to surveys in other metropolitan areas conducted in recent years

that have found TNC users to skew toward higher incomes,

although TNCs have also been

The State of Illinois levies a $4.00 airport taxi fee, but it is only collected for trips that start at the airport.

In some states, such as Maryland, Massachusetts, Nevada, Pennsylvania, Rhode Island, and South Carolina, TNC

rides are taxed under the general sales tax. See Sophie Quinton, “How should Uber be regulated?” The Pew

Charitable Trusts. 2015.

A survey conducted by UC Davis between 2014 and 2016 in seven major urban areas in the U.S. found that TNC

use was most common among respondents with the highest incomes and with the highest levels of education; 15

percent of respondents making $35,000 or less had used TNCs, compared to 33 percent of those making $150,00 or

more. A different survey of transit riders from Metropolitan Atlanta Rapid Transit Authority and New Jersey Transit

conducted by the Shared Use Mobility Center found transit riders who also use TNCs earn an average of $5,700 and

$27,000 more than riders who do not use TNCs, respectively.

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found to serve nearly every geography within large urban areas for which data has been made

available.

Among urban areas where TNCs are widely available, use by residents with low

income is likely to differ based on transit availability (including time of day considerations), car

ownership rates, local land use patterns, community safety, and other factors. One study

conducted in 2016 in Los Angeles found residents in areas with low income making more TNC

trips per capita than other income groups, indicating TNCs were being used as a primary mode

rather than simply as a back-up option to a personal vehicle.

However, the difference in per

capita use is likely to be less stark between income brackets in urban areas with better transit

coverage and less automobile dependency.

TNCs may fill a critical mobility gap for residents with low income who cannot afford a car and

live in areas with low transit availability. However, there are very limited data on use of TNCs

by residents of northeastern Illinois with low income, and it is difficult to assess the extent to

which TNCs play this role outside of the city of Chicago. ON TO 2050 recommends that private

companies share data that aid planning for the region’s transportation network, while still

ensuring rider privacy. Expanding access to TNC origin and destination data across

northeastern Illinois could be one way to better understand user demographics and the use of

TNCs by people of color and residents with low income.

The price of using TNC services is higher than the existing local fee itself, which may range

from $0.15 to $0.45 in the suburbs where imposed and would not exceed $1.25 on shared trips in

the city of Chicago. Where fees in Chicago are $1.25 or higher, riders can reduce the fee by

either using a shared ride or switching to public transit.

Traffic and parking violation fines

For most traffic and parking violations, the consequence of enforcement is a monetary fine.

These fines are generally assessed without consideration of income or ability to pay, leading

people with low income to pay a larger share of their income than people with high income.

The financial burden of fines is especially borne by Black and Latinx residents in the region,

who are disproportionately low income.

National Academies of Sciences, Engineering, and Medicine. Broadening Understanding of the Interplay among Public

Transit, Shared Mobility, and Personal Automobiles. 2018.

Anne Brown, “Ridehail Revolution: Ridehail Travel and Equity in Los Angeles.” (PhD diss., UCLA, 2018).

Chicago Metropolitan Agency for Planning, Median Household Income by Race and Ethnicity, 2018,

https://www.cmap.illinois.gov/2050/indicators/household-income-race-ethnicity

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Traffic violation fines have disproportionate impacts

In 2018, municipal police departments and county sheriffs in the CMAP region performed

1,613,832 traffic stops.

Sixty percent were for moving violations, which include speeding,

traffic signal, and lane violations, among others.

After stopping a motorist, a law enforcement

officer may issue a verbal warning, written warning, or a citation. Data analysis found that

traffic stops resulted in a motorist receiving a citation 31 percent of the time — with the majority

of citations for moving violations. Speeding led as the most common reason for both a stop and

a moving violation citation, although speeding was more likely to lead to a citation than other

moving violations.

Some national survey research suggests an association between higher income and speeding;

drivers with household income exceeding $100,000 are more likely to report speeding than

drivers in lower-income households ($30,000 or less).

However, this association is complicated

by the fact a subset of respondents reporting high household incomes are young drivers who

still live with their parents — a population at higher risk for speeding.

Disaggregating the data by race and ethnicity indicates motorists identified as Black are

stopped at a substantially higher rate than other racial and ethnic groups; motorists identified

as Black make up 31.2 percent of those stopped in the data while comprising only 16.7 percent

of the region’s population.

However, motorists identified by law enforcement as Black were

less likely to receive a citation once stopped -- receiving a citation in 22.8 percent of stops,

compared to roughly 35 percent of stops for all other racial and ethnicity groups

Overall,

CMAP analysis of 2018 IDOT Traffic Stop Study data. It should be noted that from 2017 to 2018, the Chicago Police

Department, which makes up the largest share of law enforcement traffic stops in the region, increased traffic stops

by more than 70 percent. At the same time, citations issued by the Chicago Police Department were largely flat. Matt

Masterson, “ACLU Report Finds Chicago Police Traffic Stops Jumped by 200K in 2018,” WTTW, December 19, 2019,

https://news.wttw.com/2019/12/19/aclu-report-finds-chicago-police-traffic-stops-jumped-200k-2018

IDOT Illinois Traffic Stop Study data divide the reason for traffic stops into four categories: moving violations,

equipment, license plate/registration, and commercial vehicle.

National Highway Traffic Safety Administration, 2011 National Survey of Speeding Attitudes and Behaviors, December

2013,

https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/2011_n_survey_of_speeding_attitudes_and_behaviors_811865.pdf

There are a number of limitations to using census racial and ethnic share of residential population data as a

benchmark for comparison. One major issue is that driver population likely differs from the residential population.

Utilization of census residential population figures does not account for the fact non-residents of the region also use

the roadways and are stopped by law enforcement. Additionally, members of different racial and ethnic groups in

the region drive at different rates, as indicated by prior CMAP analysis that show white workers in the region drive

alone as their commute mode at a higher rate than Black workers. Chicago Metropolitan Agency for Planning, Travel

Trends: Understanding how our region moves, 2016, https://www.cmap.illinois.gov/documents/10180/517201/FY17-

0012+Travel+Trends+Snapshot/

The Illinois Traffic Stop Study data rely on law enforcement officers to identify the race and ethnicity of stopped

drivers, which may not align with driver racial and ethnic self-identification. Additionally, there is no differentiation

in the data between race and ethnicity, with a single option for “Hispanic or Latino.”

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Figure 11 shows motorists identified as Black are most likely to receive citations on a per capita

basis, receiving 81 citations per 1,000 Black residents in the region compared to an overall rate

of 60 citations per 1,000 residents overall.

Figure 11.

Finding: Motorists identified as Black received more tickets than other motorists

Since traffic violation fines in the region are a fixed amount, irrespective of the driver’s income,

people with low income must pay a larger share of their income than those with higher incomes

for the same violation. They have limited capacity to pay off fines in full and greater difficulty

in using payment plans that require a down payment.

Traffic violation penalties vary greatly in severity depending on the offense, from a small

monetary fine to incarceration. In Illinois, a “minor traffic offense” is either a petty or business

offense under the Illinois Vehicle Code or a similar provision of a local ordinance. Petty offenses

are only punishable by fines below $1,000 and do not carry a potential prison sentence.

Business offenses carry fines above $1,000 and no prison sentence.

Figure 12 provides a selection of common minor traffic offenses and their burden on residents

with low income for illustrative purposes. Penalty amounts were drawn from the Illinois

“Your Guide to Illinois Traffic Courts,” Illinois State Bar Association,

https://www.isba.org/public/guide/illinoistrafficcourts

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Vehicle Code since local government traffic codes across the region are based on the state

framework. Residents with low income have to work longer to pay off penalties compared to

residents with high income for the same offense. It should be noted that court fees, fines, and

costs (collectively known as assessments) may be levied in addition to the traffic violation fine,

which can further increase the disproportionate burden for motorists with low income. The

Criminal Traffic Assessment Act provides that defendants who appear in court for a minor

traffic offense must pay court costs of $226.

Figure 12.

Finding: Residents with low income have to work longer to pay off fines relative to residents

with higher income for the same offense

These fines represent a significant share of income for a family with low income. Table 4 shows

that even for individuals and families earning 60 percent of the median income level, the

highest fines can exceed half of a week’s income. These proportions are greater for individuals

and families with lower incomes.

Illinois Criminal Traffic Assessment Act (705 ILCS 135/15-50).

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Table 4.

Finding: Traffic violation penalties are a significant share of weekly income for drivers with low

income

Fine

amount

Percent of weekly

earnings for a family

with low income

($987.50)

Percent of weekly

earnings for an

individual with low

income ($358)

Selected Illinois Vehicle Code traffic

violations

$600

60.8%

155.8%

Driving without mandatory insurance

$164

16.6%

45.8%

Failure to obey a stop sign

Speeding 1-20 MPH above limit

Head, tail or side light violation or broken

headlight

$100

10.1%

27.9%

Red light camera ticket

Automated speed enforcement: speeding 10+

MPH above limit

$50

5.1%

14.0%

Automated speed enforcement: speeding 6-

10 MPH above limit

$75

7.6%

20.9%

Electronic communication device: first offense

Note: Low-income household defined as earning 60 percent of the 2018 Chicago MSA median income. For illustration, the low-

income threshold for a 3-person family ($51,350 annual, $987.5 weekly) and a 1-person household ($18,616 annual, $358 weekly)

was selected. The $600 fine amount for driving without mandatory insurance includes both the $500 minimum fine (maximum of

$1,000 for the first offence) and the $100 mandatory driver’s license reinstatement fee following the stipulated 3-month license

suspension.

Source: CMAP analysis of Illinois Vehicle Code (625 ILCS 5), Illinois Supreme Court Rule 529, Criminal and Traffic Assessment Act

(705 ILCS 135), and U.S. Census data.

Initial research shows parking ticket fines can be highly inequitable; more

regional data are needed

An important consideration in implementing priced parking is the burden of enforcement and

associated tickets. Without enforcement, people will not pay for parking and it would be

impossible to manage parking demand. Parking violation fine amounts vary by violation type

and can range from lower amounts for expired meters to significantly higher for parking in

prohibited areas or without proper registration. A ProPublica investigation found that eight of

the 10 ZIP codes in Chicago with the most accumulated ticket debt per adult are majority Black

and highlighted how unpaid parking tickets can quickly spiral into personal bankruptcy.

Parking violation fines are experienced by both residents and workers. Delivery drivers, taxi

drivers, and ride-hail drivers are expected to provide quick service. In congested areas,

expediency may mean parking illegally and risking tickets for short-term parking stays. Ride-

hail customers may request pick-up or drop-off in illegal spaces. While some freight delivery

companies pay for their drivers’ parking violations, in many cases, drivers are considered

independent contractors and are responsible for any resulting fines.

Melissa Sanchez and Sandhya Kambhampati, “How Chicago Ticket Debt Sends Black Motorists into Bankruptcy,”

Propublica, February 27, 2018, https://features.propublica.org/driven-into-debt/chicago-ticket-debt-bankruptcy/

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Parking violation fines are instituted across northeastern Illinois to impose penalties for expired

registrations or parking in restricted areas. No regional data source for recipients of parking

violation fines is available; however, data from the City of Chicago are available from

ProPublica. Using this data to analyze the relationship between ticket recipients and incidence,

Figure 13 shows that the drivers who lived in neighborhoods with the lowest quantile of

median household income had the highest incidence of tickets. In this analysis, the ticket

burden fell heavily on the mostly Black south and west sides — with West Englewood’s

proportion of tickets per 1,000 residents being more than three times the city average. More data

are needed to fully understand how parking fines are distributed across drivers of different

income levels in municipalities in other parts of northeastern Illinois.

Figure 13.

Finding: Drivers who lived in neighborhoods with the lowest income levels had the highest

incidence of tickets in Chicago

Transit fares

The region’s public transit system is one of metropolitan Chicago’s most critical assets. The

transit network in northeastern Illinois, which includes service provided by CTA, Metra, and

Pace, is relied on by residents of all backgrounds. But it is especially crucial for the everyday

mobility of residents with low income, residents with disabilities, and people of color in the

region.

Maintaining affordable fares is necessary so that residents may access economic opportunities

as well as conduct the daily business of life. The authority to set fare policy lies with the service

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operators. Under Title VI of the Civil Rights Act of 1964, the Federal Transit Administration

requires that large-scale transit operators, such as those in the region, develop a process for a

fare equity analysis for any proposed changes to fares, fare medium, or fare structures. The

analysis must assess whether fare changes will have a disparate impact on members of a group

identified by race, color, or national origin, or a disproportionate burden that would affect low-

income populations more than other groups. The analysis must determine the number and

percent of users of each fare or fare type, compare fares before and after the change, evaluate

the impact on each protected class, and compare the impact on users with low income to all

users of the system.

Each transit provider develops its own analytical methodologies to comply with Title VI

requirements, which include establishing a threshold for determining when adverse effects are

disproportionate. If a disparate impact or a disproportionate burden is found during the

analysis, transit operators consider other options to avoid, minimize, or mitigate impacts.

In metropolitan Chicago, transit fares for trips vary among the three transit operators and may

even differ among riders who are using the same service to make the same trip. The analysis

below explores the different factors that determine the cost of a full-fare trip and how riders

with low income may be disproportionately impacted. Elements that may change the cost of a

transit trip include:

• distance traveled

• method of payment

• type of fare purchased, for example, a single-use ticket versus an unlimited-ride pass, or

a reduced-fare permit versus full-fare

• number of transfers taken and service providers used

Effectively, two riders on the same bus who both have paid full fare could be paying entirely

different amounts. That said, transit fares are intended to be somewhat horizontally equitable

but they are not vertically equitable, as they constitute a higher percentage of total income for

riders with low income.

Residents with low income use transit for all types of trips

Assessing the vertical equity of transit fares collected in the Chicago region requires an

understanding of who is riding transit and therefore who incurs the cost of service. Data

generated from CMAP’s Activity-Based Model

show that households with low income use

transit more frequently than households with middle and high income. Households with low

CMAP’s Activity-Based Model (ABM) assesses the socioeconomic determinants of travel choice and evaluates

modern transportation solutions. The ABM is founded on the idea that people’s travel behavior is a result of their

daily activities, i.e., the things people need to accomplish dictate where, when, how, and with whom they travel. The

ABM seeks to represent the choices made by individual travelers and generates a schedule of daily activities for

members of every household in the region, and then transforms that information into sequences of trips that occur

throughout the day

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income average 3.1 transit trips on an average Monday through Friday week, while households

with middle and high income average 2.6 and 2.5 transit trips, respectively.

When modeled transit trips are broken down by trip purpose, Figure 14 illustrates that the gap

in transit use between households with low income and other households is more pronounced

for trips that do not include work commutes. Households with middle and high income are

more likely to take transit to commute than for any other purpose. For these households,

commute trips comprise 52 and 61 percent of all transit trips, respectively, while commute trips

comprise just 31 percent of trips for households with low income.

Figure 14.

Finding: Residents with low income use transit most frequently among income groups

Conversely, households with low income are more likely to take transit for all other types of

trips, such as those taken for the purposes of shopping, traveling to school, and accessing other

social and recreational destinations. A household with low income in the region takes 29

percent more of these trips on transit than a household with middle income and 44 percent

more than a household with high income. This is due in part to a higher reliance on transit as a

primary mode of transportation, as households with low income own vehicles at lower rates

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than other households.

It also underscores the importance of ensuring that transit remains

affordable for these residents to live, work, and travel the region as they need.

Transit pass cost can be high relative to rider income

CTA and Pace charge flat fares for boarding a bus or train regardless of trip distance. Whether a

rider travels from 95th Street to Howard or between two adjacent stops, they can expect the fare

to be the same. Metra, however, uses a distance-based fare system to account for the increased

marginal cost of providing long-distance trips. The average trip length on Metra was 22.3 miles

in 2017, as compared to 5.9 miles on CTA rail, 2.5 miles on CTA bus, and 6.4 miles on Pace

bus.

There are 10 fare zones, and fares are determined by the number of zones through which

a rider travels. One-way full-fare tickets range from $4.00 for trips that do not cross zones up to

$9.50 for trips between inner Chicago and the furthest zone.

Like single-trip tickets, the cost of Metra monthly passes scale by distance. Across the three

service boards, the percent of income used to purchase passes can vary significantly by service

operator and by zone for service on Metra. A monthly pass requires a rider to pay more in

advance but can save a rider money if enough rides are taken to recoup the cost, which varies

by trip and operator. For riders with low income, the initial investment can be a substantial

outlay. The annual cost of twelve 30-day Pace passes represents 2.3 percent of income for a

household with low income and 0.7 and 0.4 percent for households with middle and high

income. Figure 15 shows that the percent of income spent on transit increases with the cost of

the pass; to buy a year’s worth of Metra’s Zone A to J (10 zones) monthly passes, a rider with

low income could pay 10.6 percent or more of their annual income, while a rider with high

income might not exceed 1.9 percent of their income.

Chicago Metropolitan Agency for Planning analysis of U.S. Census data and CMAP’s Activity-Based Model.

The Regional Transportation Authority. 2018 Sub-Regional Performance Report. December 2019.

https://www.rtachicago.org/sites/default/files/documents/plansandprograms/2018-Sub-Regional-Report.pdf

In 2018, Metra consolidated the three outmost zones and capped fares for trips that exceed 45 miles. In addition,

Metra’s zone reassignment pilot at this time lowered fares at eight Metra Electric and Rock Island stations

permanently.

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Figure 15.

Finding: The cost of monthly transit passes can constitute between 2.3 and 10.6 percent of

earnings for a rider with low income

Method of payment impacts fare cost

Riders can reduce their base fare payments on CTA and Pace regular fixed routes if they use a

Ventra card to pay their fare instead of cash.

Riders can add cash to their Ventra cards at train

stations, Pace bus terminals with a Ventra vending machine, and qualified retailers, as well as

over the phone, so it is not necessary to have a smartphone to use a Ventra card. However, the

Ventra card is most accessible to riders who have either a debit or credit card and access to the

internet, whether on a computer or a smartphone. Online, riders can link their Ventra card to a

debit or credit card and add funds when they are not physically in a train station or at a retailer.

This is convenient for bus riders who would otherwise have to first travel to a train station, visit

a retailer, or call Ventra if they are out of funds on their Ventra card to avoid paying the

surcharge for cash fare on the bus.

Using a Ventra card can provide significant savings for riders whose trips require numerous

transfers. The card can track transfers, which is not feasible under the current system for cash

payment on buses. For this reason, the geographic availability of retailers that sell Ventra cards

Fare discrepancy based on payment method does not impact all regional transit service. Riders of Pace’s express

routes and Metra pay the same fare whether or not they are paying with Ventra. There are no cost savings for

purchasing a Metra ticket on Ventra versus paying cash.

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is one component assessed under Title VI analysis, and the number of eligible retailers has

expanded in recent years. However, there are still circumstances under which a rider may need

to pay cash. For a trip that includes two bus boardings, this could double the cost.

The barrier most likely to prevent a rider — particularly bus riders — from using Ventra is

being under- or unbanked. To consistently pay lower Ventra fares and transfer costs, under- or

unbanked riders must use cash to load funds to their Ventra card in advance of a trip. If they

are unable to do so, riders who pay cash will pay more than riders who use Ventra to access the

region’s public transportation system, particularly for trips with one or more bus transfers.

Trips with certain transfers can be costly

Transfer costs can add up for riders when they are ineligible for transfer discounts. Riders using

Ventra may transfer for free between Pace and CTA; however, the cost of a trip can increase

significantly if a rider does not have access to a Ventra card. However, there are not currently

any transfer discounts for trips that include Metra if the rider does not have a monthly pass, or

for trips that require a transfer between Metra and CTA outside peak hours.

Metra monthly pass holders may purchase the Metra Link-Up pass for an additional $55 a

month, which allows transfers between Metra and the other service providers. The Metra Link-

Up pass is a monthly unlimited pass that is valid on the CTA between 6:00 and 9:30 a.m. and

between 3:30 and 7:00 p.m., and anytime on Pace. The Link-Up pass is not a viable option for

Metra riders who need a CTA transfer outside of the eligible peak hours. Riders traveling

outside a traditional work schedule, such as shift workers, have to pay the full CTA fare in

addition to the cost of their Metra pass. In 2019, Metra riders purchased 32,500 Link-Up passes,

allowing free transfers on just 3 percent of all monthly passes purchased. The total cost of a

Metra monthly pass and a Metra Link-Up pass could range between $171 and $294.25

depending on the zone. If purchased every month for a year, the total cost can be between 6.6

and 12.8 percent of a rider’s income for those making 30 percent of the MSA median.

The Metra/Pace PlusBus pass is available to Metra monthly pass holders for an additional $30

and offers free transfers between the two operators, regardless of the time of day. In 2019, Metra

riders purchased 12,100 PlusBus passes, allowing for free Pace transfers on 1.2 percent of

monthly passes purchased, although 5 percent of Pace rides include a Metra transfer.

Consequences and outcomes of the impacts of fees,

fines, and fares

The affordability of transportation fees, fines, and fares, along with Illinois’ overall regressive

tax structure, creates significant challenges for residents with low income. When the tax burden

is disproportionately placed on taxpayers with the least financial resources, it further limits

their ability to participate in the economy and can impede their mobility. In metropolitan

Chicago, residents with low income are disproportionately people of color and people with

disabilities.

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In recent years, community groups, advocates, and journalistic accounts within the region have

noted the financial drain that transportation system fines and debt can have on people with low

income and people of color.

Responding to calls for reform, the Office of the City Clerk of

Chicago convened a Fines, Fees, and Access Collaborative in 2019 that jointly developed

recommendations to reform fines, fees, and collections practices.

The city has taken initial

steps to act on these recommendations.

Limiting driver’s license suspensions for unpaid traffic fines has been an area of significant

progress. At the state level, the Transit Table coalition successfully advocated for the enactment

of the License to Work Act, which eliminated driver’s license suspensions for unpaid parking,

compliance, and tollway ticket fines or fees, among other offenses, and provided a path for

license reinstatement.

Additionally, the recently enacted Public Act 101-0652 includes

provisions rescinding holds on license renewal or reinstatement due to failure to pay traffic

violation fines and suspensions due to failure to pay fines from automated speed and red light

cameras. The legislation also prevents both future license suspensions resulting from unpaid

automated camera tickets and license renewal holds due to failure to pay traffic violation fines.

The following provides an overview of the consequences and outcomes of an inequitable

system.

Suppressed mobility diminishes economic opportunity

Transportation plays a key role in creating pathways to opportunity for low-income

communities, people of color, and people with disabilities. However, many neighborhoods with

high concentrations of people of color with low income have strong access to transit but few

jobs nearby, requiring workers to travel longer distances to access employment opportunities. If

transportation to and from job centers is not affordable to residents with low income, or the

burden of traveling long distances is too great, residents may be unable to participate in the

regional economy and lose access to upward economic mobility. When financial constraints

suppress residents’ mobility, they are less able to participate in daily activities and their

community. Improving the affordability of transportation options, alongside concerted local

economic development efforts, can improve access to economic opportunity and quality of life.

Melissa Sanchez and Elliott Ramos, “Chicago Hiked the Cost of Vehicle City Sticker Violations to Boost Revenue.

But It’s Driven More Low-Income, Black Motorists into Debt.” ProPublica and WBEZ Chicago, July 26, 2018,

https://www.propublica.org/article/chicago-vehicle-sticker-law-ticket-price-hike-black-drivers-debt

Office of the City Clerk of Chicago, Chicago Fines, Fees, & Access Collaborative, Advancing Equity: First Steps

Towards Fines & Fees Reform in Chicago, June 2019, https://www.chicityclerk.com/community-affairs/access-

collaborative

City of Chicago, Department of Finance, Debt Relief, September 27, 2019,

https://www.chicago.gov/city/en/depts/fin/provdrs/parking_and_redlightcitationadministration/news/2019/septemb

er/DebtRelief.html

Illinois Public Act 101-0623

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Unpaid fees beget more fees

The unaffordable cost of driving creates mobility challenges for residents with low income,

particularly those who do not have transit access where they live and work. While fees

associated with driving are a small part of the overall cost of driving, the consequences of not

renewing state and local vehicle registrations on time can result in an even greater expense. The

State of Illinois charges an additional $20 for a late registration, and many municipalities also

charge late fees. For example, the City of Chicago’s late fee is $60 after a 30-day grace period, on

top of the $90.88 fee. In addition, driving a vehicle without a registration can result in a ticket

for expired registration; if the ticket is not paid, the driver will be subject to additional late fees.

On June 25, 2020, the Illinois Tollway moved from a punitive system of fines to a system of

invoicing for the first 90 days after an unpaid toll. Instead of an initial $20 fine per missed toll,

customers receive an invoice for a $3.00 fee. An additional $5.00 is charged after 60 days, and

fines are reserved for tolls unpaid after 90 days.

Under the previous system, expenses were

$0.35 per dollar collected (this amount would typically include a $20.00 fine per violation).

This new, more customer-friendly system of seeking small-dollar payments by mail may be

more costly for the Tollway to administer.

Unpaid fines can be financially devastating

Unexpected expenses, such as a traffic violation fine, can cause financial devastation to people

with low income living paycheck to paycheck. Federal Reserve research indicates that

nationwide, a significant fraction of adults are in financially precarious situations. Survey

results from 2018 found 3 in 10 adults are either unable to pay their monthly bills or are one

modest financial setback away from hardship.

People with low income are disproportionately impacted by the escalating consequences of

receiving a traffic violation fine they are unable to pay. Traffic fines can compound to become a

major source of debt and a barrier to employment for residents with low income. Potential

negative outcomes include facing a debt spiral and bankruptcy, tax garnishment, license

suspensions, vehicles impoundment, employment prohibition, and credit score damage.

Debt spiral and bankruptcy

To encourage prompt repayment of traffic violations, many governments in the region have

instituted an escalating ladder of consequences, starting with late fees. One example is the City

Illinois Tollway, “Illinois Tollway Launches Tolling Reform and Relief Package,” June 25, 2020,

https://www.illinoistollway.com/media-center/inside-the-tollway?urlTitle=illinois-tollway-launches-tolling-reform-

and-relief-packageentryId856702entryId.

Illinois Tollway (Mike Colsch), Video Tolling and Collections, March 2017,

https://www.illinoistollway.com/documents/20184/532181/20170313_CSPVideoTolling.pdf/24556ba4-7001-47e0-ad73-

333b83ec3194?version=1.0.

Board of Governors of the Federal Reserve System, Report on the Economic Well-Being of U.S. Households in 2018,

May 2019, https://www.federalreserve.gov/publications/2019-economic-well-being-of-us-households-in-2018-

dealing-with-unexpected-expenses.htm

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of Chicago’s policy of doubling fines and the accrual of additional fees if tickets go unpaid.

Recent reforms in Chicago have eliminated doubling unpaid fines for not displaying a city

sticker, replacing this late repayment penalty with a $50 late fee. However, moving violations

are not covered by the reform and still incur doubling of fines.

For the most vulnerable

populations, unpaid debt can snowball, resulting in further hardships. Analysis of Chicago

ticket data by the Woodstock Institute also found that tickets issued to drivers living in low- to

moderate-income ZIP codes were more likely to go unpaid.

Academic research has even

suggested that parking ticket and fine debt is one of the largest drivers of bankruptcies by Black

residents in Cook County.

Tax garnishment

In 2012, the State of Illinois created the Local Debt Recovery Program, which provided local

units of government a new avenue to collect unpaid fees and fines. The Illinois Office of the

Comptroller assists local governments by withholding the debt amounts from residents’ tax

refunds, lottery payouts, and payroll checks. Press accounts indicate that in 2018, the program

led to $40 million garnished from debtors’ state tax refunds.

Analysis of tax refund

garnishments initiated by the City of Chicago found that 73 percent were for unpaid parking

tickets.

Vehicle impoundment

Following efforts to recoup unpaid ticket fines from motorists, local governments are able to

seize or immobilize vehicles as further penalty. This can lead to a variety of fees, including fees

to remove an immobilization device (boot), fees for the towing of a vehicle, and daily fees while

a vehicle is in a tow lot. In the end, motorists unable to pay off tickets can face a double financial

hit of significant fees accrued and the loss of a vehicle.

Even when the car is sold, some local

governments do not apply any of the sale proceeds to reduce the underlying traffic fine debt

owed by the motorist.

Municipal Code of Chicago, 9-100-050(e)

Woodstock Institute, The Debt Spiral: How Chicago’s Vehicle Ticketing Practices Unfairly Burden Low-Income and

Minority Communities, June 2018, https://woodstockinst.org/wp-content/uploads/2018/06/The-Debt-Spiral-How-

Chicagos-Vehicle-Ticketing-Practices-Unfairly-Burden-Low-Income-and-Minority-Communities-June-2018.pdf

Edward R. Morrison and Antoine Uettwiller, “Consumer Bankruptcy Pathologies“ (working paper, Journal of

Institutional & Theoretical Economics; Columbia Law and Economics September 2016).

Chris Kaergard, ”Local governments recoup $450,000 from state debt-collection program,“ Journal Star, February

19, 2019, https://www.pjstar.com/news/20190219/local-governments-recoup-450000-from-state-debt-collection-

program

Woodstock Institute, The Debt Spiral: How Chicago’s Vehicle Ticketing Practices Unfairly Burden Low-Income and

Minority Communities, June 2018, https://woodstockinst.org/wp-content/uploads/2018/06/The-Debt-Spiral-How-

Chicagos-Vehicle-Ticketing-Practices-Unfairly-Burden-Low-Income-and-Minority-Communities-June-2018.pdf

Elliott Ramos, “Chicago’s Towing Program Is Broken,” WBEZ Chicago, April 1, 2019,

http://interactive.wbez.org/brokentowing/#group-many-paths-to-impounds-wwbn6rr9WG

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Employment restrictions

As a tool to spur repayment, some governments may prohibit employment to residents who

owe unpaid debts. For instance, the City of Chicago has restrictions on hiring residents owing

money to the city and related entities until the debt has been paid. Other entities, such as

Chicago Public Schools and the CTA, have similar policies.

There are some exceptions,

including if a person has entered into a debt repayment plan and is in compliance. Nonetheless,

for residents in communities with limited employment prospects, this can represent a

significant hurdle to employment and eventual repayment.

Credit score damage

Municipalities have the option to send unpaid ticket debt to collection agencies. This can lead to

negative ramifications for motorists’ credit scores — a crucial metric that can affect

homeownership and apartment lease applications, employment, and business loans.

Existing fee and fare programs

Northeastern Illinois has several programs and policies to reduce the burden of transportation

fees, fines, and fares. These programs are relatively limited in scope and are primarily focused

on transit service, but they do alleviate costs for households and residents who qualify.

I-PASS Assist

I-PASS Assist provides Medicaid or Supplemental Nutrition Assistance Program (SNAP)

eligible drivers with the ability to obtain an I-PASS account by just adding $10 in prepaid tolls

to the account, rather than $20. The $10 deposit for the transponder still applies. This program

accounts for approximately 2,500 I-PASS accounts out of about 5.5 million total accounts. The

program is only available at Tollway Customer Service Centers. It is unclear whether the

program sufficiently addresses the needs of drivers with low income, due to the limited

opportunities to access the program and the necessity of providing funds up front. However,

the Tollway is currently considering measures to address equity as part of its plan to make

cashless tolling practices permanent.

Ride free permits

The RTA manages two types of transit ride free permits as required by law, one program for

eligible seniors and a second for riders with disabilities. To be eligible for either program, riders

must be enrolled in the Illinois Department on Aging’s Benefit Access Program. Eligibility for

both programs is based on household size and income. One-person households are eligible up

to an annual income of $33,562, two-person households are eligible up to $44,533, and

households of three or more are eligible up to $55,500. In the second quarter of 2019, there were

90,000 active senior passes and 60,000 active passes for users with disabilities.

Approximately

Chicago Municipal Code, 2-152-150, Applicants for employment – Disclosure of indebtedness to city.

Active Transportation Alliance, Fair Fares Chicagoland: Recommendations for a More Equitable Transit System,

November 2019, https://activetrans.org/busreports/wp-content/uploads/2019/11/Fair-Fares-Chicagoland.pdf

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10 percent of trips on the CTA, 1.4 percent of trips on Metra, and 16 percent of trips on Pace

fixed-route service were purchased with a ride free permit in 2019.

To receive a ride free permit, applicants must apply using a valid government-issued picture

identification card and a printed wallet-sized photo. Completing the written application may be

difficult to some eligible residents. Free permits are available to qualifying military personnel

on CTA services, and active duty military personnel ride at no cost on Pace.

Reduced fare permits

The three service operators in northeastern Illinois each offer reduced fares to qualifying

reduced fare permit holders. Based on the type of fixed-route service and whether Ventra or

cash is used for payment, a reduced fare pass entitles the rider to a discount between 49 and 55

percent. Per federal law, the following groups are eligible for reduced fares: all seniors 65 and

older, Medicare cardholders, qualifying disabled riders, and those eligible for the ADA

Paratransit Reduced Fare Permit. Reduced permits are also available to qualifying military

personnel on Metra.

During the second quarter of 2019, there were 205,000 active senior reduced passes and an

additional 9,000 reduced passes for riders eligible under one or more of the other criteria.

2019, just under 6 percent of trips on CTA, an estimated 6 percent of trips on Metra, and 14

percent of Pace fixed-route trips were purchased with a reduced fare permit. Providing reduced

fares to all seniors is a regressive use of public funds, as ability to pay is not considered in

eligibility for the benefit. However, this fare policy may provide other benefits that are difficult

to quantify.

In addition, children aged six and under ride free, and children aged seven to eleven are eligible

for reduced fares. Metra allows full-time students enrolled in an accredited grade school or high

school to purchase a reduced one-way, 10-ride or monthly pass. On the CTA system,

elementary and high school students aged 12 to 20 may use a student Ventra card for reduced

fares Monday through Friday, 5:30 a.m. through 8:30 p.m. on school days. For Pace service,

students can use a student Ventra card without school-hour restrictions. These reduced fares are

provided regardless of the rider’s household income. Full-time college students at participating

institutions are eligible for CTA’s U-Pass, which provides unlimited CTA rides while school is

in session. Pace’s Campus Connection Pass is available to college students for a fee and

provides unlimited rides on non-premium routes. The pass is valid by semester.

Transit Benefit Fare Program

The RTA and CTA both offer employee benefit programs through enrolled employers in

metropolitan Chicago that allow employees to pay for transit fares with pre-tax dollars, either

as preloaded funds on a Ventra card or on the RTA’s Transit Benefit Prepaid MasterCard. As of

2018, there were 1,350 enrolled employers in the RTA’s program with approximately 19,000

Ibid.

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eligible employees.

Other employers, particularly large employers, may offer and administer

their own commuter benefit program that provides the same pre-tax benefits.

Riders enrolled in the programs save on commuting costs by reducing their pre-tax earnings by

the amount set aside for commuting costs. Savings for participating in the program are higher

for riders with lower income, as the amount spent on transit constitutes a higher portion of total

income. The RTA estimates that riders making under $30,650 annually who purchase a $105 30-

day CTA and Pace unlimited ride pass will save $25.88 monthly, or 25 percent of the pass cost.

However, access to the savings afforded by the Transit Benefit Fare Program is not equal. Not

all employers participate, so not all riders with low income, or riders regardless of income,

particularly those who are unemployed, have access to this program. To address these

disparities, some cities, including Washington D.C., San Francisco, and New York, have enacted

local ordinances that require employers with 20 or more employees to provide pre-tax

commuter benefits. However, these requirements still exclude workers at small companies or

organizations and may not be available to workers who are under- or unemployed. In Illinois,

there have been recent but unsuccessful efforts to legislate similar requirements of smaller

employers.

Recommendations

ON TO 2050’s principles of inclusive growth, resilience, and prioritized investment support the

need to alleviate the impacts and consequences of transportation fees, fines, and fares.

A transportation system that works better for everyone will help ensure all residents are

included in the region’s economy, regardless of race or income. The burden of funding the

transportation system should not disproportionately fall on residents with low income.

Moreover, fees and fares should be structured and administered so that residents are able to

pay them and avoid consequences such as late fines.

Reducing impacts of transportation fees, fines, and fares on residents with low income will

require state and local governments to prioritize actions and investments to help these

residents. Making investments to pursue these strategies will need to be balanced with the need

to fund an accessible, multimodal transportation system. CMAP considered a variety of

strategies to determine which recommendations would best meet the goal of reducing these

impacts. Evaluations of strategies included data analysis, research, and interviews with experts

and other stakeholders. Each strategy was assessed through several lenses, to varying degrees,

depending on its applicability to the strategy in question.

A key component of the evaluation was to determine the strategy’s impact on residents with

low income, both in terms of the amount of residents who would be impacted and in terms of

Regional Transportation Authority. 2019 Operating Budget, Two-Year Financial Plan and Five-Year Capital Program.

2018.

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degree of benefit on impacted residents. Many of the strategies would reduce the revenues

available to the transportation system. This factor was balanced with the need to avoid reducing

investments in the system, which could have the consequence of actually reducing mobility

options to the detriment of residents with low income. Relatedly, some strategies could be

expensive or complex to administer. As such, ease of administration was weighed against the

actual impact of the strategy.

ON TO 2050 recommends that the transportation system be funded through user fees. As such,

the evaluation considered whether the strategy would uphold the benefit principle, where users

of the system pay according to the benefits they receive. Finally, the evaluation considered

whether goals met by complex strategies could be accomplished by simpler policies.

Recommendations based on these considerations and the resource group’s priorities are as

follows:

Improve mobility options

The region should increase access to lower-cost transportation options, including transit, bicycle

and pedestrian options, and shared mobility such as vanpooling, where transportation

resources are shared among users. Expenses related to vehicle ownership, including the vehicle

itself, maintenance, and fuel, typically exceed $8,000 annually.

A more equitable

transportation system should provide residents with options for traveling throughout the

region via transit, walking, or biking without a personal vehicle. These investments can provide

mobility alternatives for residents as well as freelance delivery drivers who may earn low

wages. Alternatives to driving can be made accessible and attractive without making driving

financially punitive to residents with low income. In addition, roadway safety improvements

and the construction of bike and pedestrian pathways in disinvested communities of color

would improve safety outcomes without increased enforcement.

The region has already made some progress on furthering investments to improve mobility

options. For example, since the 2019 rate increase, a portion of the MFT goes toward transit

improvements. Moreover, these investments in infrastructure to support non-driving modes

should be made in a performance-driven manner that focuses on mobility options in

economically disconnected areas. These include:

• Making investments to improve reliability and availability of transit

• Expanding access to options like mobility as a service, which allows users to plan and

pay for trips that require multiple providers in one place

U.S. Bureau of Labor Statistics, Consumer Expenditure Survey, 2018.

Vision Zero Network, Vision Zero Equity Strategies for Practitioners, May 2017, http://visionzeronetwork.org/wp-

content/uploads/2017/05/VisionZero_Equity.pdf

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• Enhancing bicycle and pedestrian infrastructure to provide mobility options that do not

require paying fees, fines, and fares

• Expanding opportunities to use cargo bicycles in high-density areas for last-mile

deliveries of food, packages, and small freight items, to decrease congestion, manage

curb space, and reduce necessity for delivery drivers to pay fees and fines

Implement progressive tax strategies

The transportation system should be funded through user fees, which impose a tax burden

based on the benefits that the taxpayer receives. User fees and excise taxes like the motor fuel

tax function as part of the tax system as a whole, where every broad-based tax imposed without

basis in income level has the potential to be regressive. This approach to funding the

transportation system makes it important to focus on other methods to make the overall tax

system less regressive. The most effective ways to reduce the regressiveness of transportation

fees, fines, and fares, as well as other sales and excise taxes, would be to introduce more

progressivity into the income tax.

The State should approve legislation to mitigate the regressiveness of transportation fees, fines,

and fares through introducing more progressivity into the income tax. The following strategies

are options for making Illinois’ overall tax system less regressive:

• Increase the standard state income tax exemption from $2,275 per individual

• Increase the value of the state earned income tax credit from 18 percent of the federal

credit

• Expand eligibility for the state earned income tax credit beyond federal eligibility

• Impose graduated income tax rates to reduce the burden for lower income brackets

The State could implement these strategies in a number of ways by using different amounts,

rates, and eligibility requirements. Figure 16 shows how a graduated rate structure or an

increase in the personal exemption would impact effective tax rates for a family of four, relative

to the current structure.

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Figure 16.

Finding: Implementing different tax strategies could lower the tax burden for households with

low to moderate income

As Figure 17 illustrates, most Illinois taxpayers have less than $50,000 in taxable income, which

means that they would disproportionately benefit from these changes to the structure,

regardless of the specific levels that are implemented.

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Figure 17.

Finding: The majority of taxpayers in Illinois have income less than $50,000

Make transportation fees for households with low

income more affordable

Fees and fares are intended to capture the cost of using the transportation network.

Accordingly, motor vehicle registration fees are not intended to reduce vehicle ownership, nor

are transit fares intended to discourage use of the transit system. And, as discussed previously,

transit fares do not currently cover the full cost of providing transit service. As such, they

should not be overly burdensome to households with low income. Households with low

income rely heavily on the transit system, making their ability to pay transit fares an integral

part of affordable mobility. As the state and the region look toward new user fees for the

transportation system, such as TNC fees, it is important to ensure that these fees can capture the

cost of using the transportation network while achieving equity goals.

However, increasing affordability of fees and fares reduces the revenues available for the

transportation network. The transit system is under funding constraints that make lowering

costs for residents with low income challenging, while lowering vehicle registration fees would

have a fiscal impact to the roadway network. If a new TNC fee were adopted to provide

additional funding, measures to increase affordability would reduce its ability to generate

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revenue. The following strategies are intended to prioritize ways to increase affordability, given

the inherent tradeoffs for regional mobility.

Expand reduced fare permits

The State of Illinois and the RTA should implement a means test to expand access to reduced

fare permits. Such a program could be implemented at the state or regional level, although the

authority to set the reduced prices lies with the service operators. CMAP’s activity-based

model estimates that expanding the reduced fare permit to residents with low income would

result in these residents taking 15 percent more transit trips.

Many major metropolitan areas

that offer reduced fare permits for riders with low income use the federal poverty level and

verify income through tax returns or eligibility in other means-tested programs like SNAP with

income thresholds at or below the program’s requirements. Seattle, San Francisco, and Portland

use 200 percent of federal poverty levels, Denver uses 185 percent, and New York City uses 100

percent. To make the program most accessible to residents with low income, criteria for

residents of northeastern Illinois should use 200 percent of the federal poverty level, which is

$25,200 for a family of four. This would apply to residents between the ages of 18 and 64. If

implemented, an estimated 1,160,000

or 13.6 percent of residents in metropolitan Chicago

would be eligible for participation.

Implementing an expansion to the reduced fare permit would require an ongoing and

dependable revenue source to fully compensate the service boards for the lost revenue from

providing lower fares. Depending on the resulting changes in ridership, it is possible the service

boards would need to provide additional service, which could also increase operating expenses.

Identifying stable sources that are not subject to legislative appropriation reductions would

better support this expansion than a model similar to the existing appropriations for mandatory

free and reduced fare programs. In addition, expanding reduced fares would decrease fare

revenue without a corresponding reduction in operating costs, which would leave the recovery

ratio lower than required by state statute. With regard to this expense, legislation should clarify

that associated costs be considered an approved adjustment to the recovery ratio to avoid a base

fare increase for other riders or service cuts.

In addition to the significant cost of subsidizing fares, this program would result in additional

administrative costs to expand the existing reduced fare program. These costs would depend on

whether RTA could process applications and verify income or leverage an existing means-

tested program like the Benefit Access Program run by the Department of Aging.

Estimate is for weekdays only.

Estimate is inclusive of all seven counties in the CMAP region, whereas a program would likely only cover the RTA

service territory. Note also that this estimate includes residents with low income who may already have a reduced

fare permit if they have a qualifying disability.

Chicago Metropolitan Agency for Planning analysis of 2018 Consumer Expenditure Survey microdata.

For more information, see Illinois Department of Aging, Benefit Access Program,

https://www2.illinois.gov/aging/BenefitsAccess/Pages/default.aspx

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Additionally, to increase accessibility, the program should offer the option of verification using

enrollment in other means-tested programs at or below this level to whatever extent possible.

Expand reduced vehicle registration fees

The State of Illinois should approve legislation to impose lower vehicle registration fees on

drivers who meet income-based criteria, potentially through expanding an existing program

like the Benefit Access Program run by the Department of Aging for seniors and people with

disabilities who have low income. The existing registration discount could be expanded to

anyone meeting the income criteria, not just seniors and people with disabilities; alternatively,

income criteria tied to the federal poverty level could be established. Currently, the program

brings the fee for a passenger vehicle down to $24 from $151. The challenge of lowering the fee

to this amount for all households with low income would be the potential fiscal impact on the

transportation network, particularly for the Illinois Department of Transportation. In addition, a

portion of these revenues accrue to the Road Fund, which is also used to repay bonds.

Vary state and local vehicle registration fees based on vehicle value

The State should make approving legislation to change the structure of vehicle registration fees

a long-term goal for fee reform. To the extent that there is a relationship between residents with

low income and vehicle value, basing fees on the value of vehicles could provide relief for

households with low income. Vehicle registration fees calculated by value also allow residents

to deduct the fee on their federal income taxes if the taxpayer itemizes.

The specific amount of relief to drivers with low income would depend upon the specific rate

structure. The rates should be structured in such a way to ensure the policy change is revenue

neutral. The challenge would be that the distribution of low- and high-value vehicles may not

remain stable in the long term. Such a restructure may also conflict with provisions in the

Illinois state constitution that prohibit taxes on personal property.

A vehicle registration fee is intended to be a user fee for the transportation system. However, it

is already an imperfect user fee, as vehicle owners derive a variety of benefits from the

transportation system, while the fee itself is flat. This impreciseness as a transportation user fee

would continue if the fee varied by vehicle value, a measure that also does not correlate to a

vehicle owner’s use of the transportation system.

Implementing this structure would be more administratively complex than the current flat rate

for passenger vehicles. However, approximately a dozen other states employ this structure.

Most states have thresholds for vehicle value established through the manufacturer's suggested

retail price at the time the vehicle is first titled, and decrease the value by a set percentage every

year. Some states’ rates are imposed via value thresholds, so the rate is the same for all vehicles

within the same threshold.

Illinois Const., art. IX, § 5

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Ensure any new TNC fees support regional transit goals

If a state or a regional TNC fee were to be enacted through state law, it should pursue equitable

outcomes through supporting regional transit goals. One such option could reduce TNC fees on

rides that serve as connections to transit when other transit options are not available, such as

during off-peak hours or in areas with inadequate first- and last-mile connections. Such a

design furthers regional goals for transit ridership and, if reduced fare permits were expanded,

also leverages existing resources dedicated to making the region’s transportation network more

equitable. However, implementing a fee that incentivizes transit is not possible without a fully

integrated transit fare payment system. To ensure the efficacy of such a fee, efforts should first

focus on working towards full fare integration, so that any future TNC fee can leverage this

technology.

Ensure households with low income can access tools

that provide lower costs

Northeastern Illinois residents have several ways they can lower the fees and fares they pay, but

many residents are unable to access these tools. For residents with low income, it can be

challenging to pay upfront costs and deposits associated with Ventra and I-PASS. The region

should seek to further remove these barriers and others that may arise if the state implemented

a road usage charge. Similarly, many residents benefit from income tax reductions on the

money they spend on transit fares, but residents who do not work for a participating employer

cannot take advantage of this savings. This recommendation provides strategies for making

these tools more accessible to all households, which would benefit households with low income

in particular.

Encourage employers to participate in the Transit Benefit Fare Program

Riders enrolled in the RTA’s and CTA’s employee benefit programs save money by reducing

their pre-tax earnings by the amount set aside for commuting costs. To increase access to the

program, the State of Illinois should approve legislation to require employers of a certain size in

the region to offer the benefit to employees.

While participation in the program does not address the cost of fares directly, it can reduce a

transit rider’s cost to access the transit network. Savings for participating in the program are

proportionally higher for riders with lower income. However, these benefits are only available

as an option to employees whose employer has registered for the program. In addition to rider

savings, benefits accrue for participating employers who can reduce their payroll taxes. Overall,

when the region does not take full advantage of the program, it does not fully realize the

potential benefits of a reduced federal tax burden.

Legislative efforts to accomplish this include House Bill 2802, 100th General Assembly and House Bill 2533, 101st

General Assembly.

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Other cities that require employer participation in similar transit benefit programs, such as New

York City, San Francisco, and Washington, D.C., have pursued implementation at the local

level. Such a piecemeal approach is not appropriate for metropolitan Chicago due to the

regionally-integrated nature of the public transportation system. Any efforts to require

participation should encompass the entire RTA service area.

Bolster efforts that help riders access Ventra

Since the introduction of Ventra, the RTA and the transit agencies have undertaken significant

efforts to distribute Ventra cards so that all riders can access the card’s financial benefits, such

as reduced and free transfers on eligible trips. The region should continue to support ongoing

efforts to provide free Ventra cards to riders with low income either through direct support or

helping to recruit community sponsorships.

Develop a lower-cost alternative to I-PASS transponders

One of the barriers to more widespread availability of I-PASS accounts is the high cost of the

physical transponders (approximately $7 each), in addition to high distribution costs. The

Tollway should pursue lower-cost alternatives to facilitate broader distribution of account tags.

A lower-cost tag may also reduce the need for the $10 deposit now required for transponders.

Moving to a new system for toll tags will have one-time substantial expenses for tag

distribution and setting up the infrastructure to accept such tags. However, in the long term,

alternatives to the current technology may reduce the infrastructure necessary for toll collection

and reduce the administrative burden of tolling.

Waive any road usage charge equipment cost

If the State of Illinois approves legislation to implement a road usage charge, it may require

plug-in devices, transponders, or other equipment to administer. For those vehicles that do not

have this equipment, the state should provide it for free to all who need it to alleviate the

burden of obtaining this equipment, by building the cost of the technology into the overall

program design. While the state may offer a road usage charge structure that does not require

equipment, rates under such a plan could be more costly per mile, like the Illinois Tollway toll

rate structure for cash tolls, or may be imposed on out-of-state mileage. Many vehicles will

likely be already equipped with appropriate technology for determining the number of miles

driven.

Pilot initiatives that coordinate fee and fare collection

Residents of northeastern Illinois must navigate a multitude of public agencies to pay their

public costs of the transportation network via various fees and fares. Many state vehicle fees,

like driver’s license, registration, and title, are paid to the Illinois Secretary of State (ILSOS),

while local vehicle license fees are paid to the municipality and tolls are paid to the Illinois

Tollway.

If a traveler does not pay a fee, they will receive a late fee, and eventually a fine that

Cook County collects its own vehicle license fee for unincorporated residents, called a wheel tax. See Cook County

Ordinances, Section 74, Article XIV.

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sometimes must be paid to a completely different jurisdiction. Meanwhile, transit fares are paid

to CTA, Metra, and Pace, and fare evasion is a misdemeanor under state law.

Making it easier for travelers to pay fees and fares will increase compliance and may even

reduce the incidence of late fees and fines. While there are many potential opportunities to

coordinate fee and fare collection, the following are several recommended strategies toward

achieving that goal.

Increase availability of I-PASS accounts, including to unbanked households

The Tollway should work to increase I-PASS availability through piloting a program to make I-

PASS available at ILSOS facilities or at additional retail outlets. Tollway customers without I-

PASS accounts pay double the rate of account holders. Furthermore, when customers without

accounts do not quickly pay online, the customer will incur increasing fees.

Expanding I-PASS

use is a critical first step to pursuing future opportunities for innovative programs to help

drivers, including those with low income. Ensuring that more customers have I-PASS accounts,

thus availing them of the lowest tolls, would realize the potential benefits of tolling while

improving affordability.

Efforts to make I-PASS more available should include improving service for unbanked

households, such as allowing customers to add cash to I-PASS accounts at more retailers and

other facilities. I-PASS is currently available via the website and Jewel-Osco stores, making it

less accessible to some drivers with low income. In addition, managing online service accounts

like I-PASS is often a challenge for unbanked households, which tend to have lower incomes

than other households. In the long term, future partnerships between the Tollway and the CTA

could provide residents with the ability to use tools like Ventra to pay tolls, or replenish I-PASS

through Ventra accounts or directly through Ventra machines. The administrative cost of

increasing the functionality of I-PASS accounts for unbanked households may be substantial,

depending on how the cash is handled and any arrangements with retailers. Automating this

process through a system like Ventra may reduce this additional administrative burden.

The financial impact of expanding I-PASS availability is likely to be moderate, but not

negligible. Potential additional costs would include the minor administrative cost of arranging

expanded outlets. Revenues may be lower if more customers have I-PASS accounts. However,

these negative impacts may be partially offset by administrative cost reductions from

processing pay-by-plate transactions, invoices, and fines. A minor but perhaps negligible

increase in revenue is also possible if the Tollway is more customer-friendly for people with

lower income.

Allow local fees to be paid at Illinois Secretary of State

Vehicle owners may be less likely to incur late fees and fines from local vehicle licenses if they

could pay these fees while registering their vehicle with the ILSOS. Instead of municipalities

These fees were substantially reduced in 2020 as a part of an Illinois Tollway initiative to change their processes by

initially issuing invoices rather than violation notices for unpaid tolls.

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across Illinois administering their own local vehicle fee programs, the ILSOS could administer

them. This should begin as a pilot program, with an initial rollout to a subset of ILSOS offices to

determine the most efficacious approach. This would result in additional administrative

burdens on the ILSOS, requiring investments in technology and training. These investments

could be made through allowing the agency to keep a portion of the revenue as an

administrative fee, similar to how the Illinois Department of Revenue administers local taxes.

The North Carolina Department of Motor Vehicles has a similar program, where drivers can

pay their state registration fees, along with their local vehicle property tax.

Implement full fare integration across service providers

ON TO 2050 calls for the region to continue to coordinate transfers, payment, and fares between

transit services and other modes of transportation.

This strategy represents a long-term goal

for the region that would enable residents to pay one fare for trips that use multiple providers,

as well as transfer seamlessly between transit and other mobility providers in northeastern

Illinois. Efforts towards full fare integration are already underway in several areas. As a

universal fare payment system, the Ventra platform has enabled the region to make significant

progress on fare integration; passes for all three transit agencies may be purchased through the

app, riders can seamlessly receive transfer discounts on trips that include both Pace and CTA,

and other mobility options can be integrated, such as Divvy or TNCs. Further work on this

topic area will need to address recouping lost revenue due to fare payment changes. Revenue-

sharing agreements developed for existing features and products, such as transfers between

Pace and CTA or the Metra Link-Up pass, provide potential models for future transfer

arrangements and revenue-sharing options. Continued coordination on similar efforts will be

crucial to finding long-term revenue solutions that can enable riders to use the region’s transit

network without paying multiple fares to multiple providers

Make paying for parking more feasible for both

residents and delivery drivers

Parking tends to be priced in only the highest activity areas and is otherwise generally free in

our region. The principal improvements in equity come when people are given a choice to drive

to their destination and to pay for parking or not. Highly congested areas can benefit from

setting aside some spaces for pick-ups, drop-offs, and deliveries — particularly during peak

periods. Ensuring that short-term curb access in high-demand areas can be paid for with

various payment options and limited transaction fees would help serve the people who are

working in their cars and those who do not have credit cards.

Designate short-term loading and standing spaces with reduced transaction fees

To improve compliance and reduce parking ticket fines for short-term parkers and delivery

drivers, municipalities should reduce or waive transaction fees for short-term parking.

Transaction fees vary by municipality, but typically range between $0.25 and $0.50. For short-

Chicago Metropolitan Agency for Planning, ON TO 2050, 2018,

https://www.cmap.illinois.gov/2050/mobility/transit#Coordinationprogress

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term parking, this can be a relatively large proportion of the cost of parking. While this could

drive up administrative costs, greater compliance would increase parking revenue.

Ensure multiple payment options for drivers without credit cards

Municipalities should create payment programs with payboxes that allow for cash payments or

parking cards that can be loaded with cash but do not have surcharges or restrictions like

prepaid debit cards. While the cost to collect cash payments can be more expensive, this

strategy would ensure unbanked drivers were able to pay for their parking and reduce the

incidence of parking fines.

Implement traffic and parking violation fine reform

State and local governments should implement a package of traffic and parking violation fine

reforms to address the disproportionately high financial burden for households with low

income that can lead to late fees, high debt levels, bankruptcy, and other negative impacts. On

their own, fines that incorporate ability to pay and other reforms do not mitigate the harms to

those burdened by historic and current fine practices, particularly for communities of color.

Due to the equity challenges of the current fine structure, it is critical that reform

implementation begins with an initial amnesty program that automatically gives those in fine

debt an opportunity to both pay their fines without accumulated late fees and take advantage of

new policies. The Illinois Tollway included an amnesty period as part of their tolling reform

package, TOLLING 2020.

In the first 60 days following the launch, the Tollway cleared about

65,000 outstanding violation notices — about seven times the number cleared during a similar

time period in a 2009 amnesty program.

As of February 2021, nearly 23 percent of all

outstanding violation notices have been cleared by Tollway customers.

In addition, effectively pursuing these reforms may require local jurisdictions to refocus their

goals around fines. Traffic violation fine amounts should be set to promote safety outcomes and

are not appropriate as a revenue generator. While changes to fine amounts and structures can

reduce the need to layer additional punitive measures to incentivize repayments, state and local

governments should reform both the structure of fines and consequences to nonpayment.

Significant input from marginalized communities will be required for equitable enforcement

programs and reforms, as well as carefully improving the roadways design and infrastructure.

The following strategies should be components of fine reforms.

Illinois Tollway, “Illinois Tollway Launches Tolling Reform and Relief Package,” June 2020,

https://www.illinoistollway.com/media-center/inside-the-tollway?urlTitle=illinois-tollway-launches-tolling-reform-

and-relief-packageentryId856702entryId.

Illinois Tollway, “Illinois Tollway Extends Popular Toll Violation Relief Program Through June 30, 2021,”

December 2020, https://www.illinoistollway.com/documents/20184/d51d953f-8350-ecd7-596a-

aa0b3965774a#:~:text=Under%20the%20violation%20relief%20program,collections%20for%20outstanding%20toll%20

violations.

Illinois Tollway, “Cashless Tolling - What Customers Need To Know,” February 2021.

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Integrate ability to pay through income-based fines or ability to pay waivers

A direct way to reduce the inequity of traffic violation fines is to adjust the fine amount by an

individual’s income. The State of Illinois should approve legislation to incorporate a driver’s

financial means in fine amounts through either income-based fines or extend the ability to pay

waiver framework of the Criminal and Traffic Assessment Act to cover traffic fines and

assessments. A move to income-based fines would require changes to state law concerning fine

minimums and maximums as well as significant changes to current court operations. The

Criminal and Traffic Assessment Act has a sunset provision for January 1, 2022. As renewal

legislation is reconsidered, it would be an appropriate time to also pursue an income-based fine

pilot and/or an ability to pay waiver for traffic fines.

Multiple stakeholders at the state, county, and local levels would need to align to move to either

system. Courts are especially relevant, given they presently handle fine collection. As such, a

few courts within the region could launch an income-based pilot, with an academic evaluation

component, to evaluate the policy and assess implementation concerns. A pilot program would

require state legislation to allow jurisdictions to impose fines that may be less than the current

minimum fine amounts. Expanding waivers would involve smaller operational changes than

income-based fines and would be easier to implement in the near term without a pilot. As with

all means-tested programs, ensuring the participation of eligible populations and designing

accessible waiver paperwork would be crucial components.

One of the most common forms of income-based fines are “day fines.” Day fines are typically

calculated by multiplying two components: the offender’s daily income and a unit representing

the gravity of the offense.

In the United States, several jurisdictions have piloted day fines,

primarily in the 1980s and 1990s, with a number receiving positive evaluations; however,

CMAP did not identify a jurisdiction currently employing day fines.

The other approach is creating an ability to pay waiver system that reduces fines for those who

can demonstrate low income. A number of states, including California and Texas, have recently

passed legislation requiring judges to assess ability to pay when imposing court fines and

provide payment accommodations for eligible parties. Illinois already has a similar waiver

system in place for parts of the criminal legal system. The 2018 Criminal and Traffic Assessment

Act

aimed to reduce the burden of court costs and expanded a state waiver program to cover

residents with an income below 400 percent of the poverty level or residents in a qualifying

National Institute of Justice, Alternatives to Custodial Supervision: The Day Fine, May 2010,

https://www.ncjrs.gov/pdffiles1/nij/grants/230401.pdf

United States jurisdictions that have initiated day fine pilots include: Criminal Court of Richmond County, Staten

Island, New York; Milwaukee Municipal Court, Wisconsin; Maricopa County, Arizona; Polk County, Iowa;

Bridgeport, Connecticut; and Coos, Josephine, Malheur, and Marion Counties, Oregon. In 2019, an ordinance

launching a day fine pilot in New York City covering civil offences was introduced.

Illinois Public Act 100-0987

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means-tested program. Notably, the legislation excluded Illinois Vehicle Code violations from

waiver eligibility.

Adopting income-based fines or ability to pay waivers may impact revenue collection. The

direction and magnitude of the impact is dependent on the specifics of any proposal: scope of

eligible violations, individual eligibility, the graduated structure, and how individual or

household income is defined. To project the net fiscal impact, one would also need to consider

the income composition of fine recipients and potential shifts in driver behavior.

For fines issued to high-income individuals, the shift to income-based fines would likely

increase overall revenues generated from that segment.

Ability to pay waivers would have

minimal impact on collections from residents with high income. For residents with low income,

shifting to an income-based fine or ability to pay waiver could reduce revenues generated.

However, when factoring in uncollectable fines, setting more affordable fines could actually

improve collections. Evidence from some of the U.S. day fine pilots found increased revenues

from collections after the policy was instituted.

Lastly, substantial resources are currently

devoted to run collections systems.

100

If fines were more affordable, administrative cost savings

could be realized once start-up costs are absorbed.

101

Assess appropriateness of fine and late fee amounts

Traffic and parking violation fine amounts should be targeted toward meeting safety outcomes

and not set to generate revenue. Aligning fine amounts with safety goals would include setting

a practical structure that serves as a deterrent while being affordable. Pursuant to the

Government Finance Officers Association recommendations, municipalities should review fines

at least every five years.

102

In addition, the State should thoroughly review base fines in the

Illinois Vehicle Code and related traffic assessments to determine appropriate fines levels. In

addition, municipalities should publish public documentation of parking and traffic fine

amounts.

Escalating late fees or delinquency fines are a challenge for people with low income who receive

a traffic violation. Municipalities should assess and potentially reduce the amount of late fees

Decision makers would have to consider whether fines amounts are capped or if minimums are imposed. For

particularly high-income individuals, an uncapped day fine could result in very high fines. Some proponents see that

as a positive in order to deter high-income individuals from violating traffic rules.

National Institute of Justice, Day Fines in American Courts: The Staten Island and Milwaukee Experiments, April 1992,

https://www.ncjrs.gov/pdffiles1/Digitization/136611NCJRS.pdf

100

Brennan Center for Justice, The Steep Costs of Criminal Justice Fees and Fines, November 2019,

https://www.brennancenter.org/sites/default/files/2020-07/2019_10_Fees%26Fines_Final.pdf

101

Beth A. Colgan, “Graduating Economic Sanctions According to Ability to Pay,” Iowa Law Review 103:53 ( 2017): 69-

73, https://ilr.law.uiowa.edu/assets/Uploads/ILR-103-1-Colgan.pdf

102

Government Finance Officers Association, Financial Policies for Imposed Fees, Fines, And Asset Forfeitures, 2020,

https://gfoaorg.cdn.prismic.io/gfoaorg/2e311329-a26d-4d75-9330-7d59964820e6_FeesFinesAssetForfeitures_R3.pdf.

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levied as well as introduce caps to prevent snowballing of debt. The State could also set limits

on these fees via statute.

Report ticketing outcomes and impacts with an equity lens

State and local governments should improve reporting on the incidence of fines to allow for

analysis of potential equity impacts and outcomes. Understanding the impact of traffic and

parking violation fines on households with low income is challenging due to data limitations.

In addition, access to location-based and resident-based enforcement reports is critical to

understanding equity impacts, such as whether people living in communities of color or areas

with low income receive a disproportionate share of tickets.

103

Reporting could be accomplished

by individual municipalities or through an expansion of the Illinois Department of

Transportation’s traffic ticket reports. In addition, local governments should analyze the impact

of the fines they impose along with intended goals. The academic community and relevant

organizations should also leverage reported data to provide analysis.

Offer alternatives to monetary fines

ON TO 2050 recommends education programs as an alternative to fines and supports safety

training options for drivers who receive a citation involving speeding or aggressive driving.

104

In implementing this policy, driver’s education course fees should be set at affordable levels.

If a traffic stop occurs, encouraging the issuance of warnings, rather than citations, is one

technique to educate residents about the harms of unsafe driving behaviors without imposing

financial burdens. A points system that incorporates a standardized system of warnings prior to

financial penalties should be explored.

While some propose expanded community service as an alternative to monetary fines for

residents with low income, community service itself can be very costly for residents;

participating requires people to take time off from work or school, travel to a volunteer site, or

make childcare arrangements.

105

Correctable violations or “fix-it tickets” are a promising non-

monetary approach some jurisdictions are adopting, whereby the fine for a violation is waived,

or at least significantly reduced, if one can show proof of correction within a certain time

period.

106

Fix-it tickets are well suited for equipment tickets or administrative violations, such as

a broken tail light, or a driver’s license, car registration, or insurance violation.

103

Chicago Metropolitan Agency for Planning analysis of Chicago Department of Finance and ProPublica Illinois

data, https://www.propublica.org/datastore/dataset/chicago-parking-ticket-data

104

Chicago Metropolitan Agency for Planning, ON TO 2050, 2018,

https://www.cmap.illinois.gov/2050/mobility/safety#trafficsafety

105

UCLA Labor Center, Work, Pay, or Go to Jail, October 2019, https://www.labor.ucla.edu/wp-

content/uploads/2019/10/UCLA_CommunityServiceReport_Final_1016.pdf

106

California Courts, “Correctable Violations (“Fix-It” Tickets),”

https://www.courts.ca.gov/9529.htm?rdeLocaleAttr=en

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Improve repayment plans and collection practices

To assist people with limited ability to pay, municipalities and courts should adjust payment

plan options to reduce or eliminate the required down payments and limit monthly payments

to an affordable amount. Furthermore, a payment plan should be connected to a person’s ability

to pay. Local governments should also expand eligibility to enroll in payment plans. Adjusting

the terms of repayment plans does not, in and of itself, change the amount owed. Although, it is

possible that more reasonable payment options could increase collections. Statewide guidelines

for a uniform payment plan option would help local governments pursue this best practice in a

consistent manner, including practices around grace periods and ensuring that payment plans

comprise a reasonable portion of an individual’s income.

107

Relatedly, local governments should change notification policies to improve the clarity of

notices, include information about options for residents lacking the ability to pay, and describe

alternatives to payment. Collection agencies, if used, should have limits placed on the

surcharges they can levy and be required to affirmatively inform residents of municipal

payment plan alternatives and available debt reductions.

108

Residents should still be able to

access payment plans after ticket debts are sent to collections. Municipalities should re-examine

contracting with collection agencies for ticket debt and consider reducing their use. The

surcharges or add-ons that collection agencies are allowed to apply to debt loads to fund their

operations can be particularly burdensome and sending debts to collections negatively impacts

residents’ credit scores.

The State should approve legislation to limit the percent of a tax return that can be garnished

due to traffic and parking violation fine debt for residents below a certain income threshold. In

2012, the State of Illinois created the Local Debt Recovery Program, which provided local units

of government a new avenue to collect unpaid fees and fines. The Illinois Office of the

Comptroller assists local governments by withholding the debt amounts from residents’ tax

refunds, lottery payouts, and payroll checks. In March 2021, the Comptroller announced unpaid

fines will not be deducted from the state income tax refunds of Earned Income Tax Credit

eligible taxpayers for the 2020 tax year to provide assistance to taxpayers during the COVID-19

pandemic.

109

This temporary change will allow an estimated $15 million to go back to Illinois

households via tax refunds that would otherwise have been intercepted.

107

The State of Florida has legislation suggesting payment plans correspond to 2 percent of an individual’s average

monthly income, but in a review, no county used that standard in practice. Fines and Fees Justice Center, Payment

Plans As a Compliance tool: Best Practices for Florida Courts, August 2019,

https://finesandfeesjusticecenter.org/content/uploads/2020/05/Payment-Plans-Final-1.pdf

108

The use of collection agencies can negatively impact residents’ credit scores. Credit scores are a crucial metric that

can affect homeownership and apartment lease applications, employment, and business loans.

109

Illinois Office of the Comptroller, “Comptroller Mendoza Gives Struggling Taxpayers a Break,” March 2021,

https://illinoiscomptroller.gov/news/press-releases/comptroller-mendoza-gives-struggling-taxpayers-a-break.

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End employment prohibitions due to ticket debt

State statutes, municipal ordinances, and public agency policies should be changed to allow for

residents with traffic fine debt to seek employment with a local government, public transit

agency, or school district.

110

Relatedly, municipal policies that restrict ride-hailing employment

based on ticket debt should also be reexamined.

111

For residents in communities with limited

employment prospects, this can represent a significant hurdle to employment and eventual

repayment.

Next steps

These recommendations will not be realized without policy changes by the State of Illinois, the

Illinois Tollway, the region’s transit agencies, and local governments across the region. Many of

these recommendations could be enacted individually, like reforming approaches to traffic and

parking violation fines. However, pursuing comprehensive reform would be more impactful.

Implementing many of these recommendations will take significant investment. Improving

mobility options for residents with low income, including those with disabilities or other

mobility challenges, will require reprioritizing funding toward transit infrastructure and

operations, as well as bicycle and pedestrian infrastructure. These investments will need to be

balanced with the funds needed to reduce the impacts of fees, fines, and fares on these same

residents. To meet objectives, affected residents will need to be engaged on program

development, and new programs will need to be effectively communicated to residents in order

to ensure broad implementation and participation. Beyond that, policy changes that result in

income growth for residents with low income are an important part of reducing

disproportionate impacts across residents.

Transit remains as crucial as ever to help safely move the region’s essential workers and transit-

dependent residents during the COVID-19 pandemic. It is unclear how the transit agencies will

be able to provide service at current levels into the future without additional financial

assistance, given the unprecedented challenges to transit operating budgets. Many of these

recommendations, such as those around reduced fares and vehicle registration fees, as well as

promotion of Ventra and I-PASS use, may result in a reduction in fee and fare revenue that may

not be offset by increased use. Similarly, traffic violation fine recommendations may reduce

future revenues for local government budgets and the court system. For transit in particular,

implementation will require an ongoing and dependable revenue source to adequately

compensate the service boards for the cost of providing reduced fares. Without additional

110

Chicago Municipal Code, 2-152-150 Applicants for employment – Disclosure of indebtedness to city. Chicago Bd.

of Educ. Rules, Section 4-4(g) Failure to Pay Municipal Debts.

111

Municipal Code of Chicago, Section 9-115-150 (h). See Elliott Ramos, “Chicago Is The Only Major U.S. City To Ban

Ride-Share Drivers For Parking Ticket Debt,” September 12, 2019, National Public Radio,

https://www.npr.org/local/309/2019/09/12/760121021/chicago-is-the-only-major-u-s-city-to-ban-ride-share-drivers-for-

parking-ticket-debt

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revenue or an adjustment to state requirements that set the percent of revenue that must be

recovered from operations, the current ways to make transit more accessible to residents with

low income are not financially viable.

As new programs and policies are implemented, CMAP and other partners must regularly

evaluate their performance to make sure they are meeting regional equity goals. Furthermore,

CMAP must continue to do further analysis on pursuing policies that ensure the transportation

network promotes equitable outcomes for all residents.

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Methodology

Defining households with low income

In order to effectively assess whether low-income populations are disproportionately impacted

by transportation fines, fares, and fees, it is important to establish thresholds for identifying the

region’s low-income population. During ON TO 2050 development, CMAP identified

geographies not currently well connected to regional economic progress: Economically

Disconnected Areas (EDAs). EDAs are defined as areas in the region with high concentrations

of low-income people of color or low-income people with limited English proficiency.

Consistent with ON TO 2050’s EDA definition, this analysis sets the low-income threshold at 60

percent of the Chicago Metropolitan Statistical Area (MSA) median income by household size,

identifying those who are in poverty or at risk of poverty. Using a percentage below the

regional median income is a common method and accounts for regional differences in costs of

living. For example, the U.S. Department of Housing and Urban Development uses local

median income levels to designate households as low-income and establish eligibility for a

variety of housing programs. This comparative analysis of median incomes defines not only

how households are doing but how in relation to similar households with the same standards of

living.

Households were defined as low income if they had an income at or below 60 percent of the

regional median household income by household size. Medium-income households are

between 60 percent and 140 percent of the regional median household income by household

size. High-income households are those with income levels greater than 140 percent of the

regional median income. Using this definition, the thresholds are:

Household size

MSA median

income (2018)

60% of MSA

median income

140% of MSA

median income

1-Person Households

$31,027

$18,616

$43,438

2-Person Families

$74,605

$44,763

$104,447

3-Person Families

$85,584

$51,350

$119,818

4-Person Families

$103,227

$61,936

$144,518

5-Person Families

$94,904

$56,942

$132,866

6-Person Families

$85,530

$51,318

$119,742

7-or-more-Person Families

$87,056

$52,234

$121,878

These thresholds were established using data from the America Community Survey for the

Chicago MSA, 2014-2018 estimates: 1) B19119 Median family income in the past 12 months (in

2018 inflation-adjusted dollars) by family size and 2) B19019 Median household income in the

past 12 months (in 2018 inflation-adjusted dollars) by family size.

Equity in transportation

Page 74 of 74 fees, fines, and fares

Modeling the impacts of transportation fees and fares

This study used CMAP’s Activity-Based Model (ABM) to evaluate household travel by income

group, as well as impacts of potential policies to reduce fees and fares for households with low

income. The ABM simulates a single day of travel behavior for the entire population of

northeastern Illinois.

The population considered is a “synthetic” population, created by a population synthesizer,

which represents every person in every household in the region. The population synthesizer

generates a list of household and household characteristics, including the number of household

members, the age of each member, whether the member is employed or attends school, and

household income, among other things. The model generates detailed daily activity rosters for

each traveler in the synthetic population. This is based on information about travel behavior

collected in a household travel survey and travel model-generated transportation system

supply information, such as travel times, costs, and the availability of public transit service to

access destinations throughout the region are generated. The activity rosters present all the

daily activities the traveler will undertake, what time and destination will be selected for travel,

and what mode will be selected.

The trips show whether the traveler will go to the destination with other travelers (shared

travel), such as a family shopping trip or sharing a ride to work or entertainment, and whether

the trip will take a tolled highway route or a free route. The value of time for each trip is

considered when selecting destinations, modes, and routes. The household identification

number is retained for each traveler, allowing analysis of the impacts of projects, programs, or

policies on the travel behavior of different types of households.

cmap.illinois.gov

312-454-0400

The Chicago Metropolitan Agency for Planning (CMAP) is

our region’s comprehensive planning organization. The agency

and its partners developed and are now implementing ON TO

2050, a long-range plan to help the seven counties and 284

communities of northeastern Illinois pursue strategies that

address transportation, housing, economic development,

open space, the environment, and other quality-of-life issues.

See cmap.illinois.gov for more information.

433 West Van Buren Street

Suite 450

Chicago, IL 60657

FY21-0026