E-ZPass and national interoperability

[myosh_tino]

I'm not sure if switchable transponders would work interoperably. They don't in California (where you have multiple agencies that issue FasTrak tags, if you don't have a switchable one from LACMTA, you pay the full toll regardless of how many in the vehicle) or in E-ZPass territory (where only two operators issue Flex Transponders, MdTA and VDOT). For one thing, E-ZPass Flex transponders have two switch positions (HOV off, or HOV on, with HOV defined as 3+), and LA's have three positions (1, 2, 3+).

I do wish that E-ZPass Flex had a 3 position switch like LA's FasTraks do. This would allow more acceptance of E-ZPass Flex for HOV applications in areas where an HOV is legally defined as 2+.

I think a 3-position switch is going to become a necessity regardless of what system is chosen for the national standard due to the fact that HOV is classified as 2+ on some roads and 3+ on others.

There has been a lot of talk up in northern California about converting all Bay Area FasTrak users to the switchable transponder and to require all users of the HOT/Express Lanes to have transponders whether they're solo drivers or carpools.  If the Bay Area adopts the switchable transponders, I'd expect the remaining tolling agencies to follow suit.

[Revive 755]

Wikipedia has the best chart of the different EZ Passes and the monthly charges, if any.

http://en.wikipedia.org/wiki/E-ZPass#Fees_and_discounts_by_state

The article doesn't list the extra charge in Indiana for I-Pass (Illinois) users.

[Joe The Dragon]

Wikipedia has the best chart of the different EZ Passes and the monthly charges, if any.

http://en.wikipedia.org/wiki/E-ZPass#Fees_and_discounts_by_state

The article doesn't list the extra charge in Indiana for I-Pass (Illinois) users.

any one can edit wikipedia

[mtantillo]

The hard-case QuickPass looks rather different from any E-ZPass I've ever seen. What's interesting is that apparently new Virginia E-ZPass transponders are a different shape from the square devices most of us have had for many years, but they still don't look like the QuickPass. Weird. Do you have any idea how the member agencies choose what sort of device to use? Obviously in Virginia the Flex device is one thing, but aside from that, it's interesting to discover the devices are different and I wonder why that is and whether there is any significance to it.

The old square E-ZPasses were the first generation IAG-spec tags from Mark IV. When E-ZPass was introduced, part of the deal was sole sourcing of the readers and tags from Mark IV, in order to guarantee interoperability. Some other agencies (IL, VA, MA, MD) went with equipment from the same source, not because they had to but because they wanted to be interoperable with E-ZPass in the future.

Then E-ZPass had a procurement out for 5+ years for "next generation" technology. In that time, Mark IV was bought by Kapsch and the IAG rebranded itself as "the E-ZPass Group". The new rectangular E-ZPasses are the next generation transponders from Kapsch, which were ultimately selected as part of the procurement. Eventually, all E-ZPasses will be the new style. Some agencies bought new tags right away, others had to exhaust their supply of old tags first. But the new tags cost about half as much to manufacture, so agencies like them, especially ones that give them away for free. Eventually, as batteries wear out, the old tags will be replaced with new ones.

E-ZPass Flex was obviously a special design from Kapsch to solve a specific need in Virginia, and Maryland bought onto the concept to help its residents who use the 495 Express Lanes in Virginia. 

North Carolina is not a full E-ZPass Group member, they are an affiliate member. Therefore they are not bound by the sole source equipment procurement. So they are using their own equipment that was tested in the lab to ensure it can properly interface with E-ZPass. I believe they are using TransCore readers and tags (the 6B+ protocol that is the primary protocol in NC is proprietary TransCore). So that is why there is a different design. It has more functionality than an E-ZPass because it communicates on two protocols: 6B+ for NC and FL, and IAG for the other E-ZPass states.

It is interesting to note that in Northern Virginia, TransCore is the contractor in charge of the Dulles Toll Road's toll collection system. Despite that they have their own readers and tags and even their own proprietary protocol under their own patents, they had to purchase readers and tags from Kapsch. Even now that E-ZPass IAG protocols are open source and TransCore makes E-ZPass readers (for travel time computation purposes in NYC), the full members have to get readers from the Kapsch procurement for toll collection purposes.

[mrsman]

See the following article from Toll Roads News:

http://tollroadsnews.com/news/are-we-there-yet-a-test-of-national-toll-interoperability

After reading this article, I gather that there may not be too many technological obstacles to interoperability, but the bigger difficulty is bureaucracy.  Let's find a way that people can register their license plates on one web site, and the information will be forwarded to every toll agency in the country.  Whether I have a transponder or whether the battery is out or whether I don't have a transponder, I will be registered as a user and only pay the charged toll and no additional "violation" fees.

[vdeane]

But if you use plate registration, how does one choose how to pay?  For example, if I for some reason want to pay cash on the Thruway, I can just take the transponder out of the car.  And speaking of the Thruway, what would happen if a hypothetical transponderless vehicle pulled up to a cash booth expecting to do an electronic toll transaction (as the signs say "E-ZPass accepted in every toll lane") based on the plate?  Currently, the attendant uses the presence of a transponder to determine whether to push the button that will cause the traffic light to go from red to green or to give the person a toll ticket.  I don't know if the Thruway cameras even operate unless a violation occurs.  And then you have authorities like the Bridge Authority that have gate arms; if a transponderless vehicle pulls into an E-ZPass lane on those bridges, even if registered, everyone will be sitting there for a very long time.  This would also have the effect of people using rental cars being forced to use the rental company's way of paying even more than they are now.

There's also the issue of vehicle class.  What you sometimes pull a trailer, but not all the time?  Vehicles with trailers pay a different toll rate, and therefore need to be registered separately.  Currently, one would have two registrations: one with the trailer, and one without, and swap the two tags as needed.  The system would need to be changed so that it could dynamically identify the trailer and associate it with the vehicle pulling it.  Additionally, most toll authorities out here use axle-based classes, but camera based methods use length-based class determinations (which is a problem for more than just tolling; NYSDOT can't use camera-based methods of getting a traffic count in certain locations because of this, for example).

[Brandon]

But if you use plate registration, how does one choose how to pay?  For example, if I for some reason want to pay cash on the Thruway, I can just take the transponder out of the car.  And speaking of the Thruway, what would happen if a hypothetical transponderless vehicle pulled up to a cash booth expecting to do an electronic toll transaction (as the signs say "E-ZPass accepted in every toll lane") based on the plate?

ISTHA would just call it a V-Toll based on the plate and car.  You'd be charged the rate for the transponder instead of cash, and it would be assumed that the transponder did not read for some reason.

[vdeane]

NYSTA does the same.  But what if you want to pay cash for some reason?  I've actually had some experience with this.  In one instance, when moving out of the apartment I had during my internship, Dad and I swapped vehicles as he had a business trip to Albany (I lived with my parents in Rochester at the time) and my mattress was in his truck and needed to go home with me, so he took my car, and I took his truck; I took out the E-ZPass both because I didn't feel like paying to tolls and because Dad needed receipts of all toll transactions.  In the other, I paid cash when I was using a rental car to go to a job interview with IBM (which is IBM's corporate policy, no exceptions, even if you're not an employee) and I paid cash on the Thruway because I didn't know how their reimbursement of all expenses would be affected by using the rental company's toll pass.

[Brandon]

NYSTA does the same.  But what if you want to pay cash for some reason?  I've actually had some experience with this.  In one instance, when moving out of the apartment I had during my internship, Dad and I swapped vehicles as he had a business trip to Albany (I lived with my parents in Rochester at the time) and my mattress was in his truck and needed to go home with me, so he took my car, and I took his truck; I took out the E-ZPass both because I didn't feel like paying to tolls and because Dad needed receipts of all toll transactions.  In the other, I paid cash when I was using a rental car to go to a job interview with IBM (which is IBM's corporate policy, no exceptions, even if you're not an employee) and I paid cash on the Thruway because I didn't know how their reimbursement of all expenses would be affected by using the rental company's toll pass.

Here, in Illinois, all you need do is ask the attendant for the receipt.  Of course, that doesn't work with the unattended ramp plazas.  Then again, you could print off your transactions as evidence as well.  With a rental, here, you just take your own I-Pass.  ISTHA doesn't seem to worry too much about it as long as it is recorded properly.

[vdeane]

"Just take your own I-Pass" won't work if all the tolls are processed by license plate.

[Pete from Boston]

In the other, I paid cash when I was using a rental car to go to a job interview with IBM (which is IBM's corporate policy, no exceptions, even if you're not an employee) and I paid cash on the Thruway because I didn't know how their reimbursement of all expenses would be affected by using the rental company's toll pass.

IBM requires you to arrive in a rental car and pay cash for tolls on the way there?

[vdeane]

In the other, I paid cash when I was using a rental car to go to a job interview with IBM (which is IBM's corporate policy, no exceptions, even if you're not an employee) and I paid cash on the Thruway because I didn't know how their reimbursement of all expenses would be affected by using the rental company's toll pass.

IBM requires you to arrive in a rental car and pay cash for tolls on the way there?

They require a rental for all trips over 50 miles.  I wouldn't know about the tolls - this is the only time I've ever dealt with a rental car so I have NO clue how billing for the tolls actually works, and I wanted to be sure I wouldn't be stuck with the surcharge.  Seriously, I had to mail a form, attach receipts, and bug their outsourced HR a few times to get reimbursed for all my costs (everything except the rental, hotel, and per diem meal rate, so essentially gas and tolls).

[hbelkins]

So, you are saying that if you travel more than 50 miles for a job interview with IBM, you have to rent a car to get there?

There are people in eastern Kentucky who live more than 50 miles from a rental agency!

[jeffandnicole]

See, if the government had such a policy, the media and public would be all over it.  When a private company has a policy, no one knows or cares.  In the end, it's the public that pays for it anyway (And I don't care if you say you don't buy their products. If the supermarket or convenience store has a computer system that has IBM parts to it, then yes, you indirectly do pay for it).

[Pete from Boston]

How much of the toll processing today is done by public agencies, and how much by outside contractors?

[vdeane]

So, you are saying that if you travel more than 50 miles for a job interview with IBM, you have to rent a car to get there?

There are people in eastern Kentucky who live more than 50 miles from a rental agency!

I think it has something to do with liability.  It's something everyone who had an IBM interview at Clarkson tends to complain about - just not me, because my car needed to go in for its annual inspection/remove snow tires/service check appointment around the same time, so the two dovetailed quite nicely.

[mtantillo]

Big news from Georgia today: their PeachPass system is now interoperable with SunPass (and by extension, E-Pass and LeeWay) in Florida and NC QuickPass in North Carolina!

Peach Pass users MUST have their license plates listed on their account to take part, which indicates to me that in at least some cases, the actual transponder will not be read (most likely in NC where both reader channels are used by 6B+ (FL and NC) and IAG-spec (E-ZPass), with no third channel available for Georgia's 6C transponders. But Georgia should certainly be able to read FL and NC's 6B+ transponders with the second channel on their readers, and FL should be able to read Georgia's 6C transponders directly once they finish phasing out their old legacy SunPass transponders and can dedicate that second channel to 6C.


News release:
http://peachpass.com/interoperability

Although toll pass interoperability is something that seems to be happening at a snail's pace outside of the Northeast's E-ZPass network, a lot of baby-steps have happened in the last couple of years:
-NC QuickPass and E-ZPass interoperability in early 2013 (NC QuickPass users must have a hard-case transponder)
-NC QuickPass and SunPass interoperability later in 2013
-NC QuickPass/SunPass/PeachPass in November 2014

-NTTA (Dallas) TollTag and Oklahoma's Pike Pass in 2014
-Oklahoma's Pike Pass and Kansas's K-Tag in 2014
As far as I know, K-Tag will not work on NTTA/vice versa, and PikePass will not work in Texas beyond Dallas/vice versa. So it is essentially as if Kansas, Oklahoma, Dallas area, and Rest of Texas are considered their own "areas", and each is interoperable with adjacent "areas" but nothing beyond that.

As for license plate tolling, I don't see why that can't be implemented soon. National interoperability will have to rely on both license plates and transponders for some time to come. Those agencies with gates will just have to adopt to the times. Valerie brings up valid points about NYSTA and NYSBA's current operating parameters that could get in the way temporarily, but at the end of the day, an artificial bureaucratic, "we're going to be inflexible and hide behind the rules" attitude will likely cave to progress and matching the rest of the country. I know at some transportation agencies, an attitude like that will get people disciplinary action pretty quickly....creative thinking to "get as close as you can to the standards without using it as an excuse to hold up the project" is what the people are demanding.

[mtantillo]

"Just take your own I-Pass" won't work if all the tolls are processed by license plate.

Add the license plate of the rental car to the account (like you are always told to do by E-ZPass), and it should process. I know with E-ZPass you have to add it as if it were your own car and then remember to take it off again. But with some more customer-service friendly toll agencies (SunPass in FL), they will allow you to add a rental car and set an "expiration" time. As long as you do that, rental tolls will be properly charged to your account, and it automatically expires at the time you set so you don't forget to take it off.

[mtantillo]

NYSTA does the same.  But what if you want to pay cash for some reason?  I've actually had some experience with this.  In one instance, when moving out of the apartment I had during my internship, Dad and I swapped vehicles as he had a business trip to Albany (I lived with my parents in Rochester at the time) and my mattress was in his truck and needed to go home with me, so he took my car, and I took his truck; I took out the E-ZPass both because I didn't feel like paying to tolls and because Dad needed receipts of all toll transactions.  In the other, I paid cash when I was using a rental car to go to a job interview with IBM (which is IBM's corporate policy, no exceptions, even if you're not an employee) and I paid cash on the Thruway because I didn't know how their reimbursement of all expenses would be affected by using the rental company's toll pass.

Here, in Illinois, all you need do is ask the attendant for the receipt.  Of course, that doesn't work with the unattended ramp plazas.  Then again, you could print off your transactions as evidence as well.  With a rental, here, you just take your own I-Pass.  ISTHA doesn't seem to worry too much about it as long as it is recorded properly.

If you have a New York State issued E-ZPass, you can actually click on the individual transaction number in transaction view and it will let you print a receipt for that transaction for expense reporting purposes. The rental toll pass would work to pay, but you would likely not receive your invoice from them for several weeks, making expense reporting annoying. Plus it is rather expensive with the added fees. So you might as well just bring your own toll pass (and link the license plate of the vehicle to it in case something happens or they only do video tolling).

[realjd]

In the other, I paid cash when I was using a rental car to go to a job interview with IBM (which is IBM's corporate policy, no exceptions, even if you're not an employee) and I paid cash on the Thruway because I didn't know how their reimbursement of all expenses would be affected by using the rental company's toll pass.

IBM requires you to arrive in a rental car and pay cash for tolls on the way there?

They require a rental for all trips over 50 miles.  I wouldn't know about the tolls - this is the only time I've ever dealt with a rental car so I have NO clue how billing for the tolls actually works, and I wanted to be sure I wouldn't be stuck with the surcharge.  Seriously, I had to mail a form, attach receipts, and bug their outsourced HR a few times to get reimbursed for all my costs (everything except the rental, hotel, and per diem meal rate, so essentially gas and tolls).

Companies often require a rental car for long drives on business trips because if you took your personal vehicle they'd have to reimburse for mileage which is currently 56 cents per mile (set by the IRS). Rentals are cheaper for them.

It's also pretty standard for companies to require paying cash for tolls to avoid the "convenience fees" that the rental car companies charge. The policies on that almost always have exceptions for electronic-only toll roads.

[vdeane]

As for license plate tolling, I don't see why that can't be implemented soon. National interoperability will have to rely on both license plates and transponders for some time to come. Those agencies with gates will just have to adopt to the times. Valerie brings up valid points about NYSTA and NYSBA's current operating parameters that could get in the way temporarily, but at the end of the day, an artificial bureaucratic, "we're going to be inflexible and hide behind the rules" attitude will likely cave to progress and matching the rest of the country. I know at some transportation agencies, an attitude like that will get people disciplinary action pretty quickly....creative thinking to "get as close as you can to the standards without using it as an excuse to hold up the project" is what the people are demanding.

NYSTA isn't a big issue here; I think they're the one agency in the entire state with modern toll booths.  NYSBA, MTA, etc... that's another story.  They're gonna have to finally buy cameras.

[1995hoo]

....

It's also pretty standard for companies to require paying cash for tolls to avoid the "convenience fees" that the rental car companies charge. The policies on that almost always have exceptions for electronic-only toll roads.

I found myself thinking about this issue once in the context of recovery of attorney's fees and litigation costs in federal court. There isn't any case law yet on the issue of whether a party reimbursing costs must reimburse ORT fees. That is, it's pretty standard that you can recover the amount of a toll as part of the travel costs if it was reasonably necessary to incur a toll going to or from court or a deposition or whatever. What's not clear is whether you could recover a fee charged for using such a facility without a transponder.

It seems to me it would be reasonable for a judge to allow recovery of the fee if the toll facility explicitly offers toll-by-plate and if the person isn't using the road frequently other than for purposes of the litigation (that is, if a person commutes on that road every day using toll-by-plate, it'd be reasonable for the judge to say "you'd incur that cost anyway" and allow only the specific toll charges assignable to the case). I'm thinking of the Homestead Extension as an example, as they specifically state you get charged a single $2.50 monthly administrative fee.

If the facility does not offer toll-by-plate and you use the road en route to court or a deposition, I do not think it would be reasonable for the judge to allow an administrative fee as a cost. I'm thinking of the HO/T lanes here in Northern Virginia where if they send you a bill in the mail, they charge you $12.50 per individual trip. It's in the nature of a penalty for using the lanes without a transponder and then failing to pay online within five days. I don't think it's reasonable for a judge to order an adversary party to reimburse you for what's in essence sort of like a traffic ticket.

[mtantillo]

As for license plate tolling, I don't see why that can't be implemented soon. National interoperability will have to rely on both license plates and transponders for some time to come. Those agencies with gates will just have to adopt to the times. Valerie brings up valid points about NYSTA and NYSBA's current operating parameters that could get in the way temporarily, but at the end of the day, an artificial bureaucratic, "we're going to be inflexible and hide behind the rules" attitude will likely cave to progress and matching the rest of the country. I know at some transportation agencies, an attitude like that will get people disciplinary action pretty quickly....creative thinking to "get as close as you can to the standards without using it as an excuse to hold up the project" is what the people are demanding.

NYSTA isn't a big issue here; I think they're the one agency in the entire state with modern toll booths.  NYSBA, MTA, etc... that's another story.  They're gonna have to finally buy cameras.

Believe it or not, MTA actually has cameras (this was big news to me when I spotted them the other month). Not for violation enforcement but for "big brother" keeping close watch on who is traveling through the city, looking for the boogeyman. They just need to hook them into a violation processing system. As for NYSBA, we're talking about 5 toll plazas total. The big issue with video tolling as I see it are the entry points to ticket toll roads. I know for a fact that NY Thruway, NJ Turnpike, PA Turnpike, and Mass Turnpike do not have any kind of camera on entry ramps. So if you blow through an exit toll booth, they will either: 1) charge based on "past travel history", 2) charge the max toll, or 3) charge an independent "image toll rate" that is higher than the average trip but less than the maximum toll. They make no effort to try to match an entry point to an exit point, which would be required for any type of video tolling. 

[mtantillo]

....

It's also pretty standard for companies to require paying cash for tolls to avoid the "convenience fees" that the rental car companies charge. The policies on that almost always have exceptions for electronic-only toll roads.

I found myself thinking about this issue once in the context of recovery of attorney's fees and litigation costs in federal court. There isn't any case law yet on the issue of whether a party reimbursing costs must reimburse ORT fees. That is, it's pretty standard that you can recover the amount of a toll as part of the travel costs if it was reasonably necessary to incur a toll going to or from court or a deposition or whatever. What's not clear is whether you could recover a fee charged for using such a facility without a transponder.

It seems to me it would be reasonable for a judge to allow recovery of the fee if the toll facility explicitly offers toll-by-plate and if the person isn't using the road frequently other than for purposes of the litigation (that is, if a person commutes on that road every day using toll-by-plate, it'd be reasonable for the judge to say "you'd incur that cost anyway" and allow only the specific toll charges assignable to the case). I'm thinking of the Homestead Extension as an example, as they specifically state you get charged a single $2.50 monthly administrative fee.

If the facility does not offer toll-by-plate and you use the road en route to court or a deposition, I do not think it would be reasonable for the judge to allow an administrative fee as a cost. I'm thinking of the HO/T lanes here in Northern Virginia where if they send you a bill in the mail, they charge you $12.50 per individual trip. It's in the nature of a penalty for using the lanes without a transponder and then failing to pay online within five days. I don't think it's reasonable for a judge to order an adversary party to reimburse you for what's in essence sort of like a traffic ticket.

The difference lies with "are you supposed to get on the road without an E-ZPass or not". In the case of the 495 Express Lanes, the answer is no...the sign clearly says "All Users E-ZPass Required", so in effect any administrative fee is a penalty. In the case of the ICC, the Tobin Bridge, or the Henry Hudson Bridge, you do not have to have an E-ZPass, so I would think any administrative fees would be fair game. At least if I was approving an expense report for one of my employees, that is the standard I would use...perhaps the Feds may seem differently.

As for someone using a toll road on the way to a business meeting..."reasonably necessary to incur" seems like a valid standard. If someone spends a 12-hour day in the field and spends a few dollars on the 495 Express Lanes to get home faster, I don't mind. If someone wants reimbursement for a $25 toll on the 95 Express Lanes because they overslept, then I might question it. If someone is paying the "Notice of Toll Due" rate on the ICC when I know they have an E-ZPass, I would probably politely suggest that they use E-ZPass and print off a copy of their statement so as to not overpay for no good reason.

I know my parents avoided the Homestead Extension on their way to Everglades National Park last winter because they were "scared" of all-electronic tolling and didn't know how it worked. They had such a miserable experience on US 1 heading through Kendall and Coral Gables that my dad said "screw it, we're taking the toll road back no matter how much it costs." He asked me what he needed to do next time we were on the phone, and I realized that although I had forgotten to give him my portable SunPass transponder for this trip, their vehicle was still listed on my SunPass account. Sure enough, I logged into the phone app and there were the four tolls posted at $1.02 each, based on license plate image rather than a transponder read, but still at the SunPass rate.

At any rate, I think a reasonable person would think it is okay to take the Homestead Extension for business reasons, and reimburse any and all tolls and fees associated with that trip. However, if the person had even one non-reimbursable charge on the same statement with the $2.50 fee, the "you would have incurred that anyway, so we won't reimburse that" would hold true for the admin fee, but the tolls would be reimbursed at the higher $1.30 bill-by-mail rate at which they were posted on the statement, rather then the less expensive SunPass rate.

[1995hoo]

....

It's also pretty standard for companies to require paying cash for tolls to avoid the "convenience fees" that the rental car companies charge. The policies on that almost always have exceptions for electronic-only toll roads.

I found myself thinking about this issue once in the context of recovery of attorney's fees and litigation costs in federal court. There isn't any case law yet on the issue of whether a party reimbursing costs must reimburse ORT fees. That is, it's pretty standard that you can recover the amount of a toll as part of the travel costs if it was reasonably necessary to incur a toll going to or from court or a deposition or whatever. What's not clear is whether you could recover a fee charged for using such a facility without a transponder.

It seems to me it would be reasonable for a judge to allow recovery of the fee if the toll facility explicitly offers toll-by-plate and if the person isn't using the road frequently other than for purposes of the litigation (that is, if a person commutes on that road every day using toll-by-plate, it'd be reasonable for the judge to say "you'd incur that cost anyway" and allow only the specific toll charges assignable to the case). I'm thinking of the Homestead Extension as an example, as they specifically state you get charged a single $2.50 monthly administrative fee.

If the facility does not offer toll-by-plate and you use the road en route to court or a deposition, I do not think it would be reasonable for the judge to allow an administrative fee as a cost. I'm thinking of the HO/T lanes here in Northern Virginia where if they send you a bill in the mail, they charge you $12.50 per individual trip. It's in the nature of a penalty for using the lanes without a transponder and then failing to pay online within five days. I don't think it's reasonable for a judge to order an adversary party to reimburse you for what's in essence sort of like a traffic ticket.

The difference lies with "are you supposed to get on the road without an E-ZPass or not". In the case of the 495 Express Lanes, the answer is no...the sign clearly says "All Users E-ZPass Required", so in effect any administrative fee is a penalty. In the case of the ICC, the Tobin Bridge, or the Henry Hudson Bridge, you do not have to have an E-ZPass, so I would think any administrative fees would be fair game. At least if I was approving an expense report for one of my employees, that is the standard I would use...perhaps the Feds may seem differently.

....

I thought that was more or less what I said. Of course, judges' reactions to these sorts of things may well vary around the country depending on the ubiquity of both toll roads and all-electronic tolling; I also suspect reactions might vary based on how the administrative charge is determined, whether "per-trip" or per some specified period of time. I do not think it would be proper for a judge to hold that, for example, because the witness lives in the New York City area with its plethora of tolled bridges, it is unreasonable for the witness not to have an E-ZPass such that the reimbursable cost should be limited to the "E-ZPass rate" instead of the "toll-by-plate" rate.

BTW, in the overall toll context (not limited to all-electronic tolling), "reasonably necessary to incur" also means you look at things like the routing. Just because there's a toll-free option doesn't mean the toll-free option must be considered realistic or preferable–for example, in view of the added distance and time involved it's not reasonable to contend the witness should have taken the western side of I-695 around Baltimore to avoid the tunnel toll, and it's not reasonable to contend the witness should use US-27 from Orlando to Miami to avoid the Turnpike toll. In both of those cases the use of the tolled facility is utterly reasonable.