Tag Archives: Public private partnerships

Express Lanes! Express Lanes! Get Yer Express Lanes While They’re Still Cheap!

The 495 Expressways on Northern Virginia’s capital beltway generated an average of nearly 18,600 daily trips and $828,000 total revenue in December 2012, reports concessionaire Transurban. That’s a drop in the bucket for the $2 billion project, which opened November, but the private-sector operator anticipated a long, slow ramp-up.

As congestion increased, demand for the tolled express lanes also increased, resulting in escalation of the dynamic pricing. To travel the full length of the Express Lanes, the minimum toll price for the period was $1.65 and the maximum peak price was $3.70. The average toll per trip, including shorter trips, has been $1.07. Prices are expected to escalate as more motorists use the express lanes to avoid congestion in the non-tolled lanes.

High Occupancy Vehicles (three or more passengers), buses and motorcycles, which use the express lanes for free, comprised 7% of users.

– JAB

The Beltway’s Brain

To get a taste of Virginia’s transportation future, take a spin on the 495 Express Lanes project where sensors, artificial intelligence and dynamic pricing combine to optimize scarce capacity on the Capital Beltway.

by James A. Bacon

If highways had IQs, the newly reconstructed Capital Beltway in Northern Virginia would be the Einstein of asphalt. The 495 Express Lanes have 75 electronic signs and message boards, 36 gantries and tolling points, 80 microwave-radar sensors to measure traffic speeds and innumerable video cameras to monitor road conditions, all tied together by 45 miles of high-bandwidth cable.

The beltway’s brain, where data compiled by the sensors is assimilated and acted upon, is located in a non-descript building in an industrial park just off I-95 in Alexandria. There, employees of Capital Beltway Express (CBE) keep a close eye on traffic, dispatching incident-management crews in the event of accidents or flat tires, providing customer service and otherwise ensuring that the $2 billion toll road runs smoothly. But the most important decisions — the price of tolls — are not made by humans.

Every 15 minutes a computer algorithm adjusts the rates for nine highway segments, depending upon the level of demand for each. An employee watches the algorithm, but from what I could observe when visiting the control center for more than an hour last month, the task of watching sine waves undulating across a computer monitor did not appear to be a terribly exciting one.

Humans will re-enter the pricing picture, but only briefly, when programmers periodically incorporate traffic data based upon the expressway’s real-world experience to update the algorithm. Says Jennifer Aument, vice president of corporate relations for Transurban, which owns 90% of CBE: “The system will get smarter and smarter.”

I had come to visit the 495 Express Lanes control center to get a peek at the future of transportation in Virginia, particularly in Northern Virginia which by some measures has the worst traffic congestion anywhere in the country. New highway capacity is hideously expensive to build in the Old Dominion, and even more so in the Washington suburbs where the high cost of real estate makes the acquisition of right of way prohibitive. Given intense opposition to tax increases, Northern Virginia cannot build its way out of traffic congestion. That leaves only one alternative. As Aument says, “We have to get smarter managing what we already have.”

The 495 Express Lane project, which runs 14 miles between Interstate 95 and the George Washington Parkway, uses technology and tolls to guarantee access to free-flowing express lanes for those who, at any given moment, place the greatest value on their time. The technology makes it possible to vary the price directly in response to changes in traffic volume. When volume increases, so does the price; when traffic decreases, the price goes down.

The $2 billion express lanes project creates economic value in four ways. First, it adds four new lanes to the Beltway, expanding capacity. Second, it provides three new Beltway access points in and around the Tysons business district. By allowing some toll users to exit closer to their destinations, it takes cars off congested local roads. Third, the express lanes provide time savings for people who wish to bypass congestion. Fourth, it provides predictability for everyone, whether they use an express lane or not. Northern Virginia drivers typically tack on 15- to 20-minute buffer times around meetings to give themselves leeway in the event of gridlock. Just knowing they have the congestion-free option, should traffic slow, allows people to reduce the dead time, even if they don’t actually end up using the lanes.

Capital Beltway Express is a collaboration between Transurban, an Australian toll-road company, and Fluor, a global construction company, in a public-private partnership with Virginia. The same partners are constructing the Interstate 95 express lanes, which, when complete in 2014, will merge seamlessly with the 495 lanes and will be run out of the same operations center. The state contributed $409 million to the Beltway project, mainly to offset the cost of rebuilding some 58 bridges and overpasses to accommodate the four extra lanes. Dating back to the 1960s and earlier, those facilities had accumulated a significant maintenance backlog. Transurban and Fluor invested $350 million in equity, and the rest came from bonds to be repaid with toll revenues.

As part of the deal, buses, motorcycles and vehicles with three or more drivers use the express lanes for free, treating them, in effect, like High Occupancy Vehicle (HOV) lanes. Thus, the bonds are being repaid by drivers who use the lanes to avoid congestion, not ride sharers or the general public.

Most toll facilities, like the Dulles Toll Road, publish their rates in advance and stick with them for months or years at a time. Some, like the Midtown Tunnel-Downtown Tunnel project in Norfolk, varies pricing by time of day but does so in accordance with a posted schedule. The 495 Express Lanes project is one of only five in the country that uses dynamic pricing, in which the price varies depending upon traffic conditions throughout the day. Read more.

U.S. 460 Upgrade a Done Deal

The McDonnell administration touts U.S. 460 as an economic development project, not a congestion-relief project.

The McDonnell administration has closed on a deal to finance, design and build a new U.S. 460 between Suffolk and Petersburg, providing the Hampton Roads region an interstate-quality alternative to Interstate 64 to connect with the interstate highway system.

The $1.4 billion project has been justified as a cost-effective way to promote the competitiveness of the Virginia ports, attract major industrial investment,  enhance the connectivity between military installations, create an additional hurricane evacuation route and allow visitors a more predictable route for reaching tourist destinations.

“There is a clear and critical need for the new U.S. 460,” said Governor Bob McDonnell in a press release announcing the close. “Today, the Commonwealth is finally delivering on that need and building a project that will not only make transportation better for the southeastern region and the state, it will also generate jobs and economic development opportunities, bringing extensive long-term benefits in so many ways.”

US 460 Mobility Partners, a for-profit partnership of Ferrovial Agroman, S.A. and American Infrastructure, will design and build the project. The non-profit Route 460 Funding Corporation of Virginia will issue bonds, set toll rates, collect tolls and operate the highway.

The Virginia Department of Transportation will contribute $903 million to the project, while the Virginia Port Authority will kick in another $250 million. Toll-backed bonds will account for only $243 million — or roughly one-sixth of the total cost.

The project never generated much outright opposition, although some Hampton Roads planners and business interests said the highway was a lower priority than other projects that would have relieved traffic congestion in the region’s urban core. Smart Growth groups faulted the Public Private Partnership Act process for giving the public insufficient time to review and respond to the final deal terms. Also, they say, the McDonnell administration never gave serious consideration to less expensive alternatives, nor did the Commonwealth Transportation Board ever weigh the state’s $900 million investment against competing rail, transit or local road projects.

The U.S. 460 toll road is scheduled to open in 2018.

— JAB

McDonnell to Propose $500 Million in New Transportation Revenue

Governor Bob McDonnell announced today that his administration is working on a plan to raise $500 million yearly by 2019 in new transportation revenues to fund roads, bridges, transit and passenger rail.

He provided no specifics in his keynote address to the 2012 Governor’s Transportation Conference in Tysons Corner but said details would be announced “over the coming weeks.” Said the governor:

My goal for our funding package is to generate at least $500 million in revenues annually by 2019. The new transportation revenues will be dedicated to maintenance, and will eliminate the shortfall which is causing more and more funds meant for construction to be instead spent just maintaining our existing infrastructure. This additional revenue will free up funds for new construction, and will lead to additional funds for transit and passenger rail.

Added McDonnell: “The time to address our transportation funding challenges is now.  We cannot continue kicking the can down the road.”

With stagnant transportation revenues and rising maintenance costs, the Virginia Department of Transportation expects to run out of state funds for new road projects by 2017. A broad coalition of cities, counties and chambers of commerce in Virginia’s urban crescent has called for new sources of revenue to bolster transportation spending. And Sen. John Watkins, R-Powhatan, has proposed a tax on the wholesale price of motor fuels sales.

Meanwhile, a coalition of environmental and smart-growth organizations has issued a press release denouncing the McDonnell administration for squandering billions of borrowed dollars on ill-conceived mega-projects, failing to review alternatives and running roughshod over local governments and regional planning organizations. New funding, contended the four organizations, should be tied to reforms in the Public Private Partnership Act, stronger legislative oversight, an active partnership with local and regional leaders, and an objective evaluation of alternative solutions and investments.

– JAB

Public-Private Transportation Act Needs Reform

I-495 Express Lanes: reasonably fair to taxpayers and the traveling public.

Virginia’s reliance upon the Public-Private Partnership (P3) process to build large bridge, rail and highway projects has led to the centralization of decision making in the hands of the governor’s office with little effective oversight, contends James J. Regimbal Jr. with Fiscal Analytics, Ltd., in a report sponsored by the Southern Environmental Law Center (SELC).

That centralization makes it all the more imperative that decision-making under the Public-Private Transportation Act be more transparent and accountable, concludes Regimbal in “An Examination of the Virginia Public-Private Transportation Act of 1995.

As traditional funding sources for transportation construction decline and formula allocations to systems and regions dry up, transportation decision-making is shifting away from a more diffuse system of local, regional Metropolitan Planning Organizations (MPOs), and Commonwealth Transportation Board (CTB) decision-making, to the PPTA proposer and Governor’s administrative agencies in charge of soliciting, screening and procuring PPTA projects. …

The increased centralization of transportation decision-making through the PPTA makes is more important than ever for the public and their representatives in the General Assembly to be kept adequately informed throughout the PPTA decision process.

Midtown-Downtown Tunnel — not so fair to the traveling public.

The former Virginia Finance Committee staffer advances a number of recommendations, including (1) promoting competition by requiring more bidders, (2) making the state’s “Value for Money” analysis available to the public, (3) strengthening the independence of the Commonwealth Transportation Board, and (4) requiring a public hearing after all major business points have been disclosed and before a P3 agreement has been signed.

In some cases, Regimbal suggests, the state should limit private-sector involvement to design-build contracts, which ensure that projects get built on time and under budget, rather than giving private concessionaires an ownership stake in a project. He also advocates treating some projects as regulated utilities as a way to offset risks to private-sector partners without messy non-compete clauses, built-in toll escalators and other undesirable features.

Unlike in some states, the General Assembly has no role in selecting P3 projects. The CTB has no statutory role and is referred to only as an “oversight board” in PPTA implementation guidelines.

Furthermore, says Regimbal, there are no established criteria or a transparent process for determining the level of state subsidy to P3 projects. Thus, the Downtown/Midtown Tunnel project, the top transportation priority of the Hampton Roads region, received $300 million in state subsidies for the purpose of holding down toll charges, while the Route 460 Connector, which has a much lower regional priority, will receive more than $1 billion in state and Virginia Port Authority subsidies.

The key decision point in the P3 project-development process is the Value for Money analysis conducted by the Office of Transportation Public-Private Partnerships. This cost-benefit-risk analysis has not been made available to the public in time to solicit meaningful feedback from the citizenry or affected interests.

Bacon’s bottom line: Regimbal does an excellent job of laying out the main issues associated with the increasing use of P3s. He shows how some projects, such as the Interstate 495 Express Lanes project, accomplish important public objectives at a reasonable public cost and risk profile, while others leave many questions unanswered.

Regimbal wisely refrains from criticizing the McDonnell administration or particular state agencies, focusing instead upon the structural flaws of Public Private Transportation Act as currently written. Legislators enacted the law in 1995 and have made major updates since then, but it is only in recent years, since the state has negotiated a significant number of P3 projects, that the problems Regimbal highlights have become glaringly evident. The General Assembly needs to revisit the Act again. Hopefully, we’ll see legislation in January reflecting some of his proposals.

– JAB

Australians May Dump Pocahontas Parkway

The Pocahontas Parkway -- Transurban's white kangaroo?

By Peter Galuszka

This just in from Australia! Transurban, the Aussie company that owns public-private partnered Pocahontas Parkway near Richmond, is considering selling the toll road because it has become a White Kangaroo.

If so, this is incredibly bad news for PPP3 advocates everywhere, including various moderates and conservatives such as Gov. Robert F. McDonnell and his transportation chief Sean Connaughton.

The Australian newspaper reports Aug. 7 that Transurban, a master of PPP3 deals, is considering unloading the eastern Henrico property because it has become a financial disaster that has led to a 51 percent slide in its annual profit.

Reports the newspaper: “The Pocahontas Parkway in the southern part of Virginia was constructed in anticipation of new housing developments that never materialized due to the global financial crisis.”

In June, the firm wrote down the value of the parkway to zero and took a $138.1 million charge. The newspaper says that the Virginia project is a “blight” on its other Australian entities.

The Parkway that connects I-95 with I-295 has had a history of problems. During the years of former Gov. Mark Warner its lagging tolls and debt almost cost Virginia its Triple-A bond rating. Warner put together a quick deal to unload the property.

Other than helping get traffic to Richmond International Airport, the multi-lane loan seems lonely. It extends through farmlands and pine forests that had been anticipated subdivisions and shopping malls before the 2007 real estate crisis hit.

The larger issue is that public private partnerships of the Pocahontas type are considered panaceas for states with no money to spend on big, new roads. Popular with both political parties, McDonnell has time and again tried to excite interest in PPP3 deals for his pet projects such as a superhighway to replace US 460 in southeast Virginia and tap expected new port cargo traffic when the Panama Canal expansion is completed.

The Aussies, however, are sounding a loud warning. Call it “Thunder from Down Under.”

Addendum to the Pocahontas Parkway Post

I omitted from the original draft of the “Lessons from the Pocahontas Parkway Fiasco” one of the most important lessons learned. Having appended it to  the original post, I reproduce it here for the benefit of those who might otherwise miss it:

Lesson No. 4: Public-private partnerships create transparency. As a publicly traded company, Transurban must use Generally Accepted Accounting Procedures and report material write-offs like the Pocahontas Parkway. There is no such accounting or accountability for non-tolled state projects, whose accounting is opaque and inaccessible to outsiders.

For purposes of comparison, consider Rt. 288, an untolled section of the Richmond metropolitan beltway built entirely with state dollars — including many tens of millions from the General Fund — just a few years later. Rt. 288, too, was touted for its “economic development” benefits. Has it lived up to expectations in light of the real estate crash? Do traffic counts meet projections? Is there even any way to measure the success or failure of the project? No, there is not. The public is left in total ignorance, decision makers are not held accountable, and critical questions never get asked.

– JAB

Lessons from the Pocahontas Parkway Fiasco

Pocahontas Parkway where it crosses the James River

by James A. Bacon

Transurban, the majority investor in the Pocahontas Parkway (Route 895) has learned the hard way that human settlement patterns hit a major inflection point during the 2007-2008 recession. Unlike most planners and politicians in Virginia, whose policy prescriptions presume that nothing fundamental has changed, the Australian infrastructure company has taken a $181 million write-off, effectively reducing its equity investment in the project to zero.

Said Transurban CEO Chris Lynch:

The Pocahontas investment was made in 2006 on the expectation of significant housing and other development along the corridor resulting in growing traffic volumes and revenues. That development, due to specific issues in the local area and the continuing difficult macro-economic environment, has not yet manifested and is now expected to take longer to eventuate, resulting in a significantly reduced population of potential toll paying customers.

Based on revised traffic forecasts, Transurban now believes Pocahontas’ future cash flows will be significantly impaired relative to the original forecasts.

The 8.8-mile highway, which creates a southeastern bypass for the Richmond metropolitan region, was promoted as an economic development project and opened in 2002. Toll revenues did not live up to forecasts, however, and the project was close to defeasing on its bonds. Transurban took over in 2006, recapitalized the project and began operating the toll road. Now it, too, has lost its shirt.

The significance of this announcement cannot be over-stated.

Lesson No. 1: Beware transportation projects that are justified on the basis of anticipated economic development. I’m talking to you, Loudoun County supervisors, as you prepare to approve the new financing structure for the Rail-to-Dulles project! I’m talking to you, members of the Commonwealth Transportation Board (CTB), which just approved a subordinated $80 million loan for the U.S. 460 Connector in the expectation of a Panama Canal-sparked port boom! The hoped-for traffic may not materialize.

Lesson No. 2: Beware all transportation projects built to serve the metropolitan periphery. There ain’t no more growth heading out there any time soon! The limited development that is taking place is shifting closer to the urban core. It’s re-development, really, recycling aging neighborhoods and commercial areas into walkable, mixed-use communities for which there is considerable pent-up demand. There is very little demand for conventional development on the metropolitan periphery.

Corollary to Lesson No. 2: Beware all major real estate projects built on the metropolitan periphery. I’m talking to you, CTB members, who just approved an $80 million loan to fund transportation elements of a $2 billion mixed-use mega-project in Loudoun County.

Lesson No. 3: Let the private sector shoulder the risk of speculative transportation projects. I bear Transurban no ill will, but I’m really glad that it’s Transurban taking the hit and not Virginia taxpayers. The road never should have been built in the first place. But if the state is bound and determined to get speculative roads built, then the deals should be structured so that private-sector partners assume the risk and pocket the reward. The Commonwealth of Virginia should not be in the business of making speculative infrastructure deals.

Lesson No. 4: Public-private partnerships create transparency. As a publicly traded company, Transurban must use Generally Accepted Accounting Procedures and report material write-offs like the Pocahontas Parkway. There is no such accounting or accountability for non-tolled state projects, whose accounting is opaque and inaccessible to outsiders.

For purposes of comparison, consider Rt. 288, an untolled section of the Richmond metropolitan beltway built entirely with state dollars — including many tens of millions from the General Fund — just a few years later. Rt. 288, too, was touted for its “economic development” benefits. Has it lived up to expectations in light of the real estate crash? Do traffic counts meet projections? Is there even any way to measure the success or failure of the project? No, there is not. The public is left in total ignorance, decision makers are not held accountable, and critical questions never get asked.

The Idea List

The recently published “pipeline” of 22 public-private partnership proposals does not represent a formal McDonnell administration transportation agenda. Think of it more as an inventory of ideas worth checking out.

Traffic management center in Northern Va.

by James A. Bacon

Of all the 22 public-private partnership ideas listed in a recently issued McDonnell administration document, the one that gets Tony Kinn the most stoked is a proposal to consolidate Virginia’s five regional traffic operations centers. His aspiration, says Kinn, director of the Office for Transportation Public Private Partnerships (OTP3), is to create the best traffic management system in the United States, if not the world.

Traffic operations centers do the mundane work of tracking and clearing traffic accidents, dispatching aid to stranded motorists and updating signs regarding traffic conditions. According to the Daily Press, the Hampton Roads facility in Hampton Roads, with a network of 276 closed-circuit cameras, handled more than 70,000 incidents last year and assisted 40,000 roadside motorists. And that’s just one of five around the state. The centers are run by contractors operating under four different contracts using different software platforms. The state has received 32 proposals from companies responding to a solicitation to merge them.

One advantage of a unified system, says Kinn, is that if one center goes down, others could take up the slack. Then there are the improvements that no one has thought of yet. Kinn is looking for innovation. A private-sector operator might test a new concept in one center and, if successful, roll it out to the others. Other states have dabbled with privatizing their centers, he says, but Virginia wants to take traffic operations to the next level.

Consolidation of Virginia’s traffic operations centers is one of eight ideas that have reached “candidate” status in the McDonnell administration’s P3 prospect list. The pipeline of possible projects also includes 14 projects in the “conceptual” stage. If a conceptual project survives the first cut, it goes through a more rigorous analysis as a “candidate.” Says Kinn: “All of these projects go through a high-level screening process to make sure the feasibility is there. “Does it fit the needs of the commonwealth? Can we afford it? Does it provide benefits?”

Smart Growth groups have sounded the alarm over several projects in the list, particularly a proposed North-South Corridor in Northern Virginia, as well as projects well past the “candidate” stage, such as the U.S. 460 Connector, a project estimated at $1.5 billion to $2 billion that would link Suffolk and Petersburg with an Interstate-grade highway. The McDonnell administration has “hijacked good transportation planning and prioritization in Virginia,” Stewart Schwartz, executive director of the Coalition for Smarter Growth, has said. The P3 projects are approved outside the normal process for distributing road and highway construction dollars, which gives the administration unprecedented leeway to push its own pet projects.

Kinn responds that the list was devised after extensive consultation with Metropolitan Planning Organizations and local government officials around the state, and that “candidate” projects will be elevated to actively pursued projects only after extensive local consultation. “We’re going to go to the people, and the people will have to come to us, and we’ll have to work together.”

In a Friday interview, Kinn fleshed out the thinking behind some of the projects in the pipeline.

Interstate 95 Corridor improvements. The McDonnell administration has obtained authority from the Federal Highway Administration to place tolls on I-95 south of Fredericksburg for the purpose of raising funds to make improvements to the interstate corridor. The idea here is to examine the potential for leveraging the revenue flow by means of a P3. The administration is not presupposing that a public-private partnership is a good idea, Kinn says. It is simply examining the option. “What else can we bring to the corridor?”

Interstate 64 HOV lane conversions. I-64 in Hampton Roads has under-utilized HOV lanes. Does it make sense to convert them to HOT lanes like those under construction on the Capital Beltway, in which cars are charged a toll for using a congestion-free lane but car poolers still get to use it for free? The pertinent questions, says Kinn: “Is it feasible? Can we afford it?”

Port of Richmond. APM Terminals has submitted an unsolicited bid to take over management of the Port of Virginia terminals in a deal potentially worth $3 billion to $4 billion in payments to the Commonwealth over 48 years. Says Kinn: “The Panama Canal is going to create a huge influx of business. We are sitting on the threshold of an opportunity for major business growth. … APM has submitted a proposal — we want other proposals to come in.”

Hampton Roads crossings improvements. A “third crossing” between Norfolk and the Peninsula has been a top priority of Hampton Roads planners for many years. The McDonnell administration wants to see if these projects are feasible using a P3 model.

NoVa North-South Corridor. The idea of building a north-south corridor linking Interstate 66 and Route 7 in Northern Virginia is “in the very preliminary stage,” says Kinn. The administration wants to see if P3s can be used to “do that in a profitable and efficient way.” Continue reading.

McDonnell Team Ponders 22 Public Private Partnerships

HOT lanes under construction on the 495 Beltway

by James A. Bacon

The McDonnell administration has announced a draft list of projects to be pursued by the Office of Transportation Public-Private Partnerships (OTP3). Eight projects  deemed formal “candidates” for consideration range from corridor improvements along Interstate 95 to the conversion of HOV lanes into HOT lanes in Hampton Roads. Fourteen “conceptual” projects vary from rest area enhancements and cell tower opportunities to Dulles Metro rail station air rights and Wallops Island visitor & support facilities.

“The past two years have seen the McDonnell administration take several proactive steps to meet Virginia’s transportation challenges including streamlining the PPTA implementation guidelines and creation of the OTP3 to focus on the identification, development and delivery of P3 projects across all modes of transportation in Virginia,” said Transportation Secretary Sean Connaughton in a prepared statement. “The OTP3 has been charged with creating an environment that encourages private investment and proactively identifies, assesses and implements the Commonwealth’s priority transportation projects.”

Said OTP3 Director Tony Kinn: “The pipeline is a significant step forward and reinforces why Virginia continues to be viewed as a national leader in public-private partnerships.”

However, the list did not win universal plaudits.

“We believe that the PPTA program has hijacked good transportation planning and prioritization in Virginia,” said Stewart Schwartz, executive director of the Coalition for Smarter Growth in a press release issued yesterday. “A small group of officials including the Secretary of Transportation have too much power to divert tax subsidies to private contractors for a list of projects that they alone develop. Are these mega-projects the right approaches for these corridors?  Are they where we really need transportation investments?”

Smart Growth groups identified the U.S. 460 Connector project and a proposed NOVA North-South Corridor as particularly worrisome, the former because the state is promising $750 million in state and Virginia Port Authority funds and the latter because it would advance a sprawl-inducing outer beltway around the Washington region.

“We are very concerned about the diversion of public dollars to private priorities,” said Chris Miller, President of the Piedmont Environmental Council. “I fear there is a rush to commit the last remaining transportation dollars to projects that fail to address the concerns of the public about the poor state of existing local road networks across the Commonwealth.”

Virginian-Pilot reporter Debbie Messina interviewed Connaughton about converting HOV to HOT lanes and other proposals affecting Hampton Roads.

“We need to try to get more through-put with the existing capacity,” Connaughton said. He added that building more lanes may also be considered. …

It’s no surprise that the list also includes widening I-64 between Newport News and Richmond, and expanding Hampton Roads water crossings, which is offered as a package of projects that would include the Hampton Roads Bridge-Tunnel and the Patriots Crossing/Third Crossing.

“It’s quite clear to us that when you look at the Hampton Roads crossings, you have to look at them as a complete system and develop them either incrementally or with a total approach,” Connaughton said. Tackling them individually provides only marginal improvements, he added.

I don’t have time today for anything more than this quick-and-dirty response but I will follow up with a closer analysis of the list.