Rhode Island’s controversial truck tolling program, RhodeWorks, may see a resurgence following a recent ruling by the First Circuit Court of Appeals. The decision partially overturns a 2022 lower court ruling that blocked the toll system, giving the green light to tolls targeting Class 8 vehicles, while striking down specific provisions that capped payments.
The ruling is a setback for the American Trucking Associations (ATA), which has been at the forefront of legal opposition to RhodeWorks. However, the decision also acknowledges flaws in some elements of the tolling structure, providing a partial victory for ATA and other plaintiffs.
Under scrutiny was whether tolling only Class 8 vehicles, such as tractor-trailers, violated the dormant Commerce Clause, a legal principle ensuring state regulations do not unfairly burden interstate commerce. The Appeals Court found no violation, ruling that focusing on Class 8 vehicles was reasonable given their disproportionate use and impact on Rhode Island’s 13 toll-eligible bridges. Earlier iterations of the toll system had included Classes 6 and 7 but were later narrowed to Class 8 vehicles exclusively.
However, the court invalidated RhodeWorks’ toll-capping provisions, which limited daily and trip-specific charges for trucks. These caps were designed to provide financial relief to frequent local users but were deemed discriminatory, as they disproportionately benefited Rhode Island-based trucks. ATA presented data showing that nearly 40% of toll reductions due to these caps favored in-state trucks, despite their accounting for less than 19% of toll transactions. The court ruled this arrangement unconstitutional under the dormant Commerce Clause, citing an unfair advantage to local operators over interstate competitors.
The decision further addressed the “fair approximation” of tolls, a standard requiring fees to reflect users’ impact on the tolled facilities. The court upheld Rhode Island’s rationale, stating that Class 8 vehicles, as the most intensive users of the state’s bridges, could justifiably bear the tolls without necessitating fees for smaller vehicles.
Despite invalidating the caps, the court concluded that this flaw does not render the entire RhodeWorks system unconstitutional. The ruling emphasized that excising the defective provisions aligns with the state’s intent to fund bridge repairs and maintenance through toll revenue.
The case now returns to a lower court for further proceedings, leaving the future of RhodeWorks and its implementation subject to additional legal scrutiny. Rhode Island officials, including Attorney General Peter Neronha, welcomed the decision as a critical step toward reinstating the tolls, which aim to address the state’s infrastructure needs.
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