“DOTR-LTO TRB MEMO CIRCULAR should not be implemented, cash lanes should be maintained to give motorists option in tollways”- – LCSP

LAWYERS for Commuters Safety and Protection (LCSP) oppose the implementation of DOTR LTO TRB Memorandum Circular 2024-01 that the TRB would want to implement on October 1, 2024.

It was originally scheduled to be implemented last August 31, 2024 but was deferred by TRB due to the directive of Congress.

While we respect the regulatory powers of DOTR, LTO and TRB, LCSP believes that we should present to TRB the peculiarity of our toll ways.

Implementing DOTR LTO TRB Memo circular 2024-01 will be prejudicial to the motorists. Thus, not only should the memo circular be deferred but should be scrapped.

The Memo circular will remove cash lanes. Hence, all motorists entering toll ways should have an RFID sticker.

Without a sticker motorist will be fined P1,000 for the first offense, P3,000 for the second offense and P5,000 for succeeding offense.

Entering the toll expressway without enough balance to cover fees will be fined P500 for the first offense, P1,000 for the second and P2,500 for succeeding offenses.

The penalties are not only excessive but does not solve the traffic that non RFID users are allegedly creating in the toll ways.

If DOTR LTO TRB claims that ninety percent are already RFID equipped, then how would the ten percent non RFID users create traffic when they have an exclusive cash lane.

And what vehicles have no RFID. Those vehicles which are not frequent users of toll ways. Why don’t the penalty include payment for RFID installation or load.

If as DOTR LTO TRB claim that the ten percent are the ones creating traffic then in its first offense why don’t they install RFID (part of the penalty) so that there will be no more second or succeeding violation.

Another objectionable provision is penalizing a motorist who already entered the toll way but because his load is no longer enough to exit, he should be penalize.

How many motorists will be able to compute how much load he needs to exit. Hence, to be safe, he will load more just for good measure unjustly increasing the so called floating money of RFID providers.

Even if he does not need it to exit the toll way. Why don’t DOTR, LTO, TRB penalize RFID providers every time the barriers fail to open up despite sufficient load of the motorists?

Note that 90% of the complaints of toll users are RFID related issues on missing loads, slow lifting barriers etc. Will penalizing these none RFID users solve these complaints?

Also there are tollways which have no service roads for those vehicles which could not afford paying toll fees. It is cheaper for these motorists to use the cash lane than loading RFID.

LCSP is not against the use of an efficient RFID provider in our toll ways. But we should also give an option to those who prefer to use the cash lanes because they feel that using the cash lanes are more economical and practical for them. Why penalize these motorists?

Once implemented, DOTR, LTO, TRB Memo Circular will render poor motorists even more CASHLESS.