In this issue:
- Truck-Only Toll Lanes Gain Credibility
- Suburbs vs. Urban Cores
- Managed Lanes for the Midwest
- Freight Rail Conflicts with High Speed Rail
- Natural Gas Autos and “Oil Addiction”
- Composite Bridges
- Upcoming Conferences
- News Notes
- Quotable Quotes
Truck-Only Toll Lanes Gaining Credibility
Eight years ago Peter Samuel, Jose Holguin-Veras, and I coauthored a Reason Foundation policy study introducing the idea of adding truck-only toll lanes to major Interstate corridors. We suggested that in addition to safety and pavement-cost savings (due to shifting heavy trucks to lanes designed for heavier loads), there could be significant productivity gains if federal law permitted longer combination vehicles (LCVs) such as turnpike doubles and triples to operate on such lanes in the many states where LCVs are currently prohibited by federal law. We also provided calculations showing that in some cases, such lanes might be self-supporting from toll revenues.
Despite initial skepticism, the idea now seems to be reaching critical mass. A case in point is the just-completed Phase 1 study of dedicated truck lanes on I-70 from Kansas City on the west to the Ohio/West Virginia line on the east. The study, done by a team led by Wilbur Smith Associates and HNTB for the DOTs of Missouri, Illinois, Indiana, and Ohio, concluded that the best alternative for congested, aging I-70 across these states is to rebuild it with dedicated truck-only lanes along its entire 800-mile length. The business case analysis concluded that safety, productivity, and cost-avoidance benefits would exceed the costs of building, operating, and maintaining the truck lanes. You can read the excellent 23-page summary report here: www.i70dtl.org/images/final_summary_report.pdf.
Since the four states don’t begin to have the mega-bucks needed to build the preferred alternative, the study did a preliminary tolling analysis, testing a number of possible toll rates and configurations, including tolling all lanes (since car drivers would benefit, too, from separation of heavy vehicles). Using the best of these alternatives, toll finance could cover between 45 and 74 percent of project costs, with the latter reflecting a PPP model. I think the idea of tolling all lanes of a completely rebuilt Interstate is likely the best way to go. Among other things, it would make it more acceptable to the trucking industry to pay for their share of the reconstruction.
Let me also call your attention to a highly detailed report on this subject from TRB’s highway and freight research programs. “Separation of Vehicles—CMV-Only Lanes” was done by Cambridge Systematics and released in June. It is NCHRP Report 649 and also NCFRP Report 3, which you can download by Googling either name. It draws on previous research by half a dozen entities (including several Reason studies) to analyze the potential benefits and costs of truck-only lanes in both urban and long-haul settings. And while it finds substantial benefits (especially with LCVs on long-haul truck lanes), one of its key findings is that positive benefit/cost ratios depend critically on the fraction of trucks using the lanes. The trucking industry has been strongly opposed to mandatory use of truck lanes, especially if those lanes are tolled. But in my view, if truck lanes are added as part of a complete reconstruction of an Interstate with all lanes ending up tolled, then the safety benefits of car/truck separation—to both types of vehicles—should reduce or eliminate trucking’s opposition to mandatory truck-lane use in such cases. (That point is mine, not that of Cambridge Systematics.) My one quibble with the report is that it ignores the potential of LCVs in certain types of urban truck lanes, such as those involved in serving container ports. This is despite its reproducing a table from a Reason urban truck lane study, which it uses to illustrate LCV productivity gains on long-haul truck lanes.
Finally, let me also recommend AASHTO’s new “Unlocking Freight” report, which makes a very strong case for adding highway capacity in key trucking corridors. Among the quantitative recommendations is the addition of 8,000 lane-miles of truck-only toll lanes to selected Interstates. If that is done via the industry’s preferred two lanes per direction, that would mean 2,000 route miles equipped with truck toll lanes. You can find the report at http://expandingcapacity.transportation.org.
Suburbs vs. Central Cities: the Battle Continues
Are significant numbers of people relocating from suburbs to central cities? Many advocates of high-density “smart growth” contend not only that densification is a good idea but that it’s an important ongoing trend that transportation policy should encourage. Other analysts say there is little or no evidence of such a trend, and that recent attempts to demonstrate one amount to “torturing the data until it confesses.”
The latest round in this battle was set off by an op-ed piece in the Wall Street Journal by demographer Joel Kotkin (“The Myth of the Back-to-the-City Migration,” July 6, 2010, also available at www.newgeography.com/content/001657-the-myth-back-city-migration). Kotkin cited census data showing that “Over the past decade, the percentage of Americans living in suburbs and single-family homes has increased,” and also cited the debacle of vastly overbuilt downtown condos in Las Vegas, Los Angeles, Miami, and elsewhere. He closed by urging planners “not to try forcing a market beyond proven demand.”
That op-ed prompted a response from Alan Berube of the Brookings Institution, on The New Republic’s blog (www.tnr.com/blog/the-avenue/76082/misleading-indicator-head-counts-not-condos-better-reveal-city-trends). Berube dismisses the condo-price collapse as beside the point, citing instead data on city population trends from his colleague Bill Frey, who found that 2008-2009 was “the most pro-urban year for population growth in at least a decade, with cities and suburbs growing at roughly equal rates.”
And that, in turn, prompted demographer Wendell Cox to release a detailed quantitative response on July 13th. Cox used annual Census Bureau data on both domestic and international migration. These data are at the county level, so the basic comparison is core county vs. suburban counties. Between 2000 and 2009, 48 major metro areas lost 1.9 million people to domestic migration. But that is the net result from core-county losses of 4.5 million and suburban county gains of 2.6 million. In addition, over the same decade, urban areas lost 200,000 domestic migrants to exurban counties, outside the formally defined metro area. (www.newgeography.com/content/001666-special-report-move-suburbs-and-beyond-continues)
For core counties, however, their final population changes do not look as bad as the above numbers suggest. During the same decade that they were losing 4.5 million domestic migrants, the core counties gained just over 4 million international migrants. So their overall totals have not declined all that much. But that result has nothing to do with people migrating back from suburbs to downtowns, for which Cox concludes that there is “not a shred of evidence.”
Managed Lanes Come to the Midwest
Until very recently, the idea of priced, congestion-relief express lanes has been largely a Sunbelt phenomenon. But congestion is also a major problem in those parts of the Midwest that are thriving (such as Chicago and Indianapolis), even if not in struggling places like Cleveland and St. Louis. So I’m not surprised that managed lane proposals are now on the table in both Chicago and Indianapolis.
Several years ago the Illinois Tollway issued a proposal for “Green Lanes” on the most congested portions of its metro Chicago area toll roads. It would have added 80 miles of new lanes, which would be open to customers willing to pay a congestion-priced toll rate (and to HOVs and hybrids at regular toll rates). But that plan got caught up in the corruption problems of former Gov. Rod Blagojevich and was terminated after his resignation.
A new report by Wilbur Smith Associates (WSA) calls for implementing managed lanes on three expressways: the Stevenson (I-55, from I-355 to downtown), the Jane Adams Tollway (I-90, from IL-31 to I-294), and the existing reversible lanes on the Kennedy Expressway (I-90/I-94). Thus, we have three different types of projects: adding MLs to an existing freeway, adding MLs to an existing tollway, and converting non-priced reversible express lanes to priced MLs. The study was sponsored by the Metropolitan Planning Council and the Illinois Tollway, and was funded largely by the FHWA. (www.metroplanning.org/news-events/article/5918)
In addition to documenting rush-hour time savings motorists would gain from using the managed lanes, the report also summarizes results from focus groups and a stated-preference survey. The latter found very strong support for the idea, with 85% saying they would pay a premium toll if it gave them congestion relief and 82% supporting the idea of using tolling to pay for highway improvements that relieve congestion. The focus group results illustrated a contrast I’ve often observed between the views of elected officials and planners, on the one hand, and typical motorists on the other hand. The latter said that “revenues generated by congestion pricing should be used for roadway improvements and maintenance,” while the former favored “reinvesting any revenues into transit infrastructure and operations.”
Things have not gotten quite that far in Indianapolis (which ranks #34 in the Texas Transportation Institute’s table of metro areas on Travel Time Index, compared with Chicago at #2). But a Central Indiana Transit Task Force report released in mid-July recommended the addition of express toll lanes on two congested Indianapolis-area freeways: I-69 south of Fishers and I-65 between downtown and Southport. As reported by Chris Kikich in the Indianapolis Star (July 14th), the task force’s founder, Mark Miles, “said that the more the group looked into express lanes, the more compelling the argument became to implement them. The business implications could be huge, he said, from helping customers get to work to moving freight more quickly.”
The Emerging Conflict Between Freight and High(er) Speed Rail
Back in March 2009, in Issue No. 65, I wrote about the inherent conflict between high-speed passenger rail and freight rail, making the well-known railroading point that because the service characteristics are so different, you can optimize a rail system for one or the other, but not both. Europe, I noted, after World War 2 opted for passenger rail, and as a result by 2005 their rail system handled only 10% of all freight ton-miles. By contrast, during that same half-century, the United States optimized its system for freight, with the result that as of 2005, rail’s share of freight ton-miles was 41% here.
The problem with current federal rail policy is that it seeks to both expand freight rail’s share of goods movement (to get more trucks off the highways, per the DOT’s Draft Strategic Plan) and to add 110 mph passenger service to those very same freight rail lines. (All but two of the Administration’s 30 “high speed rail” grants are for enhancements to Class 1 freight lines to permit passenger trains at up to 79 mph, 90 mph, or in a few cases 110 mph; this is better referred to as higher-speed rail.)
The past two months have witnessed a growing awareness of this conflict, not only within the railroad industry but in the mainstream media. Besides a very basic piece in the Washington Post (July 20th), perhaps the most detailed look appears in the July 24th issue of The Economist. The article’s subtitle says it all: “America’s system of rail freight is the world’s best. High-speed passenger trains could ruin it.” (www.economist.com/node/16636101?story_id=16636101&fsrc=rss)
The main conflicts are explained in some detail in a long June 10th article in Progressive Railroading. (www.progressiverailroading.com/pr/article.asp?=23532) Associate editor Angela Cotey points out that each major (Class 1) railroad has its own set of rules that states and passenger rail operators must follow to ensure that passenger trains don’t conflict with freight service. The main categories are capacity, liability, safety, cost, and compensation. Of the big four Class 1s, only Union Pacific (UP) is willing to consider passenger train speeds up to 110 mph (on a case by case basis). CSX and BNSF will consider up to 90 mph, while Norfolk Southern’s limit is 79 mph. Any operation wanting to exceed those limits would have to build its own track adjacent to (and not interfering with) the freight tracks, at far greater cost than simply paying for upgraded signaling, improved grade crossings, and more passing sidings. In New York State, CSX estimates that a separate track from Albany to Buffalo for 110 mph passenger trains would cost $8 billion. Another issue is maintenance. For 110 mph service, track needs to be Class 6, with much tougher and more expensive maintenance requirements than the Class 4 that suffices for lower-speed freight runs at 50-60 mph.
And railroad media have been buzzing ever since DOT Secretary Ray LaHood held a meeting with senior Class 1 executives on June 9th, essentially accusing them of attempting to “sidetrack President Barack Obama’s signature transportation project before it even got started,” according to Crain’s Chicago Business. Blogger Garl Latham of MyProgressiveRailroading (June 16th) castigated LaHood for “making thinly veiled threats” and reminding the executives of “pretty significant investments” in freight railroads via recent federal programs.
Apparently the railroad officials were not pleased with the (May 12th) 19-page Federal Railroad Administration draft of the “Stakeholder Agreements” that must be signed by the relevant railroad involved in each higher-speed railroad project. It requires state DOTs and the railroads to agree to meet stringent performance measures, which if not achieved will require repayment of the federal grant money. And any new capacity created must be reserved for passenger rail use and not be used to increase freight capacity. According to Ken Orski’s Innovation NewsBriefs (June 16th), “The FRA directive reportedly ‘stunned’ the railroad industry.” And “although none of the parties would go on record as threatening to break off negotiations and walk away from the high speed rail program, several senior railroad executives have left no doubt that there are limits to how far they were willing to compromise their paramount objectives of maintaining safe operations and keeping commitments to their customers—objectives that require giving precedence to freight operations.”
While it is understandable that FRA seeks to ensure that its grant funds are not wasted, it looks to me as if no one in the Administration has thought through how much its freight rail and passenger rail goals are in direct conflict.
How Not to End America’s “Oil Addiction”
James Woolsey is a former director of the CIA—but that doesn’t make him an energy expert. In an April 15th op-ed in the Wall Street Journal, Woolsey bemoaned America’s “oil addiction,” echoing numerous politicians, including most of our recent presidents. While correctly criticizing a policy of government “picking winners” (whether of technologies or energy source), a few paragraphs later he endorsed T. Boone Pickens’ idea of converting the U.S. motor vehicle fleet to natural gas (of which Pickens has rights to huge quantities), beginning with truck fleets. A subsequent letter to the editor (April 24th) cited an interview with Pickens on CNBC on April 14th, in which Pickens argued for government subsidies of $65,000 apiece to convert or replace as many as 8 million trucks. That adds up to $520 billion, at what I’d guess would be a very high cost per ton of CO2 eliminated. And that would just cover the truck fleet. Providing, say, $10,000 apiece for individuals to replace or convert 135 million cars would cost another $1.35 trillion.
Natural gas, of which the United States now has a 100-year supply, according to Cambridge Energy Research Associates (thanks to huge finds in Texas, Pennsylvania, and elsewhere), has a role to play in reducing CO2 emissions. It’s not in motor vehicles, however, but rather in providing a substitute for coal in generating electricity. Economist Robert Samuelson penned an excellent piece on the folly of political quests for energy independence on Real Clear Politics last month, titled “Energy Pipedreams.” (www.realclearpolitics.com/articles/2010/06/21/energy_pipedreams_106036.html)
In it he cites Robert Bryce’s excellent new book, Power Hungry: The Myths of “Green” Energy and the Real Fuels of the Future, which I have recommended previously.
I’m very impressed by recent progress in using unconventional, lighter-weight materials for bridge structures. Engineering News-Record carried several stories this spring about such materials, which promise strength and durability for bridge beams, decks, and other elements with little or no maintenance over lifetimes up to 100 years.
ENR gave its 2010 Award of Excellence to engineer John Hillman for his invention and 14 years of work developing a hybrid composite beam (HCB). It consists of a fiberglass box section containing self-consolidating concrete, steel strands, and foam. The development of the beam was supported by funding from the Transportation Research Board’s Innovations Deserving Exploratory Analysis (IDEA) program, and later by FHWA’s Innovative Bridge Research & Development (IBRD) program. The latter funded the first two permanent bridges using the HCB. The High Road Bridge in Lockport Township, IL is a 58-foot crossing, using six HCBs. The second, 31-feet long, is the Route 23 crossing in Cedar Grove, NJ. In both cases, the light-weight beams were set in a single day, without heavy equipment. Although a bridge using HCBs currently costs a bit more up-front, it is quicker to build and has much lower maintenance costs, meaning it easily wins on life-cycle cost.
Another new material is fiber-reinforced polymer (FRP) composites for use as bridge decks, pilings, and other structural applications. The Navy and the maritime industry have taken the lead on FRPs, starting with replacement of wood pilings with far longer-lasting FRPs. Early developers in the late 1990s had problems with design and composition of deck structures, and a pioneering firm (Hardcore Composites) went bankrupt after delivering only a handful of decks. But this decade, FRP bridge decks up to 40 feet in length have been built in New York, Wisconsin, and Manitoba. AASHTO is working on codes for FRP bridge decks and composite repairs of concrete, a process expected to take several more years. Most DOTs will not want to proceed with FRP until such codes are in place. Also problematic is a rule from FHWA that limits the use of proprietary, sole-source materials or structures, due to competitive bidding requirements. At a time when we need innovations like FRP and HCBs, this seems short-sighted. What should count is the lowest life-cycle cost that meets a DOT’s performance requirements, not whether two or more companies can provide a particular technology or material.
A third innovation is the use of recycled structural plastic composites (RSPC) as another lightweight, nearly maintenance-free structural element for bridges. A decade ago, initial projects were mostly replacement of wooden bridges of relatively short spans, at Fort Leonard Wood in Missouri and Wharton State Forest in New Jersey. More recently, the Army has contracted for two railroad bridges at Fort Eustis, Virginia. While these are still short spans (9 to 11.5 feet), these bridges will have impressive load-carrying capacity. Two shorter RSPC bridges at Fort Bragg, NC were designed to support 71-ton Abrams tanks.
With America’s huge backlog of deficient bridges, more cost-effective structures are an important development. I hope federal and state policymakers will be more receptive to these new materials by shifting more to performance specifications and life-cycle costing.
Note: I don’t have space to list all the transportation conferences going on; below are those that I or a Reason colleague are participating in.
International Bridge, Tunnel, and Turnpike Association 78th Annual Meeting, Sept. 12-15, San Diego, CA, Hilton San Diego Bayfront. Details at: www.ibtta.org/Events/EventDetail3.cfm?ItemNumber=4428&token=22270&userID=.
8th Annual Preserving the American Dream Conference, Sept. 23-25, Orlando, FL, Doubletree Resort. Details at http://americandreamcoalition.org. (Sam Staley and Shirley Ybarra speaking)
Wisconsin Transportation Builders Association Annual Fall Meeting, Sept. 29, Madison, WI, Marriot Hotel. Details at www.wtba.org. (Robert Poole speaking)
Two Texas Toll Concessions Are ARTBA PPP Projects of the Year
Two mega-projects in the Dallas/Fort Worth area were honored as PPP Projects of the Year at ARTBA’s 22nd Annual PPPs in Transportation Conference, July 22-23. Both the $2.1 billion North Tarrant Express and the $2.6 billion I-635/LBJ Managed Lanes projects will add variably priced tolled express lanes to congested urban freeways. Both are 52-year concessions with the same project team: Cintra, Meridiam, and the Dallas Police & Fire Pension Fund. And both were financed using a mix of private activity bonds, TIFIA loans, and sponsor equity, as well as a state DOT investment.
New Insights in O’Toole’s Gridlock
I’ve read so many commentaries and policy studies by Randal O’Toole, that I held off reading his recent Cato Institute book, Gridlock, figuring there wouldn’t be much new. Wrong! I was surprised by fascinating bits of transportation history, many new insights into current transportation policy issues, and some provocative public policy proposals. You can order the book directly from Cato. (http://store.cato.org)
The Importance of Reliability in Transportation
The OECD and International Transport Forum’s Transport Research Center have released a 163-page report called Improving Reliability on Surface Transport Networks. In addition to underscoring the importance of reliability, it includes chapters on how to include reliability in benefit/cost analysis, the role of supply provision and management in increasing reliability, and the role pricing can play. This is a valuable contribution to transportation policy.
Madrid Stations Win Award
Last issue I wrote about the privately financed and operated Intermodal Exchange Stations in Madrid, linking radial highways with bus and rail transit infrastructure serving downtown. Now comes news that the International Transport Forum and the International Association of Public Transport have selected this project as the winner of their joint award for Outstanding Innovation in Public Transport. ITF called the interchange stations an “example of innovation and a global benchmark.”
Corrections from Last Issue
Alert readers spotted two typos in the June issue. The correct website for the Eno Transportation Foundation is www.enotrans.com. And Prof. Ram Pendalya is at Arizona State University, not the University of Arizona. My apologies to both.
GDOT’s Managed Lanes Network Plan Wins Award
Each year, FHWA and FTA join with the American Planning Association to give out Transportation Planning Excellence Awards. One of the winners was Georgia DOT, winning in the category of modeling and technology applications, for development of the Atlanta Regional Managed Lane System Plan. Congratulations to GDOT and its consultant, HNTB.
Cox’s Critique of the Smart Growth/Transit Model
Despite its somewhat inflammatory title, demographer and transportation analyst Wendell Cox does a good job taking on a number of misleading and just plain incorrect beliefs about rail transit, cities and cars in a new Heritage Foundation study, “Washington’s War on Cars and the Suburbs.” Go to: www.heritage.org/Research/Reports/2010/06/Washingtons-War-on-Cars-and-the-Suburbs-Secretary-LaHoods-False-Claims-on-Roads-and-Transit.
“The U.S. needs to reduce its imports and grow its exports by expanding its tradable goods sector. The emphasis should therefore be on lowering the costs of freight transportation, not on getting people out of cars and into trains. It is far more important to get goods from American factories, farms, and mines to container ships bound for foreign customers at lower cost than it is to cut five minutes off the daily commutes of office workers in New York and New Jersey. Focusing on freight infrastructure improvements means that, among other things, we need to build more highway lanes and in some cases new highways for the trucks that will continue to carry most freight.”
--Michael Lind, “Goodbye, Bullet Trains and Windmills,” June 8, 2010 (www.salon.com/news/economics/index.html?story=/opinion/feature/2010/06/08/infrastructure_concrete_rail_lind)
“The challenge confronting America’s transportation infrastructure is not a matter of falling bridges and decaying roads. Rather, our transportation sector suffers from a growing lack of efficiency—in terms of how we allocate money, as well as how we manage capacity and supply. We spend many billions of taxpayer dollars on our transportation infrastructure each year, and we possess a great deal of capacity—but the wasteful use of both costs the country enormously, in time and in money. Our transportation system does cry out for reform, though not in the form of simple cash infusions from Washington. Instead, policymakers need to grasp what our transportation problem actually is—and what solutions will get America moving.”
--Tyler Duvall, National Affairs, Issue No. 3, Spring 2010 (www.nationalaffairs.com/publications/detail/unclogging-transportation)
“Unfortunately, the U.S. Conference of Mayors report only serves to support the criticism that the Obama administration’s attention to high-speed rail is out of scale to the needs of the country and, more significantly, to financial reality. Just look at the cover, where it notes the report is ‘sponsored by Siemens.’ That’s why you’ll find inside such vapid conclusions as ‘Jobs, wages, business sales and value added will significantly increase with the introduction of high-speed rail services.’ Maybe they will, in the right places at the right times. But what the report doesn’t get around to is what really should concern everyone with a stake in transportation: How do you pay for this? . . . The mayors’ report can serve one purpose: With states and cities nationwide struggling to fill their most basic needs on tight budgets these days, it’s a reminder that transportation companies should be watching closely where their taxes are being spent.”
--Paul Page, “High Speed,” Journal of Commerce, July 12, 2010.
“If states or other grantees do not come up with their share, they will be unable to use the federal [HSR] funds. Industry stakeholders stated that, in order to be successful, intercity passenger rail service would need stable state operating support in addition to capital funding provided by the federal government because all of the passenger rail systems we studied required some level of public operational and capital subsidy. . . . However, during the current economic environment, it is uncertain the extent to which states will be able to provide funding support—capital or operating—as simulations show near-term projected state and local deficits continuing for several years into the future.”
--Government Accountability Office, “High Speed Rail: Learning from Service Start-ups, Prospects for Increased Industry Investment, and Federal Oversight Plans,” GAO-10-625, June 2010.
“An entire network of infrastructure will be needed to support these [electric car] facilities and the people who operate them. The smaller recharging stations could easily require 300 to 500 acres of land just to handle the traffic flows. . . . What about the user side? Take a typical family of four on the trip from New York to California. Instead of stopping for 10 minutes every three to four hours so the fidgeting kids can go to the bathroom, a family would be able to stop every hour with a guaranteed stop time of 15 to 60 minutes [for recharging]. The green way of life consumes time.”
--Don L. Short II, “Are We Being Sold a Bill of Goods?” Engineering News Record, July 5, 2010.
“Missing from the DOT draft [strategic plan] are any references to the benefits of travel—such as helping the unemployed find jobs—or the preferences of American travelers. Also missing are hard data on costs and benefits, on amounts of travel now and in the future, or even an acknowledgment that one of America’s great strengths is the mobility of its people. There is also negligible discussion of the private sector’s role in providing roads or airports, and little discussion of the appropriate division of labor among different levels of government. The plan reveals that it is the policy of this administration to force us out of our cars. Even while the government all but owns an automobile company, General Motors, in this document it has declared war on the auto.”
--Gabriel Roth, “Menace to Mobility,” The American (American Enterprise Institute), June 30, 2010 (www.american.com/archive/2010/june-2010/menace-to-mobility)
“Thanks to an infusion of $34.5 billion from the General Fund into the Highway Trust Fund, the surface transportation program is assured of adequate funding (i.e., at the levels authorized for FY 2009) at least through the end of Fiscal Year 2010 and perhaps as long as the second or third quarter of Fiscal Year 2013, according to our reading of the recent Congressional Budget Office projections. . . . Hence, the transportation sector is not in dire need of funds at this point. Postponing a multi-year bill until after the 2012 presidential election will allow the nation to consider new ways of paying for transportation infrastructure in a more favorable climate and in an environment less colored by electoral politics.”
--Ken Orski, “Some Frank and Unscripted Comments from Capitol Hill,” Innovation NewsBriefs, June 3, 2010 (www.innobriefs.com)