&EPA
United States Air and Radiation EPA420-S-01-003
Environmental Protection Transportation and Air Quality September 2OO1
Agency
Implementing Commuter
Benefits Under the
Commuter Choice
Leadership Initiative
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COMMUTER CHOICE LEADERSHIP INITIATIVE
The National Standard of Excellence for Commuter Benefits
Transit and Vanpool Benefits
Implementing Commuter Benefits under the
Commuter Choice Leadership Initiative
• Employers can provide up to $65 per month in tax-free transit/vanpool benefits to
employees. The employer does not pay payroll taxes on the benefit, and employees do
not pay income or payroll taxes on it. As a result, giving an employee $65 in
transit/vanpool benefits is less expensive for an employer than raising the employee's
salary by $65, and the employee takes home more. The tax-free limit on transit/vanpool
benefits will rise to $100 per month for tax year 2002.
• transit/vanpool benefits may be provided in a variety of ways: through regional voucher
programs, transit passes, or cash reimbursement (in certain circumstances).
• Providing transit/vanpool benefits is one of the primary benefits under the Commuter
Choice Leadership Initiative (CCLI). Employers must offer at least one of three primary
benefits to their employees in order to participate hi the CCLI (the other two are parking
cash out and telecommuting). Under this option, the employer agrees to provide at least
$32.50 per month in transit/vanpool benefits for any employee (or the full monthly com-
muting expense if its less than $32.50 per month).
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COMMUTER CHOICE LEADERSHIP INITIATIVE
The National Standard of Excellence for Commuter Benefits
This document is one in a series of Commuter Choice Leadership Initiative briefing papers designed to help
employers implement commuter benefits.
The U. S. Environmental Protection Agency (EPA) and the U. S. Department of Transportation (DOT)
have established a voluntary National Standard of Excellence for employer-provided commuter benefits.
Commuter benefits help American workers get to and from work in ways that cut air pollution and global
warming pollution, improve public health, improve employee recruiting and retention, improve employee
job satisfaction, and reduce expenses and taxes for employers and employees. Participants in the
Commuter Choice Leadership Initiative (CCLI) agree to meet the National Standard of Excellence, and
qualify as Commuter ChoiceSM Employers. CCLI participants agree to:
• Centralize commute options information so that it is easy for employees to access and use;
• Promote the availability of commuter benefits to employees;
• Provide access to a guaranteed ride home program;
• Provide one or more of the following primary commuter benefits:
/• Vanpool or transit benefits of at least $32.50 per month
/ Parking cash out of at least $32.50 per month
/ Telecommuting program that averages six percent of daily work force
/ Other option proposed by employer and agreed to by EPA
• Provide three or more of the following additional commuter benefits:
/ Ridesharing/carpool matching
/ Pre-tax transit/vanpool benefits
•/ Shuttles from transit station
S Parking at park-and-ride lots
•/ Provision of real-time transit information
/ Preferred parking for ridesharers
S Reduced parking costs for ridesharers
/ Employer-sponsored vanpool or subscription bus
programs
S Employer assisted vanpools
/ Secured bicycle parking, showers, and lockers
S Electric bicycle recharging stations
•/ Employee commuting awards programs
/ Discounts/coupons for bicycles and walking shoes
•/ Compressed work schedules
S Telecommuting
/ Lunchtime shuttle
/ Proximate commute (working closer to home)
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COMMUTER CHOICE LEADERSHIP INITIATIVE
The National Standard of Excellence for Commuter Benefits
Disclaimer
EPA provides this briefing as a service to employers participating in the CCLI. Information about private
service providers is intended for informational purposes and does not imply endorsement by EPA or the
federal government.
The information presented here does not constitute official tax guidance or a ruling by the U.S.
Government. Taxpayers are urged to consult with the Internal Revenue Service of the U.S. Department of
Treasury or a tax professional for specific guidance related to the Federal tax law.
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CCLI: Transit and Vanpool Benefits
fTable of Contents
TRANSIT AND VANPOOL BENEFITS:
ASUMMAR
EMPLOYER BENEFITS ........................................ 1
COST SAVINGS [[[ 2
TAX CONSIDERATIONS ...................................... 3
EMPLOYER-PAID BENEFITS .................................................. 3
EMPLOYEE PRE-TAX SALARY DEDUCTION ..................... 4
EXAMPLES OF TAX BENEFITS ............................................. 4
EMPLOYEE BENEFITS
EMPLOYEE COST SAVINGS
INCREASED EMPLOYEE SATISFACTION..
..4
...4
...5
WHEN TRANSIT/VANPOOL BENEFITS
MAKE SENSE 5
LOCATIONS WITH ACCESS TO TRANSIT OR HIGH
OCCUPANCY VEHICLE LANES 5
LOCATIONS WITH LIMITED OR EXPENSIVE PARKING
AND LONG COMMUTES 5
EMPLOYERS WITH RECRUITMENT OR RETENTION
ISSUES 5
IMPLEMENTATION ISSUES AND COSTS 5
FEWER ADMINISTRATIVE REQUIREMENTS THAN
CAFETERIA PLANS 6
COSTS AND CORPORATE CASH FLOW 6
DISTRIBUTION OF PASSES OR VOUCHERS 7
DEALING WITH MULTIPLE TRANSIT AGENCIES 7
USING CASH REIMBURSEMENT 8
EQUITY ISSUES 8
GUIDE TO IMPLEMENTATION 8
EMPLOYER QUESTIONS AND ANSWERS ....11
QUESTION: HOW DIFFICULT - AND COSTLY - IS IT
TO ADMINISTER A TRANSIT/VANPOOL BENEFIT
PROGRAM? 11
QUESTION: WHAT ARE THE COST IMPLICATIONS OF
IMPLEMENTING TRANSIT/VANPOOL BENEFITS FOR
MY COMPANY? 12
QUESTION: IF I IMPLEMENT A TRANSIT/VANPOOL
BENEFIT PROGRAM, AM I REQUIRED TO OFFER THE
FULL VALUE OF $65 TO MY EMPLOYEE? 12
QUESTION: WHAT IF A MONTHLY PASS COSTS $75 PER
MONTH? AM I LIMITED TO PROVIDING A $65 BENEFIT
PER MONTH? 12
QUESTION: DO TRANSIT PASSES NEED TO BE DISTRIB-
UTED ON A MONTHLY BASIS? WHAT IF I WANT TO
PROVIDE MY EMPLOYEES WITH ANNUAL TRANSIT
PASSES? 13
QUESTION: HOW ARE BENEFITS TREATED IF AN
EMPLOYEE TERMINATES EMPLOYMENT AND THE
TRANSIT PASSES COVER MULTIPLE MONTHS? 13
QUESTION: MUST A QUALIFIED TRANSPORTATION
FRINGE BENEFIT PLAN BE IN WRITING? 14
QUESTION: WHAT ARE THE BENEFITS AND DOWNSIDES
OF USING A COMMERCIAL VOUCHER PROVIDER? 14
QUESTION: WHAT IS A VANPOOL? 14
QUESTION: DOES AN EMPLOYER NEED TO OPERATE
A VANPOOL TO PROVIDE VANPOOL BENEFITS? 15
QUESTION: WHAT ARE THE BEST WAYS TO PROMOTE
A TRANSIT/VANPOOL BENEFIT PROGRAM? 15
QUESTION: DO ANY STATE OR LOCAL GOVERNMENTS
OFFER ANY INCENTIVES FOR DOING THIS? 15
EMPLOYER CASE STUDIES 15
SEATTLE, WASHINGTON - MINOR & JAMES
MEDICAL CLINIC 15
BOSTON, MASSACHUSETTS 16
CHICAGO, ILLINOIS - GENERAL GROWTH PROPERTIES.. 16
PORTLAND, OREGON - INTEL CORPORATION 16
ATLANTA, GEORGIA— GEORGIA PACIFIC/
SOUTHERN COMPANY 17
MILWAUKEE, WISCONSIN - UNIVERSITY OF
WISCONSIN 17
BETHESDA, MARYLAND - CALVERT GROUP 17
LOS ANGELES, CALIFORNIA - TRANSAMERICA
LIFE COMPANIES 18
MINNEAPOLIS, MINNESOTA - AMERICAN EXPRESS ....18
SERVICES THAT SUPPORT
IMPLEMENTATION 18
LOCAL GOVERNMENTS AND TRANSIT AGENCIES 18
SUPPORTING SERVICES - GUARANTEED RIDES
HOME AND INFORMATION PROVISION 18
ASSOCIATIONS AND CONTACTS 19
FEDERAL TRANSIT ADMINISTRATION 19
REGIONAL AND LOCAL TRANSIT AGENCY AND
GOVERNMENT CONTACTS 19
TRANSIT/VANPOOL VOUCHER PROVIDERS AND
OTHER SERVICES (REGIONAL AND NATIONAL) 19
FOR MORE INFORMATION ON EMPLOYER AND
EMPLOYEE TAX IMPLICATIONS 20
EMISSIONS AND TRANSPORTATION
BENEFITS 20
VEHICLE TRIPS 20
EMISSIONS : 22
REFERENCES AND PUBLICATIONS 22
APPENDIX A: REGIONAL TRANSIT
BENEFITS PROGRAMS 24
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CCLI: Transit and Vanpool Benefits
jOCRANSIT AND VANPOOL BENEFITS:
E4. SUMMARY
%1£S2_ - ^
Transit/vanpool benefits are qualified transporta-
tion fringe benefits that employers provide to
their employees to help them commute to work
using transit or vanpools.1 In most cases, the
employer purchases a transit pass or a transit/van-
pool voucher and gives it to the employee. In
some cases, the employer may reimburse employees
in cash for transit expenses.2 Although this paper
uses the general term "transit pass," a pass could
be an unlimited ride pass, tokens, tickets, or fare-
cards.3 Passes are generally issued by a single
transit agency only for use on its services. On
the other hand, a transit/vanpool voucher can be
exchanged by the employee for a transit pass,
tokens, or tickets on multiple transit services, or
payment of vanpool charges. Vouchers cannot be
exchanged for cash; they must be redeemed by
designated transit agencies or vanpool operators.
Federal tax code allows employers to offer up to
$65 per month ($780 per year) in transit/vanpool
benefits tax-free. In 2002, the maximum amount
eligible to be treated as tax-exempt will increase
to $100 per month ($1,200 per year).
To qualify the transit or vanpool benefit as a primary
benefit under the CCLI, an employer must con-
tribute at least $32.50 per month. If the monthly
commuting expense for employees is less than
$32.50 per month (e.g. $25/month), the employee
1 For more information on vanpools, see the separate
briefing paper on Vanpool Programs.
2 The employer may provide transit benefits through a
cash reimbursement plan only if vouchers are not
"readily available." See Implementation Issues and
Costs section.
3 Although the IRS regulations include "voucher" with-
in their definition of "transit pass," because of the
operational differences this briefing paper defines
them separately.
is only required to contribute that amount per
month ($25/month instead of $32.50). Some
employers allow employees to purchase the tran-
sit or vanpool benefit using pre-tax dollars (fre-
quently called a pre-tax transit or vanpool bene-
fit). While this option does take advantage of
some of the tax benefits of transit and vanpool
benefits, it does not provide either the full value
of transit or vanpool benefits to the employees or
the employers. It is therefore not considered a
"primary benefit" under the CCLI.
Employer-provided transit/vanpool benefits make
it less expensive and easier to use transit or van-
pools to commute to work, and usually are seen
as popular by employees. In recent years, pro-
grams encouraging distribution of transit passes by
employers have become increasingly popular.
Employers tend to view the programs as a low-
cost way to provide employees with a very desir-
able benefit. Since transit/vanpool benefits are
tax-free transportation fringes, employers can
save money on payroll taxes when they offer
these programs.
The employer is not limited to providing a transit/
vanpool benefit of $65 per month. However, if,
for any month, an employer provides an employee
with a qualified transportation fringe benefit that
exceeds the statutory tax-free limit, the excess
value must be included in the employee's gross
income for income and employment tax purposes.
A brief history of recent changes in tax legislation
that have affected transit benefits is provided in
Appendix C.
^EMPLOYER BENEFITS
An employer can benefit in several ways by
offering transit/vanpool benefits.
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CCLI: Transit and Vanpool Benefits
Transit/vanpool benefits can improve employee
morale and make an organization a more desir-
able place to work, which can:
• Reduce employee absenteeism
* Reduce employee turnover
• Support recruiting and retention goals
A DOT survey of employers offering
TransitChek® in the New York and Philadelphia
areas found overwhelming positive response by
employers and employees:
Over 70 percent of the TransitChek® users in the
first two surveys said they developed more posi-
tive opinions of their employers because of
TransitChek®. Favorable comments from respon-
dents included that the program gave transit a
favorable image, increased their usage of transit,
was simple and easy to use, and helped to defray
transit costs and fare increases.
When asked to characterize the relative impor-
tance of TransitChek* as an employee benefit, 48
percent [of employers] viewed it as "very impor-
tant," 40 percent said it was "somewhat impor-
tant," 12 percent chose "of limited importance,"
and only 1 percent said that it was "not important
at all."
All of the organizations reported TransitChek®
was very popular among their employees, and the
companies themselves viewed it positively, in
general.
One state agency, prevented from raising employ-
ee salaries by state legislation, appreciated
TransitChek® as a means to give employees a tax-
free benefit equivalent to a greater value in pre-
tax salary dollars (DOT, 1995).
Reaction to university programs mirrors these
positive reactions, even to improving recruitment
and retention.
students to UWM. Spring 1995 survey results
indicate 15% of respondents said the UPASS
would have a major impact on their decision to
attend UWM in future semesters while 21%
indicated the UPASS would have a minor
impact. (Meyer and Beimborn, 1996)
Cost Savings
Offering transit/vanpool benefits can be a very
low cost way to provide employees with an addi-
tional benefit. Transit/vanpool benefits provide
the employer with lower payroll taxes compared
to offering an equivalent salary increase. Offering
a pre-tax deduction option can actually save a
company money since the company does not pay
payroll taxes on the amount of income reserved
by the employee. Employees also pay less in
income taxes and social security taxes. However,
in some cases, voucher providers charge fees,
which may reduce the cost savings to employers.
Moreover, reducing the number of employees
driving to work can result in reduced needs for
employee parking. Parking is expensive to build
or lease, particularly in urban areas. As a result,
transit/vanpool benefits often provide a low-cost
way to avoid the large expense associated with
securing additional parking. Unlike parking,
which is a long-term decision (leases are typically
negotiated on an infrequent basis, and the deci-
sion to construct new parking has long-term
implications) transit/vanpool benefits can be
adjusted immediately.
[AX CONSIDERATIONS '
Tax provisions that allow transit/vanpool benefits
to be taken as a tax-free fringe benefit offer sub-
stantial financial savings for both employers and
employees.4
UPASS has the ability to attract and retain stu-
dents at University of Wisconsin-Milwaukee
(UWM). Participants in focus group discussions
mentioned the UPASS could attract potential
4 Employers should review with their tax advisor the
tax implications for themselves and their employees.
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CCLI: Transit and Vanpool Benefits
Transit/vanpool benefits may be provided tax-free
to employees up to $65 per month. Tax benefits
accrue to businesses and employees whether the
employer pays for the benefits or the employee
pays for it through a pre-tax salary deduction, as
shown in Figure 1.
Figure 1: Tax Savings for Employers and Employees
Option
Employer Tax Employee Tax
Benefit Benefit
Employers give
their employees
up to $65/month
to commute via
transit or van-
pools
Employers allow
employees to use
pre-tax income
to pay for transit
Employer saves
payroll taxes
(7.65%) com-
pared to offering
taxable salary.
Employer saves
on payroll taxes
(7.65% savings).
No payroll taxes
are paid on the
income that is
reserved by the
employee.
Employee
receives up to
$65/month tax-
free. The employ-
ee does not pay
any taxes on the
value of the ben-
efit.
Employee saves
on income tax
and payroll taxes.
The amount of
income reserved
for transit/ van-
pooling (up to
$65/month) is no
longer treated as
taxable salary.
Employer-Paid Benefits
If the employer pays for the transit/vanpool bene-
fit, the value of the benefit is tax-free to the
employee, as well as free of employer payroll
taxes. As a result, providing transit/vanpool bene-
fits is a low-cost way to provide employees with
an additional benefit, and saves considerable
money compared to an increase in taxable salary.
For example, as shown in Figure 2, by providing a
$65 per month ($780 per year) transit/vanpool
benefit rather than an increase in salary, the
employer saves $59.67 per year in payroll taxes
($780 tunes 7.65% PICA).
Employer
Savings
Employee
Savings
Figure 2: Sample Tax Savings from offering
$780 Commuter Benefit rather than Salary
Meanwhile, the employee saves about $325 in
taxes compared to receiving taxable income (based
on a 28% federal income tax, 6% state income tax,
and 7.65% PICA). With taxable salary, over 40
percent of the salary increase is never seen by the
employee. In contrast, the employee receives the
full $780 per year ($65 per month) in transit/van-
pool benefits paid by the employer.
Note that some transit voucher providers charge an
administrative fee for ordering the vouchers, which
would slightly increase the cost to the employer.
On the other hand, some transit agencies offer
discounts for purchasing transit passes in bulk,
which would lower the cost. Some states and
localities also offer tax credits, further lowering
the cost to the employer. The employee takes
home the full $780 benefit, tax-free.5 To net an
increase in after-tax income of $780 would require
a salary increase of over $1,300.
Under Federal tax law, an employee who pays to
park at a qualified parking area (like a transit sta-
tion) and then takes mass transit or a commuter
highway vehicle to work can receive a combina-
tion of transit/vanpool and qualified parking
benefits, up to a combined benefit of $245
5 Some transit systems add value when fares are pur-
chased in larger increments, resulting in a larger
employee benefit. For example, the Washington, DC
area Metro system adds 10 percent to farecards pur-
chased in amounts over $20.
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CCLI: Transit and Vanpool Benefits
per month ($65 for the transit/vanpool benefit and
$180 per month for parking) or a maximum of
$2,940 per year.
Employee Pre-Tax Salary Deduction
If the employer does not pay for the fringe bene-
fit, but deducts the pass and/or parking cost from
an employee's pre-tax income:
• The employer sees a reduction in payroll
taxes, and
• The employee does not pay federal income,
payroll, and possibly state income taxes on
the deducted amount.
Employers do not pay any payroll (PICA) taxes
on the amount of income that is reserved by the
employee from taxable income. PICA consists of
Social Security and Medicare taxes paid on
wages. For tax year 2001, employers and employ-
ees pay equal amounts: 6.2 percent of wages up
to $80,400 per year per employee for Social
Security and 1.45 percent of total wages for
Medicare (no salary limit). As a result, for every
dollar that an employee reserves for a pre-tax
transportation fringe benefit, the employer saves
about 7.65 cents (for employees making less than
$80,400 per year).6 An employee who reserves
$65 per month for transit or vanpools will save
over $59 per year for the employer in reduced
PICA taxes. If an employee reserved the full
$180 per month for qualified parking, employer
tax savings would be over $165 per year.
Employees also receive substantial tax savings.
An employee in the 28 percent federal tax bracket
who reduces his or her pre-tax income by $65 per
month to pay for transit or vanpooling expenses
could save $218 per year in federal income taxes
and an additional $59.67 in payroll taxes.
Employees could also save on state income taxes
that piggyback on the federal tax definitions of
compensations. For example, in a state with a 5
percent income tax, employees could save anoth-
er $39 in taxes. In total, an employee could be
saving over $316 each year. This brings the real
transit cost to the employee down from $65 per
month to $38.67 per month, a savings of more
than 40 percent.
As either a salary substitute or additional benefit,
transit benefits provide more value for less
money than cash.
Some states tax transit benefits as regular income
for employees. Employers should consult with
their tax departments to review the tax treatment
of transportation benefits, particularly if they
operate in multiple states.
Examples of Tax Benefits
Detailed examples of how to calculate tax bene-
fits are contained in a separate briefing paper,
Commuter Tax Benefits.
?LO*YEE .BENEFITS
Employee Cost Savings
Employees who ride transit or use vanpools save
money with these benefits. If the employer pays
the full benefit, the employee's transportation
expenses are considerably reduced. If the
employee pays the benefits, s/he still receives a
reduction in transportation costs, since the taxable
salary is reduced by the amount of the benefit,
thus resulting hi a lower tax assessment.
* For employees earning over $80,400 per year, there
would be less savings to the employer because Social
Security taxes are not paid on any salary above
$80,400 (in 2001; salary limits change annually).
Medicare taxes have no salary limit.
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CCLI: Transit and Vanpool Benefits
Increased Employee Satisfaction
Employees view transit/vanpool benefits
extremely favorably. Transit/vanpool benefits
can:
Lower employee commute stress
Provide additional choices to employees
Heighten employee appreciation of employer
Help make benefits plans more employee-
friendly and environmentally friendly
TRANSIT/VANPOOL BENEFITS
Any employer with a commuting workforce can
offer transit/vanpool benefits. There are certain
conditions, however, that make it easier or more
beneficial for an employer to implement such
programs.
Locations with Access to Transit or High
Occupancy Vehicle Lanes
Transit passes and vanpool programs can be
implemented in all types of locations, including
both urban and suburban areas. Transit programs,
however, will generally be most effective in loca-
tions where transit options are readily available
and with frequent service. These conditions are
typically the case in central business districts and
other dense urban areas, although certain subur-
ban areas may also fit into this group.
Vanpooling can work well in more suburban
areas not well served by fixed route transit. The
availability of high-occupancy vehicle (HOV)
lanes and park-and-ride facilities make vanpool-
ing more appealing to employees.
Locations with Limited or Expensive Parking
and Long Commutes
Constrained parking tends to increase the desir-
ability and improve the effectiveness of
transit/vanpool benefits since employees may
wish to avoid driving under these conditions.
Employees with long commutes are often most
interested in vanpooling since they can use the
time that would have been spent driving more
productively, or to rest or talk to co-workers. Such
factors as employee work hours matching transit
schedules and a supportive employer attitude
toward vanpooling can also have important effects
on the success of programs. (FHWA, 1993)
Employers with Recruitment or Retention Issues
In a tight labor market, employers can make
themselves more attractive to employees through
offering commuter benefits.
"IMPLEMENTATION ISSUES AND COSTS [
Employers must address various administrative
issues in implementing a transit/vanpool benefits
program. Although all employers must spend
some staff time setting up the program, the larger
the employer the more complex and potentially
challenging the issues. Small and medium
employers, especially those with only one work-
site, tend to find these benefits fairly straightfor-
ward to implement and administer.
Because transit/vanpool benefits are a tax
deductible business expense, they can often be
provided at relatively little cost to an employee
and with relatively little administrative burden.
As noted above, implementing an employee "pre-
tax" payroll deduction program can actually
result in total tax bill reductions for a company,
but this is not as valuable to employees.
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CCLI: Transit and Vanpool Benefits
Fewer Administrative Requirements than
Cafeteria Plans
Transportation fringe benefit programs have con-
siderably fewer administrative requirements than
IRS Section 125 cafeteria plans. What sets trans-
portation fringe benefits apart from other pre-tax
programs like cafeteria plans and flexible spend-
ing accounts is its ease of use and exemption
from the usual pre-tax program restrictions. There
are no complicated plan filings or forms to fill
out, no "use it or lose it" rules, no irrevocable
elections, and no mandatory enrollment dates.
In particular:
• Nondiscrimination rules that apply to cafete-
ria plans do not apply to transportation bene-
fits. An employer can offer transportation
benefits to any group of employees without
concern about disproportionate use by the
highly compensated.
• Unlike cafeteria plans, salary reduction elec-
tions do not need to be made before the
beginning of the plan year. The employer may
allow elections for transportation benefits to
be made before any period during with the
employee will receive the benefits. For exam-
ple, an election period may be for a calendar
month, providing greater flexibility for
employees.
• Unlike cafeteria plans, transportation benefits
are not subject to Form 5500 annual reporting.
Costs and Corporate Cash Flow
The primary cost of employer-based transit bene-
fits programs is the contribution to the employ-
ee's transit cost. Although providing transhVvan-
pool benefits costs a company less than providing
additional salary (due to payroll tax savings),
cash flow associated with purchasing transit pass-
es or vouchers can be an issue for some compa-
nies. For example, some transit agencies and
voucher providers recommend that employers
purchase vouchers for three months at a time,
rather than one. Although advance purchase may
not be required, the voucher provider or transit
agency may give financial incentives for advance
purchase, such as lower shipping charges or auto-
matic re-ordering. In addition, voucher providers
generally charge a small administrative fee.
Ongoing direct administrative costs tend to be
small, depending upon the number of participat-
ing employees and the number of vouchers or
passes distributed. According to David Judd, Vice
President of Commuter Check, their internal
research shows that for many small companies,
administration takes only a few hours per month.
(Judd, 2001)
Although no written rules are required by tax law,
a company will typically want to set up program
administrative guidelines. The guidelines will
address issues such as: How do employees elect
the benefits? How often will voucher distribution
take place? How often can employees change
their pre-tax elections? Can an employee return
the vouchers for taxable cash if they do not use
them? Setting up program procedures often
entails initial start-up time, but can ultimately
save administrative costs by ensuring a clear,
consistent set of procedures.
Some employers may encounter payroll difficul-
ties combining a partial employer-provided tran-
sit/vanpool subsidy with a pre-tax election. For
example, at the University of California,
Berkeley, staff and faculty are given a choice
between reserving pre-tax salary to purchase tran-
sit/vanpool passes and participating in the
University's subsidy program. Employees cannot
combine the benefits.
Distribution of Passes or Vouchers
An important concern is pass/voucher distribu-
tion, in terms of both logistics and security.
Transit passes and vouchers generally do not con-
tain identifying characteristics that clearly
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CCLI: Transit and Vanpool Benefits
show they belong to a specific person. As a
result, the employer must match the transit
vouchers they receive from the transit agency
with the elections made by individual employees.
The process can be further complicated if the
employer payroll operation is centralized but
facilities are spread throughout a region or the
country. In general, distribution is probably a
greater problem for large companies with multi-
ple sites, and not much of a problem for small
employers with a single site.
Employers have responded in several ways. Some.
employers have employees pick up passes or
vouchers in person from a designated contact per-
son. Other employers send passes or vouchers
directly to employees' homes to simplify the
process. Some employers use a cash reimburse-
ment system to avoid having to distribute vouch-
ers altogether; however, there are regulations
specifying when cash reimbursement can be used,
depending on whether vouchers are "readily
available" (described further below). Some com-
mercial services also offer a service in which they
send passes or vouchers directly to employees'
homes, saving the employer from distribution; a
fee is charged for this service. There is no one
best way; each employer must choose a solution
that fits.
Dealing with Multiple Transit Agencies
Dealing with multiple transit systems can be a
challenge for employers, whether one has multi-
ple work sites or the region is served by several
transit agencies. Within a given region, there may
be dozens of individual transit systems, each with
different types of transit passes. If an employer
needs to distribute different kinds of passes to
different employees, this can soon become a
major task.
There are several options for the employer inter-
ested in minimizing personnel staff time in pro-
gram implementation, while handling different
transit systems and vanpools. Although this sec-
tion describes the types of programs available in
a general way, please see Appendix A for a list of
programs arranged by city or region.
• Regional Transit/Vanpool Vouchers: In
most large metropolitan areas, regional transit
vouchers are available, which are good for
services on multiple transit agencies, includ-
ing vanpools. These regional vouchers tend to
come from either a large regional transit
agency or a commercial voucher provider.
i/ Vouchers from Transit Agencies: Many
large metropolitan areas have simplified
the process by creating regional transit
vouchers that are good for services on
multiple transit agencies, including van-
pools. For example, in the Washington,
DC metropolitan area, Metrocheks are
available through the Washington
Metropolitan Area Transit Authority
(WMATA). Metrocheks are accepted by
over 100 bus, rail, and vanpool services in
the DC area. The employee either uses the
Metrochek directly on Metrorail or trades
the voucher in for a Metro bus pass,
another local bus pass, commuter rail tick-
ets, or vanpool pass. Many regional transit
services also now have employer coordi-
nators and special program materials for
employers to make it easy for employers
to start a program. Some transit agencies
even provide discounts to employers who
order in bulk.
«^ Commercial Voucher Providers: In other
metropolitan areas, the regional voucher is
available from a commercial voucher
provider. A commercial voucher provider
serves as a middleman between employer
and transit agencies, and a clearinghouse
for transit agencies: the voucher provider
offers transit passes that can be used on
any transit system in the region.
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CCLI: Transit and Vanpool Benefits
Three of the largest commercial voucher
providers are: Commuter Check Services
Corp., TransitCenter, and Work/Life
Benefits. If using these voucher providers,
the employer responsibility becomes limit-
ed to only the purchase and distribution of
vouchers. The services typically charge an
administrative fee. (Garvey, 2000)
• Other Transit/Vanpool/Parking Benefit
Services: In addition to these options, a com-
mercial venture called Wage Works works
with employers to set up a commuter benefit
program that allows employers to order tran-
sit, vanpool, and parking vouchers on-line.
An employer would set up an account with
Wage Works. The employees can order passes
on-line and get them sent directly to their
homes, without the employer having to worry
about distributing vouchers. Wage Works
charges an administrative fee.
Using Cash Reimbursement
Cash reimbursement may be used instead of tran-
sit/vanpool vouchers only if the employer can
show that vouchers or passes are not "readily
available." According to IRS regulations, a
voucher is considered "readily available" unless
one of the following two conditions applies:
• If fees charged by a transit voucher provider
exceed one percent of the average annual
value of the vouchers (excluding per order
delivery charges of under $15), or
• If there are non-financial restrictions on
vouchers that make voucher use inappropriate
for particular companies. These include
advance purchase requirements (e.g., one
year), minimum purchase requirements (e.g.,
a company wants to buy $200 worth of
vouchers but the minimum requirement is
$1,000), or limits on the denominations (e.g.,
a company wants $40 in vouchers for each
employee but they are only available in
denominations of $60).
Employers cannot consider internal costs (e.g.,
distribution costs) in claiming that vouchers are
not readily available. In addition, the "one per-
cent" rule does not take effect until January 1,
2004. In the interim, employers can use the old
standard of "significant administrative costs."
This phrase was not defined in the previous
regulations.
Equity Issues
For employers with multiple worksites, especially
in different states, there may be equity issues to
consider before implementing transit/vanpool
benefits. Because transit fares vary so widely,
giving the same dollar amount to employees in
different locations (or even to those in the same
location who use different means of transit) will
result in different levels of coverage for employ-
ees' transit needs. A $65 benefit would more than
cover a $35 monthly bus pass (although the
employee would not receive the additional $30 in
cash), but commuter rail expenses could easily
exceed $100 per month, in which case the
employee would have to make up the difference.
The other option is to pay a similar proportion of
all employees' commuting expenses, although any
benefits over $65 would not be tax-free. There is
no one correct approach to the issue, but employ-
ers served by a variety of transit agencies must
take the issue into account.
TQjMPLEMENTATION
An employer would need to take a number of
steps to implement a transit benefit program. The
first two steps below would be the same for any
employer; however, once an employer has decid-
ed whether to use a voucher system or a cash
reimbursement system, the steps diverge. Both
possibilities are presented below.
Appendix B contains a flow chart to assist
employers with decision-making about the vari-
ous choices involved in implementing a
transit/vanpool benefits program.
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CCLI: Transit and Vanpool Benefits
1) Determine what Form of Transit/Vanpool
Voucher is Available for your Location
Many cities and regions already have transit
voucher programs through which employers can
purchase transit vouchers in bulk for their
employees. The largest programs are listed in the
Associations and Contacts section below, under
"Regional and Local Transit Agencies and Other
Contacts." For regions not listed here, an employ-
er should contact the local transit agency to deter-
mine whether they participate in such a program.
At this early stage, employers should also deter-
mine how many different transit systems their
employees use; in a small city, where all bus
services are provided by a single agency, a pro-
gram might function differently than in the San
Francisco Bay Area, with over two dozen transit
agencies. This may be a particular difficulty for
multi-region employers, especially those whose
offices are served by smaller agencies.
2) Determine Whether to Use Voucher/Pass
System or Cash Reimbursement System
According to IRS regulations, a cash reimburse-
ment system can be used only if an existing
voucher program does not impose any restrictions
that would cause the vouchers to be considered
not "readily available." A voucher would be con-
sidered not "readily available" under two circum-
stances: if the provider imposes a fee of over one
percent, or has other restrictions such as advance
purchase requirements, minimum purchase
requirements, or limits on the voucher denomina-
tions that do not meet employer requirements.
As noted above, the "one percent" rule does not
take effect until January 1, 2004. In the interim,
employers are advised to consult with a tax advi-
sor to determine if fees would constitute "signifi-
cant administrative costs," the current standard.
If the employer chooses to implement a voucher
system, the following steps would apply:
1) Contact Transit Pass or Voucher Provider
After determining to participate in a voucher pro-
gram, the employer could contact a representative
from the provider to review program, costs, and
logistics. If there are multiple transit agencies, an
employer should discuss how this may affect
employee's use of the program. Some voucher
programs also offer the option of registering
online.
2) Determine how Voucher/Pass Program will
Operate
Vouchers or passes may be used either for
employees to purchase with pre-tax dollars, or as
an employer-paid benefit. Employers must
decide which of these options better meets their
needs. If the employer is paying for the benefit,
they must also decide whether they will offer the
full $65 to all employees, or whether they will
pay a certain percentage of costs. (For example,
if a monthly bus pass costs only $45, but rail
costs $100 per month, an employer must decide
how much of each cost to subsidize).
3) Obtain Senior Management Approval
Senior management would need to approve this
type of addition to existing benefits. Because the
most effective programs in reducing solo driving
are those that are supported by management, if
one of the employer's goals is to reduce the per-
centage of single-occupant vehicles, on-going
management support of the program is critical.
4) Make Appropriate Changes to Payroll
System
If the program is designed to allow employees to
purchase pre-tax vouchers, payroll procedures
must be changed to reflect this new benefit. This
may mean setting up new deduction codes,
redesigning payroll forms, or working with a
third-party payroll vendor to implement the
change. An employer must also decide if benefits
will be available at any time, or if employees will
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CCLI: Transit and Vanpool Benefits
only be able to enroll during certain election
times, and how employees will enroll (via printed
forms, electronically, or through some other
means). If there will be different denominations
of transit vouchers available, this should be
reflected in enrollment procedures. At this point,
employers should also decide how vouchers or
passes will be distributed, on a monthly, quarter-
ly, or annual basis; and whether they will be
mailed to employees or picked up at a central
point at specified times.
5) Enroll in Voucher or Pass Program
Employers must enroll with the voucher or pass
provider. Providers may have minimum order
levels; they may also make recommendations as
to how many vouchers or passes should be
ordered (usually five percent above anticipated
demand). It will generally take several weeks
before the employer obtains the vouchers or pass-
es. Employers should ensure that employees
receive their vouchers or passes within a reason-
able time after beginning to make deductions.
In a voucher program, the employer should
decide what denominations make sense. For
example, if the main transit provider is a bus
service, and a monthly pass costs $40, the
employer would want to order both $10 and $30
vouchers. A $30 voucher would leave the
employee to pay the remaining $10, while two
$30 vouchers would mean a waste of $20, since
riders cannot redeem the extra voucher amount
for cash. Voucher providers may have denomina-
tions specific to the city and transit agency.
6) Publicize the Program to Employees
Employers should communicate the new benefits
to employees. Information about the benefits
should also be incorporated into orientation ses-
sions and company benefits literature and internal
communications.
7) Enroll Employees
Once the benefit is set up and announced with a
start date, the employer should be prepared for a
large one-time influx of new enrollees. For on-
site distribution, employers should make arrange-
ments to have sufficient vouchers or passes on
hand at the site, and ensure that personnel under-
stand the distribution procedures.
8) Set up a System for Continuing Distribution
Once the initial enrolment period has passed,
employers should ensure that the system contin-
ues to operate smoothly. This would include con-
tinuing publicity of the program, monitoring pro-
gram usage, ordering new vouchers or passes on
a regular basis, and answering employee ques-
tions about the program.
If the employer chooses to implement a cash
reimbursement system, the following steps
would apply:
1) Determine how Cash Reimbursement
Program will Operate
The employer must decide whether the program
will operate as an employee-paid or an employer-
paid program. An employee-paid reimbursement
program operates like a flexible spending
account, in which the employees reserves a spe-
cific amount of pre-tax money every month, up to
$65. The employee then requests reimbursement
using these funds for actual transit expenses
incurred. An employer-paid program would
allow employees to request reimbursement up to
$65 per month from the employer. Both types of
programs must meet IRS criteria about reim-
bursement; the employers must implement a "rea-
sonable procedure" to ensure that the employee
spent the money on qualified transit expenses.
Also, reimbursement program must operate on a
reimbursement basis; the employer cannot reim-
burse an employee until an expense has actually
been incurred.
10
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CCLI: Transit and Vanpool Benefits
2) Obtain Senior Management Approval
Senior management would need to approve this
type of change in benefits. If the employer wants
to reduce the percentage of single-occupant vehi-
cles, on-going management support of the pro-
gram is critical. Even more important than man-
agement support is management participation; if
senior level employees ride transit, employees
will be more likely to believe that the company
has a serious commitment to the program.
3) Make Appropriate Changes to Payroll
System
If the program is designed to allow employees to
reserve pre-tax funds to pay for transit, payroll
procedures must be changed to reflect this new
benefit. This may mean setting up new deduction
codes, redesigning payroll forms, or working
with a third-party payroll vendor to implement
the change. If the program will be employer-paid,
any reimbursement procedures the company
already has in place will need to include transit
reimbursements; this may require adding expense
codes or enrolling employees who do not normal-
ly request expense reimbursements.
An employer must also decide if benefits will be
available at any time, or if employees will only
be able to enroll during certain election times,
and how employees will enroll (via printed
forms, electronically, or through some other
means). At this point, employers should also
decide how often reimbursement will be distrib-
uted: on a monthly, quarterly, or annual basis, and
how employees will submit claims for reimburse-
ment (on paper or electronically, and whether
receipts or copies of transit passes will be
required).
4) Publicize the Transit Cash Reimbursement
Program to Employees
Employers should communicate the new benefits
to employees. Information about the benefits
should also be incorporated into orientation ses-
sions and company benefits literature and internal
communications.
5) Enroll Employees
Once the benefit is set up and announced with a
start date, the employer should be prepared for a
large but one-time influx of new enrollees, as
well as the first batch of requests for reimburse-
ment.
6) Set up a System for Continuing Cash
Reimbursements
Once the program has been implemented and any
bugs worked out, the employer should ensure that
the program continues to operate smoothly. This
would include continuing publicity of the pro-
gram, monitoring program usage, and answering
employee questions about the program.
EMPLOYER QUESTIONS AND ANSWERS
These questions might commonly be asked by an
employer (e.g., a human resources administrator
or business manager) considering a commuter
benefits program.
Question: How difficult - and costly - is it to
administer a transit/vanpool benefit program?
A study of firms that have implemented transit
pass programs generally found negligible imple-
mentation costs. The study found that transit pro-
grams are in many cases simple to organize and
implement and that their ongoing administration
poses no extra cost to the firm. Companies inter-
viewed generally felt that the benefits of the pro-
gram far outweighed the added administrative
time necessary to implement the program and dis-
tribute vouchers. Some companies hire outside
firms to deal with voucher purchase, distribution,
and advertisement. Although these companies
charge for their services, some companies have
11
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CCLI: Transit and Vanpool Benefits
found that these extra costs can be less than actu-
al tax savings for both programs where the
employer provide vouchers and where employees
pay with pre-tax income. (Litman, 1999)
However, implementing programs also involve
initial start-up costs in terms of staff time needed,
which may fall heavily on the human resources
section. In addition, some companies have found
that the number of people who will be interested
in receiving the benefits is too small to justify the
time and effort involved.
Question: What are the cost implications of
implementing transit/vanpool benefits for my
company?
The total financial effects of a benefits program
will vary depending on the specific conditions of
a company, including existing parking arrange-
ments, location, transit availability, and current
travel patterns of employees. If the benefit is paid
by employees out of their pre-tax earnings, the
employer will incur only administrative costs. If
the employer pays for the benefit, costs will be
substantially higher, based on the amount of the
benefit and the number of employees who partici-
pate. In addition, the use of commercial transit
voucher providers may entail an administration
fee.
If the employer pays for the benefit, the cost to
the employers will be less than if the employers
had increased employees' salaries by an equiva-
lent amount. If the employees pay for the benefits
out of pre-tax income, the employer saves on
payroll taxes. The payroll tax savings should gen-
erally offset the administration fees charged by
commercial providers.
It is important to note that many of the costs may
be more than offset by other significant long-term
cost savings. Employers interviewed in case stud-
ies consistently remarked that the transit benefits
are an added fringe benefit that helps to recruit
and retain employees: "It tips the scale in our
favor when a recruit is comparing offerings of
other companies to ours." (Wells, 1999)
Moreover, by equalizing benefits, companies pro-
vide a more equitable compensation package for
all their employees. Together, these features may
help to reduce recruitment and retention costs for
the company. In addition, for employees who per-
sonally support environmental goals, such bene-
fits may make the company more attractive than
one that simply offers free parking and does not
address other commute modes. Together, these
features may help to reduce recruitment and
retention costs for the company.
Question: If I implement a transit/vanpool bene-
fit program, am I required to offer the full value
of $65 to my employee?
No. An employer may provide benefits of any
amount.
Question: What if a monthly pass costs $75 per
month ? Am I limited to providing a $65 benefit
per month?
No. An employer may provide transit/vanpool
benefits of any amount. The tax-free benefit for
transit/vanpool benefits, however, is currently
limited to $65 per month. As a result, the employ-
ee and employer must pay taxes on the value of
the benefit that exceeds the $65 statutory limit.
For example, if the employer provides the
employee with a monthly pass valued at $75 per
month, $65 is a tax-free fringe benefit, and the
excess - $10 - must be included in the employee's
wages for income and employment tax purposes.
Similarly, if the employer offers a pre-tax salary
deduction option, the employee may be allowed
to purchase a pass with a value of more than $65
per month. Then, $65 per month will be deducted
from the employee's wages for income and
employment tax purposes. The remaining cost
will be included in taxable salary but be used by
the employer to purchase the pass.
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CCLI: Transit and Vanpool Benefits
Question: Do transit passes need to be distrib-
uted on a monthly basis? What if I want to pro-
vide my employees with annual transit passes?
Transit passes may be distributed up to twelve
months in advance. In the case of a pass that is
valid for more than one month, such as an annual
pass, the value of the pass may be divided by the
number of months for which it is valid to deter-
mine whether the value of the pass exceeds the
statutory monthly limit.
For example, an employer may provide employ-
ees with transit passes near the beginning of each
calendar quarter for that calendar quarter. In this
case, an employer may provide employees with
transit passes with a value of $195 on March 31
for the calendar quarter covering the months
April, May, and June. Since $195 is within the
statutory limit (three months times $65 equals
$195), the total value is excludable from the
employees' wages for income and employment
tax purposes.
Question: How are benefits treated if an
employee terminates employment and the transit
passes cover multiple months?
In general, the value of transit passes provided in
advance to an employee for a month in which the
individual is not an employee must be included in
the employee's wages for income tax purposes.
Transit passes distributed in advance to an
employee are excludable from wages for employ-
ment tax purposes if the employer distributes
transit passes to the employee in advance for not
more than three months. At the time the passes
are distributed, there cannot be an established
date that the employee's employment will termi-
nate (for example, if the employee has given
notice of retirement) occurring before the begin-
ning of the last month of the period for which the
transit passes are provided.
Assume the employer distributes transit passes
quarterly, and the employee elects to have $195
deducted from salary to cover transit vouchers for
April, May, and June. If employment terminates
on May 31, and there was not an established date
of termination at the time the transit passes were
distributed, then the value of the transit passes
provided for June ($65) is excludable from the
employee's wages for employment tax purposes.
However, the value of the transit passes distrib-
uted for June ($65) is not excludable from wages
for income tax purposes. If the employee's termi-
nation date was established at the time the transit
passes were provided, then the $65 is included in
the employee's wages for both income and
employment tax purposes.
Question: Under what circumstances can an
employer offer benefits in the form of cash pay-
ments rather than using transit vouchers or
passes?
The tax code states that transportation reimburse-
ments must be made through vouchers or passes,
rather than cash payments, unless the employer
can show that vouchers or passes are not "readily
available." The January, 2001 IRS regulations
define the term "readily available" by stating that
only fees charged by transit voucher providers,
and non-financial restrictions on vouchers, could
be considered in making a determination of
voucher availability, not internal administrative
costs. Passes are to be considered readily avail-
able if an employer can obtain a pass on terms no
less favorable than those available to an individ-
ual employee, as long as the voucher provider
does not charge a fee in excess of one percent of
the average monthly value of the voucher.
However, the "one percent" rule does not go into
effect until January 1, 2004. In the interim, the
previous standard that vouchers were not consid-
ered "readily available" if there were "significant
administrative costs" to the employer appears to
remain in effect. Previous regulations did not
define the term "significant administrative costs."
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CCLI: Transit and Vanpool Benefits
In making a determination of voucher availabili-
ty, employers cannot consider internal costs, but
can include non-financial restrictions, such as
whether there are reasonable advance purchase
and minimum purchase requirements and whether
vouchers can be purchased in appropriate denom-
inations. (Federal Register, 2001)
Internal administrative costs that cannot be con-
sidered in determining voucher availability
include expenses incurred by the employer to dis-
tribute the vouches (i.e., if the employer chooses
to mail vouchers to employees, the postal fee
cannot be considered); any additional security
measures that must be taken to safeguard the
vouchers, expenses incurred to advertise the pro-
vision of transit vouchers, etc. Non-financial
restrictions that can be taken into consideration
include the following: if a voucher provider does
not make vouchers available for purchase at rea-
sonable intervals, or if a voucher provider fails to
provide vouchers within a reasonable period after
receiving payment for the voucher.
Question: Must a qualified transportation fringe
benefit plan be in writing?
No. The Internal Revenue Code does not require
that a transportation fringe benefit be in writing.
However, a company may wish to have certain
rules and procedures written in order to answer
employee questions.
Question: What are the benefits and downsides
of using a commercial voucher provider?
Commercial voucher providers can greatly simplify
the process of implementing a transit voucher pro-
gram.
• Fewer Administrative Requirements
Compared to Cash Reimbursement.
Because vouchers can be ordered in bulk, and
are generally valid for many months, an
employer can order several times per year,
instead of processing many reimbursements
every month. Commercial voucher providers
can set up automatic reminders about re-
ordering. Using a voucher system reduces
both the HR and employees' administrative
requirements, because they do not have to file
for reimbursement or handle reimbursement
requests. Once the employee has received the
voucher, the employer's tasks are completed.
• Simpler Relations with Transit Agencies. In
areas with multiple transit agencies, employ-
ees can generally use vouchers at any
provider. Employers do not have to purchase
passes from multiple agencies.
• Customer Friendly. An account representa-
tive may provide a human resources employ-
ee with valuable experience about expected
employee response to vouchers.
• Easier for Multi-State Employers. Employers
with locations in two or more states may
choose to use commercial voucher providers
because of the time and effort involved in
administering the program in different states.
The main downside is that commercial voucher
providers change an administration fee equal to sev-
eral percent of the total cost of the vouchers sup-
plied. The more employees that enroll, the more
expensive the service becomes on an absolute basis.
Question: What is a vanpool?
A vanpool operates like a mini-transit service,
with an organized route, schedule and passenger
fare charges. Vanpools are comprised of at least
six people, plus a driver, and fares depend on the
commute distance, the total number of riders, the
type of van, company-provided equipment, and
incentives or subsidies. Vanpooling tends to
appeal particularly to long distance commuters
who can reduce their commute costs and get to
work in a stress-free way by sharing the ride with
others. Typically, the vanpool driver rides free in
exchange for driving, collecting fares, and man-
aging maintenance for the van. Vanpools can be
either employer-sponsored, use third party leases,
or be owner-operated. More information on van-
pools is contained in a separate briefing paper.
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CCLI: Transit and Vanpool Benefits
Question: Does an employer need to operate a
vanpool to provide vanpool benefits?
No. An employer does not need to own or lease
the vans in order to provide a vanpool benefit to
employees.
Question: What are the best ways to promote a
transit/vanpool benefit program?
An employer has numerous options to inform
employees about the benefits. Some of the more
frequent methods include but are not limited to
the following:
• Company orientation meetings for new
employees;
• Advertisements in places seen frequently by
employees (cafeteria, garage, elevators, etc);
• Distribution of program brochures;
• Company newsletters;
• Voicemail or e-mail broadcast;
• Special promotional days (example: a "Pool
Day" to encourage car- and vanpooling)
• Awards or prize drawings to recognize
employees using transit or carpools;
• Inserts to paychecks;
• Company web site or intranet.
Question: Do any state or local governments
offer any incentives for doing this?
Yes. Several states offer tax incentives for provid-
ing transit/vanpool benefits. Maryland offers a 50
percent tax credit up to $30 per employee per
month for costs associated with providing tran-
sit/vanpool benefits to employees. Minnesota pro-
vides a tax credit equal to 30 percent of the dif-
ference between what the employer pays for tran-
sit/vanpool passes and what employees are
charged for the passes. Georgia offers a $25 tax
credit for each employee receiving a transporta-
tion fringe benefit, as long as the tax credit does
not exceed the amount of money spent on the
program. Other states, including Delaware,
Connecticut, New Jersey, and Oregon, offer tax
credits to eligible companies that implement com-
muter transportation benefit plans, which could
include transit/vanpool benefits.
State tax credits may reduce the amount of feder-
al tax savings, due to smaller federal deductions
for state taxes. Employers should discuss state tax
credit implications with a qualified tax advisor.
More detailed information on state tax credits is
contained in a separate briefing paper, Commuter
Tax Benefits.
CASE STUDIES
Both public and private sector employers have
implemented successful programs across the U.S.
Following are examples of employers that have
implemented commuter pass programs of varying
scales.
Seattle, Washington - Minor & James Medical
Clinic
Minor & James Medical Clinic in Seattle pro-
vides all of its employees with an Annual Flex
Pass, which is good for unlimited free transit
rides in King County, Washington. The Annual
Flex Pass provides the approximately 340
employees of the clinic with free transportation to
work using public transportation. According to
Joann Wray, the Human Resources director and
Transportation Director, the Annual Flex Pass is
greatly appreciated by employees.
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CCLI: Transit and Vanpool Benefits
The pass normally retails at a cost of $1,746. The
program has been in effect since about 1997, and
about 80 percent of the employees (275 out of
340) take transit to work each day. No parking is
provided at the clinic, except for employees who
were grandfathered into the program (about 100)
and those that are required to work late night
hours. Employees like the pass program because
it allows them to commute to work free. Part of
the commute program that makes it successful is
a guaranteed ride home program that is paid for
by the clinic. The guaranteed ride home program
offers employees the ability to take transit to
work with the security of knowing that they will
be able to get home quickly in the event of an
emergency or special circumstance. (Wray, 2001)
Boston, Massachusetts
A Boston-based Internet startup with about 70
employees gives its employees free passes to use
in the Boston subway system. Management's pri-
mary goal is to keep the benefits free even as the
firm grows to an anticipated 100 employees in
the months ahead. The company reports that the
program has been very well received and is one
tool among many to attract high-quality employ-
ees. The pass "really excites people" because it is
something tangible they can use right away. To
compete, the company wants to make it as easy
as possible for employees to commute and avoid
parking expenses, which can add up to an esti-
mated $225 a month in downtown Boston.
(Garvey, 2000)
Chicago, Illinois - General Growth Properties
General Growth Properties, a Chicago-based
company that manages shopping malls across the
country, allows its employees to take a payroll
deduction of up to $65 a month in pre-tax dollars
to be used for transit vouchers, rather than pro-
viding a direct benefit. About 250 of the compa-
ny's 500 headquarters employees have enrolled in
the program managed by General Growth's pay-
roll/accounting department.
Given that the company's payroll is done in-house,
the program managers feel that administration of the
program on an ongoing basis takes very little extra
effort. Setting a limit on when employees can opt in
or out of the program makes the program more
manageable. Allowing monthly enrollment or other
changes would be difficult from an administrative
perspective, so General Growth's program limits
changes to once a quarter.
Under the company's program, General Growth
purchases transit vouchers that cover a broad base
of the Regional Transit Authority/Chicago Transit
Authority's mass transportation options. The
vouchers are in different denominations, made
out to General Growth and can be used to pay for
transportation on any part of the regional system.
Vouchers are distributed to employees once a
month through the company's security desk.
Those enrolled in the plan must show identifica-
tion and sign for the vouchers. The company does
not offer any form of parking benefit.
Portland, Oregon - Intel Corporation
Intel Corporation, with major offices in Arizona,
Washington, California, and Oregon, has a wide
range of transit benefits available to employees.
At their Santa Clara facility, employees receive
free Ecopasses for the Valley Transportation
Authority light rail system, as well as $30 per
month in subsidized metro/bus passes. In
Portland, Intel Corporation bought annual bus
and light-rail passes from Tri-Met, the local tran-
sit authority, for $10 apiece instead of the retail
price of $505. The company received the dis-
count by purchasing passes for all eligible mem-
bers of their work force. The corporation pur-
chased 10,400 passes and will provide them free
of charge to all employees. Under the State's new
commute-reduction law, businesses that provide
transit passes for their employees receive a 35
percent State tax deduction.7
7 See
www.epa.gov/oms/transp/comchoic/ccmeasur.htm and
www.commuterchoice.com/employers/
Example_Intel_RideShare.pdf
16
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CCLI: Transit and Vanpool Benefits
According to a 1999 report, 40 percent of Intel's
workforce in Arizona and Washington were not
driving alone to work, as were 32 percent of
California employees.
Atlanta, Georgia •
Company
Georgia Pacific/Southern
Between 1997 and 1999, Georgia
Pacific/Southern Company instituted a series of
commuter benefits designed to allow their
employees to assist in reducing Atlanta's worsen-
ing air pollution. One benefit gives employees
$65 per month in subsidies for transit, shuttles, or
vanpools. In addition, to encourage rail ridership,
the company beefed up its MARIA shuttle opera-
tions, shortening headways to 10 minutes or less
throughout the day. Use of alternative commute
modes increased from 300 employees in 1997 to
1,500 employees in 2000, or from 10 percent to
50 percent of all employees. Ridership on the
MARTA shuttle was at 11,000 boardings per
month in June 2000, up from 6,000 per month in
1997.8
Milwaukee, Wisconsin - University of Wisconsin
The UPASS transit pass program at The
University of Wisconsin-Milwaukee (UWM) is
an innovative transit program developed by the
University and the Milwaukee County Transit
System (MCTS) in which all UWM students
receive an unlimited transit pass as part of their
tuition. The pass can be used anytime, anywhere,
for any trip purpose throughout Milwaukee.
County without any additional fare required.
Program findings indicate that UPASS has been
effective in reducing vehicle trips, increasing
transit ridership, and reducing the impact of the
automobile on the environment. The UPASS pro-
gram has influenced modal shifts. Students who
drive to UWM declined from a rate of 54% prior
to UPASS to a rate between 38% to 41% after the
implementation of UPASS. Students choosing to
ride MCTS increased from 12% prior to UPASS
to a rate of 25% to 26% since the implementation
of UPASS.
The UPASS program has also increased transit
ridership for trips to work, to shopping, and to
other locations. Transit mode split for work trips
by survey respondents showed nearly a doubling
over pre-UPASS semesters from a rate of 8% to
approximately 15%. Surveys indicate a 17% to
18% increase in transit ridership for these trip
purposes compared to pre-UPASS ridership.
MCTS on-board ridership counts indicate express
service to UWM showed a 75% to 136% increase
compared to ridership counts conducted prior to
the UPASS program. The UPASS program
reduced vehicle trips to the university, which
resulted in a reduction in emissions, fuel con-
sumption, and student dollar savings. The UPASS
program resulted in 221,055 fewer vehicle trips
made to UWM during the 1994-95 academic
school year.
Bethesda, Maryland - Culvert Group
The Calvert Group, a socially-responsible invest-
ment fund located hi suburban Washington, DC,
offers a commuter benefits program to cover
every potential mode, including walking and
bicycling. Although Calvert subsidizes employees
who drive at a rate of $75/month, persons who
ride transit are reimbursed the full value of the
transit costs, regardless of provider. Employee
turnover dropped from 25 to 12 percent after
implementation of the program, and Calvert man-
agement sees the plan as integral to its recruit-
ment and morale. The company has gained
national attention for the quality of its employee
programs in national publications such as
Business Week and Working Mothers Magazine.9
Example from: www.commuterchoice.com
9 Example from: www.commuterchoice.com/employ-
ers/success
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CCLI: Transit and Vanpool Benefits
Los Angeles, California - Transamerica Life
Companies
Transamerica Life Companies, an insurance com-
pany with approximately 1,000 employees, is
located just south of downtown Los Angeles. Los
Angeles area companies with over 250 employees
are mandated by the South Coast Air Quality
Management District to institute trip reduction
programs. Transamerica Life's commuter pro-
gram, which developed over a period of 13 years,
includes a vanpool program (leased vans; mainte-
nance, insurance, and administration provided),
free parking for vanpools and parking discount
for carpools, and a 50 percent transit subsidy (up
to $65/month). Employees can purchase transit
passes on-site; the Transportation Coordinator
sends down a list of participants to the store, and
the employee pays the balance of the amount.
The company supports these financial elements
with a guaranteed ride home program, emergency
use of company cars, work hours flexibility, and
bike racks and shower/locker facilities. As a
result of these measures, approximately 500
employees participate in the transit pass program,
and an additional 175 use carpools or vanpools.
(FHWA, 1993; Corona, 2001)
Minneapolis, Minnesota -American Express
In 1998, American Express, a major financial
services company, became the first Twin Cities
employer to take advantage of the Metropass pro-
gram offered by regional bus service provider
Metro Transit. The program allows employers
with over 100 employees to obtain reduced-cost
monthly bus passes to their employees. For the
first year, American Express paid Metro Transit
$1.8 million, based on an estimate of the number
of employees who would ride the bus. Employees
could then purchase monthly bus passes for $25
pre-tax, a significant savings over the usual price
of $76. Employees received photo bus passes to
reduce the risk of fraud. Of the company's 6,000
employees in Minneapolis, approximately 70 per-
cent use the program. (Putsch, 2001; U.S. EPA
Commuter Choice Case Studies)
THAT SUPPORT
Local Governments and Transit Agencies
Services to help employers implement commuter
benefit programs are provided by many regional
and local government entities. Transit agencies,
metropolitan planning organizations (MPOs), city
and county transportation agencies, transportation
management associations (TMAs), and trans-
portation management organizations (TMOs)
throughout the U.S. provide assistance to
employers in starting and maintaining transporta-
tion demand management programs like transit
passes and vanpools. They often provide informa-
tion to employers about options to reduce driving
to work, implementation issues, and local pro-
grams that support employer initiatives.
Transit agencies often allow employers to pur-
chase deeply discounted transit passes for their
employees in an effort to boost ridership and
meet environmental goals. Employers who take
advantage of these programs should be aware that
transit pass costs may rise after a year or two and
plan accordingly. One potential solution to this
problem might be for a company to carry the cost
of transit passes for the initial years, and then
share costs with employees later on.
Supporting Services - Guaranteed Rides Home
and Information Provision
One of the barriers that prevents some employees
from taking transit or a vanpool to work is the fear
that they will not be able to get home quickly in
the event of an personal emergency, such as pick-
ing up a sick child from school, or working
unscheduled overtime. Guaranteed Ride Home
(GRH) programs provide commuters who regular-
ly carpool, vanpool, bike, walk or take transit to
work with a reliable ride home when an unexpect-
ed emergency arises. GRH programs are designed
to rescue commuters who are worried about how
they'll get home when an emergency arises.
Knowing there is a guaranteed ride home gives
18
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CCLI: Transit and Vanpool Benefits
many people the security to take commuting
options like transit and carpools with confidence.
GRH programs may be established by individual
employers; usually the employer will pay for a
taxi home in case an employee who takes transit
or a vanpool needs to go home at a time when
transit services are not available or without the
vanpool. Some MPOs and local governments
have also established regional or county-wide
GRH programs for employees that register for the
program. GRH programs tend to be low-cost
ways to encourage transit use, especially if a
company only "fills in" coverage for areas not
covered under a broader regional program. For
example, a regional transit agency may provide a
guaranteed ride home for monthly passholders, so
a company would have to provide GRH only for
carpoolers.
Employers can also support transit and vanpool-
ing by providing information on these options to
their employees. A bulletin board or display with
transit route maps and schedules can often be put
up in a Human Resources office, lounge area, or
hallway. Employers can also send periodic
reminders to their employees about the availabili-
ty of benefits through company voicemail or e-
mail systems, company newsletters, or an awards
program designed to recognize alternative com-
muters. A supportive attitude toward transit and
vanpooling can also help. Supervisors should rec-
ognize their vanpoolers' schedule; for example,
they should not hold late meetings that would
require employees to miss their vanpool.
SSOCIATIONS AND CONTACTS
This section includes information on experts that
employers might wish to utilize for expertise in
understanding, promoting, or providing technical
information on transit/vanpool benefits.
(Employers seeking information on implementing
vanpool programs should consult the separate
briefing paper on vanpool programs.) Individual
employers are directed to contact their local
MPOs, transit agencies, TMAs/TMOs, or other
groups that provide services to support
transit/vanpool benefit implementation.
Federal Transit Administration
Employers are encouraged to utilize FTA's
Commuter Choice Toolkit, which contains an
extensive Voucher and Pass Programs Directory.
The Toolkit is available electronically at
www.fta.dot.gov/library/policy/cc/cctoc 1 .htm
Regional and Local Transit Agency and
Government Contacts
Many transit agencies, MPOs, and state and local
transportation agencies have programs to support
transit/vanpool benefits. An extensive list of
regional programs is provided in Appendix A,
Regional Transit Benefits Programs. If an area is
not listed in Appendix A, the MPO for the region
may offer more assistance on locating rideshare
programs. The appropriate MPO can be located
through the Association for Metropolitan
Planning Organizations (202-457-0710 x!9); a
list of MPOs with web pages is available at
www.ampo.org/mposnet_old.html.
Transit/Vanpool Voucher Providers and Other
Services (Regional and National)
The following commercial voucher providers sell
transit/vanpool vouchers to employers. Depending
on the provider, vouchers may be available for
multiple regions. These contacts include:
Transit/Vanpool Voucher Providers
Commuter Check Services, Corp.
Richard Oram, President, or David Judd, Vice
President
401 S. Van Brunt Street
Engelwood,NJ 07631
Tel: 201-833-9700, Fax: 201-833-8704
www.comrnutercheck.com
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CCLI: Transit and Vanpool Benefits
TransitCenter
2901 Sidco Drive
Nashville, TN 37204
Tel; 800-945-CHEK
inquiries@transitcenter.com
www.transitcenter.com
Work/Life Benefits
P.O. Box 6045
Lakewood, CA 90714
Tel: 714-899-4400
www.accorcs-us.net
VPSI
CommuterBucks Program
1220 Rakin Street
Troy, MI 48083-6004
Tel: 800-826-7433, Fax: 810-597-3501
www.vpsiinc.com
Other Services
Wage Works Inc.
Sheila Villaroman
400 South El Camino Real, Suite 600
San Mateo, CA 94402-1705
Tel: 650-373-2900, Fax: 650-373-2919
www.wageworks.com
Commuter Choice Leadership Initiative
For more information on the Commuter Choice
Leadership Initiative, contact the Commuter
Choice Hotline at 888-856-3131, or visit
www.commuterchoice.gov
Information on Tax Considerations
The Internal Revenue Code that governs employ-
er-provided commuter benefits is found at 26
USC Section 132(f), and is available on the web
at: uscode.house.gov/usc.htm or
tmi.cob.fsu.edu/act/f benefithtm
For more information relating to qualified trans-
portation fringes in Section 132(f), visit the
Internal Revenue Service (IRS) web site at
www.irs.gov. This site contains useful informa-
tion for employers regarding the tax treatment of
fringe benefits. Some publications available from
the IRS that may be useful include:
• Publication 15a, Employer's Supplemental Tax
Guide - Section 6. Employee Fringe Benefits
www.irs.gov/prod/forms_pubs/pubs/pl5a08.htm
• Publication 15b, Employer's Tax Guide to
Fringe Benefits - Transportation (Commuting)
Benefits
www.ks.gov/prod/formsjpubs/pubs/p 15b0215.
htm
• Final Regulation Concerning Qualified
Transportation Fringe Benefits (Issued
January 11,2001)
frwebgate.access.gpo.gov/cgi-
bin/getdoc.cgi?dbname=2001_register&docid
=01-294-filed.pdf
For more information relating to qualified trans-
portation fringes in Section 132(f), send a written
request to: Freedom of Information Reading
Room, PO Box 795, Ben Franklin Station,
Washington DC, 20044; or contact Patricia
Holtzman at the IRS at 202-622-6040.
AND TRANSPORTATION
SNEFITS
Transportation benefits can be an effective means
of reducing vehicle travel and associated emis-
sions of air pollutants and greenhouse gases, traf-
fic congestion, and parking problems.
Vehicle Trips
Transit pass programs typically produce substan-
tial shifts away from driving to work alone.
Studies of programs in New York City,
20
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CCLI: Transit and Vanpool Benefits
Philadelphia, and San Francisco found an
increase in employee transit use for both com-
muting and non-work trips among those receiving
employer-provided transit benefits.10 On aver-
age, employees receiving benefits took 1.7 to 3.2
new transit trips per week, as shown in the fol-
lowing table. (US DOT, 1995; Metropolitan
Transportation Commission)
Figure 3: Change in Transit Use due to
Employer-Provided Transit Benefits
Region
San
Francisco
Bay Area
Philadelphia
New York
Type of trip
Commute
Non-work
Total trips
Total trips
Commute
Non-work
Total
% employees
reporting
'increased
transit use.
34%
29%
N/A
N/A
11-23%
14-22%
N/A
Average increase
in transit trips.,
per week per
employee
(among employ-
ees receiving
benefit)
2.05
1.19
3.24
2.5
1.1-1.2
0.55-1.7
1.7-2.9
users of transit, and remain irregular users." The
largest increases in transit use appear to be in
suburban areas, where existing transit share is
lower than urban areas. For example, in the Bay
Area study, the average increase was 3.03 new
transit trips for employees working in San
Francisco and 3.74 new transit trips per week for
employees working outside of San Francisco.
Correspondingly, the reason the average increase
in transit trips was lower in New York than in
other regions may be because New York already
has a high transit share. In the surveys where
respondents were asked about their auto use, the
percent of respondents reporting a decrease in
auto/taxi use was nearly equivalent to the percent
reporting an increase in transit use. These find-
ings suggest that new transit trips are associated
with a reduction in driving trips.
Other studies of transit pass programs at individ-
ual employers confirm the effects of these pro-
grams at reducing vehicle travel. The extensive
U-PASS transportation benefit program at the
University of Washington (UW) produced
remarkable impacts in a short time:
Although most of the employees taking transit
benefits already commuted by transit, the surveys
suggest that most of the users who increased tran-
sit use were previously non-users or infrequent
10 Metropolitan Transportation Commission. Impact of
the Bay Area Commuter Check Program: Results of
Employee Survey. Oakland, California. U.S. Department
of Transportation, Federal Transit Administration.
TransitChek in the New York City and Philadelphia
Areas. Prepared by Research and Special Programs
Administration. Final Report. October 1995.
11 It is not clear to what extent the level of the subsidy
affects the number of new transit trips. One would expect
that a higher subsidy would yield greater transit use. The
San Francisco study, however, suggests that the level of
the transit subsidy has little bearing on the transit rider-
ship effect. No correlation was found between the
amount of subsidy received and the number of new tran-
sit trips. The 1994 New York survey, however, found that
employees receiving $31 or more per month took on
average over three times as may additional trips as those
receiving $30 or less per month. A comparison of the
three New York surveys reveals that the increase in tran-
sit commute trips did not change much over time (about
1.1-1.2 new transit trips per week), even though the
average subsidy in 1994 was about three times as high as
in 1990. However, the number of new non-work trips
was significantly higher per recipient in 1994, suggesting
that the higher subsidy induces more transit trips for non-
work purposes.
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CCLI: Transit and Vanpool Benefits
On September 30, 1991, the University of
Washington, in cooperation with the Municipality
of Metropolitan Seattle, implemented U-PASS, one
of the most comprehensive transportation demand
management programs in the United States. The
U-PASS program was developed in response to
campus and community concerns for trip reduction
and improved commuter services in view of possi-
ble impacts from planned campus development.
The U-PASS program is a flexible package of
transportation benefits offered through a pass that
allows University of Washington students, faculty,
and staff to choose from a variety of commuting
options at a greatly reduced price. After 1 year of
operation,...[v]ehicle trips to campus are down 16
percent, parking lot use has decreased from 91 per-
cent to 78 percent, transit ridership is up 35 per-
cent, carpools have increased 21 percent and the
number of vanpools grew from 8 to 20 in less than
9 months. (William and Petrait, 1993)
These gains have persisted over time; between
1990 and 1999, total UW-Seattle ridership grew
to 7.2 million trips annually, a 68 percent
increase. In the latest (1998) survey, only 25% of
commuters to campus drove alone, a remarkable
accomplishment over a period in which SOV
mode share has risen nationwide. (University of
Washington, 1999) The identically named pro-
gram at the University of Wisconsin was similar-
ly successful, moving an estimated 221,055 vehi-
cle trips to transit during the 1994-1995 academic
year. (Meyer and Beimborn, 1998)
Emissions
Reducing vehicle miles traveled (VMT) reduces
vehicle emissions. The University of Wisconsin
U-PASS program found a 20 percent reduction in
emissions for trips to the university. (Meyer and
Beimborn, 1998) Emissions reductions will gen-
erally track reductions in vehicle miles traveled,
although if employees drive and then park-and-
ride at transit stations, their cold-start emissions
will cut into the emissions benefits.
DEFERENCES AND PUBLICATIONS
Association for Commuter Transportation. "Tax
Benefits," available at www.ACTweb.org
Association for Commuter Transportation. "TDM
Tool Kit."
Bullard, D.L. 1988. Evaluation of Employer
Distributed Transit Pass Programs in Texas.
Texas Transportation Institute. College Station,
TX.
Duff, S. 1999. "New benefits address the heavy
toll of commuting." Employee Benefit News,
vl3,n9,p!57. August.
Federal Highway Administration. 1993. A Guidance
Manual for Implementing Effective Employer-Based
travel Demand Management Programs, available at
www.bts.gov/ntl/DOCS/474.html.
Federal Transit Administration. 1999.
"Commuter Choice Toolkit."
66 Fed. Reg. 2241 (January 11, 2001).
Garvey, C. 2000. "Steer Worker (administering
tax-advantaged commuting benefits)."
HRMagazine v45, n8, p99. August.
Hevener, M.B. and M.G. Dyson. "Easy new payroll
tax savings from employee-paid parking and transit
benefits." Tax Executive v52, n2, pi 15. March.
International Council for Local Environmental
Initiatives (ICLEI). available at
www.iclei.org/us/cashout/
Judd, David. 2001. Personal communication.
Telephone conversation between David Judd,
Vice President, Commuter Check, and Liisa
Ecola, ICF Consulting, April 6, 2001.
22
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CCLI: Transit and Vanpool Benefits
Krechmer, D., F. Spielberg, and V. Milione. 1982.
"Evaluation of employer-based transit pass pro-
grams." Transportation Research Record issue
857, p58.
Litman, T. 1999. Evaluating Public Transit
Benefits and Costs, prepared for Victoria
Transport Policy Institute. January.
Metropolitan Transportation Commission.
Undated. Impact of the Bay Area Commuter
Check Program: Results of Employee Survey.
Oakland, California.
Meyer J. and E. Beimborn. 1996. Evaluation of
an Innovative Transit Pass Program: the UPASS.
March, available at
www.uwm.edu/Dept/CUTS/upassum.htm
Pietsch, B. 2001. Personal communication.
Telephone conversation between Brian Pietsch,
Director of Government Relations/Public Policy
Affairs, American Express, and Liisa Ecola, ICF
Consulting, February 23, 2001.
PR Newswire Association. 1999. "Tax savings for
commuters boost transit pass sales." PRNewswire,
v6915, August.
U.S. Department of Transportation, Federal
Transit Administration, available at
www.fta.dot.gov/
U.S. Department of Transportation, Federal
Transit Administration. 1995. TransitChek in the
New York City and Philadelphia Areas. Prepared
by Research and Special Programs
Administration. Final Report. October.
U.S. Environmental Protection Agency. Employer
Provided Benefits, available at
www.epa.gov/oms/transp/comchoic/ccmeasur.htm
U.S. Environmental Protection Agency. 1998.
Protocol Development Guidance: Using Emission
Reductions from Commuter Choice Programs to
Meet Clean Air Act Requirements. June.
U.S. Environmental Protection Agency. No Date.
Commuter Choice Case Studies.
University of Washington. 1999. U-PASS Annual
Report, September 1998-September 1999. avail-
able at
www.washington.edu/upass/report99/index.html
Victoria Transport Policy Institute. TDM
Encyclopedia: Employee Financial Incentives.
available at www.vtpi.org
Wray, J. 2001. Personal Communication.
Telephone Conversation between Joann Wray,
HR Director and Transportation Director of
Minor & James Medical Clinic and Michael
Grant of ICF Consulting, January 29, 2001.
Wells, SJ. 1999. "Using rush hour to your advan-
tage: offering commuting benefits."
HRMagazine. v44, no.3, p.26-32. March.
Williams, M.E. and K.L. Petrait. 1993. "U-PASS:
A Model Transportation Management Program
That Works," in Transportation Research Record
No. 1404, Transportation System Management,
Parking, and Travel Demand Management,
Washington: Transportation Research Board of
the National Academy Press.
23
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ORDERING
This publication may be ordered from the National Service Center for Environmental Publications (NSCEP) at:
U.S. Environmental Protection Agency
NSCEP
P.O. Box 42419
Cincinnati, OH 45242-2419
Phone: (800)490-9198, Fax: (513)489-8695
FOR MORE INFORMATION
This guidance document and other information about the Commuter Choice Leadership Initiative are available
atwww.commuterchoice.gov or by calling the Commuter Choice voicemail request line at (888) 856-3131.
ACKNOWLEDGEMENTS
This document was prepared for EPA's Office of Transportation and Air Quality under contract 68-W6-0029,1
Michael Grant and Liisa Ecola of ICF Consulting, 9300 Lee Highway, Fairfax, VA 22031, (703) 934-3000.
We would like to thank the various reviewers who provided comments and feedback on the document.
Recycled/Recyclable. Printed wild Vegetable Oil Based Inks on Recycled Paper (Minimum 50% Postconsumer) Process Chlorine Free
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