SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

1 Final Staff Report with Appendices for Rule 9410 SAN JOAQUIN VALLEY UNIFIED AI R POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

Rule 9410 (Employer Based Trip Reduction)

December 17, 2009

Prepared by: Jessica Hafer Fierro, Senior Air Quality Specialist Nichole Corless, Air Quality Specialist

Reviewed by: Lori Sheridan, Air Quality Inspector Colette Kincaid, Senior Air Quality Specialist Patia Siong, Senior Air Quality Specialist Joe Nazareno, Senior Air Quality Engineer Sharon Kendall, Personnel Administrator Lucinda Roth, Supervising Air Quality Specialist George Heinen, Supervising Air Quality Engineer Errol Villegas, Planning Manager Scott Nester, Director of Planning

I. SUMMARY

The District is required and committed to adopt an employer based trip reduction rule.

Both the federal and Californ ia Clean Air Acts require ozone nonattainment areas like the San Joaquin Valley to adopt all reasonable and feasible measures to reduce ozone precursor emissions. The California Health and Safety Code Section authorizes and sets expectations for the District to adopt an employer trip reduction program. Rule 9410 (Employer Based Trip Reduction) satisf ies a federally-enforc eable commitment in District State Implementation Plans (the 2007 Ozone Plan and the 2008 PM2.5 Plan ) and is designed to share the air pollution clean-up burden traditio nally targeted at stationary sources.

Through employer based trip reduction, employers establish programs to help employees use ridesharing and alternative transportation. Studies show that comprehensive, multi-faceted programs t hat combine marketing, program support, services and facilities, alternative schedules, and incentives are the most successful.

Although there are several regi onal trip reduction programs in existence in California, the District has engaged in an ex tensive process to tailor the program to the uniqueSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

2 Final Staff Report with Appendices for Rule 9410 needs of diverse Valley employers. District staff researched relevant commute studies, law, and human resources issues and proacti vely created numerous opportunities for

the District to discuss the rule and listen to stakeholder suggestions and concerns. The District held 11 public meetings as well as 20 meetings with interested employers, industry groups, and service organizations. The District also met with each of the Valley’s eight counties and 10 largest cities, as these are some of the Valley’s largest employers. In total, District addressed about 400 individuals representing hundreds of

thousands of commuters.

This dialog helped define the s pecifications for a successful rule. The Valley has a great diversity of employers r epresenting a variety of industries, regions, urban and rural areas, and work cultures. Employers em phasized that transit is not available everywhere and that ridesharing may potentiall y impact productivity, as in production line environments. Thus, em ployers need flexibility to adopt suitable trip reduction programs, and employers must consider labo r laws and union cont racts. Employers also emphasized the need for low administrat ive costs and technical assistance.

The District developed Rule 9410 to meet these specifications. The menu-option approach addresses the Valley’s diversity of employers and tr ansit limitations, offering each employer flexibility to implement programs that can work for their worksites and employees. The District is committing to extensive and continuous employer implementation assistance with training sessions, guidance, templates, newsletters, and turnkey program components. District staf f researched potential labor law and union issues and incorporated appropriate provisions into the rule, such as distinguishing production line workers in applicable measur es and special provisions for employers with employees protected by the Migrant an d Seasonal Agricultural Worker Protection

Act.

Proposed Rule 9410 will be successful in achi eving the goals of the rule with minimal disruption to employers. St aff has designed the rule to a ssure that each employer has sufficient options for rule compliance, and employer programs will help employees choose to use ridesharing and alternative trans portation. Rule 9410 is tailored for the Valley, providing a straight-forward and a ttainable approach for Valley employers as compared to South Coast Rule 2202’s mandated participation le vels and fees. As such, Rule 9410 is expected to kick-start a c hange in the Valley’s commute behaviors and achieve the goal of reducing vehicle miles traveled (VMT) and trips.

Through Rule 9410, employers provide the infr astructure that facilitates employees choosing to use ridesharing and alternative transportation. Rule 9410 also provides accountability needed for credit in the Stat e Implementation Plan. Employers will submit annual reports to the District, and this information will allow the District to verify

emissions reductions to the U.S. Envi ronmental Protection Agency (EPA).SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

3 Final Staff Report with Appendices for Rule 9410 The District’s Personnel Department assess ed potential workers’ compensation, labor law, and liability issues, ensuring that each menu-option is feasible from a human resources perspective. The District’s Ou treach and Communications Department has developed a plan for the significant out reach that will be required during rule implementation. With this diverse inte rnal involvement and extended stakeholder outreach, Rule 9410 has trul y been a comprehensive effort.

A. Reasons for Rule Development and Implementation

The San Joaquin Valley Air Basin is designated nonattainment for the National Ambient Air Quality Standard (NAAQS) for 8-hour ozone and for PM2.5. The Valley is also

nonattainment for the California ozone and PM standards. By reduc ing VMT, Rule 9410 can decrease emissions of ozone precursors , direct PM2.5, and PM2.5 precursors. Decreasing VMT can also contribute to efforts to reduce greenhouse gases (GHG).

Reducing mobile source emissions is key to the success of the San Joaquin Valley’s (Valley) attainment strategies for the federal 8-hour ozone and PM2.5 (particulate

matter that is 2.5 microns or less in diam eter) standards. About 75% of the Valley’s oxides of nitrogen (NOx) emissions come from mobile sources, and NOx is a key ingredient in both ozone and secondary particula te matter formation. However, state and federal laws preempt the Sa n Joaquin Valley Air Pollution Control District’s (District) authority to regulate tail-pipe emi ssions for mobile sources.

The California Air Resources Board (ARB) is responsible for regulating emissions from
on-road motor vehicles, and ARB also establishes fuel specifications for California. Local governments, such as cities and count ies, can influence air quality by addressing

emissions from vehicles in their land-us e and transportation planning processes and projects. For example, reducing urban spra wl and increasing street connectivity reduce emissions and help im prove air quality.

While the District cannot regulate the vehicles themselves or the fuel s the vehicles use,

the District can reduce mobile source emi ssions through other avenues. The District’s Emissions Reduction Incentive Program (ERI P) provides financial incentives to help replace older cars and engines through a few different programs. One program targets cars with histories of needing smog repairs, but are currently legally registered and able

to be driven. Based on the results of an emissi on test, incentives are available for up to $5000 to replace an older car. Other incentives are also given so older engines are replaced with newer, cleaner engines years bef ore these engines wo uld be required to be replaced through regulation or natural attr ition. The District encourages carpooling, trip linking, and similar activities through Heal thy Air Living, the District’s principle public outreach effort. Through the District’s Indi rect Source Review (ISR) rule 9510, the added vehicle miles traveled that results from new development is mitigated throughSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

4 Final Staff Report with Appendices for Rule 9410 onsite and off-site measures. The District will also reduce vehicle emissions through adoption and implementation of Rule 9410, Employer Based Trip Reduction. The

District committed to this rule in both the 2007 Ozone Plan and the 2008 PM2.5 Plan

.

Between 2000 and 2020, the populat ion of the San Joaquin Va lley is expected to grow by 60%. In contrast, the total population for t he state of California is expected to grow 29% over the same time period. 1 Population growth typically leads to increased vehicle activity and increased emissions of ozone pr ecursors, slowing the progress made by regulations that require new er automobiles to pollute less than older models. Furthermore, the Valley’s total vehicle miles traveled (VMT) is increasing at an even faster rate than the populat ion (see Figure1). So the Valley has more people, and they’re generally driving more.

Figure 1 San Joaquin Valley Percent Grow th in Population and Vehicle Miles Traveled as compared to 1980

0 50 100 150 200 250 300 350

1980 1985 1990 1995 20 00 2005 2010 2015 2020Percent Growth Vehicle Miles Traveled

Number of People

Despite VMT increases, total passenger vehicle emissions have decreased significantly with improvements in technology and fuel fo rmulations (see Figure 2). The Department of Transportation (DOT) Federal Highway Admi nistration (FHWA) projects that VOC emissions could rise slowly after 2010 in areas projecting annual VMT increases of more than 2 percent, even t hough emissions are project ed to remain well below 1990 levels through at least 2015. NOx emissions r eductions are also projected to offset VMT growth through at least 2010 in areas expe cting more rapid growth and beyond 2015 in those areas expecting slower VMT increas es. However, with EPA's new health-based

1 Based on data from www.arb.ca.gov/app/emsinv/trends.em_trends.php , developed using reports from the California Department of Finance.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

5 Final Staff Report with Appendices for Rule 9410 standards for PM2.5 and 8-hour ozone adopt ed in 2006 and 2008, respectively, the immense attainment challenges before t he Valley demand further reductions from a variety of sources. The proposed Employer Based Trip Reduction rule will achieve

some of the additional mobile source em issions reductions needed to contribute to the Valley's progress towards EPA's increas ingly stringent air quality standards.

According to the Department of Transporta tion’s (DOT) National Household Travel Survey 2 , as a nation-wide average, tr ips to and from work account for 17% of all private vehicle trips (see Figure 3). The survey also found that private vehicl e use is the largest mode of transportation to and from work , accounting for about 92% of all work commutes (see Figure 4).

Figure 2 Mobile Source Em issions, Light Duty Passenge r and Light Duty Trucks

0 20 40 60 80 100 120 140

1990 1995 2000 2005 2010 2015 2020 2025Emissions, tons per day

2 The 2001 surveys were released in July 2005. A 2008 upda te is in progress with a target completion date in fall

2009.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

6 Final Staff Report with Appendices for Rule 9410 Figure 3 Private Vehicl e Trip Purposes, 1990-2001

Source: A dapted from DOT 2001 National Household Transportation
Survey 

### 3%

8% 1%

25% 17%

46% To/From Work

Work-Related Business

Family/Personal Business

School or Church

Social & Recreational

Other

Figure 4 Modes of Transportation To and From Work, 1990-2001

Source: Adapted From DOT 2001 National Household Transportation Survey 

### 4%

3%

1% 92% Private Vehicle

Public Transit

Walk

Other

The DOT survey also found that average vehicle occupancy to and from work has declined since 1977, and the average distance for commuting to work has continued to increase over the same time period (see Figur e 5). The work commute is not the only

arena where vehicle miles traveled can be r educed, but it carries some significant advantages and benefits. For ex ample, carpooling to work is convenient in that coworkers are going to the same place at th e same time. Using carpooling to decreaseSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

7 Final Staff Report with Appendices for Rule 9410 single occupancy vehicle use and vehicle miles traveled during the common work commute times can decrease congestion as well as improve air quality.

Figure 5 Average Vehicle Occupancy (AVO) and Trip Length To and From Work

Source: Adapted from DOT 2001 National Household Transportation Survey 1 1.05

1.1 1.15

1.2 1.25

1.3 1.35

1977 1983 1990 1995 2001 AVO

0 2 4 6 8 10 12 14

Miles

Average

Vehicle Occupancy

Average Trip Length

B. Description of Project

Consistent with the District’s plan commi tments, Rule 9410 would require larger employers (those with 100 or more eligible employees) to establish employee trip reduction programs to reduc e VMT, reducing emissions associated with work commutes. The Proposed Rule uses a menu-based Employer Trip Reduction Implementation Plan (ETRIP) and peri odic reporting requirements to evaluate performance on a phased-in compliance schedule. The goal of the ETRIP is to provide employees with opportunities that make rides haring and alternative transportation more accessible while not requiring a certain num ber of participants, as employers cannot legally mandate their employees ’ activities outside of working hours. Employers can choose which services and programs work best for their operations and their employees. Starting in 2014, employers would also conduct periodic employee

Commute Verification to be r eported to the District annually. This accountability that has been built into the rule will help verify em issions reductions and rule effectiveness to the U.S. Environmental Protection Agency (EPA). The Proposed Rule also includes a section on District support, where the District is committing to providing trainings,SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

8 Final Staff Report with Appendices for Rule 9410 guidance, and turnkey progr am elements to assist employers with program implementation.

C. Rule Development Process

As part of the rule development process, District staff conducted public scoping meetings in February 2009. At the scoping meetings, Di strict staff presented the objectives of the proposed rulemaking projec t and solicited suggestions from affected stakeholders on how best to achieve the goal s of the project. The knowledge gathered during the scoping meetings was incorpor ated into Draft Rule 9410 presented in subsequent workshops.

In July 2009, a voluntary survey was sent to large employers to solicit information about their current work environment, including em ployee information and rideshare programs currently in place. Information provided thro ugh the survey assisted the District in the development of Rule 9410 and supporting materials.

The first Draft Rule and revised Draft Staff Report were presented at workshops held in July 2009, followed by a public comment per iod. A socioeconomic focus group was held directly after one of the workshops to solicit comments and information to be used

for the socioeconomic and environmental anal yses. The results of the socioeconomic analysis will be published in a report and pr esented along with the proposed rule during the final workshop.

The second round of workshops was held in September 2009, followed by a public comment period. The revised Draft Rule and revised Draft Staff Report were published prior to the meeting. Socioeconomic and co st effective analyses were discussed at the workshops and available for comments.

The final workshops were held October 26 and 28, 2009 to allow for further time for stakeholders to comment and provide informa tion to the District regarding the costs associated with rule implem entation. These final workshops also provided an opportunity for outreach to those who had not yet been involved in the Rule 9410 development process.

Throughout the rulemaking process, Distric t staff has met with many potentially impacted stakeholders, particula rly the Valley’s counties and la rger cities. At these meetings, District Personnel, Outreach, and Pl anning staff have fostered multi-faceted

discussions of rule elements and received st akeholder feedback contributing to a rule that can be successful at a wide range of wo rksites. The dialogue between the District

and affected stakeholders led to a number of rule improvements throughout the

process.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

9 Final Staff Report with Appendices for Rule 9410 The Proposed Rule and staff report with appendices, and final draft socioeconomic analysis report was published and available to affected sources and interested parties prior to a public hearing bef ore the District Governing Board to consider adoption of Rule 9410 on December 17, 2009. The notice of the public hearin g for the proposed rule was published in a general circulation newspaper in each of the eight San Joaquin Valley counties. The public notice was also mailed to affected sources and interested parties. The notice of public hearing solicits written comment s, and identifies the name and telephone number of Distr ict staff who can answer questions and respond to comments. A public comment on the Pr oposed Rule was held from November 16 –
November 30, 2009.

II. BACKGROUND

A. History and Legislative Authority

On January 20, 1994, the District Govern ing Board adopted Rule 9001 (Commute Based Trip Reduction) in response to Calif ornia Clean Air Act (CC AA) requirements to reduce single occupancy commute vehicle trips and to reduce motor vehicle emissions. In October 1995, Senate Bill (SB) 437 created Health and Safety Code (H&SC) section 40929(a) (renumbered to 40717.9), which prohibi ted any public agen cy from requiring an employer to implement an employee tr ip reduction program unless expressly required by federal law. District staff det ermined that Rule 9001 was inconsistent with the new H&SC section, so the District ceased enforcement of the trip reduction rule as of October 9, 1995, and the rule was repealed on February 15, 1996.

More recent legislation gives the District authority to implement measures such as an employer based trip reduction rule or a commute options program:

• 2008 California Assembly Bill (AB) 2522 (Arambula) authorizes the San Joaquin Valley Air District to adopt rules and regulat ions to reduce vehicle trips in order to reduce air pollution from vehicular sources (H&SC Section 40612(a)(2)).

• 2003 California SB 709 (Florez) authorizes the San Joa quin Valley Air District to adopt rules and regulations to require businesses that employ at least 100 people to establish a rideshare pr ogram (H&SC Section 40601(d)).

Also, under Clean Air Act Section 182(d)(1 )(B) and 182(e), severe and extreme nonattainment areas may adopt control meas ures requiring employers to implement programs to reduce work-related vehicle trips and miles traveled by employees.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

10 Final Staff Report with Appendices for Rule 9410 The District’s 2007 Ozone Plan identified Employer Based Tr ip Reduction as one of the innovative strategies for reducing ozone precursors. The 2008 PM2.5 Plan also committed to adopt a rule requiring employer s with 100 or more employees to establish employee trip reduction programs.

B. Related Legislation

Related state laws include California Labor Code Section 3600.8, which states that when an employee voluntarily pa rticipates in an alternative commute program that is provided or subsidized by an employer complying with an air district trip reduction mandate, this commute is not wit hin the scope of employment.

In addition, H&SC Section 43845 states that employers are to offer their employees a parking cash-out program if:

• The worksite is in an area (such as the San Joaquin Valley) that does not attain state ambient air quality standards;

• The employer has at least 50 employees; and

• The employer does not own the parking ar ea (i.e., the employer leases the parking area. Under a parking cash-out program, an empl oyer provides a cash allowance to employees who do not use a parking space, wit h this cash allowance being equivalent to the cost of parking space. H&SC Section 43845 was put into place by AB 2109 (1992) in response to studies showing that employees are more likely to rideshare when they have to pay the full cost of parki ng spaces, and employer subsidized parking encourages single-occupancy vehicle commuti ng. H&SC Section 43845 was recently amended by SB 728 (Lowenthal, approved by t he Governor on October 11, 2009) in response to reports that H&SC was not bei ng enforced. SB 728 amends H&SC Section 43845 to authorize either ARB or a local agency (s uch as a city, county, or air district) to establish penalties to ensure employer complia nce with this statute. Local agencies are not required to enforce H&SC Section 43845, but the amendment provid es the option of doing so through adoption of a local regulat ion. AB 1186 (Blumenfield, 2009) would have incorporated additional provisions, but AB 1186 was vetoed by the Governor.

The District will be in contact with ARB to discuss parking cash-out enforcement needs. Further study is needed to determine how many Valley employers are be subject to the

state law and assess the emission reduction potential of enforcement. Although the District is not adding parking cash-out to Rule 9410, employers can earn ETRIP points for offering a monetary incentive to employees, regardless of whether it is characterized as parking-cash out.

The federal Migrant and Seasonal Agricult ural Worker Protection Act (MSPA) also affects employers in the Valley subject to this rule. MSPA applies to migrant and seasonal workers employed in the term “Agricultural Employment:”SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

11 Final Staff Report with Appendices for Rule 9410 “Agricultural employment means employ ment in any service or activity included within the provisions of sect ion 3(f) of the Fa ir Labor Standards Act of 1938 (29 U.S.C. 203(f)), or section 3121(g) of the Internal Revenue Code of 1954 (26 U.S.C. 3121(g)) and the handling, planting, drying, packing, packaging, processi ng, freezing, or grading prior to delivery for storage of any agricultural or horticultural commodity in its unmanufactured state.” 29 U.S.C. 1801, et seq., Sec. 3 (3).

Dialogue with affected stakeholders demons trated that employ ers with eligible employees protected by the M SPA would not be in conflict with the federal regulation if required to comply with Phase 1 and Phase 2 poi nt targets only. Phase 3 options that would require employers to facilitate or promote ridesharing and alternative transportation would be inconsistent with f ederal regulations on these employers.

C. Supporting Studies

The proposed rule emphasizes education and in frastructure for trip reduction programs through implementation of four ETRIP strategies represent ing various ways to promote and facilitate employee trip reduction. Studies have shown significant participation rates associated with a comprehensive ETRIP t hat would be established through the implementation of proposed Rule 9410.

The Victoria Transport Policy Institute TD M Encyclopedia states that a comprehensive trip reduction program, such as what this ru le will require, “typically reduces peak-period automobile trips by 5-20% at a worksite and more if supported by regional TDM strategies such as transit improvements.”

The DOT and EPA Commuter Choice Primer found:

• Employer based trip reduction programs that emphasized commute alternatives (such as vanpools) realized an average trip reduction of 8.5%.

• Programs that focused on financial incentives and disincentives (such as transit subsidies and parking pr icing) reduced an average of 16.4% of employee

commutes.

• Employers that combined both commute alternatives (e.g., vanpool program) with incentives or disincentives (e.g., vanpool subsidies) achieved an average trip reduction of 24.5%.

The DOT FHWA report “Multi-Pollutant Emissions Benefits of Transportation Strategies,” supports similar findings in their discussion of employer based Transportation Demand Management (TDM ) programs and evaluat ion of program impacts using EPA’s COMMUTER model. The report’s example showed increases in participation dependent on the meas ures offered in the trip reduction program such as:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

12 Final Staff Report with Appendices for Rule 9410 • Offering information on alternative transportation and a quarter-time transportation coordinator resulted in ca rpool and vanpool participation increases by 15% and 20%, respectively.

• Programs that offered commute in formation and coordinator as well as ridematching and flex schedules to help accommodate transit achieved participation increases of 10% in carpools, 40% in v anpools, and a 50% increase

in transit use.

Based off of the FHWA report, District staff utilized EPA’s COMMUTER model to estimate the impacts of some ETRIP scenarios, resulting in consistent findings. Multiple tools are available for employers to asses thei r trip reduction program or possibilities for

their worksite such as EPA’s COMMUTER Model, DOT’s Commuter Choice Decision Support Tool, and best Workplaces for Commuters Business Savings Calculator.

III. SUMMARY OF PROPOSED RULE

A. Employer Requirements of Draft Rule 9410

Rule 9410 would require larger employers (those with 100 or more eligible employees) to establish employee trip reduction progr ams to reduce VMT associated with work commutes. Eligible employees do not include the following:

• Employees who do not report to work between 6 AM and 10 AM.

• Emergency health and safety employees such as sworn peace officers and firefighters

• Employment agency personnel

• Farm workers

• Field personnel

• Field construction workers

• Home garage employees

• On-call employees

• Part-time workers

• Seasonal workers (employed 16 weeks or less per year)

• Volunteers

Rule 9410 would apply to an estimated 1,883 worksites throughout the Valley, representing a wide range of sectors and accounting for approximately 500,000 commuting employees. This rule distinguishes those facilities into tw o tiers. Tier One

Worksites are those with 100- 249 eligible employees and Tier Two Worksites have 250 or more eligible employees. There are an estimated 1,342 Tier One Worksites and 541

Tier Two Worksites.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

13 Final Staff Report with Appendices for Rule 9410 Rule 9410 proposes a menu-based Employer Trip Reduction Implementation Plan (ETRIP) with periodic reporting. The District is assuring the success of the rule through a phased-in compliance schedule and commitment s to provide extensive support to

minimize the administrative burde n of rule implementation.

There are three main components of employ er compliance in Proposed Rule 9410:

• Employer registration

• Employer Trip Reduction Implementation Plan (ETRIP)

• Commute Verification with Annual Reporting

Employer registration: Employers subject Rule 9410 (i .e., worksites with 100 or more eligible employees) would register with the District by July 1, 2010 (see Section 6.1 of the Draft Rule).

• Employers who become subject to Rule 9410 after January 1, 2010, due to a change in the workforce, would register within 180 days after becoming subject to Rule 9410 (see Sections 6.1 and 6.6.1 of the Draft Rule).

• Employers who fall below the 100 eligible employee level after registering with the District for this rule would notify the Dis trict in writing of their change in status within 90 days of their change in status (see Section 6.6.1.1 of the Draft Rule).

ETRIP: The ETRIP is a check-list of menu options, through which employers plan facility and operation changes that make rideshar ing and alternative transportation more accessible to employees. The menu approach allo ws employers the flexibility to choose measures to implement that ar e appropriate for their employees and their operations.

No employee will be forced to use ridesharing or alternative transportation through Rule 9410, and employers cannot mandate employees to use specific modes of commuting. Most of the menu options are, therefore, not predicated on participation by employees. Each menu option has a point value, and employers must achieve specified point targets, depending on the size of their worksite (Tier 1 worksites, with 100 to 249 eligible employees, and Tier 2 worksites, with 250 or more eligible employees).

Employers must meet specified point targets in the rule for their total ETRIP and for four strategy areas. The strategies are being ph ased in over a three-year period to allow

time for education and awareness of trip reduction opportuniti es and benefits as well as to minimize the cost impact on employer s. The phase in schedule is as follows:

• Phase 1: “Marketing Strategy” and “Pr ogram Support Strategy” should be added to the ETRIP by September 2011, with implementation by January 2012.

• The Marketing strategy includes measures to increase program awareness, such as being a Healthy Air Living partner, distributing a rideshare newsletter, or posting a bulle tin board dedicated to ridesharing and alternative transportation.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

14 Final Staff Report with Appendices for Rule 9410 • The Program Support strategy ma kes ridesharing and alternative transportation easier for employees through programs like guaranteed ride home or ride matching services.

• Phase 2: “Services and Facilities Strategy” should be added to ETRIP by September 2012, with implem entation by January 2013.

• Services and Facilities measures ar e deployed in the workplace so that employees are less likely to need to travel offsite a break times. Examples include on-site food service and on-site postal service (i.e., stamps available for sale and a pl ace to leave personal stamped mail).

• Phase 3: “Transportation, Alternative Sc hedules, and Incentives Strategy” should be added to ETRIP by September 2013, wit h implementation by January 2014. Employers also select additi onal measures from any st rategy to reach a total ETRIP target, which is greater than the sum of the minimu ms for the four strategy

areas.

• Transportation, Alternative Schedules, and Incentives include a wide range of options: comprehensive vanpool programs, comprehensive carpool programs, monetary incentives for using ridesharing, subsidized transit passes, telecommuting, etc.

• The “Additional Points Needed” category puts the total ETRIP target at a higher level than the sum of the four strategy ar ea minimums. Additional points can come from any of the four strategy areas or from measures prorated and applied to employees or wo rksites that are otherwise exempt

from the rule.

Employers with eligible employees protec ted by the federal Migrant and Seasonal Agricultural Worker Protection Act will be r equired to comply with Phase 1 and Phase 2 point targets only. Phase 3 requirements w ould be inconsistent with federal regulations on these employers.

Table 1 shows the ETRIP-phase in schedule. Beginning in 2015 (or after the employer has become subject to the rule and has subm itted their first ETRI P), the employer will submit the complete ETRIP form to the Distr ict annually by March 31. Any changes the employer made to their trip reduction progr am will be reflected on their new ETRIP. The District would act on ETRIPs within 45 days of submittal. Employers would keep records of steps taken to implement measures for the ETRIP on file for at least five years, making records available to the District or EPA upon request. Figure 1 shows the 2013 ETRIP template, a straight forward check list employers could use to report

ETRIP measures to the District.

Each measure on the ETRIP list is expected to help employees choose to leave their cars at home, using ride sharing and alter native transportation instead. Each ETRIP measure has an associated point value, and em ployers are to choose the collection of

measures that work best for their worksites wh ile achieving the point targets specified inSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

15 Final Staff Report with Appendices for Rule 9410 the rule. In the rule, measur es are organized by strategy ar ea. Here, the measures are ranked by point value. Points we re assigned based on two factors: (1) Level of effort and cost (initi ally and ongoing) to the employer (2) Expected effectiveness in facilitating employee usage of ridesharing and alternative transportation

Assessment of these factors was based on available commute literature and interviews of Valley employers and employees. Measures that ranked highly in both of these areas are assigned higher point values (15 being the highest), while measures that ranked relatively low in both of these areas are assigned com paratively low point values (1 being the lowest). Table 2 shows ETRIP measures, definitions, and points analysis.

Table 1: ETRIP Point Targets

ETRIP Tier One

Worksite Tier Two

Worksite Initial Submittal

Deadline Starting Implementation Minimum points per strategy 1

Phase 1: Marketing Strategy 6 10 September 2011 January 2012

Phase 1: Program Support Strategy 6 8 September 2011 January 2012

Phase 2: Services and Facilities Strategy 8 10 September 2012 January 2013

Phase 3: Transportation, Alternative Schedules, and Incentives Strategy 14 20 September 2013 January 2014

Phase 3: Additional Points Needed (from any measure or combination of measures) 10 18 September 2013 January 2014

Total Points Goal 44 66 September 2013 January 2014

1 Employers with workers protec ted by the Migrant and Seasonal Workers Protection Act will complete Phase 1 and Phas e 2 ETRIP requirements only.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

16 Final Staff Report with Appendices for Rule 9410 Figure 1: Sample ETRIP Template, 2013SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

17 Final Staff Report with Appendices for Rule 9410SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200918Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessTrans., AltSchedules,andIncentivesCompressed Work Week (CWW) –A regular, full-time work schedule which eliminates at least one round-tripcommute trip (both home-to-work andwork-to-home) at least once everytwo (2) weeks for participating employees. A CWW schedule must beimplemented in a manner that reduces trips to the worksite, as analternative to completing the basic work requirement of five eight-hourworkdays in one week, or ten eight hour workdays in two weeks.•9/80 Schedule – The employee works eight nine-hour days, and oneeight-hour day. The employee is thusoff of work one day every tendays.•4/10 Schedule – The employee works four ten-hour days each week.The employee thus takes one day off work in every five day period.•3/36 Schedule – The employee works three twelve-hour days and takestwo days off work every five days.Up to15dependsonparticipationrateHighHighTrans., AltSchedules,andIncentivesMonetary Incentive –The employer, or other funding sources,provides eligible employees withcash subsidies, at least on a quarterly basis, for participation in the tripreduction program. The District recommends that the monetary incentiveequals at least two times the state minimum wage at least once per month.The measure can provide a monetary incentive to eligible employees whouse alternative transportation a predetermined, minimum number of timesper month or pay period.12HighHighSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200919Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessTrans., AltSchedules,andIncentivesTelecommuting Program –A system of working at home, offsite,or at a telecommuting center for a fullworkday. Telecommuting should eliminatethe trip to work or reduce thetravel distance to the worksite by more than 80 percent. The employer shouldmake telecommuting available to at least10 percent of its Eligible Employeesexcluding production workers, field construction workers, and employees whospend 20 percent or less oftheir work time per week at the worksite. In makingtelecommuting available to at least 10percent of applicable employees, theemployer can claim ETRIP points for this measure even the possibleparticipants do not take advantage ofthe program. Each participant whotelecommutes should be allowed to telecommute at least one day per week.9HighHighTrans., AltSchedules, andIncentivesComprehensive Vanpool Program –Employer-promoted program designed to encourage the use of existingvanpools or the developmentof new vanpools. Theemployers must provideEligible Employees information onvanpool availability, benefits ofvanpooling, and any incentives offered by the employer or an outsideagency.8MediumHighTrans., AltSchedules,andIncentivesComprehensive Carpool Program –Employer-promoted program designed to encourage the use of existingcarpools or the development of new carpools. This is intended to be a multifaceted program that includes internalride matching or personalized commuteassistance, ridesharing information, and resources on how to start a carpool.The employer should also publicizeany local ridesharing events to itsemployees.8MediumHighSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200920Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessTrans., AltSchedules,andIncentivesComprehensive Bicycle Program –Employer-promoted program which encourages bicycle commuting. This isintended to be a multi-faceted program that includes bicycle racks,information (such as bicycle lanes and safety considerations), and a repair kitor tools (such as a tire pump). Theemployer should also publicize any localBike to Work events, typicallyheld in May, to its employees.7MediumMediumServices &FacilitiesOnsite Food Service, or food service within 1⁄4 mile of worksite –Employer provides an onsite area whereeligible employees can consistentlypurchase meals, such as a cafeteria orlunch truck service. Food servicewithin 1⁄4 mile of worksite qualifies.7MediumMediumServices &FacilitiesOnsite Child Care, or child carewithin 1⁄4 mile of worksite –Daycare service provided to eligible employees.7HighLowServices &FacilitiesShowers and/or Lockers onsite7HighLowTrans., AltSchedules,andIncentivesExtra Time Off –The employer provides eligible employees additional time off for participationin the trip reduction program. This can include, but is not limited to, allowingeligible employees to accrue time offfor every time they use alternativetransportation or ridesharing.7MediumMediumMarketingHealthy Air Living Partner –Register with the SanJoaquin Valley Air Pollution Control District as aHealthy Air Living Partner and remaina partner in good standing. Seewww.healthyairliving.comfor more information.6MediumMediumProgramSupportInternal Ride Matching –The employer provides rideshare matching service, zip code list orassistance in finding commute alternatives for all eligible employees.Information must be updated semiannually.5MediumMediumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200921Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessProgramSupportInternal Guaranteed Ride Home Service –The employer directly provides eligibleemployees with a return trip to thepoint of commute origin, when a need for the return trip arises and theemployer participated in ridesharing oralternative transportation that day.This need, as defined by the employer, may be a personal emergency, anunplanned situation or business-related activities (such as overtime). Thisservice may be provided by employervehicle, rentalcar, taxi, anotheremployee or by a TMA/TMO.For Production Workers – 5For staff who are not Production Workers (i.e.,office staff) - 55MediumMediumProgramSupportPersonalized Commute Assistance –The employer provides personalized assistance such as transit itineraries,carpool matching and personal follow-upto eligible employees at leastannually. Examples of ways an employer can provide this service to eligibleemployees are:•Organize carpool/vanpool formation meeting(s).•Assist in identifying park and ride lots.•Assist in identifying bicycle and pedestrian routes.•Assist in providing personalized transit routes and schedule information.•Provide personalized follow-up assistance to maintain participation inthe commute program.5MediumMediumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200922Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessMarketingEmployer Rideshare Event –Employer sponsored events availableto all eligible employees whichpromote rideshare opportunities, such as:•Employee Rideshare Fair that has multiple agencies or resources aboutalternative transportation in the vicinity of the worksite•Presentation on the alternative transportation opportunities and servicesavailable to the worksite and benefits of ridesharing. This should be atleast a one-hour meeting for all eligible employees or the equivalent.•Week-long Alternative Transportation/Rideshare event where eligibleemployees are encouraged to try alternative transportation throughoutthe week.5MediumMediumMarketingEmployer Rideshare/Alternative Transportation Meetings –Semiannual meetings available to all eligible employees to help thoseemployees identify those who live in similar areas to foster the ridesharecoordination.5MediumMediumMarketingEmployer Rideshare/Alternative Transportation Focus Group(s) –Meetings conducted at least semiannually with a sample of eligibleemployees to solicit inputon commute behavior, incentives to rideshare, andany constraints to alternative commute modes.5MediumMediumServices &FacilitiesOnsite break room and kitchenette –Eating area at the worksite that includes, at a minimum, a sink and microwave.5MediumMediumServices &FacilitiesElectric vehicle recharging5MediumMediumTrans., AltSchedules,andIncentivesShuttles –Employers provide a shuttle for daily work commutes between employerworksites or between transportation stations and the worksite.5MediumMediumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200923Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessTrans., AltSchedules,andIncentivesVanpool Subsidy –Employers pay for all or part of the costof commuting by vanpool for eligibleemployees that use these services. Theemployer must provide the monetaryvalue of the vanpool subsidy andthe frequency of distribution.5MediumMediumTrans., AltSchedules,andIncentivesTransit Subsidy –Employers pay for all or part of thecost of commuting by local transit,commuter rail or train for eligible employees that use these services. Theemployer must provide the monetaryvalue of the transit subsidy and thefrequency of distribution.5MediumMediumTrans., AltSchedules,andIncentivesBicycle Subsidy –Employers pay for all or part of the purchase of a bicycle and/or bicycleimprovements, repair, andstorage for eligible employees that use theseservices and regularly commute by bicycle. The employer must provide themonetary value of the bicycle subsidy and the frequency of distribution.5MediumMediumMarketingOnsite Transit Information Center –Employer-provided transit informationcenter for general transit informationand/or the onsite sale ofpublic transit passes, tickets or tokens to thatworksite’s eligible employees. Information must be verified and updated, asnecessary, at least quarterly.3LowMediumMarketingRideshare and Alternative Transportation Bulletin Boards –A communication tool that displays materials that publicizes incentives andencourages participation in a rideshareprogram. The bulletin board shouldbe in a location that would be most likely viewed by the majority of theeligible employees. It may be necessary to have more than one bulletinboard. The board should be verifiedand updated, as necessary, at leastquarterly.3LowMediumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200924Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessMarketingAttendance at a Marketing Class/Focus Group –Annual attendance by the ETC at anEmployee Trip Reduction programmarketing class provided by the District or its designee.3LowMediumMarketingEmployer Rideshare Newsletter –An employer-generated newsletter thatdiscusses alternative transportationmodes, outlines incentives, and encourages participation in a rideshareprogram. Must be distributedat least quarterly to all eligible employees. Anewsletter should be at least two pagesalong and be text-driven to provideeligible employees with detailed information about ridesharing and alternativetransportation. Could be an electronic newsletter.3LowMediumMarketing“Best Workplacesfor Commuters” Recognition –Businesses who, through application tothe Best Workplaces for Commutersprogram, are found to meetthe National Standard ofExcellence in commuterbenefits can be included in the nationallist of Best Workplaces forCommuters. This is a standard created by the Center for UrbanTransportation Research and the U.S. Environmental Protection Agency.Seewww.bestworkplaces.orgfor more information.3MediumLowProgramSupportRide match bulletin board –The employer provides an area for employees to find coworkers who may beinterested in ridesharing.3LowMediumProgramSupportExternal Employee Ride Matching Services –The employer promotes the use of athird-party rideshare program to helpeligible employees identify appropriate opportunities for ridesharing.Employers must promote theseservices at least annually.3LowMediumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200925Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessProgramSupportExternal Guaranteed Ride Home Service –The employer utilizes a third-party service to provide eligible employees witha return trip to the pointof commute origin, when aneed for the return triparises and the employer participated in ridesharing or alternativetransportation that day. Thisneed may be a personal emergency, anunplanned situation or business-related activities (such as overtime). Theemployer needs to indicate if thisservice would be provided by employervehicle, rental car, taxi, another employee or by a TMA/TMO.3LowMediumTrans., AltSchedules,andIncentivesFlex Time Schedule –Eligible employees are permitted toadjust their work hours in order toaccommodate public transit schedules or rideshare arrangements.For production workers 3For staff who are not production workers(i.e., office staff) 33MediumLowTrans., AltSchedules,andIncentivesStaggered Work Schedule –The employer selects different start and stop times for departments orindividuals within the company to promote ridesharing and accommodatepublic transit.3MediumLowTrans., AltSchedules,andIncentivesStartup Incentive –Designed to reward commuters whopreviously commuted via singleoccupancy vehicle by offering a one-timeor short-term incentive when theybegin using ridesharing or alternativetransportation on a regular basis.3LowMediumTrans., AltSchedules,andIncentivesDiscount Transit Passes –Employers pay for part of the cost ofcommuting by local transit, commuterrail or train for eligible employees that use these services.3LowMediumSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200926Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessTrans., AltSchedules,andIncentivesDiscounted/Free Meals –Employers provide participating eligibleemployees with meals free or at least50% discounted for their participationin the commute reduction program.The employer must offer meals to all eligible, participating employees at leastonce per month.3MediumLowServices &FacilitiesOnsite Bike Repair –Services that would allow a bicycle repair person to repair and/or tune upemployee bicycles onsite at least twice per month ifor when eligibleemployees sign up and agree to pay for said services.2MediumLowServices &FacilitiesOnsite ATM2MediumLowServices &FacilitiesOnsite vending machines2MediumLowServices &FacilitiesBike Racks –Racks and secure bike parking is provided to accommodate eligibleemployees who bike to work. The employer must provide secure bike parkingfor the foreseeable need of the bicycle commuters.2MediumLowServices &FacilitiesOnsite Health Facilities,or health facilities within1⁄4 mile of worksite –Services that provide first aid to eligible employees including, but not limitedto, first aid, onsite nurse, etc.2MediumLowServices &FacilitiesEmployer Provided Bicycles –Provided by the employer and made available for employee use during lunchand breaks.2MediumLowSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200927Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessServices &FacilitiesFitness Area and/or Classes onsite, orwithin 1⁄4 mile of worksite –Employer provided area to exerciseduring breaks or lunches. Examples mayinclude, but are not limited to:•Fitness area with exercise equipment available for employee use•Room designated for an exercise video or fitness instruction duringlunch at least once per week2MediumLowMarketingRideshare Flyer –A flyer that provides updates to eligible employees on alternative commutemodes and incentives offered by theemployer to encourage participation in arideshare program. The flyer would be one page and may include graphicsand short summaries to highlight program basics and updates. Must bedistributed at least quarterly to all eligible employees.1LowLowMarketingCEO Communication –Direct communication by the employer’s CEO to introduce alternativecommute modes, outline incentives, and encourage participation in arideshare program. This must occur, at a minimum, on an annual basis.Might occur as verbal orwritten communication.1LowLowMarketingEmployer-adopted policy statement supporting employee ridesharing andalternative transportation1LowLowMarketingRideshare Orientation for New Employees –Explanation of alternative transportation modes and employer incentives topromote and encourage participation in a rideshare program during theemployer’s regular orientations for new, eligible employees.1LowLowMarketingRideshare agency registration –Provide worksite information to a regional rideshare agencyand maintain orupdate information as appropriate and requestedby the regional agency1LowLowSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200928Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessServices &FacilitiesEmployer-Organized Lunch Delivery –Employer-organized lunch deliveryat least twice per month.1LowLowServices &FacilitiesCheck cashing1LowLowServices &FacilitiesDirect Deposit1LowLowServices &FacilitiesBreak and/or Lunch Activities –Employer-sanctioned or employer-promoted activities that may reduce theamount of eligible employees going offsite duringbreaks and/or lunches atleast two times per month. May include activities such as games, movies,etc.1LowLowServices &FacilitiesDry Cleaning –Onsite pick up and delivery through an outside agency.1LowLowServices &FacilitiesPostal Service, or post officewithin 1⁄4 mile of worksite –Stamps for sale onsite and onsite mailpick up for eligible employees’personal mail. Post office within 1⁄4 mile of worksite qualifies1LowLowServices &FacilitiesOnsite picnic tables1LowLowServices &FacilitiesMaps to local conveniencesEmployer-provided map and/or listing of stores, restaurants, etc. within walkingdistance of the worksite.1LowLowTrans., AltSchedules,andIncentivesPoints Program –Program where eligible employees earnpoints for each day of participation inthe trip reduction program. Points are redeemed for such rewards as time off,gift certificates, cash or merchandise.1LowLowSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Staff Report: Rule 9410December 17, 200929Final Staff Reportwith Appendices for Rule 9410Table 2: ETRIP measures, definitions, and points analysisStrategyETRIP measure and descriptionPointsEffort& CostEffective-nessTrans., AltSchedules,andIncentivesPreferential Parking –The employer provides preferentialparking spaces for use by eligibleemployees when they participated inridesharing. These spaces must beclearly posted or marked in a manner that identifies them for carpool orvanpool use only. Of all parking spacesavailable for any eligible employees(not including spaces reserved for management, visitors, or employer fleet),at least 5% should be permanently designated as carpool spaces.1LowLowTrans., AltSchedules,andIncentivesPrize Drawing –Eligible employees areprovided with a chance to win prizes, at leastquarterly, for participation inthe trip reduction program.1LowLowSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

30 Final Staff Report with Appendices for Rule 9410 Commute Verification Starting in the 2014 calendar year, employers w ould collect information on their eligible employees’ commute modes through Commute Ve rification. Results are informational, helping the employer and the District asse ss the ETRIP’s success in facilitating alternative transportation and ridesharing. T he data collected will al so be a measure of accountability to EPA, helping the District to verify emissions reductions. The Commute Verification process asks the employees how they commuted to work (i.e., drove to work alone, carpooled, bicycled, zero emissions vehicle, or public transit) each day for a typical workweek. The employer can implement Commute Verification one of two ways:

• In the first option, the employer distributes Mandatory Commute Verification Forms to all eligible em ployees. Employers can use Districtprovided templates and reporting options. Employers may be able to incorporate this into an existing proc ess, such as regular staff meetings, timesheets, or other employee form collection.

• In the second option, the employer may propose an alternative data collection approach to collect data from a representative sample of eligible employees. Employers would submit their methodologies to the District for approval at least 120 days prior to the start of the calendar year in

which the method would be used.

Employers would keep Commute Verification re cords on file for at least five years, making records available to the District or EPA upon request. Commute Verification results would be reported to the District by March 31 of every year, beginning in 2015. Figure 2 shows a sample Commute Verificati on form that employers could distribute to and collect from their employees.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

31 Final Staff Report with Appendices for Rule 9410 Figure 2: Commute Verification form

B. District Commitments in Draft Rule 9410

The District is committing to provide resources, templates, and trainings in the regulatory language of the rule to provide assurance to em ployers that the District will work to make ETRIPs and surveys as tu rnkey and successful as possible. These

commitments are summarized in Table 3.

C. Healthy Air Living

Healthy Air Living is the Air District’s ca mpaign to help Valley residents and businesses make air quality a priority in day-to-day decision making. The Healthy Air Living campaign has provided public education informing Valley residents and businesses alternative transportation possibilities and ways to reduce emissions. The Healthy Air Living initiative also offers tool kits to employers, including the Employee Trip Reduction

Resource Book ( www.healthyairliving.com/docs/ Trip%20Reduction%20Book.pdf ). The Healthy Air Living program will continue to se rve Valley residents. For more information,

visit healthyairliving.com/business.htm

.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

32 Final Staff Report with Appendices for Rule 9410 Healthy Air Living would be coupled with Rule 9410 as a compliance option and as a vehicle to provide turnkey program elements. Employers who elect to become Healthy Air Living Business Partners under the Dis trict’s revamped Part ners program would receive credit towards Rule 9410 compliance, and Partners would periodically receive sample newsletters, trainings, recognition, and other strategic s upport. In exchange,

Partners would commit to various outreach st rategies, such as distributing outreach materials to employees.

Table 3: Rule Compliance Support Materi als to be Provided by the District

District-provided Resource Corresponding Employer Requirement Deadline

District webpage and listserv

dedicated to Rule 9410 NA February 1, 2010

Employer Registration Template and online Registration option Section 6.1 February 1, 2010

Marketing and Program Support Strategies guidance and templates Marketing and Program Support Strategies,

Section 5.2 March 1, 2011

Marketing training sessions, organized and facilitated by the

District Marketing Strategy,

Section 5.2 First training to be held by April 1, 2011, with public noticing and outreach at least 30 days before the first training session

Services and Facilities guidance and resources Services and Facilities Strategy, Section 5.2 March 1, 2012

Transportation, Alternative

Schedules and Incentives Strategy guidance and

resources Transportation, Alternative

Schedules and Incentives Strategy, Section 5.2 March 1, 2013

Transportation, Alternative Schedules, and Incentives training sessions, organized and facilitated by the District Transportation, Alternative

Schedules and Incentives Strategy, Section 5.2 First training to be held by April 1, 2013, with public noticing and outreach at least 30 days before the first training session

Commute Verification Form templates and online reporting options Sections 6.4 and 6.5 September 1, 2013SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

33 Final Staff Report with Appendices for Rule 9410 IV. DISCUSSION

A. Regulations in other Ca lifornia Air Districts

South Coast Air Quality Management District adopted Rule 2202 On-Road Motor Vehicle Mitigation Options on December 8, 1995. South Coast Air Quality Management District Rule 2202 requires larger employer s (250 or more employees) to achieve annual emission reduction targets by paying into the Air Quality Investment Program, using mobile source Emission Reduction Cr edits, or implement ing Vehicle Miles Traveled (VMT) reduction programs, or a comb ination of these strategies. Employers can be exempted by achieving an employee av erage vehicle ridership of 1.3 to 1.75, depending on the employer’s loca tion in one of three zones.

Bay Area Air Quality Management District’s Ru le 1 Trip Reduction Requirements for Large Employers, under R egulation 13, was adopted in 1992 and vacated by SB 437 (Lewis) in 1996. This rule required employ ers with 100 or more employees to implement a trip reduction plan. Currently, Bay Area AQMD promotes voluntary employer based trip reduction programs through their Transporta tion Control Measures (TCMs) stated in the 2000 Clean Air Plan and updated in the 2005 Ozone Strategy. TCM 1 states that the Metropolitan Transportation Commission will continue to administer the regional ridesharing program funded by Bay Area AQMD’s Transportation Fund for Clean Air (TFCA). TFCA also funds TCM 13 Transit Us e Incentives providing 58 employers with monthly transit passes, TCM 14 Rideshare and Vanpool Services, and TCM 16 Intermittent Control Measure/Public Education Spare the Air Program which is currently partnered with 1, 021 employers.

Also in the Bay Area, the cities of San Francisco, Berkeley, and Richmond have city ordinances requiring employers with at leas t 20 employees to provide transportation benefit programs of employer- paid alternative transportation or pre-tax programs for

alternative commute modes.

B. Additional Resources

There is a multitude of em ployer based and regional pr ograms in and outside of California that provide services to reduce VMT and emissions. Though they have been successful, the efforts still remain voluntar y in nature and limited in scope. Mandatory trip reduction programs have the potential to provide wi despread change and achieve significant reductions in VMT. Employers may be able to partner with existing programs and services, or employers may be benefit from implementing programs similar to those that have already been shown to be successful.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

34 Final Staff Report with Appendices for Rule 9410 Best Workplaces for Commuters: Best Workplaces for Co mmuters is a nation-wide program dedicated to employer recogniti on and resources for commuter benefits. Applicants agree to offer a selection of commuter benefits and ensure a minimum level of employee participation. This program was created by the Center for Urban Transportation Research and the U.S. En vironmental Protection Agency. See www.bestworkplaces.org for more information. The San Joaquin Valley Air District applied for Best Workplaces for Commuters recognition in February 2009.

Valley Transit Services: Employers in some areas may be able to take advantage of

local transit services in their area. Tabl e 4 summarizes some of the major Valley bus
systems.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

35 Final Staff Report with Appendices for Rule 9410 Table 4: Valley Bus Information

City Bus System Fare Website Hours

Available Routes

Available

Online

Bakersfield GET (Golden Empire Transit) $0.90 www.getbus.org/ 6:00am10:45pm Yes

Clovis Stageline and

FAX Route 28 $1 www.cityofclovis.com/UMAP.asp?FolderID

=249 6:00am8:25pm Yes

Fresno FAX (Fresno Area Express) $1 www.fresno.gov/DiscoverFresno/ PublicTransportation/default.htm 5:30am10:00pm Yes

Hanford KART (Kings Area Rural Transit) $1 www.kartaits.com/karthome.htm 5:50am11:00pm Yes

Lodi Grape Line $1 www.lodi.gov/transit/introductions.html 6:00am7:00pm Yes

Madera MAX (Madera Area Express) $0.75 www.maderactc.org/pubtrans.html 7:00am6:30pm Yes

Manteca Manteca Transit $1 www.ci.manteca.ca.us/mantecatransit/gen

eral.htm 6:00am7:00pm Yes

Merced The BUS $1 www.mercedthebus.com/index.html 7:00am6:00pm Yes

Modesto MAX (Modesto Area Express) $1.25 www.modestoareaexpress.com/

default.htm 6:30am6:00pm Yes

Porterville Porterville Transit $1 www.portervilletransit.org/ 7:00am7:00pm Yes

Stockton RTD (Regional Transit District) $1.50 www.sanjoaquinrtd.com/Default.htm 6:00am10:45pm Yes

Tracy Tracer $1 www.mvtransit.com/Tracer_home.htm 7:00am7:00pm Yes

Turlock BLAST (Bus Line Service of Turlock) $1.25 www.ci.turlock.ca.us/citydepartments/ developmentservices/transitservices/blastb

us/ 5:35am6:15pm Yes

Visalia VCC (Visalia City Coach) $1 www.ci.visalia.ca.us/depts/transit/ visalia_city_coach_(vcc)/default.asp 6:00am9:30pm YesSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

36 Final Staff Report with Appendices for Rule 9410 Resources for Ridesharing There are many programs operating regio nally throughout California to provide alternative transportation services such as ride matching, co mmute calculators, employer resources, incentives and discounts and Guaranteed Ride Home services. Though it is not nearly exhaustive, the following list is of a few notable programs in the San Joaquin Valley:

• Commute Connection ( www.commuteconnection.com ) is a regional rideshare program operated by the San Joaquin Council of Govern ments, in partnership

with Stanislaus Council of Government s, and helps commuters find suitable alternative transportation options. The pr ogram includes free services such as

commuter ride matching , Guaranteed Ride Home and employer assistance, while raising public awareness about the connection between transportation choices, air quality, and traffic congestion. Commute Connection currently serves almost 10,000 commuters in San Joaquin, Stanislaus, Calaveras and Tuolumne

Counties.

• Kings County Area Public Transit Agency ( www.kartaits.com ) sponsors two programs that serve Kings County as well as other surrounding communities. Kings Area Rural Transit (KART) is Kings County's complete public rural and urban transportation provider. KART provides service within the Downtown areas

of Hanford and Lemoore and regular route service between Hanford and the cities and communities of Armona, Av enal, Corcoran, Fresno, Grangeville, Hardwick, Kettleman City, Laton, Lemoore, Stratford, and Visalia. The AITS program is a vanpool program, also s ponsored by Kings County Area Public Transit Agency, which provides agricult ural workers in Kings, Tulare and Fresno Counties with safe, affordable vans they can use to drive themselves and others to work. AITS offers start-up grants to purchase the vans, and riders pay only a

nominal fee to cover the co st to operate, maintain a nd insure the vehicle. The vans are also each equipped with a Global Po sitioning System, fi rst aid kits, fire extinguishers and roadside safety items.

• Kern Commuter Connection ( www.commutekern.org ) serves Kern County offering information on carpooling, vanpool ing and other modes of alternative transportation as well as air quality and road information and employer

resources.

• Merced Rides ( www.mercedrides.com ) serves Merced C ounty with information on transit, ridesharing, and the “Car-less Commute” program.

• South Valley Rideshare ( www.southvalleyrideshare.com ) is an innovation of Visalia City Coach in collaboration with the Kings County Area Public Transit Agency serving Madera, Fresno, Kings, Tulare, and Kern Counties. The website provides listings of open carpools and vanpools and provides other transit

information.

• Valley Rides ( www.valleyrides.com ) is a cooperative effort between California State University Fresno and the Council of Fresno County Governments servingSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

37 Final Staff Report with Appendices for Rule 9410 the Central Valley students and businesses. Valley Rides offers information on park and ride lots in the area and carpooling tips.

C. Successes

Successes in Ridesharing The following worksites have successfully inco rporated carpooling, vanpooling, or other mass transit options in their trip reduction efforts:

• The San Joaquin Valley Air District curr ently operates a vol untary Alternative Transportation Incentive Program for it s employees. This program provides monetary incentives and preferential parking for t hose employees who use alternative modes of transportation, such as carpooling, biking, and public transit

for at least 60% of commu tes to and from work. Cu rrently, this program has about 37% participation and has been a role model for the Valley.

• Paramount Farms in Northwestern Ke rn County operate employee vanpools for its sites in Lost Hills and Kings County.

• Pelco in Fresno has a wide variety of employee focused programs that reduce vehicle miles travelled, including bike to work and bus incentives.

• IKEA Wholesale in Bakersfield partic ipates in and encourages carpooling and other alternative transportation with subsidies and competitions between employees.

• Tejon Ranch is implementing a vanpool to serve the many employees at IKEA and Tejon Industrial Complex.

• Diamond Foods in Fowler are in the process of getting bus service to their site and will provide a bus schedule to all employees.

• Frito-Lay is establishing a rideshare program at the worksi tes in Crows Landing and Bakersfield to help reduce vehicle trips.

• Cal State University Bakersfield encourages student use of busses by subsidizing bus passes, and by sponsori ng an Alternative Transportation Day. They are also exploring ways to get more people involved such as incentivizing alternative transportation with gift drawings.

• Chevron facilities in Fresno operate vanpools to outlying field areas.

• Aera Energy operates vanpools from the offices in Bakersfield.

• Dreyers Ice Cream in Bakersfield encour ages their employees to walk, bike, and carpool to work.

Successes in Services and Facilities Onsite facilities and services make choosing alternative transportation more convenient. Programs currently in place that offer additional services to employees as a part of their trip reduction efforts include:

• The District offers its employees various facilities like showers and lockers, bike racks, bikes available for break and l unchtime use, lunch activities, postalSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

38 Final Staff Report with Appendices for Rule 9410 services, order in lunches, and dry cleaning pickup and delivery. These additional services help reduce vehicle trips at lunch and for running errands, especially complementing those who do commute alternatively.

• Paramount Farms has a cafeteria in the Lost Hills facility to keep employees from commuting offsite for meals.

• Pelco has an onsite food service, pos tal services, and dry cleaning service helping to decrease additional trips employees need to make.

• IKEA contracts with a catering service to keep employees on site for meals.

• CSUB offers many internet classes and has dining facilities, postage facilities, and provides daycare for students and staff.

• The Chevron facility has a gym on site, provides lunch service, postal service, and bicycle storage.

• Aera Energy also has a gym on site, ATM, and provides lunch service for employees.

Successes in Alternative Work Schedules and Telecommuting Many employers utilize flexible schedules and telecommuting to help reduce vehicle trips, congestion, and pollution:

• The District has implemented flexible work schedules and telecommuting to reduce vehicle trips to and from work and meetings. The District’s flexible work schedule consists of working 9 days out of a two week period but still achieving 80 hours (9/80 schedule). This is done by working 9 hours a day Monday through Thursday and then 8 hours on the working Friday and then off on the second Friday therefore reducing a day of commuting to work.

• Paramount Farms saves travel with teleconferencing between offices in Lost Hills and Santa Monica, and allows employee telecommuting.

• Pelco allows flex work schedules to better suit employees.

• IKEA has a telecommuting program that a llows some job classifications to work

from home.

• Chevron also operates on a 9/80 schedul e to help reduce vehicle trips.

• Aera Energy operates on a 9/80 schedule in addition to their other trip reduction

efforts.

• Dreyers utilizes video-conferencing and te lecommuting to cut down on travel.

D. Benefits of a Trip Reduction Program

The Employer Based Trip Reduction program is part of the District’s strategy for bringing the San Joaquin Valley Air Basi n into attainment of EPA’s health-based air quality standards for PM2.5 and 8-hour ozone. A majority of the Valley’s NOx emissions come from mobile sources, and these emissions contribute to both ozone and PM concentrations. Employer based trip reduction programs c an provide a step inSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

39 Final Staff Report with Appendices for Rule 9410 reducing vehicle trips in the Valley to r educe mobile source emissions and improve air quality.

California Senate Bill 375 The District’s Employer Based Trip Reduction rule can also reduce GHG emissions and help the Valley comply with California Senate Bill (SB) 375. U nder SB 375, approved on August 22, 2008 and codified in the Calif ornia Government Code and Public Resources Code, metropolitan planning organizations (MPOs) must adopt a

Sustainable Communities Strat egy as part of their regional transportation plans. SB 375 links regional planning to Assembly Bill (AB) 32, which requires the State of California to reduce greenhouse gas (GHG) emissions to 1990 levels no later than 2020. Under SB 375, ARB will provide MPOs with GHG emission reduction targets. The MPOs will then incorporat e strategies like better use of mass transit and bicycle

lanes as well as mixed-use or denser devel opment practices into their Sustainable Communities Strategies to reduce GHG em issions. This effort and the District’s Employer Based Trip Reduction are comple mentary programs, incorporating similar strategies to achieve separate goals.

Additional Benefits Workplace trip reduction programs can hav e a wide range of benefits, depending on how programs are implemented, and the benefits can affect multiple parties. Table 5 summarizes some of the potential benef its of trip reduction programs.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

40 Final Staff Report with Appendices for Rule 9410 Table 5: Possible Benefits of a Trip Reduction Program

Benefits Employee Employer Community Decrease parking fees and costs D D Expanded employee benefit s at low/no cost D D

Lower absenteeism and tardiness D D Increased employment opportunities for

disabled and others unable to meet

traditional work hours D D

Enhanced employee productivity through teleconferencing and telework options D D

Increase in transport options D D Increase road safety D D Save money on gas and insurance D

Decrease vehicle wear and tear D Boost mental health by decreasing stress from driving and traffic D

Relieve overcrowded parking areas D

Reduced overhead costs such as office space requirements if telecommuting D

Tax Benefits D Enhanced employee recruitment and

retention D

Expanded service hours if changes made to

work hour schedules D

Reducing road and parking facility requirements D

Decrease congestion D Improve air quality D

Reduce road and traffic service costs D

More efficient land use D Community livability DSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

41 Final Staff Report with Appendices for Rule 9410 E. Conjunction with Other District Programs

The District has programs already in plac e that reduce emissions from mobile sources. One example is the District's H ealthy Air Living program, discussed earlier in this staff report. Since reductions achieved through Healthy Air Livi ng are voluntary, the District does not quantify or credit these reductions in the attainment planning process. In contrast, the Dis trict's Indirect Source Review (ISR) program, Rule 9510, is a quantifiable and creditable mechanism for reducing mobile source emissions, specifically those associat ed with new development. New development can increase emissions both during construction and after, when increased vehicle traffic to and from the development increases an area's VMT. ISR requires developers of larger
residential, commercial, and indus trial projects to reduce emi ssions indirectly generated by their projects through ei ther onsite measures (like siting near transit or retail services) or through off-site measures. Fo r off-site measures, the developer pays an off-site mitigation fee to the District, and then those funds are used in the District's existing grant programs to fund emissions reductions projects.

Some of the mobile source reductions obtained through the Dis trict's Emissions Reduction Incentive Program (ERIP) are a result of ISR funds, and some funding comes

from other sources. ERIP provides a variety of financia l incentives and grants for projects that reduce air pollut ant emissions from mobile or non-mobile sources. Some ERIP projects that reduce emissions from mobile sources include subsidized van pools. The District has also awarded a gr ant to the Visalia City Coac h that subsidizes the cost of monthly transit passes (called "Hop Pass"), providing a discount for new bus commuters for up to six months.

Rule 9410 provides another important opportunity for the District to help the Valley achieve additional, much-needed mobile source emissions reductions. While Employer Based Trip Reduction has potential to reac h a different and larger target group of commuters than those reached through ISR and ERIP, it is possible that some employees will be reducing trips by utilizing programs and services put in place through

ISR and ERIP. The District must not coun t the same emissions reductions in two different programs.

Through ERIP record keeping, the District maintains information on vanpool ridership and transit pass subsidies. The District will compare this to information collected through Rule 9410 record keeping to prevent double counting of emissions reductions. At this time, the District expects the only a very small percentage of those participating in Employer Based Trip Reduction will also receive District transportation subsidies.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

42 Final Staff Report with Appendices for Rule 9410 IV. EMISSIONS REDUCTION ESTIMATE

District staff has estimated the potential emissions reduction to be achieved from implementing the proposed Rule 9410. Please refer to Appen dix B of this staff report for the analysis and detail on the emissions reduction estimate.

V. ECONOMIC ANALYSIS

Pursuant to H&SC 40728.5, District sta ff has prepared a cost effectiveness and socioeconomic analysis to analyze the economic feasibility of the proposed rule. See Appendices C and D of this Staff Report.

VI. ENVIRONMENTAL IMPACTS

Pursuant to Section 15061 of the California Environmental Quality Act (CEQA), staff has investigated the possible environmental im pacts of the propos ed amendments to Rule 9410 and prepared an Initial Study. Based on the lack of evidence to the contrary, staff has concluded that the proposed amendments to the rules wi ll not have any significant

adverse effects on the environm ent. Staff recommends fili ng a Notice of Exemption under the provisions of Public Resource Code 15061 (b)(3).

VII. RULE CONSISTENCY ANALYSIS

Before adopting, amending, or repealing a rule or regulation, an air dist rict must identify and evaluate any existing federal rules or rules within that air distri ct that apply to the same equipment or source ty pe (California Health and Safe ty Code Section 40727.2). Elements of review include work practice, re porting, and recordkeep ing requirements. Through Rule 9410, employers will put measures in place that facilitate ridesharing and alternative transportation. Employers will al so Commute Verification Forms collecting information on employee commute modes. T here are no existing f ederal or District regulations that apply to empl oyee commutes. Therefore, adoption of Rule 9410 would not conflict with any existing federal or District requirements.

VIII

. REASONABLY AVAILABLE CONTROL TECHNIQUES (RACT) ANALYSIS

Clean Air Act Section 182(b)(2) states that ozone attainment plans shall assure that RACT for VOC is applied at major stationar y sources and on any source category for

which the US EPA has issued a Control Techni que Guideline (CTG). Section 182(f) of the CAA extends federal RACT requirement s to NOx, both for CTG categories andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

43 Final Staff Report with Appendices for Rule 9410 major stationary sources. Although Rule 9410 represents a very progressive and innovative emission control measure, District staff believes that it is not subject to federal RACT requirements for two main r easons. First, employee commute trips are not covered by any EPA-issued CTG. Sec ond, the rule does not address emissions under the direct control of any stationary source, whether major or minor. Rule 9410 merely requires employers to establish prog rams to encourage their employees to use alternative transportation. As such, District staff concludes that a RACT analysis is not appropriate or necessary.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 9410 December 17, 2009

44 Final Staff Report with Appendices for Rule 9410 IX. REFERENCES 1. San Joaquin Valley APCD. 2007 Ozone Plan . April 30, 2007. 2. San Joaquin Valley APCD. 2008 PM2.5 Plan . April 30, 2008. 3. SJVAPCD Healthy Air Living Business Page www.healthyairliving.com/business.htm 4. SJVAPCD HAL Employee Trip Reduction Resource Book http://www.healthyairliving.com/ docs/Trip%20Reduction%20Book.pdf 5. U.S. Department of Transportation and F ederal Highway Administration. “Summary of Travel Trends: 2001 National Household Travel Survey”. December, 2004.

6. SJVAPCD Alternative Trans portation Incentive Program 7. Employment Development Department, Labor Market Information Division. Third Quarter, 2007. http://www.labormarketinfo.edd.ca.gov/?pageid=138 8. Bay Area AQMD. “Regulatio n 13 - Transportation Control Measures. Rule 1 - Trip Reduction Requirements for Large Employers”. Adopted December 16, 1992. Suspended by the CA Legi slature January 1, 1996. 9. Bay Area AQMD. “2005 Oz one Strategy”. January 4, 2006.
10. South Coast AQMD. “Rule 2202. On -Road Motor Vehicle Mi tigation Options” and “Employee Commute Reduction Program Guidelines”. February 6, 2004.

11. Commute Connection www.commuteconnection.com 12. South Valley Rideshare www.southvalleyrideshare.com

13. Commute Kern http://commutekern.org/ 14. Valley Rides for Central California www.valleyrides.com 15. Best Workplaces For Commuters www.bestworkplaces.org/index.htm

16. Kern Commuter Connection commutekern.org/index.html

17. Merced Rides www.mercedrides.com 18. Kings County Area Public Transit Agency www.kartaits.com 19. Victoria Transport Policy Institute. “T ravel Impacts”, TDM Encyclopedia: Commute Trip Reduction Programs That Encourage Employees to Use Efficient Commute Options, 2009. 20. U.S. DOT FTA and FHWA, U.S. EPA. “Summary of Choices – What works?”,

Commuter Choice Primer. 21. U.S. DOT FHWA. “Employer-Based TDM Programs”, Multi-Po llutant Emissions Benefits of Transportation Strategies, 2006. 22. U.S. EPA, Commuter Model, http://www.epa.gov/oms/statere sources/policy/pag_transp.htm 23. U.S. DOT, Commuter Choi ce Decision Support Tool, http://ops.fhwa.dot.gov/Prime rDSS/guidancetool/step1.htm?i = 24. Best Workplaces for Commute rs, Business Savings Calculator, http://www.bestworkplaces.org/?page_id=28SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-1 APPENDIX A

Public CommentsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-3 Written Comments on the Draft Staff Report for Rule 9410

Comment period held from October 26 through November 4, 2009.

Comments were received from the following people and organizations:

Bolthouse Farms (Bolthouse) California League of Food Processors and the Manufacturers Council of the Central Valley (CLFP/MCCV) City of Clovis (Clovis) City of Fresno Department of Public Utilities, Wastewater Management Division (FWMD) Coalition for Clean Air (CCA) Hospital Council of Northern and Central California (HCNCC) Kern County Department of Human Services (Kern DHS) Modesto Irrigation District (MID) Rain for Rent (RFR) Turlock Irrigation District (TID)

General

1. Comment: We do not see the need for the formal oversight, inspections, and possible fines for this ru le, particularly when employers may already have many program options in place. (Bolthouse) Response: The formality and reporting of the rule are important for verifying emissions reductions needed for the Valley’s significant attainment challenges. The District will be making a variety of templates, resources, and trainings available as the rule is implemented to assist employers. For employers that already have programs in place, the addition al efforts required fo r this rule should

be minimal.

2. Comment: You have no jurisdiction or authority to control or regulate travel. We

will not be forced to limit the freedom of travel our employees enjoy. (RFR) Response: The District will not be regulating indivi duals’ travel in this rule. The District’s authority for this rule comes California Health and Safety Code (H&SC)

Sections 40601 and 40612 as well as feder al Clean Air Act Section 182(d)(1)(B).

3. Comment: We appreciate the District’s approach of not imposing a one-sizefits-all program, and we appreciate the c hanges that have been made in the rule so far. (MID, TID) Response: Comment noted.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-4 4. Comment: According to the San Joaquin Valley Express Transit Study, many of the services necessary for trip reduction ar e not currently available in the Valley.

It is also clear that the MPOs view this rule as a source of funding. (CLFP/MCCV) Response: Available services will vary between worksites, and more services may become available as the rule is implemented. The ETRIP menu options provide a sufficient variety of measures for successful trip reduction programs for
all worksites, based on the services ava ilable for those sites. Generally, MPOs offer ride matching and other resources at no cost.

5. Comment: The District should consider a specif ic and unique set of guidelines for hospitals and other employers that se rve the public safety and well-being. Hospitals are 24/7/365 operations that cannot easily postpones products or services to accommodate ridesharing. (HCNCC) Response: In consideration for the public he alth benefits of Rule 9410, hospitals can be important partners in this effort . To determine whether a hospital is subject to Rule 9410, the hospital woul d exclude from their eligible employee count any part time employee, on-ca ll employees, and employees who do not

start work between 6 AM and 10 AM. As with other employers, no hospital employees will be forced to use rideshar ing or alternative transportation, and those employees with more predictable shi fts would be the most likely employees to use ridesharing and alternative transporta tion. Many hospitals will likely find that they have many ETRIP measures al ready in place, such as on-site food service and compressed work weeks.

Excluded Employees

6. Comment: The home garage definition should include employees who receive a vehicle allowance for use of their privat e vehicle for business purposes in lieu of being provided an employer-owned vehicl e. (Clovis) The number of home garage employees may change from day to day, so not all employees take home an employer-owned vehicle every day. (TID) Response: Home garage employees are ex cluded from the rule due to the potential liabilities associated with an em ployer-owned vehicle; however, these liabilities are not an issue in a pers onal vehicle that may be subject to an employer vehicle allowance. In cases where the num ber of home garage employees change from day to day, the employer should use an average for the

work week.

7. Comment: Employees already established in a compressed work week schedule or ride-sharing program should be excluded. (FWMD) Response: For reporting purposes and fo r simplicity of employer implementation, these empl oyees are not excluded from the rule. Through thisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-5 rule, it is expected that more employ ees will be established in compressed work week schedules or ride-sharing programs.

8. Comment: Employees traveling from rural, isolated areas and whose facility is in a rural area which requires a travel distance of six miles or more one-way should be excluded. (FWMD) Response: Employees who travel longer di stances from work may be able to carpool with coworkers who live closer to work, picking them up on the way. Employees who travel longer distances to work may be good candidates for vanpooling or telecommuting, dependi ng on the work environment.

9. Comment: Employees whose scheduled work week includes Saturdays and Sundays should be excluded. (FWMD) Response: Employees who do not report to work during the peak period are excluded employees in Rule 9410. The “p eak period” is defined as 6 AM to 10 AM Monday through Friday. Therefore, shifts worked on Saturdays and Sundays are not considered as the employer dete rmines whether they are subject to the rule. However, employees who may work on Saturdays and Sundays are counted as eligible employees for shifts worked during the peak period.

10. Comment: Employees who are on-call/stand- by 24/7 should be excluded. (FWMD) Many of our employees are emergency responders that must sometimes deal with unanticipated situati ons and work unexpected hours. (MID) Response: The rule has been revised to include a definition for on-call employees, with these employees excluded from the rule if the definition is met.

11. Comment: The definition of field employees is a concern for us. Many of our employees do not meet this definition because, although they spend less than

20% of their time at the central work locati on, they report at the central location at the beginning and end of t he work day to pick up and return an employerprovided vehicle and other supplies. M any of these employees may have to work overtime or be on-call, so their shift may be unpredictable. (TID, MID) Many ETRIP measures would not be av ailable to field employees. (MID) Response: Employers should keep their off-site employees in mind in selecting

ETRIP measures. While some ETRIP m easures would not be available, they may not relate to issues of concern for off-site employees. For example, these employees may not be as likely to ta ke advantage of onsite food service, but because they may be able to stop for food in their work vehicle, access to food is not an impediment to ridesharing and alte rnative transportation. No employee will be forced to use ridesharing or alter native transportation. Employees with more predictable schedules or with schedul es similar to coworkers will be the most likely to use ridesharing or alternative transportation.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-6 12. Comment: The definition of emergency per sonnel should be expanded to include patient care providers in hospital s. Trip reduction rules and programs should distinguish between direct patient care providers (who often have varying and unpredictable shifts or may have to be on-call) and administrative staff show work more “traditional” hours. (HCNCC) Response: Employees with predictable schedules will be the most likely to use ridesharing or alternative transportation. Many direct care providers may have

routine schedules. On-call staff have been defined in the revised rule and are

included in the definitio n of excluded employees.

13. Comment: The rule should include a provis ion that would waive Rule 9410 provisions for hospitals for times of disasters. (HCNCC) Response: Most ETRIP measures remain in place once implemented and would not be impacted by disast er situations. Many othe r rule elements (such as the commute verification process, rides hare newsletters, employer rideshare events, etc) have flexibility to allow t he employer to decide the best time for implementation, so employers can work around times of disasters, busier work product times, and other situations.

ETRIP measures

14. Comment: Compressed work weeks cannot be appl ied to all of our employees

due to the nature of our work. (FWMD) Response: There are several levels of points and participation for the compressed work week ETRIP measure so employers can receive points according to their ability to implement the measure. District staff understands that compressed work weeks will not work for all employers.

15. Comment: We would like to see more flexibilit y in Phase 3, as these measures can be very challenging for employers (TID). Response: A degree of additional flexibility is being incorporated into Phase 3 for Tier Two Worksites in the Proposed Rule 9410; the Distr ict has slightly lowered the point target for “Trans portation, Alternative Schedules, and

Incentives” but increased the “Additional Po ints Needed” so that the total ETRIP points stays the same but employers hav e more choices on which strategy to emphasize. Phase 3 measures are important because they can increase employee participation in alternat ive transportation and ridesharing.

16. Comment: Monetary incentives c an be problematic for a public utility. (TID) Response: Monetary incentiv es are part of employee compensation. Employers can still attain enough ETRI P points while deemphasizing monetary incentives by prioritizing other measures.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-7 17. Comment: Contract negotiations with unions di ctate terms and conditions for employment. (TID) Response: ETRIP measures that may be subj ect to contract negotiations have been phased in for the 2013 ETRIP submi ttal with implementation by 2014. Employers therefore have a few year s to introduce ETRIP measures into negotiations.

18. Comment: Compressed work week and telecommu ting are options for many of our staff, but not at the percentages s pecified in the ETRIP measures. These measures might be modified to base percentages on eligible employees not including field staff. (TID) Response: The Proposed Rule now excludes fi eld staff from the telecommuting measure. Field staff may still be eligib le for compressed work weeks, depending

on the nature of their work.

19. Comment: Employer-imposed requirements for employees to live within a set, short distance from work could be an ETRIP measure. (MID) Response: This would not be a reasonable op tion for the majo rity of Valley employers. An employer may include an option like this as part of “Other measures approved by the District” if it will ensure alternative transportation or ridesharing.

20. Comment: Can the “rideshare newsletter” be an existing/general employee

newsletter that includes a rideshare section that advises staff of resources and rideshare events? (Kern DHS) Response: Yes.

21. Comment: For the Preferential Parking meas ures, the 5% requirement for carpool spaces might be too high when parking is at a premium and the spaces might not be used. (Kern DHS) Response: The 5% minimum helps increase t he visibility of the ridesharing option and creates a desirable incentive to those who carpool. Employers who decide that 5% is too high can elect not to use the preferential parking ETRIP measure. These employers may find it beneficial to start with a lower number of carpool spaces and gradually increase t he number as these spaces are used.

22. Comment: Comment: The number of available ETRIP options in a manufacturing environment is very limited. Consequently, we believe that manufacturing facilities, as previously defined be required to comply with the Phase 1 and Phase 2 point totals only. (CLFP/MCCV) Response: To increase flexibility, the “Tr ansportation, Alternative Schedules, and Incentives Strategy” point target fo r Tier Two worksites has also beenSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-8 decreased with the Additional Points needed increasing to allow for more flexibility in the ETRIP options.

23. Comment: Many of the Phase III transpor tation and alternative schedule measures are incongruous with a manuf acturing work environment and with union negotiations. First, the union focu ses on compensation increases that benefit every member of the group and subsidies or ince ntives that will only be paid to participating employees will not effectively represent their entire constituency. Incentives or subsidies may also increase union dues since fees are established based on the wages of union members. Second, some manufacturers are governed by labor contracts that are mu lti-state or national in scope. The only clear exceptions to this during contract negotiations on national contracts are specific to State Wage and Hour Laws, and these exceptions would then apply to every site within that state, not just one site located in the San Joaquin Valley. (CLFP/MCCV) Response: Provisions have been added to the Telecommuting, Flex Schedule and Compressed Work Week schedule measures so that points can be awarded when offered to workers not on a producti on line. See also Comment 22.

24. Comment: There may some manufacturing em ployers who cannot attain the requisite points in the Program Support Strategy. (CLFP/MCCV) Response: The District modified the Progr am Support Strategy to include separate points available for offering In ternal Guaranteed Ride Home Service to production line workers and other workers su ch as office staff, due to the legal and practical challenges in manufacturing facilities.

25. Comment: An employer/worksite should be allowed to utilize points from other strategies to make up a deficit in another category. (CLFP/MCCV) Response: The minimum point target in each st rategy was set so that employers implement a comprehensive trip reduction program and the additional points needed foster flexibility to offer more options in the employer’s strategy of choice.

Other Definitions

26. Comment: Manufacturing line workers should reflect the definition in the Industrial Welfare Commission Wage Orders 1

‐ 2001, Manufacturing Industry;

3

‐ 2001; 3

‐ 2001, Canning, Freezing, and Preserving Industry; and/or 8

‐ 2001, Industries Handling Products After Harves t. The IWC wage order definitions are legally recognized and most precisely categorize the manufacturing sector. (CLFP, MCCV) Response: The Proposed Rule includes a defi nition for Production Line Worker that incorporates the IWC wage orders.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-9 27. Comment: The rule should define a “standard work week” as Monday through Friday. The “standard reporting to work ti me” should be included in the rule and defined as 6 am to 10 am. (FWMD) Response: “Peak period” is defined in Section 3. 0 of the rule as 6 AM to 10 AM Monday through Friday.

Survey

28. Comment: Survey requirements are cumberso me and impractical (Bolthouse). Response: P eriodic data collection on empl oyee commute modes are crucial demonstrations of accountability that c an help the Valley avoid more stringent ridesharing mandates. Proposed Rule 9410 shifts away from the “survey” concept and reframes commute data colle ction as “Commute Verification” to communicate the importance of this data. The Proposed Rule also reflects a change in frequency and return rates for data collection. The current approach is simple, straight forward, and keeps t he administrative burden at a minimum.

29. Comment: The 90% survey response rate is unrealistic and creates an undue administrative tracking burden. (Clovis, CLFP/MCCV, TID, MID, Kern DHS) A 50% response rate is more realistic and should provide a sufficient amount of

data for the District to infer emissions reductions. Additional ETRIP points could be awarded to employers who ac hieve higher return rates. (Clovis) The District would refrain from setting a minimum at th is time and, instead, see what survey response rates are like for the first year of surveys and set a survey return rate requirement based on the first year. (TID) Response: See Comment 28. The Proposed Rule includes two ways for the employer to implement Commute Verificati on. In the first option, the employer

distributes Commute Verifica tion Forms to all eligible employees. Employers can use District-provided templates and reporti ng options. Employers may be able to incorporate this into an existing proc ess, such as regular staff meetings, timesheets, or other employee form colle ction. In the second option, the employer may propose an alternative dat a collection approach to collect data from a representative sample of eligible employees. Employers would submit their methodologies to the District for appr oval at least 120 days prior to the start of the calendar year in which the method would be used.

30. Comment: Requiring additional surveys for em ployers who do not achieve the 90% survey return rate adds unnecessa ry administrative burdens. (Clovis, CLFP/MCCV) It is likely that the same people will be responding each time, and with repeated surveys, they may stop responding. We don’t think repeated surveys will give the District accu rate information. (TID, MID) Response: See Comments 28 and 29.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-10 31. Comment: A baseline survey should be required prior to the implementation of any of the rules requirements. This will allow the Air District to gauge improvements once the rule implementation begins. (CCA) Response: Requiring a baseline survey w ould increase compliance costs. Valley-specific data collect ed by the U.S. Census Bureau in 2006-2008 (part of the “American Community Survey”) est ablishes an appropriate baseline from which to evaluate changes in commute behaviors and emissions reductions. Prioritizing the ETRIP early in implement ation also allows employers to focus their implementation efforts on the actions that can facilitate commute changes. Implementing Commute Verifi cation after the full ETRIP is put into place gives

ETRIP measures a chance to work.

32. Comment: Requiring multiple surveys each year would improve representativeness of the data. Requiring additional surveys only when survey response is limited, is an im provement from previous dr afts but still does not do enough to gather useful data nor to disc ourage possible gaming of the survey mechanism. (CCA) Response: Commute verification would be based on a five-day work week. The District estimates that about 500,000 employ ees in the Valley would be eligible employees subject to Commute Veri fication. Thus, Proposed Rule 9410 generates about 2.5 million data points every year, a vast amount of data that should be sufficient to verify emission reductions. Requiring additional data collection would increase complianc e time and costs without necessarily improving the representativenes s of data. Because compliance with the rule is not based on the number of employees who participate in ridesharing and alternative transportation, and because empl oyers are required to save survey records for at least five years for possible APCO requests, there should be no incentive or motivation for manipulating t he integrity of the Commute Verification

forms.

Cost

33. Comment: We think we will have to hire someone dedicated to ensuring Rule 9410 compliance (Bolthouse). Response: Hiring a full time staff person ded icated to Rule 9410 would be excessive for the vast majority of em ployers. The District will be providing templates, trainings, guidance documents, and other tools to minimize the administrative burdens of Rule 9410 as much as possible. Although some ETRIP measures will require some effort when they are initially put into place, many require little to no ongoi ng effort. Employers may be able to delegate Rule 9410 tasks among several existing staff to minimize the burden on any oneSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-11 person. Alternatively, employers may find that an intern or temporary staff person may be able to help put Rule 94 10 measures and efforts in place.

34. Comment: As written, Rule 9410 does not look “low or no cost.” (Bolthouse)

The costs associated with this rule ar e a burden in an the already-challenging economy. (RFR, Clovis) The rule will r equire diverting already scarce internal resources. (HCNCC) Response: See Comment 33.

35. Comment: We do not want to pay more ta xes to support excess government spending. (RFR) Response: There are no fees paid to the Distr ict to comply with Rule 9410.

36. Comment: The District should do modeling of how these rules will impact specific sub-sets of employers, including hospitals. (HCNCC) Response: Please refer to the Socioeconomic Analysis in Appendix C of the Staff Report.

Cost Effectiveness and Socioeconomic Analysis

37. Comment: We believe the District has signifi cantly underestimated the costs

associated with this Rule. Data from our members indicate a cost ranging from $49,007 per ton to $74,194 per ton, fa r above the $25,000 cost effectiveness

threshold and of that estimated in t he staff report. The District underestimates the average hourly rate and the amount of time it will take to administer the program. Another gross underestimation is the average rate of pay for the policy

review and administration of the program. Local industry averages validate that these assumptions are off as much as $19 per hour. Also, while the current worksheet does account for employee labor to fill out the survey, it does not

include the cost of lost production hours which our member companies factor into

their cost vs. return models. (CLFP/MCCV) Response: The District used a Valley-wide aver age hourly rate (including benefits) calculated from the Employm ent Development Department (EDD). The

District based time estimates on the Distr ict’s in-house programs, and these are considered reasonable in light of the re sources the District will provide employers

to reduce administrative time and co sts. The amount of time needed for employees to complete Commute Veri fication should be minimal and should not result in significant lost production ti me. The District recommends that employers choose the least time consuming manner to administer Commute Verification. Employers may be able to incorporate this into an existing process, such as regular staff meetings, timesheets, or other employee form collection.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-12 38. Comment: Why did the District use employm ent data from just one quarter rather than an average based on several ye ars of data? Using third quarter data may skew the data due to seasonal food processing employment. (CLFP/MCCV) Response: Employment data from one quarte r was used because it was the most specific information available, pr oviding the number of employees broken down by employer size. It was also the mo st recent information available at that

time which would reflect the current economic situation.

39. Comment: How did the District derive that 36 .27 percent of Valley employees

work at sites with more t han 100 employees? (CLFP/MCCV) Response: The EDD data was used to tota l the number of employees at worksites with more than 100 employees and then adjusted to account for possible excluded employees and exempt sites.

40. Comment: According to the San Joaqui n Valley Express Transit Study, approximately 25 percent of the Valley workforce al ready commutes to work using some means other than a single pa ssenger vehicle. Was this taken into account? (CLFP/MCCV) Response: The District was unable to find this particular statistic in the document cited by the co mmenter. However, calc ulations based on 2006-2008 Census data for the eight counties in the San Joaquin Valley support 22% of Valley employees use alternative transpor tation. Though this percentage is close to that cited by the commenter, it is not representative of the employees subject to Rule 9410. The census data includes the large number of employees in the agricultural sector participating in su ccessful carpool and vanpool programs, many of which are exempt from this rule. Therefore, t he given percentage was

not used to calculate baseline emissions.

41. Comment: On page C

‐ 7 of the October 21, 2009 sta ff report, the total number of eligible employees is listed as 390,650 (Table C

‐ 4). How was this number derived? Why didn’t the District use this fi gure to estimate total NOx emissions reduction potential—it would reduce the estimate by about 23 percent and significantly decreases the cost e ffectiveness of the Rule. (CLFP/MCCV) Response: The number of eligible employees in Table C-4 was calculated based on an average number of eligible employees used only to estimate costs for Tier

One and Tier Two worksites. To estimate costs, it was assumed that Tier One worksites have 150 eligible employees and Tier Two worksites have 350 eligible employees.

42. Comment: The socioeconomic analysis conducted by ADE seems to indicate that there are 398,016 total pr ivate sector employees at work sites with over 100 workers. However, this seems to be a total number, not adjusted for the numberSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-13 of eligible employees. Further, why is this number higher than the 390,650 figure used by the District in Table C

‐ 4? How can the private sector total exceed the total for all employers? (CLFP/MCCV) Response: The Socioeconomic Analysis has been updated to include discussion on these points.

43. Comment: The socioeconomic analysis provi ded did not include many of the cost benefits to businesses or the employees from the ETRIP rule. (CCA) Response: The District recognizes there are pot ential cost savings associated with implementing many of the ETRIP measures . The purpose of the socioeconomic analysis is to describe how the implementation costs would affect

industries and sectors thr oughout the Valley. While savings are identified for some measures, such as direct deposit, the analysis does not take into account less quantifiable cost benefits. Some of the general benefits ar e described in the staff report. Employee savings are expecte d to be significant, but these are not analyzed as direct cost savings for the employer.

Emissions Reductions

44. Comment: The rule needs to identify how the District will measure the impact of trip reduction relative to reduced emissions. (Clovis) Response: The District’s emission reduction estimate and methodology are included in Appendix B of the Staff Repot. The District will use employersubmitted Commute Verification data to verify reductions.

Compliance

45. Comment: Rule 9410 should include clearly stat ed penalties for noncompliance. (CCA) Response: California Health and Safety Code Sections 42402 – 42403 provides the penalty tiers for noncompliance with California air district rules. Noncompliance penalties are often a ssessed on a per-day-of-noncompliance basis, and the ultimate goal is to bring vi olators into compliance of the rule.

When the District identifies t hat someone is out of comp liance with a District rule, the District issues a notice to comply or a notice of violation, depending on the nature and severity of the violation. The consequences of a violation depend on the nature and persistence of the violation, the length of time over which the violation occurred, the fr equency of past violations, and the action taken by the business to mitigate the violation. T he District will verify compliance with Rule 9410 through records review and periodic inspections.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-14 46. Comment: The District should include the state’ s parking cash-out law in Rule 9410. (CCA) Response: The District has reviewed existing state laws for parking cash-out.

The District will be in contact with ARB to discuss enforcement needs. Further study is needed to determine how many Va lley employers are be subject to the

state law and assess the emission reducti on potential of enforcement. Although the District is not adding parking cash- out to Rule 9410, employers can earn ETRIP points for offering a monetary in centive to employees, regardless of whether it is characterized as parking-cash out.

Employer Liability

47. Comment: It is a concern that the more an employer becomes involved in the activities outside of work, in this case the commute to and from work, the more the burden of accountability shifts from t he employee to the em ployer. California Labor Code Section 3600.8 states “An employee who is injured while acting

outside the course of his or her employment, or his or her dependents in the event of the employee's death, shall not be barred from bringing an action at law for damages against his or her employer as a result of this section.” (CLFP/MCCV) Response: No governmental entity can ever fully guarantee that a particular regulation will not be t he subject of litigation. The District’s position is that the requirements of Rule 9410 are drafted in such a way that it will not subject employers to meritorious claims. Labor Code section 3600.8 makes it very clear that employers who have employees that voluntarily participate in alternative commute programs mandated by a government al entity (such as Rule 9410) are not subject to worker’s compensation liabi lity. The Commenter raises concerns that this section may not insulate employ ers against other forms of liability, such as tort liability, and that such legal ques tions remain untested. However, the courts have repeatedly determined that things such as commute stipends, even when part of a collective bargaining agr eement, do not subject employers to liability for auto accidents occurri ng during the employee’s commute. See

Anderson v. PG&E (1993) 14 Cal.App.4 th 254; Caldwell v. A.R.B., Inc. (1986) 176 Cal.App.3d 1028; Harris v. Oro-Dam Constructors (1969) 269 Cal.App.2d 911. Although the amount of control an employer exercises over a particular activity is relevant to the analysis, the District believe s all of the measures that an employer can choose for Rule 9410 compliance can be implemented in a manner that requires limited or no employer contro l. Thus, although the District advises employers to check with their legal c ounsel when determining which measures work for them, the District does not believe that Rule 9410 has liability issues that cannot be easily overcome.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-15 Written Comments on the Proposed Rule 9410

Comment period held from November 16 through November 30, 2009.

Comments were received from the following people and organizations:

Merced County (Merced) Nabors Well Services Company (NWSC) Greater Madera County Industrial Association (GMCIA) Coalition for Clean Air (CCA)

General

48. Comment: According to the San Joaqui n Valley Express Transit Study, approximately 25 percent of the Valley workforce al ready commutes to work using some means other than a si ngle passenger vehicle. (GMCIA) Response: Refer to Comment 40.

Excluded Employees

49. Comment: NWSC field employees report to a ma in location to then participate in a “continued rideshare” to a satellite field location to reduce trips. These types of field employees should be excluded from the eligible employee count.

“Continued rideshare” shoul d also be added as one of the menu options in the

ETRIP. (NWSC) Response: Field employees who report to a central location before reporting to the field still have an opportunity to rides hare or use alternative transportation when commuting to the central location. Co ntinued rideshare is a great way to reduce trips and can be submitted as “Other measures approved by the District.”

Cost Effectiveness and Socioeconomic Analysis

50. Comment: District staff should conduct a cumulative cost analysis on affected industries including requirements from other regulatory agencies and the abilities of companies to invest in emissions reductions projects. (NWSC) Response: While the impacts of other r egulations and agencies is beyond the scope of the District’s economic analysis, cumulative impacts are addressed in the baseline employment and profitability trends of eac h affected sector of industry in the socioeconomic analysis. Stakeholders are encouraged to relay

economic information to District staff and the District’s economic consultant so that specific impacts can be acknowledged.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-16 51. Comment: Has the District considered the cost and time of documentation required by Wage Order 4 for meals and breaks of all employees, including
telecommuters, in the cost analysis? (NWSC) Response: The cost analysis only considered costs specifically associated with the requirements for this rule. The requirements of Wa ge Order 4 are not specifically mandated by this rule, as the employer would need to follow them regardless.

Cost

52. Comment: We believe the District has signifi cantly underestimated the costs

associated with this Rule. The District underestimates the average hourly rate and the amount of time it will take to administer the program. Another gross underestimation is the average rate of pay for the policy review and administration of the program. Also, while the current worksheet does account for employee labor to fill out the survey, it does not include the cost of lost production hours which our member companies factor into their cost vs. return models. (GMCIA) Response: Refer to Comment 37.

53. Comment: Given the intense requirements of the rule, the county, with three Tier Two worksites, will need to hire at least one new staff member to oversee the implementation of the pr ograms necessary to meet t he point targets. With all of the employee layoffs and furloughs, the remaining workforce does not have the capacity to take on additional duties of running new programs. The amount of time before registration in July 2010 is not sufficient to designate a coordinator. (Merced) Response: Refer to Comment 33.

Survey

54. Comment: The survey should require a 50 % return rate only and additional points should be given to companies that achieve higher survey return rates than 50%. (NWSC) Response: Refer to Comments 28 and 29.

55. Comment: Given the relatively low cost of im plementation of this rule, based on the socioeconomic report, a baseline surv ey should be required prior to the implementation of any of t he rules requirements. This will allow the Air District to gauge improvements once the rule implementati on begins. The District has yet to provide any actual data that supports that a baseline survey would be too expensive to require of employers. (CCA)SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-17 Response: Refer to Comment 31. Though a basel ine survey would be helpful, it is not completely necessary and woul d only create additional unneeded costs and burden on employers especially in the current economic climate.

56. Comment: Requiring commute verification mu ltiple times each year would improve representativeness of the data and be harder to manipulate to show improvement in participation. (CCA) Response: Refer to Comment 32.

ETRIP measures

57. Comment: The Program Support Strategy has several incompatible options that will add to the degree of difficulty for comp liance in manufactur ing environments.

Without additional flexibilit y, there may be some manufacturing employers who cannot attain the point totals in the Program Support Strategy. (GMCIA) Response: Refer to Comment 24.

58. Comment: High point targets and low values giv en to many of the most low-cost

and achievable ETRIP measures will make it difficult for employers to meet the overall point goal. In most cases, measures with the lowest point values are really the only options for local gover nments under the stra in of a massive recession and severe State funding cuts. The point values for ETRIP options

should be altered to increase available options for organizations that are struggling financially and may not be able to implement several of the more costly options. (Merced) Response: The point values were determi ned based on the amount of time,

cost and effort the measure would require as well as the effectiveness the option would provide in reducing trips. Please re fer to the points analysis in this Staff Report. Based off of dialogue with mu ltiple stakeholders, many employers already have multiple options in place at their worksites that can aid in meeting the ETRIP point targets. The District is providing many resources and tools to help employers implement turnkey strategi es and will be available to work with employers to determine cost effect ive options for their worksites.

59. Comment: The “Additional Points Needed” section is unnecessarily

burdensome and should be elimin ated. It negates the reduction in the point target for the Transportation, Alternative Schedule s, and Incentives Strategy. The point target for Phase III is excessive and wil l prohibit most employers from cost effectively complying by having to choose expensive options or multiple low-cost options requiring more money and new staff to operate. Phase III should be satisfied by implementing no more than one or two measures, as each constitute a major undertaking for employers. The point value for Comprehensive CarpoolSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-18 Program should increase from 8 points to 10 points to help employers comply with Phase III targets. (Merced) Response: The “Additional Points Needed” targets allow employers to have more flexibility in choosing ETRIP opti ons and creating successful trip reduction programs. The “Additional Po ints Needed” point targets can easily be achieved by becoming a Healthy Air Living part ner and committing to the marketing options included in that. Re fer to Comments 53 and 58.

60. Comment: The county has implemented Compressed Work Week schedules; however, participation is below the 10% threshold. Local governments are limited in the implementation of alternative schedul es in ways private industries are not by needing to provide public services dur ing normal business hours. Even if a 10% threshold was achieved, the points a llotted do not adequately assist in Rule 9410 compliance. (Merced) Response: In speaking to all Valley count ies and many large cities during the rule development process, the District learned that many municipalities have already implemented or are planning to implement Compressed Work Week. Although the offices are closed one day every two weeks in a 9/80 schedule, people have been able to take advantage of these offices being open one hour later every day. The multiple participat ion levels added to the Compressed Work Week option has increased the availability of that option fo r many employers.

Refer to Comment 58.

Employer Liability

61. Comment: Many ETRIP options that are implemented or arranged by the employer will increase liability and legal ri sk to the employer or are not conducive to a manufacturing en vironment. (GMCIA) Response: Refer to Comment 47.

Compliance

62. Comment: Rule 9410 should include clearly st ated penalties for noncompliance and provide additional clarific ation as to what kind of noncompliance practices would result in what level of punishment to help deter noncompliance. (CCA) Response: Refer to Comment 45.

63. Comment: The District should include the state’ s parking cash-out law in Rule 9410. Since a parking cash-out adopti on was initially included in an earlier

version of the rule it should not be difficu lt to add it to the current rule. (CCA) Response: Parking cash-out is already requir ed by state law and applies to a larger set of employers than Ru le 9410. Refer to Comment 46.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-19 Written Comments on the Proposed Rule 9410

The following comments were received bet ween December 1 and December 17, 2009.

Comments were received from the following people and organizations:

Modesto City Schools (Modesto Schools) Stanislaus County (Stanislaus) Anlin Window Systems (Anlin) Hedrick’s Chevrolet (Hedrick’s) Bingham Toyota/Scion (Bingham)

Compliance

64. Comment: How does the Air District propose to track applicable employers? (Modesto Schools) Response: District staff have compiled a lengt hy mailing list with employers throughout the Valley that have over 100 employees. Notices have been sent to each employer on the list. Employers are responsible for registering with the

District.

65. Comment: What are the penalties for non-compliance? (Modesto Schools) Response: Refer to Comment 45.

66. Comment: The inflexibility of the ru le and the costs associated with implementing such a plan without funding is impractical especially for local government entities. Many of the measures may have tax and union implications that would limit the availability of m easures to reach the point targets. The

administrative and financial resources are not available to administer and monitor the program. The District should administe r Commute Verificati on to employees

to reduce the burden for em ployers. (Stanislaus) Response: The menu-based approach provides flexibility while the minimum point targets ensure a comprehensive and well-rounded program will be put in place. Employer based trip r eduction programs have been shown to be successful in multiple studies whic h are outlined in the staff report. The District’s Personnel Department has evaluated the ETRIP measures and determined there should not be any overarching tax implicat ions. The District should be contacted if a unique situation may determine otherwise. See also Comment 17.The District will provide various methods to submit Commute Verification data such as online, by phone and timecards as well as multiple tools and templates to decrease the

administrative time and cost.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-20 Cost

67. Comment: Will the District provide direct and personal assistance to local public school districts to ensure compliance is achieved in the most cost effective manner? (Modesto Schools) Response: District staff are available to empl oyers. The District will also provide multiple tools, resources and trainings as outlined in Section 7.0 in the rule.

68. Comment: The requirements of the rule would require hiring a part time employee to perform record keeping, t hereby reducing employee related cost

elsewhere. The District should not bur den businesses with an additional expense during the current economic climate, providing yet another reason why businesses are leaving California. (B ingham) How will the rule achieve any measurable reduction in air polluti on? (Anlin) Mandates should be on the consumer not passed along to the businesses. (Hedrick’s) Response: Refer to Comment 33.

Emission Reductions

69. Comment: How will the rule achieve any measurable reduction in air pollution? (Anlin) Response: Refer to Comment 44.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-21 Letters Submitted on the Proposed Rule 9410

Two hundred and two individuals submitted sim ilar letters as summarized below. The

letters were received between Dece mber 10 and December 17, 2009.

K. Walser, Modesto S. Herman, Sacramento Y. Peck, Orangevale K. Achee, Bakersfield
D. Buckheim, Atascadero D. Ledden, Rancho Murieta D. Watson, Sacramento
P. Nelson, Twain Harte M. Meyer, Wawona K. Norton, Sacramento R. Robinson, Sacramento
H. Beauchaine, Tulare J. Sorby, Stockton C. Fink, Stockton K. Manning, Sacramento F. Palmer, Sacramento
V. Hartman, El Portal B. Etgen, Sacramento C. Carr, Big Oak Flat M. Yang, Turlock C. Graybill, Sacramento J. Young, Carmichael E. Obara, San Ramon L. Smith, California Hot Springs
R. Halliwell, Danville T. Hutchinson, California City D. Cho, Tracy K. Harper, Citrus Heights T. Clark, Arroyo Grande C. Benedict, Merced M. Baker, Tehachapi R. Robinson, Fresno L. Rank, Auberry S. Roberts, Wawona
A. Louin, Fresno B. Olson, Sanger
J. Tabacco, Riverbank H. White, Coarsegold B. Quintana, Soulsbyville
P. Roe, Turlock T. Harrington, Sonora
R. Kuhn, Fresno K. Steele, Pleasanton J. Satchell, Sacramento K. Linarez, Carmichael
B. Hochendoner, Patterson C. Bowman, Sacramento R. Clarke-Roberts, Riverbank L. Lynch, Elk Grove
K. Bithell, Madera M. Taylor, Sacramento S. Anderson, Stockton T. Alice, Mariposa P. Meierding, Yosemite J. Sabo, Escalon
N. Novak, Fresno S. Holzberg, Folxom D. Cobb, Stockton E. Storar, Sacramento B. Newstrom, Stockton S.E. Miranda, Antelope
F. Mathes, Madera S. Commons, Sacramento
P. Helman, Pleasanton P. Tidwell, Visalia J. Buhowsky, San Ramon D. Asay, Sacramento K. Wang, Turlock S. Goldstein, Danville R. Glover, Fresno R. Sullivan, Sacramento J. Tessman, Sacramento
J. Kirk, Modesto J. Nonya, Sacramento M. Hamlett, Sacramento C. LeBlanc, SacramentoSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-22 C. Roe, Fresno T. Moore, Coarsegold
W. Webster, Danville K. Avance, Sacramento J. Ball, Sacramento B. Hughes, Ridgecrest R. Morris, Bakersfield K. Avance, Sacramento
D. Dorinson, North Fork R. Harvey, Paso Robles J. Koshear, Coarsegold P. Rockey, Oakdale M. Setaro, Modesto T. Gonzalez, Lancaster J. Nommensen, Bakersfield
W. Wilke, Fresno K. Silva, Tulare B. Steele, Springville D. Murray, Sacramento D. Ramsey, Sacramento M. Skercevic, Sacramento J. Columbia, Bakersfield E. Thayer, Brentwood N. Kelly, Fresno P. Del Prato, Sacramento M. Ott, Pleasanton E. Adan, Carmichael J. Greer, Denair
R. Bates, Fresno R. Longer, Elk Grove K. Jones, Sacramento S. Still, Sonora C. Wieland, San Ramon K. Evans, Sacramento
L. Arenas, Fresno D. Sproull, Stockton M. Graf, Bakersfield J. Perugini, Folsom J. Nakata, Citrus Heights G. Watkins, Elverta W. Mittig, Mariposa I. Macias, Sacramento G. Lynn, Bakersfield D. D'Amico, Carmichael M. Brinich, Chowchilla S. Summers, Carmichael D. Woolf, Catheys Valley S. Edie, Antelope
L. White, Folsom L. Fultz, Fresno L. Roberts, Fresno J. Acuna, Sacramento E. Seekamp, San Ramon B. Peloquin, Bakersfield R. Cassinelli, Sacramento J. Bowman, Sacramento S. Hampton, Sacramento M. Mallett, Sacramento J. Ostoich, Sacramento D. DeTora, Citrus Heights C. Michaelides, Galt R. Vosburg, Bakersfield
J. Womble, Lodi B. Vanhorn, Gustine C. Yee, Sacramento L. Young, Mariposa R. Sennett, San Luis Obispo R. Young, Sacramento M. Clipka, Lathrop G. Kinsey, Elk Grove J. Rutledge, Antelope F. Reyes, Los Banos L. Austin, Sacramento P. Sparry, Morgan Hill E. Robin, Bakersfield K. Monk, Citrus Heights H. McLean, Sacramento L. Slattery, Modesto P. Gullam, Bakersfield S. Arteaga, Modesto S. Hafer, Sacramento R. Sullivan, Woodbridge
L. Hicks, Fresno L. Coffman, Atascadero C. Chenkin, Citrus Heights L. Norried, Valley SpringsSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-23 T. Philipson, Danville R. Reed, Tollhouse G. Sheets, Merced S. Hodges, Sacramento J. Krase, San Ramon L. Redding, Sacramento
B. Martin, Fresno J. Seghieri, Manteca R. Grace, Morgan Hill J. Harvey, Pioneer C. Riley, Citrus Heights A. Lopez, Folsom T. Manning, Springville M.C. Nothern, Danville
K. Dolder, Danville M. Gracey, Danville J. Murphy, Modesto P. Edmonston, Mariposa K. Dawdy, San Ramon
J.R. Donaldson, Fresno J. Trujillo, Tehachapi C. Shadish, Mariposa D. Santone, San Ramon A. Peterson, Stockton B. Cohen, Fresno E. Stanley, Sacramento D. Figge, Fresno E. Rees, Folsom P. Sessa, Sacramento J. Dettman, Sonora G. Crapson, Exeter K. Peck, Carmichael
A. Arcure, Fresno S. Taylor, Sacramento J. Myrick, Morgan Hill N. Cohn, Atascaadero S. Odry, Fish Camp R. Blakemore, Mariposa M. Todd, Folsom B. Odelberg, Kirkwood

70. Comment: I support your efforts to reduce emissions from mobile sources by implementing Rule 9410, the employer-based trip reduction program. In the adoption of Rule 9410, I urge you to inco rporate strong accountability measures that include clear penalties for non-co mpliance, a baseline survey to help measure progress, and further annual surveys that gather data on the

effectiveness of the rule. I believe that a strong 9410 would help to reduce the dangerous air pollution that we suffer in the valley and at our nearby national parks. Response: Refer to Comments 31, 32 and 45.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Public Co mments December 17, 2009

Final Staff Report with Appendices for Rule 9410 A-24 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-1 APPENDIX B

Emission Reduction AnalysisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-2 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-3 EMISSIONS REDUCTION ANALYSIS

The 2008 PM2.5 Plan contained an emissions invent ory for On-Road Motor Vehicles based on the ARB emissions inventory (C EFS v1.06). The inventory included categories that would be used for commuting , specifically light and medium duty passenger cars and trucks. This rule affects ox ides of nitrogen (NOx), volatile organic compounds (VOC), and direct PM2.5 from these vehicles. Table B-1 shows the baseline emissions inventory for these pollutants.

Table B-1 Total Emissions from Light and Medium Duty Vehicles (tons per day, or tpd)

2010 2014 2023

NOx 44.7 32.1 16.4

VOC 41.9 31.9 20.6

PM2.5 2.3 2.6 3.2

The Department of Transportation’s (DOT) National Household Travel Survey found that, as a nation-wide average, work commu te Vehicle Miles Traveled (VMT) account for about 27% of total VMT for personal vehicle use 3 . Table B-2 shows the emissions

from work commute VMT.

Table B-2 Emissions from Light and Me dium Duty Vehicles for Work Trips (tpd)

2010 2014 2023

NOx 12.1 8.7 4.4

VOC 11.3 8.6 5.6

PM2.5 0.62 0.69 0.87

3 U.S. Department of Transportation (DOT) and Federal Highway Administration (FHWA). “Commute VMT and Total VMT by Year” Table 24, page 42. National Household Travel Survey, 2004.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-4 According to the Employment Devel opment Department, about 36% of Valley employees are employed at worksi te with 100 or more employees. 4 Table B-3 shows the emissions from commute trips of those subject to the rule.

Table B-3 Emissions for work trips at employers with at least 100 employees (tpd)

2010 2014 2023

NOx 4.4 3.1 1.6

VOC 4.1 3.1 2.0

PM2.5 0.23 0.25 0.32

The California Department of Transportation (Caltrans) California Statewide Household Travel Survey 5 states that the weekday average vehicle occupancy (AVO) for home to work trips is 1.1, equating to 11 persons per 10 vehicles (11÷ 10=1.1). The proposed rule emphasizes education and infrastructure for trip reduction programs through various ETRIP measures phased in at a wo rksite over time. A collaborative report 6
prepared by the U.S. DOT Federal Transit Administra tion (FTA), Federal Highway Administration (FHWA), and EPA states that combining commute alternatives with incentives results in an average trip reduc tion of 24.5%, which equates to an AVO of approximately 1.32 (AVO=1/[1-0 .245]). Other reports have shown similar participation rates given the amount of measures provided in the comprehensive ETRIP. 7 8 Given

that these studies evaluated vo luntary programs, the District is confident a regulatory program will surpass the average participation achieved from these programs. With the combination of various strategies to creat e a comprehensive ETRIP, the District expects an AVO for affected employers of between 1. 3 and 1.4. Table B-4 shows the emissions that will be eliminated by the im plementation of this rule.

4 Adjusted to account for possible exempt employees. Employment Development Department (EDD). “Number of Employees by Size Category” Table 3B, Labor Market Information Division, Third Quarter, 2007. http://www.labormarketinfo.edd.ca.gov/?pageid=138

5 Caltrans. “Table B: 2000-2001 Key Trip Statistics” , California Statewide Household Travel Survey, 2002.

6 U.S. DOT FTA and FHWA, U.S. EPA. “Summary of Choices – What works?”, Commuter Choice Primer.

7 U.S. DOT FHWA. “Employer-Based TDM Programs”, Mu lti-Pollutant Emissions Benefits of Transportation Strategies, 2006.

8 Victoria Transport Policy Institute. “Travel Impacts”, TDM Encyclopedia: Commute Trip Reduction Programs That Encourage Employees to Use Efficient Commute Options, 2009.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-5 Table B-4 Rule 9410 emissions reductions from projected AVO (tpd)

2014 2023

NOx 0.6 0.3

VOC 0.6 0.4

PM2.5 0.05 0.06

The following discussion shows the emissions reductions calculations for NOx, VOC and PM2.5 in greater detail.

To account for Valley commuters who alre ady use alternative transportation, prebaseline emissions were established usi ng a scenario where 100% of eligible employees in the Valley are using single occupancy vehicles. Pre-baseline emissions were found by multiplying the baseline AVO 9 of 1.1 by the rule baseline emissions in Table B-3 and are repres ented in Table B-6.

Table B-6 Hypothetical pre-baseline em issions resulting from 100% SOV use (tpd)

2014 2023

NOx 3.4 1.8

VOC 3.4 2.2

PM2.5 0.28 0.35

Next, the District has set an AVO target range of 1.3 to 1.4 for eligible employees. To calculate projected emissions resulting from the target AV O, the pre-baseline emissions are divided by the range midpoint, 1.35, as shown in Table B-7.

Table B-7 Emissions produced at 1.35 AVO (tpd)

2014 2023

NOx 2.5 1.3

VOC 2.5 1.6

PM2.5 0.2 0.3

9 See footnote 5.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-6 The emission reductions resulting from ac hieving the 1.35 aver age target is the difference between the baseline emissions for Rule 9410 and the projected emissions in

Table B-7.

An example of the calculation for the estima ted reductions of NOx in 2014 is as follows:

3.1 tpd rule baseline x 1.1 baseline AVO = 3.4 tpd pre-ba seline emissions (representing 100% single occupancy vehicles)

3.4 tpd pre-baseline emissi ons / 1.35 projected AVO = 2.6 tpd projected emissi ons (representing 1.35 AVO)

3.1 tpd rule baseline - 2.6 tpd projected emissions = 0.6 tpd NOx reduced by Rule 9410

The estimated NOx emissions reductions calc ulated in this staff report are higher than the projected emissions reductions in the 2007 Ozone Plan . This can be attributed to an updated emissions inventory and employment and commute data made available by the DOT National Household Travel Survey and Employment Development Department.

Table B-8 demonstrates the difference in t he Rule 9410 baseline compared to that of

the 2007 Ozone Plan. The current proposed rule baseline is only a portion of that of the

2007 Ozone Plan. In the 2007 Ozone Plan , the control measure baseline only included light duty vehicles, whereas the Rule inventor y baseline, at this time, includes medium duty vehicles as well to account for SUVs and van use. The updated information has helped the District better determine the potential of this rule.

Table B-8 Rule 9410 baseline percentage of 2007 Ozone Plan baseline (%)

2014 2023

NOx 65.5 67.1

VOC 7.75 8.29

Though the estimated VOC emissions reductions calculated in this report are slightly lower in tons per day than what was committed to in the 2007 Ozone Plan , this rule should achieve a higher perc ent of VOC reductions of the updated baseline emissions inventory than the plan projec ted. Table B-9 compares t he emissions reductions from

the 2007 Ozone Plan to proposed Rule 9410 as compared to their respective baselines. There will be surplus emissions reductions from other measures committed to in the

2007 Ozone Plan to account for the discrepancy in actual tons per day. Exempt worksites may also participate in trip reducti on efforts with the tools developed for thisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-7 rule, achieving additional reductions. However, since these reductions are not enforceable, they can not be credited in the Stat e Implementation Plans.

Table B-9 Emissions reductions co mparison between Rule 9410 and the 2007

Ozone Plan (%)

2014 2023

Ozone Plan Rule 9410 Ozone Plan Rule 9410

NOx 5 18 12 18

VOC 2 18 3 18

The emissions reductions in the 2008 PM2.5 Plan were under review and not determined at the time of pl an adoption. Therefore, no specif ic target PM2.5 reductions were projected in the 2008 PM2.5 Plan.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reducti on Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 B-8 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-1 APPENDIX C

Costs and Cost Effectiveness AnalysisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-2 This page is intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-3 I. INTRODUCTION

California Health and Safety Code (CH &SC) Section 40920.6(a) requires the San Joaquin Valley Unified Air Pollution Control District to conduct both an "absolute" cost effectiveness analysis and an “incremental” co st effectiveness analysis of available emission control options prio r to adopting each Best Av ailable Retrofit Control Technology (BARCT) rule. The purpose of conduc ting a cost effectiveness analysis is to evaluate the economic reasonableness of the po llution control measure or rule as it applies to operators in the San Joaquin Valley Air Basin. The analysis also serves as a guideline in developing the cont rol requirements of a rule.

Incremental cost effectiveness (ICE) is intended to measure the change in costs (in $/year) and emissions reductions (in tons reduced/year) between two progressively more effective control options or technol ogies. ICE compares the differences in

costs and the differences in emissions reduc tions of candidate control options. ICE does not reveal the emission reduction potent ial of the control options. Unlike the absolute cost effectiveness analysis that identifies the control option with the greatest emission reduction, ICE does not present any correlation between

emissions reductions and cost effectivene ss. Therefore, the relative values produced in the ICE analysis and the absolut e cost effectiveness values are not comparable and cannot be evaluated in the same way as absolute cost

effectiveness numbers.

II. SUMMARY

Rule 9410 would require large worksites to promote and facilitate trip reduction from their employees to reduce vehicle miles traveled (VMT) and emissi ons of oxides of nitrogen (NOx), volatile organi c compounds (VOC), and parti culate matter 2.5 microns in diameter or less (PM2.5) associated with work commutes. Worksites would have to implement an Employer Trip Reduction Im plementation Plan (ETRIP) by choosing applicable measures from a m enu of options to achieve a specified point target.

Rule 9410 will apply to an estimated 1883 facilities throughout the Valley. This rule separates those facilities into two tiers based on the number of eligible employees at the

worksite. Tier One Worksites are those with 100-249 eligible employees and Tier Two

Worksites have 250 or more e ligible employees. There are an estimated 1,342 Tier One

Worksites and 541 Tier Two Worksites.

Worksites that employ migrant and/or seasonal workers that would fall under the Migrant and Seasonal Agricultural Worker Protection Act (MSPA) have different requirements under Rule 9410 to avoid inconsistency with existing regulations. The MSPA worksites have an altered compliance plan implementing only Phase One andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-4 Phase Two of the ETRIP. Of the estimated 1,883 facilities this rule applies to, 28 of those employ workers pr otected by MSPA.

A. Absolute Cost Effectiveness

Absolute cost effectiveness (ACE) of a control option is the added cost of a control technology or technique, divided by the emis sion reduction achieved (in tons reduced per year). The costs include capital equipment costs, labor, and maintenance costs. The estimated ACE range for this analysis is $8,000 - $15,000 per ton of NOx, VOC, and

PM2.5 emissions reduced as estimated from Appendix B. The ACE for each type of

worksite is shown in Table C-1. Factors affecting the ACE are summarized in Section

IV.

Table C-1 District Estimate of Absolute Cost Effectiveness

Type of Worksite Absolute Cost Effectiveness ($/tpy reduced)

Tier One 13,894

MSPA Tier One 14,796

Tier Two 8,375

MSPA Tier Two 12,221

Weighted Average 11,253

Manufacturing stakeholders’ provided an ACE range from $49,000 - $74,000 per ton of NOx, VOC, and PM2.5 emissi ons reduced per year and are summarized in Table C-2. The stakeholder provided ACE is based off of a previous version of the staff report. The following table also includes the District’s adj ustment of stakeholder’ s cost effectiveness

based on the final draft staff report showing an improvement in the stakeholder ACE by 45%. The estimates provided are for Tier One and Tier Two manufacturing facilities only.

Table C-2 Manufacturing St akeholder Estimate of

Absolute Cost Effectiveness

Type of Manufacturing

Worksite Stakeholder Provided

Absolute Cost Effectiveness ($/tpy reduced) District Adjusted A

Stakeholder Estimated

Absolute Cost Effectiveness ($/tpy reduced)

Tier One $74,194 $41,044

Tier Two $49,007 $27,040

Total $60,609 $33,481

A District staff adjusted t he stakeholder provided ACE using the updated emissions reductions provided in Appendix B of the Final Draft Staff R eport and stakeholder provided costs and number of facilities.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-5 B. Incremental Cost Effectiveness

Incremental cost effectiveness (ICE) is intended to measure the change in costs (in $/year) and emissions reductions (in tons reduced/year) between two progressively more effective control options or technologi es. Rule 9410 provides worksites with the flexibility to comply with the requirement s by choosing the required minimum number measures from a list of menu options or devel oping measures of their own not specified in the rule for District approval. In general, since worksites have the flexibility to choose from a list of menu options, Dis trict staff believe worksites will likely choose the option with the best cost effectiveness for their particu lar operation. As a result, District staff believes an ICE analysis is not appropriate for this rule.

III. ESTIMATED COMPLIANCE COSTS

Throughout the rule development process, multiple worksites throughout the Valley have been utilized as examples of worksites wit h successful trip reduction measures in place. While there may be many facilities with some of the menu options already in place, this report does not take into account those possibilities. Costs will be provided for every menu option as well as an ACE analysis of a feasible ETRIP applicable to the majority of facilities within the Valley. District staff estimat ed costs for one-time and recurring administrative and employee labor, ma terials, and other operations as well as annualized capital cost for equipment and installa tion for each year of implementation.

As stated previously, costs were estima ted for Tier One and Tier Two regular and

MSPA worksites. Please refer to Attachment s 1-6 for the estimat ed compliance costs.

A. Estimated Costs

Rule 9410 will be phased in over a period of six years beginning in 2010. Costs were calculated incorporating one-ti me, annualized capital, and recurring costs for each year of rule implementation. Co sts are calculated separately according to tier and MSPA

worksites. Estimated annual costs are summarized in Tabl e C-3. See Attachments 1-4

for detailed cost estimates.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-6 Table C-3 District Estimated Annual Costs

Type of

Worksite 2010 2011 2012 2013 2014 2015+ Average

Annual

cost,

2010-2014

Tier One $44 $1,373 $3,801 $3,033 $3,298 $4,462 $2,310

Tier Two $44 $1,816 $5,635 $3,604 $5,143 $6,827 $2,460

MSPA Tier One $44 $1,373 $1, 734 $4,733 $4,413 $6,295 $3,249

MSPA Tier Two $44 $1,816 $2, 399 $9,714 $9,729 $11,944 $4,741

Reporting requirements have changed from a semiannual survey requirement to Commute Verification, as outlined in Sectio n 6.4 of the Rule, since the costs were estimated and would affect costs occurring in 2014 and thereafter. Administrative costs will likely be lower as a result of these c hanges but the cost range estimated for the previous semiannual survey requirement is reasonable for the Commute Verification requirement and was not altered.

Stakeholder estimated annual costs for manufa cturing sites are summarized in Table C4. Stakeholder estimated costs are higher t han those estimated by the District due to

increased estimated time needed to administe r the program, increased wage scale for some of the administrative costs, specif ically policy development, and using a cost versus return model for the survey requi rements. Stakeholder estimates also do not reflect more recent changes to the reporting r equirements, specifically the change from the semiannual survey requirement to Commute Verification.

Table C-4 Stakeholder Estimated Annual Costs

Type of

Worksite 2010 2011 2012 2013 2014 2015+ Average

Annual

cost,

2010-2014

Tier One $76 $3,100 $7, 377 $12,392 $11,174 $13,929 $6,824

Tier Two $76 $4,100 $10, 493 $18,132 $19,651 $22,971 $10,490

Costs estimated by District staff, though lo wer than those provided by stakeholders, offer a reasonable range for various reasons . The District used a Valley-wide average hourly rate including benefits, not specific to one industry, calculated from the Employment Development Department (EDD). The administrative time estimates to develop and administer the program were calculated based on information from the District’s in-house options and considered reasonable especially in light of the number

of resources the District has committed to providing to reduce administrative time and costs, such as sample policies and templates. Since stakeholder costs have beenSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-7 submitted the reporting requirements in the proposed Rule 9410 have been revised and as a result, the costs should be lower. St akeholder estimated costs for the survey reporting requirements incorporat ed a cost versus return model for lost production time. The amount of time needed for employees to complete the mandatory Commute

Verification form should be minimal over the course of the year and should not result in significant lost production time. The District recommends that the employer chooses the least time consuming manner to administer the Commute Verification method of their

choice.

B. Sources of Cost Data

District staff used cost information provi ded by stakeholders through interviews and voluntary surveys and based information on exis ting programs, such as the District’s own trip reduction program. Administrati ve and employee participation hours were estimated and were reviewed by the District’s Personnel and Administration Departments.

District staff actively solicited written and verbal cost data from stakeholders and incorporated these comments into the co st effectiveness analysis. Manufacturing stakeholders provided cost estimates and have been summarized in this analysis.

C. Assumptions Used in Calculating Estimated Costs

District staff has assumed certain specifications to perform the cost effectiveness analysis including the following:

1. Administrative and employee hours were estimated for development and participation in the worksite’s trip reduction program. The use of District templates and resources that will be provided to employers was taken into

account.

2. The measures that offer a financial in centive to participating employees would be agreed upon as part of the employee compensation package and therefore, would have no additional cost not already included in the employer’s set budget. Employee compensation negotiations o ccur regardless of Rule 9410. 3. The assumptions made for the emissi ons reduction calculation in Appendix B apply to the emissions reductions portion in this Appendix. 4. The total annualized compliance cost for all compliance scenarios include all the appropriate annualized capital costs as we ll as any additional annual operation, maintenance, and labor costs.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-8 IV. COST EFFECTIVENESS ANALYSIS

A. Cost Effectiveness Analysis Procedure

Following is the procedure used by District staff in conducting the cost effectiveness analysis of this rule: (1) Identify a compilation of menu options for an ETRIP applicable to any type of Tier One and Tier Two worksite; (2) Estimate the one-time and recu rring administrative and employee participation hours associated wi th each of the menu options; (3) Estimate the one-time and recurring materials and operations costs for each of the menu options; (4) Estimate the equipment annualized co st of each applic able menu option; (5) Calculate the annual cost to impl ement each phase of the ETRIP and the administrative requirements; (6) Calculate the emissions reduc tion based on participation in a comprehensive trip reduction program; and (7) Calculate the absolute cost ef fectiveness of the given ETRIP.

As previously mentioned, cost effectiveness of a control technology is calculated by dividing the annualized cost of a control technique with the annual emission reduction achieved by the control technique. The co st effectiveness is expressed in dollars per ton of pollutants reduced ($/ton).

B. Emissions Reduction Analysis

District staff analyzed the potential emissions r eduction of Draft Rule 9410 as detailed in Appendix B of the Draft Staff Report. The summary of the estimated emissions

reduction is shown in Table C-5.

Table C- 5 Emissions Reduction

2014 Pollutant tons/day tons/yr

NOx 0.571 208

VOC 0.571 208

PM2.5 0.046 17

Total 1.188 433

Staff then estimated emission reductions fo r each type of worksite by apportioning the total reductions according to the total numbe r of employees as used for the estimated costs, shown in Table C-6.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-9 Table C-6 Emissions Reduction for Each Type of Worksite

Type of

Worksite Average Number of Employees per

Worksite A Number of

Worksites Total Number of Employees B Reductions (tons/yr)

Total 1,883 390,650 433

Tier One 150 1,322 198,300 220

MSPA Tier One 150 20 3,000 3

Tier Two 350 533 186,550 207

MSPA Tier Two 350 8 2,800 3

A The average number of employees listed per worksi te were used only for the cost estimates.

150 employees were used to estimate Tier One costs and 350 employees were used to

estimate Tier Two costs.

B Estimated number of employees = Tier One Average number of empl oyees x Number of

worksites. Example for Tier One: 150 em ployees x 1,322 worksites = 198,300 employees The estimated total number of employees were calculated only for the cost effectiveness and

not used elsewhere.

Staff then divided the annual average cost fo r each type of worksite by the annual average emission reduction to generate cost effectiveness values for each type of

worksite and the rule as a whole. Table C- 7 shows the cost effectiveness of Rule 9410 as calculated by District staff.

Table C-7 District Calculated Absolute Cost Effectiveness

Type of

Worksite Number of

worksites Average annual

cost/worksite

until 2014 (from Table C-3) Annual

cost for all

worksites C

($/ton/yr) Emissions

Reduction

(tons/yr) Absolute Cost

Effectiveness ($/ton reduced)

Tier One 1,322 $2,310 $3,053,820 220 13,894

MSPA Tier One 20 $2,460 $49,200 3 14,796

Tier Two 533 $3,249 $1,731,717 207 8,375

MSPA Tier Two 8 $4,741 $37,928 3

C Annual cost for all worksites = Average annual cost per worksite x num ber of worksites. Example for Tier One: $2,310/worksite x 1,322 worksites = $3,053,820/year total cost; 12,221

Total 1883 $3,190 $4,872,665 433 11,253

$3,053,820/year total cost ÷ 220 ton/year reducti on = $13,894/ton reducedSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-10 Stakeholders provided the following estimat ed costs and ACE for manufacturing sites

summarized in Table C-8. Differences from Dis trict cost estimates are discussed in Section III A of this analysis. Stakehol ders used the number of manufactu ring worksites provided in the Socioeconomic Report Table 3. The Soci oeconomic Report provided a conservative estimate by not taking into account the po ssible excluded employees when stating the

number of worksites with 100 or more employees. Therefore, the number of manufacturing worksites is likely less than stated in the following table.

Table C-8 Cost and Abso lute Cost Effectiveness Provided by Stakeholders for Manufacturing Facilities

Type of Manufacturing

Worksite Number of

worksites D Average

annual

cost/worksite

until 2014 Annual

cost for all

worksites Emissions

Reduction

(tons/yr) E Absolute Cost

Effectiveness ($/tpy reduced)

Tier One 157 $6,824 $1,071,368 14.44 $74,194

Tier Two 79 $10,490 $828,710 16.91

D Manufacturing sites only as based on data prov ided in the socioeconomic report. Actual number may be lower. $49,007

Total 236 $1,900,078 31.35 $60,609

E Emissions reductions calculated fr om data provided by the District.

Similar to Table C-2, the stakeholder prov ided ACE is expected to improve based on

the revision to the Emissions Reductions An alysis in Appendix B in the Final Draft Staff Report.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Costs and Co st Effectiveness Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 C-11 ATTACHMENTS 1- 6

COST ESTIMATE TABLESAttachment 1: Tier 1 Estimated Costs for Feasible ETRIPRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+44 1373 3801 3033 3298 4462ADMINISTRATIVE REQUIREMENTS($/yr)Employer RegistrationAdmin labor one-time 2 44 44 0 0 44Notify Employees Admin labor one-time 2 44 44 0 0 44Develop each phase ofETRIPAdmin labor recurring 0 0 60 1,3291,329 1329 1329 1329Survey 2x/yr starting in 2014Preparation Admin labor recurring 0 0 15 332332 332 332Distribution Admin labor recurring 0 0 15 332332 332 332Completion byemployeesEmployee labor recurring 0 0 75 1,6611,661 1661 1661Materials Materials recurring 0 100 100 100 100Compile Survey Results Admin labor recurring 0 0 35 775775 775Revise ETRIP Admin labor recurring 0 0 35 775775 775Approval, submission toDistrictAdmin labor recurring 0 0 15 332332 332Plan event Admin labor recurring 0 0 4 8989 89 89 89 89Employee time to attend Employee labor recurring 0 0 37.5 831831 831 831 831 831Employee time to hosteventAdmin labor recurring 0 0 2 4444 44 44 44 44Materials from District Materials recurring 0 0 0 00000Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222 22 22 22 22Time to fill out form Admin labor one-time 1 22 22 0 0 22Request and distributematerialsAdmin labor recurring 0 0 1 2222 22 22 22 22Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222 22 22 22 22Develop policy andproceduresAdmin labor one-time 8 177 177 0 0 177Organize/post info Admin labor recurring 0 0 4 8989 89 89 89 89Accounting - for transitpassesAdmin labor recurring 0 0 6 133133 133 133 133 133Energy consumptionand spaceMaterials recurring 0 0 0 00000Initial purchases & setupMaterials one-time 2 44 55 99 0 0 99Update informationQuarterlyAdmin labor recurring 0 0 4 8989 89 89 89 89Onsite transit information centerDistribute CEO letter/emailDistribute District information to employeesRegister with local rideshare agencyEmployer Trip Reduction Implementation Plan (ETRIP)E-mail blasts to employeesHost a Rideshare eventAnnual Report starting in 2015MARKETING STRATEGYTier One Worksites Annual TotalOne-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsReceive training at a District marketing classRideshare & alternative transportation bulletin boardsC-12Final Staff Reportwith Appendices for Rule 9410Attachment 1: Tier 1 Estimated Costs for Feasible ETRIPRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsAnnual class Admin labor recurring 0 0 6 133133 133 133 133 133Prepare using DistricttemplatesAdmin labor recurring 0 0 4 8989 89 89 89 89Paper and ink Materials recurring 0 0 80 80 80 80 80 80Download forms Admin labor one-time 0.5 11 11 0 0 11Complete/submit forms Admin labor one-time 1.5 33 33 0 0 33Develop policy andproceduresAdmin labor one-time 8 177 177 0 0 177Policy development Admin labor one-time 8 177 177 0 0 177Outreach to Employees Admin labor one-time 2 44 44 0 0 442 requests/month Admin labor recurring 0 0 2 4444 44444444Outreach to employees Admin labor one-time 2 44 44 0 0 44SERVICES AND FACILITES STRATEGYSolicit and reviewproposalsAdmin labor one-time 16 354 354 0 0 354Service contractpreparationAdmin labor one-time 16 354 354 0 0 354Space required is 100sq. feet (machines - 1soft drink and 1 snack)space costs,$/sq. ft./monthrecurring 0 0 160 160 160 160 160Electricity costs -operate 24/7 – power isalready availablesame cost asrefrigeratorrecurring 0 0 428 428 428 428 428Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0 532Contract preparation Admin labor one-time 24 532 532 0 0 532Refrigerator delivery fee capital 0 947 154 0 154 154 154Microwave oven capital 0 262 43 0 43 43 432 dining tables and 8chairscapital 0 950 155 0 155 155 155Cabinets, Counter, Sink- 6 feetcapital 0 2,016 328 0 328 328 328Space required is 200sq. feetcost, $/sq.ft./monthrecurring 0 0 320 320 320 320 320Cleaning Labor/month recurring 0 0 20 443 443 443 443 443Supplies recurring 0 0 240 240 240 240 240Cost for 150 employees Cost per employerecurring 0 0 17938 17,938 17938 17938 17938Savings - Postage &Printing0 0 -22227 (22,227) -22227 -22227 -22227Prepare policy andproceduresAdmin labor one-time 8 177 177 0 0 177Postal ServiceDirect Deposit PayrollOnsite Breakroom and KitchenetteOn-site Vending MachinesExternal Employee Ride Matching ProgramInternal Guarenteed Ride Home ServiceAdministrativePROGRAM SUPPORT STRATEGYHealthy Air Living PartnerEmployer rideshare newsletterC-13Final Staff Reportwith Appendices for Rule 9410Attachment 1: Tier 1 Estimated Costs for Feasible ETRIPRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsBalance accounts,purchase and sellstamps, inventorystampsAdmin labor recurring 0 0 4 8989 89 89 89Policy development Admin labor one-time 8 177 177 0 0 177Coordinate information Admin labor recurring 0 0 6 133133 133 133Provide information toemployeesAdmin labor recurring 0 0 4 8989 89 89Policy development Admin labor one-time 8 177 177 0 0 177INCENTIVES STRATEGYPainting & StencilingbumpersLabor one-time 3 66 66 0 0 66Materials - paint &stencilsone-time 165 165 0 0 165Development of policyand proceduresAdmin labor one-time 6 133 133 0 0 133Balance accounts,purchase and distributepasses, inventorypassesAdmin labor recurring 0 0 8 177177 177 177Notes and assumptionsNumber of employees 150Labor rate for wages,benefits, overhead$22.15Sales tax rate, $/$1.00 0.09Electricity costs $/kwhr 0.15Cost recovery factor forannualized costs0.1627Material costs includessupplies and smallequipmentcostsDiscount Transit PassesPreferencial ParkingStaggered Work SchedulesCarpool ProgramTRANSPORTATION AND ALTERNATIVE SCHEDULES STRATEGYC-14Final Staff Reportwith Appendices for Rule 9410Attachment 2: Tier 2 Estimated Costs for Feasible ETRIPRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+44 1816 5635 3604 5143 6827ADMINISTRATIVE REQUIREMENTS($/yr)Employer RegistrationAdmin labor one-time 2 44 44 0 0 44Notify Employees Admin labor one-time 2 44 44 0 0 44Develop each phase ofETRIPAdmin labor recurring 0 0 80 1,7721,772 1772 1772 1772Preparation Admin labor recurring 0 0 20 443443 443 443Distribution Admin labor recurring 0 0 20 443443 443 443Completion byemployeesEmployee laborecurring 0 0 175 3,8763,876 3876 3876Materials Materials recurring 0 0 100 100 100 100Compile Survey Results Admin labor recurring 0 0 40 886886 886Revise ETRIP Admin labor recurring 0 0 40 886886 886Approval, submission toDistrictAdmin labor recurring 0 0 20 443443 443Plan event Admin labor recurring 0 0 4 8989 89 89 89 89EmployeetimetoattendEmployee laborecurring 0 0 87.5 1,9381,938 1938 1938 1938 1938Employee time to hosteventAdmin labor recurring 0 0 2 4444 44 44 44 44Materials from District Materials recurring 0 0 0 0 0 0 0 0Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222 22 22 22 22Time to fill out form Admin labor one-time 1 22 22 0 0 22 0 0 0Request and distributematerialsAdmin labor recurring 0 0 1 2222 22 22 22 22Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222 22 22 22 22Develop policy andproceduresAdmin labor one-time 8 177 177 0 0 177Organize/post info Admin labor recurring 0 0 4 8989 89 89 89 89Accounting - for transitpassesAdmin labor recurring 0 0 8 177177 177 177 177 177Energy consumptionand spaceMaterial recurring 0 0 0 0 0 0 0 0Rideshare & alternative transportation bulletin boardsInitial purchases & setupMaterials one-time 2 44 55 99 0 0 99Update informationQuarterlyAdmin labor recurring 0 0 4 8989 89 89 89 89One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsEmployer Trip Reduction Implementation Plan (ETRIP)Tier Two Worksites Annual TotalRegister with local rideshare agencyE-mail blasts to employeesAnnual Report starting in 2015Survey 2x/yr starting in 2014Host a Rideshare eventMARKETING STRATEGYReceive training at a District marketing classOnsite transit information centerDistribute CEO letter/emailDistribute District information to employeesC-15Final Staff Reportwith Appendices for Rule 9410Attachment 2: Tier 2 Estimated Costs for Feasible ETRIPRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsAnnual class Admin labor recurring 0 0 6 133133 133 133 133 133Prepare using DistricttemplatesAdmin labor recurring 0 0 6 133133 133 133 133 133Paper and ink Materials recurring 0 0 120 120 120 120 120 120Download forms Admin labor one-time 0.5 11 11 0 0 11Complete/submit forms Admin labor one-time 1.5 33 33 0 0 33Develop policy andproceduresAdmin labor one-time 8 177 177 0 0 177Policy development Admin labor one-time 8 177 177 0 0 177Outreach to Employees Admin labor one-time 4 89 89 0 0 895 requests/month Admin labor recurring 0 0 5 111111 111111111111Outreach to employees Admin labor one-time 4 89 89 0 0 89Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0 354Service contractpreparationAdmin labor one-time 16 354 354 0 0 354Space required is 300sq. feet (machines - 6soft drink and 6 snacks)space costs,$/sq. ft./monthrecurring 0 0 480 480 480 480 480Electricity costs -operate 24/7 – power isalready availablesame cost asrefrigeratorrecurring 0 0 428 428 428 428 428Space (outdoor)required is 100 sq. feetper rack for 6 bicyclesNo cost recurring 0 0 0 0 0 0 03 Racks – 6bicycles/rackCost & laborto installcapital 0 1,377 224 0 224 224 224Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0 532Contract preparation Admin labor one-time 24 532 532 0 0 5323 Refrigerators delivery fee capital 0 2,621 426 0 426 426 4265 Microwave ovens delivery fee capital 0 1,474 240 0 240 240 2405 dining tables and 20chairsdelivery fee capital 0 3,161 514 0 514 514 514Cabinets, Counter, Sink- 5 x 6 feetcapital 0 10,081 1640 0 1640 1640 1640Space required is 3 x100 sq. feetcost, $/sq.ft./monthrecurring 0 0 480 480 480 480 480Cleaning Labor/month recurring 0 0 20 443 443 443 443 443Supplies recurring 0 0 720 720 720 720 720AdministrativePROGRAM SUPPORT STRATEGYHealthy Air Living PartnerEmployer rideshare newsletterOnsite Breakroom and KitchenetteExternal Employee Ride Matching ProgramInternal Guarenteed Ride Home ServiceSERVICES AND FACILITES STRATEGYBicycle RacksOn-site Vending MachinesC-16Final Staff Reportwith Appendices for Rule 9410Attachment 2: Tier 2 Estimated Costs for Feasible ETRIPRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsPrepare policy andproceduresAdmin labor one-time 16 354 354 0 0 354Set up costs (assumepayroll is processedelectronically)Admin labor one-time 20 443 443 0 0 443Balance accounts,process checksAdmin labor recurring 0 0 15 332332 332 332 332Cost for 350 employees Cost per emplorecurring 0 0 29768 29,768 29768 29768 29768Savings - Postage &Printing0 0 -39776 (39,776) -39776 -39776 -39776Prepare policy andproceduresAdmin labor one-time 8 177 177 0 0 177Balance accounts,purchase and sellstamps, inventorystampsAdmin labor recurring 0 0 8 177177 177 177 177Policy development Admin labor one-time 8 177 177 0 0 177Coordinate information Admin labor recurring 0 0 8 177177 177 177Provide information toemployeesAdmin labor recurring 0 0 8 177177 177 177Policy development Admin labor one-time 8 177 177 0 0 177Coordinate information Admin labor recurring 0 0 8 177177 177 177Provide information toemployeesAdmin labor recurring 0 0 6 133133 133 133Development of policyand proceduresAdmin labor one-time 8 177 177 0 0 177Incentive10%employeeparticipationrecurring 0 0 0 0 0 0Notes and assumptionsNumber of employees 350Labor rate for wages,benefits, overhead$22.15Sales tax rate, $/$1.00 0.09Electricity costs $/kwhr 0.15Cost recovery factor forannualized costs0.1627Material costs includessupplies and smallequipmentcostsCheck CashingPostal ServiceTRANSPORTATION AND ALTERNATIVE SCHEDULES STRATEGYMonetary IncentiveCarpool ProgramVanpool ProgramINCENTIVES STRATEGYDirect Deposit PayrollC-17Final Staff Reportwith Appendices for Rule 9410Attachment 3: MSPA Tier 1 Worksites Estimated Costs for Feasible ETRIPRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+44 1373 1734 4733 4413 6295ADMINISTRATIVE REQUIREMENTS($/yr)Employer RegistrationAdmin labor one-time 2 44 44 0 0 44Notify Employees Admin labor one-time 2 44 44 0 0 44Develop each phase ofETRIPAdmin labor recurring 0 0 60 1,3291,329 1329 1329Survey 2x/yr starting in 2014Preparation Admin labor recurring 0 0 1 2222 22 22Distribution Admin labor recurring 0 0 1 2222 22 22Completion byemployeesEmployee labor recurring 0 0 75 1,6611,661 1661 1661Materials Materials recurring 0 100 100 100 100Compile Survey Results Admin labor recurring 0 0 35 775775 775Revise ETRIP Admin labor recurring 0 0 35 775775 775Approval, submission toDistrictAdmin labor recurring 0 0 15 332332 332Initial purchases & setupMaterials one-time 2 44 55 99 0 0 99Update informationQuarterlyAdmin labor recurring 0 0 1 2222 22 22 22 22Annual class Admin labor recurring 0 0 6 133133 133 133 133 133Outreach to Employees Admin labor one-time 2 44 44 0 0 44Paper and ink Materials one-time 0.2 4 58.00 620 62Outreach to employees Admin labor one-time 2 44 44 0 0 44SERVICES AND FACILITES STRATEGYSolicit and reviewproposalsAdmin labor one-time 24 532 532 0 0 532Contract preparation Admin labor one-time 24 532 532 0 0 532Refrigerator delivery fee capital 0 947 154 0 154 154 154Microwave oven capital 0 262 43 0 43 43 432 dining tables and 8chairscapital 0 950 155 0 155 155 155Cabinets, Counter, Sink- 6 feetcapital 0 2,016 328 0 328 328 328Space required is 200sq. feetcost, $/sq.ft./monthrecurring 0 0 320 320 320 320 320Cleaning Labor/month recurring 0 0 20 443 443 443 443 443Supplies recurring 0 0 240 240 240 240 240Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0 354External Employee Ride Matching ProgramPROGRAM SUPPORT STRATEGYOnsite Breakroom and KitchenetteOn-site Vending MachinesRideshare mapReceive training at a District marketing classRideshare & alternative transportation bulletin boardsEmployer Trip Reduction Implementation Plan (ETRIP)Annual Report starting in 2015MARKETING STRATEGYMSPA Worksites Annual Total(Omitting Phase 3 Costs)One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsC-18Final Staff Reportwith Appendices for Rule 9410Attachment 3: MSPA Tier 1 Worksites Estimated Costs for Feasible ETRIPRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsService contractpreparationAdmin labor one-time 16 354 354 0 0 354Space required is 100sq. feet (machines - 1soft drink and 1 snack)space costs,$/sq. ft./monthrecurring 0 0 160 160 160 160 160Electricity costs -operate 24/7 – power isalready availablesame cost asrefrigeratorrecurring 0 0 428 428 428 428 428Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0 354Space (outdoor)requiredNo cost recurring 0 0 0 0 02 6' Picnic Table Equipment capital 0 0 1120.00 182 0 182 182 182Notes and assumptionsNumber of employees 150Labor rate for wages,benefits, overhead$22.15Sales tax rate, $/$1.00 0.09Electricity costs $/kwhr 0.15Cost recovery factor forannualized costs0.1627Material costs includessupplies and smallequipmentcostsOnsite picnic tablesC-19Final Staff Reportwith Appendices for Rule 9410Attachment 4: MSPA Tier 2 Worksites Estimated Costs for Feasible ETRIPRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+44 1816 2399 9714 9729 11944ADMINISTRATIVE REQUIREMENTS($/yr)Employer RegistrationAdmin labor one-time 2 44 44 0 0 44Notify Employees Admin labor one-time 2 44 44 0 0 44Develop each phase ofETRIPAdmin labor recurring 0 0 80 1,7721,772 1772 1772 1772Preparation Admin labor recurring 0 0 1 2222 22 22Distribution Admin labor recurring 0 0 1 2222 22 22Completion byemployeesEmployee laborecurring 0 0 175 3,8763,876 3876 3876Materials Materials recurring 0 0 100 100 100 100Compile Survey Results Admin labor recurring 0 0 40 886886 886Revise ETRIP Admin labor recurring 0 0 40 886886 886Approval, submission toDistrictAdmin labor recurring 0 0 20 443443 443Rideshare & alternative transportation bulletin boardsInitial purchases & setupMaterials one-time 2 44 55 99 0 0 99Update informationQuarterlyAdmin labor recurring 0 0 1 2222 22 22 22 22Annual class Admin labor recurring 0 0 1 2222 22 22 22 22District providednewsletterAdmin labor recurring 0 0 1 2222 22 22 22 22Paper and ink Materials recurring 0 0 0 0 0 0 0 0District provided flyer Admin labor recurring 0 0 1 2222 22 22 22 22Paper and ink Materials recurring 0 0 0 0 0 0 0 0Outreach to Employees Admin labor one-time 2 44 44 0 0 44Paper and ink Materials one-time 0.2 4 58.00 62 0 62Outreach to employees Admin labor one-time 4 89 89 0 0 89Policy development Admin labor one-time 8 177 177 0 0 177Outreach to Employees Admin labor one-time 2 44 44 0 0 442 requests/month Admin labor recurring 0 0 2 2222 22 22 22 22Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0 532Contract preparation Admin labor one-time 24 532 532 0 0 5323 Refrigerators delivery fee capital 0 2,621 426 0 426 426 4265 Microwave ovens delivery fee capital 0 1,474 240 0 240 240 240SERVICES AND FACILITES STRATEGYOnsite Breakroom and KitchenetteRideshare mapPROGRAM SUPPORT STRATEGYMARKETING STRATEGYEmployer rideshare newsletterReceive training at a District marketing classRideshare flyerInternal Guarenteed Ride Home ServiceOne-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital CostsEmployer Trip Reduction Implementation Plan (ETRIP)MSPA Worksites Annual Total(Omitting Phase 3 Costs)Annual Report starting in 2015Survey 2x/yr starting in 2014External Employee Ride Matching ProgramC-20Final Staff Reportwith Appendices for Rule 9410Attachment 4: MSPA Tier 2 Worksites Estimated Costs for Feasible ETRIPRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)2010 2011 2012 2013 2014 2015+One-Time Costs Recurring Costs Total Costs Each Year ($/yr)Capital Costs5 dining tables and 20chairsdelivery fee capital 0 3,161 514 0 514 514 514Cabinets, Counter, Sink- 5 x 6 feetcapital 0 10,081 1640 0 1640 1640 1640Space required is 3 x100 sq. feetcost, $/sq.ft./monthrecurring 0 0 480 480 480 480 480Cleaning Labor/month recurring 0 0 20 443 443 443 443 443Supplies recurring 0 0 720 720 720 720 720Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0 354Service contractpreparationAdmin labor one-time 16 354 354 0 0 354Space required is 300sq. feet (machines - 6soft drink and 6 snacks)space costs,$/sq. ft./monthrecurring 0 0 480 480 480 480 480Electricity costs -operate 24/7 – power isalready availablesame cost asrefrigeratorrecurring 0 0 428 428 428 428 428Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0 354Space (outdoor)requiredNo cost recurring 0 0 0 0 02 6' Picnic Table Equipment capital 0 0 1120.00 182 0 182 182 182Outreach to Employees Admin labor one-time 2 44 44 0 0 44Paper and ink Materials one-time 0.2 4 58.00 62 0 62Organize/post info Admin labor recurring 0 0 2 4444 44 44 44Notes and assumptionsNumber of employees 350Labor rate for wages,benefits, overhead$22.15Sales tax rate, $/$1.00 0.09Electricity costs $/kwhr 0.15Cost recovery factor forannualized costs0.1627Material costs includessupplies and smallequipmentcostsOnsite picnic tablesMap to local conveniencesOn-site Vending MachinesC-21Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)Employer RegistrationAdmin labor one-time 2 44 44 0 0TOTAL44 0 0Notify Employees Admin labor one-time 2 44 44 0 0Develop each phase ofETRIPAdmin labor recurring 0 0 60 1,3291,329TOTAL44 0 1329Preparation Admin labor recurring 0 0 15 332332Distribution Admin labor recurring 0 0 15 332332Completion byemployeesEmployee labor recurring 0 0 75 1,6611,661Materials Materials recurring 0 0 100 100TOTAL0 0 2426Compile Survey Results Admin labor recurring 0 0 35 775775Revise ETRIP Admin labor recurring 0 0 35 775775Approval, submission toDistrictAdmin labor recurring 0 0 15 332332TOTAL0 0 1883Download forms Admin labor one-time 0.5 11 11 0 0Complete/submit forms Admin labor one-time 1.5 33 33 0 0Develop policy andproceduresAdmin labor one-time 8 177 177 0 0TOTAL222 0 0Plan event Admin labor recurring 0 0 4 8989Employee time toattendEmployee labor recurring 0 0 37.5 831831Employee time to hosteventAdmin labor recurring 0 0 2 4444Materials from District Materials recurring 0 0 0 0TOTAL0 0 964One-Time Costs Recurring CostsCapital CostsEmployer Trip Reduction Implementation Plan (ETRIP)ADMINISTRATIVE REQUIREMENTSSurvey 2x/yr starting in 2014Annual Report starting in 2015MARKETING STRATEGYHealthy Air Living PartnerAdministrativeHost a Rideshare eventC- 22Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsPrepare using DistricttemplatesAdmin labor recurring 0 0 1 2222TOTAL0 0 22Time to fill out form Admin labor one-time 1 22 22 0 0TOTAL22 0 0Request and distributematerialsAdmin labor recurring 0 0 1 2222TOTAL0 0 22Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222TOTAL0 0 22Develop policy andproceduresAdmin labor one-time 8 177 177 0 0Organize/post info Admin labor recurring 0 0 4 8989Accounting - for transitpassesAdmin labor recurring 0 0 6 133133Energy consumptionand spaceMaterials recurring 0 0 0 0TOTAL177 0 222Initial purchases & setupMaterials one-time 2 44 55 99 0 0Update informationQuarterlyAdmin labor recurring 0 0 4 8989TOTAL99 0 89Annual class Admin labor recurring 0 0 6 133133TOTAL0 0 133Prepare using DistricttemplatesAdmin labor recurring 0 0 4 8989Paper and ink Materials recurring 0 0 80 80E-mail blasts to employeesRegister with local rideshare agencyDistribute District information to employeesDistribute CEO letter/emailOnsite transit information centerRideshare & alternative transportation bulletin boardsReceive training at a District marketing classEmployer rideshare newsletterC- 23Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsTOTAL0TOTAL for Healthy Air Living Partner 520 0 1473Semiannual meetings Admin labor recurring 0 0 5 111111Employee Attendance Employee labor recurring 0 0 150 3,3233,323Energy, space,materialsMaterials recurring 0 0 0 0TOTAL0 0 3433Semiannual meetings Admin labor recurring 0 0 5 111111Employee Attendance Employee labor recurring 0 0 20 443443Energy, space,materialsMaterials recurring 0 0 0 0TOTAL0 0 554Complete a new applicatAdmin labor one-time 2 44 44 0 0Collect supporting materiAdmin labor one-time 0.5 11 11 0 0Annual Status UpdateAdmin labor recurring 1 22 22 0 0Annual Membership Feerecurring 0 0 230 230TOTAL78 0 230Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222Paper and ink Materials recurring 0 0 40 40TOTAL0 0 62Initial development Admin labor one-time 4 89 89 0 0Presentation to newemployeesEmployee labor recurring 0 0 0.8 1818Paper, ink Materials recurring 0 0 0 0TOTAL89 0 18Initial development Admin labor one-time 4 89 89 0 0TOTAL89 0 0PROGRAM SUPPORT STRATEGYRideshare & alternative transportation meetingsRideshare & alternative transportation focus group"Best Workplaces for Commuters" RecognitionRideshare flyerRideshare orientation for new employeesEmployer-adopted alternative transportation policy statementC- 24Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsDevelop application one-time 450 9968 9968 0 0Outreach to Employees Admin labor one-time 1 22 22 0 0TOTAL9990 0 0Outreach to employees Admin labor one-time 2 44 44 0 0TOTAL44 0 0Research and postinformationone-time 1 22 22 0 0Annual Outreach toemployeesAdmin labor recurring 0 0 1 2222TOTAL22 0 22Policy development Admin labor one-time 8 177 177 0 0Outreach to Employees Admin labor one-time 2 44 44 0 02 requests/month Admin labor recurring 0 0 2 4444TOTAL222 0 44Policy development Admin labor one-time 8 177 177 0 0TOTAL177 0 0Outreach to Employees Admin labor one-time 2 44 44 0 0Paper and ink Materials one-time 0.2 4 58.00 62 0TOTAL107 0 0Develop policy andproceduresAdmin labor one-time 4 89 89 0 0Organize/post info Admin labor recurring 0 0 2 4444Outreach to Employees Admin labor one-time 2 44 44 0 0TOTAL133 0 44Develop policy andproceduresAdmin labor one-time 4 89 89 0 0Organize/post info Admin labor recurring 0 0 1 1111SERVICES AND FACILITES STRATEGYInternal Ride MatchingExternal Employee Ride Matching ProgramPersonalized commute assistanceInternal Guarenteed Ride Home ServiceExternal Guaranteed Ride Home ServiceRideshare mapOnsite/Local Food ServiceOnsite/Local Child CareC- 25Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsOutreach to Employees Admin labor one-time 2 44 44 0 0TOTAL133 0 11Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0Contract preparation Admin labor one-time 24 532 532 0 010 x 12 feet bathroomwith closet (ProjectCost)one-time 0 26250 4271 0Cleaning Labor/month recurring 0 0 20 443443TOTAL1063 4271 443Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0Contract preparation Admin labor one-time 24 532 532 0 0Refrigerator delivery fee capital 0 947 154 0Microwave oven capital 0 262 43 02 dining tables and 8chairscapital 0 950 155 0Cabinets, Counter, Sink- 6 feetcapital 0 2,016 328 0Space required is 200sq. feetcost, $/sq.ft./monthrecurring 0 0 320 320Cleaning Labor/month recurring 0 0 20 443 443Supplies recurring 0 0 240 240TOTAL1063 679 1003Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Service contract one-time 0 9260 9260 0 0Electricity costs - ownerpays (like getting gas)00 0TOTAL9614 0 0Develop policy andproceduresAdmin labor one-time 4 89 89 0 0Showers and Lockers OnsiteOnsite Breakroom and KitchenetteElectric Vehicle RechargingOnsite Bike RepairC- 26Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsSpace (outdoor)requiredNo cost recurring 0 0 0 0Outreach to Employees Admin labor one-time 2 44 44 0 0TOTAL133 0 0Solicit and reviewproposalsAdmin labor recurring 16 354 354 0 0Space required is 100sq. feetspace costs,$/sq. ft./monthrecurring 40.00 40 0 0TOTAL394 0 0Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Service contractpreparationAdmin labor one-time 16 354 354 0 0Space required is 100sq. feet (machines - 1soft drink and 1 snack)space costs,$/sq. ft./monthrecurring 0 0 160 160Electricity costs -operate 24/7 – power isalready availablesame cost asrefrigeratorrecurring 0 0 428 428TOTAL709 0 588Space (outdoor)required is 100 sq. feetper rack for 6 bicyclesNo cost recurring 0 0 0 02 Racks – 6bicycles/rackCost & labor toinstallcapital 0 1,048 171 0TOTAL0 171 0Develop policy andproceduresAdmin labor one-time 6 133 133 0 0Space required No cost recurring 0 0 0 0Outreach to Employees Labor recurring 0 0 0 2 4444TOTAL133 0 44Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Onsite ATMOnsite Vending MachinesBicycle RacksHealth FacilitiesEmployer provided bicyclesC- 27Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsSpace required is 100sq. feetspace costs,$/sq. ft./monthrecurring 0 0 160 1605 Bikes capital 0 750.00 198 0Tire pump capital 0 24.00 6 05 Helmets capital 0 100.00 26 05 Locks capital 0 70.00 18 0TOTAL354 249 160Develop policy andproceduresAdmin labor one-time 6 133 133 0 0Space required No cost recurring 0 0 0 0Setup/Cleanup Labor recurring 0 0 0 12 266266Outreach to Employees Labor recurring 0 0 0 3 6666TOTAL133 0 332Coordinate anddistribute lunchAdmin labor recurring 0 0 534 11,82811,828Gas for employervehiclerecurring 0 0 30 30Process forms &paymentAdmin labor recurring 0 0 438 9,7029,702TOTAL0 0 21560Cost for 150 employees Cost per employerecurring 0 0 17938 17,938Savings - Postage &Printing0 0 -22227 (22,227)TOTAL0 0 -4289Prepare policy andproceduresAdmin labor one-time 16 354 354 0 0Set up costs (assumepayroll is processedelectronically)Admin labor one-time 20 443 443 0 0Balance accounts,process checksAdmin labor recurring 0 0 10 222222TOTAL797 0 222Employer Organized Lunch Delivery (twice/month)Direct Deposit PayrollCheck CashingBreak and/or Lunch ActivitiesFitness Area and/or ClassesC- 28Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsSetup/Cleanup Labor recurring 0 0 0 30 665665Outreach to Employees Labor recurring 0 0 0 7 159159TOTAL0 0 824Prepare policy andproceduresAdmin labor one-time 4 89 89 0 0Outreach to Employees Labor recurring 0 0 0 2 4444TOTAL89 0 44Prepare policy andproceduresAdmin labor one-time 8 177 177 0 0Balance accounts,purchase and sellstamps, inventorystampsAdmin labor recurring 0 0 4 8989TOTAL177 0 89Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Space (outdoor)requiredNo cost recurring 0 0 0 02 6' Picnic Table Equipment capital 0 0 1120.00 182 0TOTAL354 182 0Outreach to Employees Admin labor one-time 2 44 44 0 0Paper and ink Materials one-time 0.2 4 58.00 62 0Organize/post info Admin labor recurring 0 0 2 4444TOTAL107 0 44Policy development Admin labor one-time 12 266 266 0 0TOTAL266 0 0Policy development Admin labor one-time 12 266 266 0 -0Dry CleaningPostal ServiceCompressed Work Week SchedulesTelecommuting ProgramOnsite picnic tablesMap to local conveniencesTRANSPORTATION AND ALTERNATIVE SCHEDULES STRATEGYC- 29Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsAlternate SiteInspectionsAdmin andEmployeeLaborrecurring 22.5 498 23 498 997 3 663 66133TrainingAdmin andEmployeeLaborrecurring 7.5 166 7.5 166 332 1 2212244Provide information toemployeesAdmin labor recurring 2 44 44 0 2 4444TOTAL1639 0 222Policy development Admin labor one-time 8 177 177 0 0Coordinate information Admin labor recurring 0 0 6 133133Provide information toemployeesAdmin labor recurring 0 0 4 8989TOTAL177 0 222Policy development Admin labor one-time 8 177 177 0 0Coordinate information Admin labor recurring 0 0 6 133133Provide information toemployeesAdmin labor recurring 0 0 4 8989TOTAL177 0 222Policy development Admin labor one-time 8 177 177 0 0Coordinate information Admin labor recurring 0 0 6 133133Provide information toemployeesAdmin labor recurring 0 0 4 8989Space (outside)required is 100 sq. feetper rack for 6 bicyclesNo cost recurring 0 0 0 02 Racks – 6bicycles/rackCost & labor toinstallcapital 0 1,048 171 0Storage capital 0 396 64 0Repair Kit capital 0 17 3 0TOTAL177 238 222Solicit and reviewproposalsAdmin labor one-time 16 354 354 0Vanpool ProgramCarpool ProgramBicycle ProgramShuttlesC- 30Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsContract Information Admin labor one-time 16 354 354 0Shuttle (Extended Van)5 years, 6%Interestcapital 0 41179 8,055 0Gas recurring 0 4529 4,529Maintenance recurring 0 5460 5,460Insurance recurring 0 7153 7,153Outreach to Employees Admin labor one-time 2 44 44 0TOTAL753 8055 17142Policy development Admin labor one-time 8 177 177 0 0TOTAL177 0 0Policy development Admin labor one-time 8 177 177 0 0TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive10% employeeparticipationrecurring 0 3240 3,240IncentiveCompensationPackagerecurring 0 0 -3240 (3,240)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive10% employeeparticipationrecurring 0 1803987 3,987IncentiveCompensationPackagerecurring 0 0 -3987 (3,987)TOTAL177 0 0Vanpool SubsidyFlex Work SchedulesStaggered Work SchedulesMonetary IncentiveExtra Time OffINCENTIVES STRATEGYC- 31Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsDevelopment of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive8% employeeparticipationrecurring 0 2400 2,400IncentiveCompensationPackagerecurring 0 0 -2400 (2,400)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive1% employeeparticipationrecurring 0 360 360IncentiveCompensationPackagerecurring 0 0 -360 (360)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive1% employeeparticipationrecurring 0 360 360IncentiveCompensationPackagerecurring 0 0 -360 (360)TOTAL1770 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive10% employeeparticipationrecurring 0 2250 2,250IncentiveCompensationPackagerecurring 0 0 -2250 (2,250)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 6 133 133 0 0Balance accounts,purchase and distributepasses, inventorypassesAdmin labor recurring 0 0 8 177177Discount Transit PassesTransit SubsidyBicycle SubsidyStartup IncentiveC- 32Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsTOTAL133 0 177Development of policyand proceduresAdmin labor one-time 4 89 89 0 050% discount meal(1/month)10% employeeparticipationrecurring 0 0 630 630Coordinate anddistribute mealsrecurring 0 0 3 6666TOTAL89 0 696Painting & StencilingbumpersLabor one-time 3 66 66 0 0Materials - paint &stencilsMaterials one-time 165 165 0 0TOTAL231 0 0Development of policyand proceduresAdmin labor one-time 4 89 89 0 0Outreach to employees Admin labor one-time 1 22 22 0 0Track employee points,give out prizesAdmin labor recurring 0 0 25 554554PrizeSome providedby Districtrecurring 0 0 80 80TOTAL111 0 634Development of policyand proceduresAdmin labor one-time 4 89 89 0 0Outreach to employees Admin labor one-time 1 22 22 0 0Receive entries,drawing, notifyemployeesAdmin labor recurring 0 0 2 4444Prize recurring 0 0 80 80TOTAL111 0 124Notes and assumptionsNumber of employees 150Labor rate for wages,benefits, overhead$22.15Prize DrawingDiscounted MealsPreferencial ParkingPoints ProgramC- 33Final Staff Reportwith Appendices for Rule 9410Attachment 5: Tier One Estimated Costs for Every Menu OptionRule ElementDescription ofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsSales tax rate, $/$1.00 0.09Electricity costs $/kwhr 0.15Cost recovery factor forannualized costs0.1627Cost recovery factor forannualized costs (5years)0.26380Material costs includessupplies and smallequipmentcostsC- 34Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)Employer RegistrationAdmin labor one-time 2 44 44 0 0TOTAL44 0 0Notify Employees Admin labor one-time 2 44 44 0 0Develop each phase ofETRIPAdmin labor recurring 0 0 80 1,7721,772TOTAL44 0 1772Preparation Admin labor recurring 0 0 20 443443Distribution Admin labor recurring 0 0 20 443443Completion byemployeesEmployee laborecurring 0 0 175 3,8763,876Materials Materials recurring 0 0 100 100TOTAL0 0 4862Compile Survey Results Admin labor recurring 0 0 40 886886Revise ETRIP Admin labor recurring 0 0 40 886886Approval, submission toDistrictAdmin labor recurring 0 0 20 443443TOTAL0 0 2215AdministrativeDownload forms Admin labor one-time 0.5 11 11 0 0Complete/submit forms Admin labor one-time 1.5 33 33 0 0Develop policy andproceduresAdmin labor one-time 8 177 177 0 0TOTAL222 0 0Plan event Admin labor recurring 0 0 4 8989Employee time to attend Employee laborecurring 0 0 87.5 1,9381,938Employee time to hosteventAdmin labor recurring 0 0 2 4444Materials from District Materials recurring 0 0 0 0TOTAL0 0 2071Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222TOTAL0 0 22MARKETING STRATEGYOne-Time Costs Recurring CostsCapital CostsADMINISTRATIVE REQUIREMENTSEmployer Trip Reduction Implementation Plan (ETRIP)Survey 2x/yr starting in 2014Annual Report starting in 2015Healthy Air Living PartnerHost a Rideshare eventE-mail blasts to employeesC-35Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsTime to fill out form Admin labor one-time 1 22 22 0 0TOTAL22 0 0Request and distributematerialsAdmin labor recurring 0 0 1 2222TOTAL0 0 22Prepare using DistricttemplatesAdmin labor recurring 0 0 1 2222TOTAL0 0 22Develop policy andproceduresAdmin labor one-time 8 177 177 0 0Organize/post info Admin labor recurring 0 0 4 8989Accounting - for transitpassesAdmin labor recurring 0 0 8 177177Energy consumptionand spaceMaterial recurring 0 0 0 0TOTAL177 0 266Initial purchases & setupMaterials one-time 2 44 55 99 0 0Update informationQuarterlyAdmin labor recurring 0 0 4 8989TOTAL99 0 89Annual class Admin labor recurring 0 0 6 133133TOTAL0 0 133Prepare using DistricttemplatesAdmin labor recurring 0 0 6 133133Paper and ink Materials recurring 0 0 120 120TOTAL0TOTAL for Healthy Air Living Partner 520 0 2625Semiannual meetings Admin labor recurring 0 0 5 111111Employee AttendanceEmployeelaborrecurring 0 0 350 7,7537,753Employer rideshare newsletterRideshare & alternative transportation meetingsRegister with local rideshare agencyDistribute District information to employeesDistribute CEO letter/emailOnsite transit information centerRideshare & alternative transportation bulletin boardsReceive training at a District marketing classC-36Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsEnergy, space,materialsMaterials recurring 0 0 0 0TOTAL0 0 7863Semiannual meetings Admin labor recurring 0 0 5 111111Employee AttendanceEmployeelaborrecurring 0 0 20 443443Energy, space,materialsMaterials recurring 0 0 0TOTAL0 0 554Complete a new applicatAdmin labor one-time 2 44 44 0 0Collect supporting materAdmin labor one-time 0.5 11 11 0 0Annual Status UpdateAdmin labor recurring 1 22 22 0 0Annual Membership Feerecurring 230 230 0 0TOTAL308 0 0Prepare using DistricttemplatesAdmin labor recurring 0 0 1 22 22Paper and ink Materials recurring 0 0 40 40TOTAL0 0 62Initial development Admin labor one-time 4 89 89 0 0Presentation to newemployeesEmployeelaborrecurring 0 0 1.7 3737Paper, ink Materials recurring 0 0 0.00 0TOTAL89 0 37Initial development Admin labor one-time 4 89 89 0 0TOTAL89 0 0Develop application one-time 450 9968 9967.5 0 0Outreach to Employees Admin labor one-time 1 22 22 0 0TOTAL9990 0 0Outreach to employees Admin labor one-time 4 89 89 0 0Employer-adopted alternative transportation policy statementPROGRAM SUPPORT STRATEGYExternal Employee Ride Matching ProgramRideshare & alternative transportation focus group"Best Workplaces for Commuters" RecognitionRideshare flyer (quarterly)Rideshare orientation for new employeesInternal Ride MatchingC-37Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsTOTAL89 0 0Research and postinformationone-time 1 22 22 0 0Annual Outreach toemployeesAdmin labor recurring 0 0 1 22 22TOTAL22 0 22Policy development Admin labor one-time 8 177 177 0 0Outreach to Employees Admin labor one-time 4 89 89 0 05 requests/month Admin labor recurring 0 0 5 111111TOTAL266 0 111Policy development Admin labor one-time 8 177 177 0 0TOTAL177 0 0Outreach to Employees Admin labor one-time 2 44 44 0 0Paper and ink Materials one-time 0.2 4 58 62TOTAL107 0 0Develop policy andproceduresAdmin labor one-time 4 89 89 0 0Organize/post info Admin labor recurring 0 0 2 4444Outreach to Employees Admin labor one-time 3 66 66 0 0TOTAL155 0 44Develop policy andproceduresAdmin labor one-time 4 89 89 0 0Organize/post info Admin labor recurring 0 0 0.5 1111Outreach to Employees Admin labor one-time 2 44 44 0 0TOTAL133 0 11Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0Contract preparation Admin labor one-time 24 532 532 0 010 x 12 feet bathroomwith closet (ProjectCost)one-time 0 52500 8542 0Onsite/Local Food ServiceOnsite/Local Child CareShowers and Lockers OnsiteSERVICES AND FACILITES STRATEGYRideshare mapPersonalized commute assistanceInternal Guarenteed Ride Home ServiceExternal Guaranteed Ride Home ServiceC-38Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsCleaning Labor/month recurring 0 0 40 886 886TOTAL1063 8542 886Solicit and reviewproposalsAdmin labor one-time 24 532 532 0 0Contract preparation Admin labor one-time 24 532 532 0 03 Refrigerators delivery fee capital 0 2,621 426 05 Microwave ovens delivery fee capital 0 1,474 240 05 dining tables and 20chairsdelivery fee capital 0 3,161 514 0Cabinets, Counter, Sink- 5 x 6 feetcapital 0 10,081 1640 0Space required is 3 x100 sq. feetcost, $/sq.ft./monthrecurring 0 0 480 480Cleaning Labor/month recurring 0 0 20 443 443Supplies recurring 0 0 720 720TOTAL1063 2821 1643Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Service contract one-time 18519 18519 0 0Electricity costs - ownerpays (like getting gas)00 0TOTAL18873 0 0Develop policy andproceduresAdmin labor one-time 4 0 0 0 0Space (outdoor)requiredNo cost recurring 0 0 0 0Outreach to Employees Admin labor one-time 2 0 0 0 0TOTAL00 0Solicit and reviewproposalsAdmin labor recurring 16 354 354 0 0Space required is 100sq. feetspace costs,$/sq. ft./monthrecurring 0.00 0 0 40 40TOTAL354 0 40Onsite Vending MachinesOnsite Breakroom and KitchenetteElectric Vehicle RechargingOnsite Bike RepairOnsite ATMC-39Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsSolicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Service contractpreparationAdmin labor one-time 16 354 354 0 0Space required is 300sq. feet (machines - 6soft drink and 6 snacks)space costs,$/sq. ft./monthrecurring 0 0 480 480Electricity costs -operate 24/7 – power isalready availablesame cost asrefrigeratorrecurring 0 0 428 428TOTAL709 0 908Space (outdoor)required is 100 sq. feetper rack for 6 bicyclesNo cost recurring 0 0 0 03 Racks – 6bicycles/rackCost & laborto installcapital 0 1,377 224 0TOTAL0 224 0Develop policy andproceduresAdmin labor one-time 6 133 133 0 0Space required No cost recurring 0 0 0 0Outreach to Employees Labor recurring 0 0 4 89 89TOTAL133 0 89Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Space required is 200sq. feetspace costs,$/sq. ft./monthrecurring0 320 32012 Bikes capital 1800.00 4752 Tire pumps capital 48.00 1312 Helmets capital 240.00 6312 Locks capital 168.00 44TOTAL354 249 160Develop policy andproceduresAdmin labor one-time 6 133 133 0 0Space required No cost recurring 0 0 0 0Setup/Cleanup Labor recurring 0 0 15 332 332Outreach to Employees Labor recurring 0 0 4 89 89Bicycle RacksEmployer provided bicyclesHealth FacilitiesFitness Area and/or ClassesC-40Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsTOTAL133 0 421Coordinate anddistribute lunchAdmin labor recurring0 192 4253 4,253Gas for employervehiclerecurring0 0 30 30Process forms &paymentAdmin labor recurring0 876 19403 19,403TOTAL0 0 23686Cost for 350 employees Cost per emplorecurring 0 0 29768 29,768Savings - Postage &Printing0 0 -39776 (39,776)TOTAL0 0 -10009Prepare policy andproceduresAdmin labor one-time 16 354 354 0 0Set up costs (assumepayroll is processedelectronically)Admin labor one-time 20 443 443 0 0Balance accounts,process checksAdmin labor recurring 0 0 15 332332TOTAL797 0 332Setup/Cleanup Labor recurring 0 0 30 665 665Outreach to Employees Labor recurring0 7 159 159TOTAL0 0 824Prepare policy andproceduresAdmin labor one-time 4 89 89 0 0Outreach to Employees Labor recurring 0 0 2 44 44TOTAL89 0 44Prepare policy andproceduresAdmin labor one-time 8 177 177 0 0Balance accounts,purchase and sellstamps, inventorystampsAdmin labor recurring 0 0 8 177177TOTAL177 0 177Check CashingBreak and/or Lunch ActivitiesDry CleaningEmployer Organized Lunch Delivery (twice/month)Direct Deposit PayrollPostal ServiceC-41Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsSolicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Space (outdoor)requiredNo cost recurring 0 0 0 03 6' Picnic Table Equipment capital 0 0 1680.00 273 0TOTAL354 273 0Outreach to Employees Admin labor one-time 2 44 44 0 0Paper and ink Materials one-time 0.2 4 58.00 620Organize/post info Admin labor recurring 0 0 2 4444TOTAL107 0 440Policy development Admin labor one-time 12 266 266 0 0TOTAL266 0 0Policy development Admin labor one-time 12 266 266 0 -0Alternate SiteInspectionsAdmin andEmployeeLaborrecurring 52.5 1163 53 0 1163 5 1115 111222TrainingAdmin andEmployeeLaborrecurring 17.5 388 18 0 388 2 4424489Provide information toemployeesAdmin labor recurring 2 44 44 0 2 4444TOTAL1861 0 354Policy development Admin labor one-time 8 177 177 0 0Coordinate information Admin labor recurring 0 0 8 177177Provide information toemployeesAdmin labor recurring 0 0 8 177177TOTAL177 0 354Policy development Admin labor one-time 8 177 177 0 0Coordinate information Admin labor recurring 0 0 8 177177Provide information toemployeesAdmin labor recurring 0 0 6 133133TOTAL177 0 310Onsite picnic tablesMap to local conveniencesTRANSPORTATION AND ALTERNATIVE SCHEDULES STRATEGYVanpool ProgramCarpool ProgramCompressed Work Week SchedulesTelecommuting ProgramC-42Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsPolicy development Admin labor one-time 8 177 177 0 0Coordinate information Admin labor recurring 0 0 6 133 133Provide information toemployeesAdmin labor recurring 0 0 4 89 89Space (outside)required is 100 sq. feetper rack for 6 bicyclesNo cost recurring 0 0 0 03 Racks – 6bicycles/rackCost & laborto installcapital 0 1,377 224 0Storage capital 550 89Repair Kit capital 17 3TOTAL177 316 222Solicit and reviewproposalsAdmin labor one-time 16 354 354 0 0Contract Information Admin labor one-time 16 354 354 0 0Shuttle (Extended Van)5 years, 6%Interestcapital 82358 17,831 0Gas recurring0 9058 9,058Maintenance recurring0 10920 10,920Insurance recurring0 14306 14,306Outreach to Employees Admin labor one-time 2 44 44 0 0TOTAL753 17831 34284Policy development Admin labor one-time 8 177 177 0 0TOTAL177 0 0Policy development Admin labor one-time 8 177 177 0 0TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0INCENTIVES STRATEGYFlex Work SchedulesStaggered Work SchedulesMonetary IncentiveBicycle ProgramShuttlesC-43Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsIncentive10%employeeparticipationrecurring 0 478 478IncentiveCompensationPackagerecurring 0 0 -478 (478)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive10%employeeparticipationrecurring 0 4209303 9,303IncentiveCompensationPackagerecurring 0 0 -9303 (9,303)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive8% employeeparticipationrecurring 0 5600 5,600IncentiveCompensationPackagerecurring 0 0 -5600 (5,600)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive1% employeeparticipationrecurring 0 840 840IncentiveCompensationPackagerecurring 0 0 -840 (840)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive1% employeeparticipationrecurring 0 840 840IncentiveCompensationPackagerecurring 0 0 -840 (840)TOTAL1770 0Transit SubsidyBicycle SubsidyStartup IncentiveVanpool SubsidyExtra Time OffC-44Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsDevelopment of policyand proceduresAdmin labor one-time 8 177 177 0 0Incentive10%employeeparticipationrecurring 0 5250 5,250IncentiveCompensationPackagerecurring 0 0 -5250 (5,250)TOTAL177 0 0Development of policyand proceduresAdmin labor one-time 6 133 133 0 0Balance accounts,purchase and distributepasses, inventorypassesAdmin labor recurring 0 0 8 177177TOTAL133 0 177Development of policyand proceduresAdmin labor one-time 6 133 133 0 050% discount meal(1/month)10%employeeparticipationrecurring 0 0 1470 1,470Coordinate anddistribute mealsrecurring 0 0 6 133133TOTAL133 0 1603Painting & StencilingbumpersLabor one-time 6 133 133 0 0Materials - paint &stencilsone-time 330 330 0 0TOTAL463 0 0Development of policyand proceduresAdmin labor one-time 4 89 89 0 0Outreach to employees Admin labor one-time 1 22 22 0 0Track employee points,give out prizesAdmin labor recurring 0 0 50 55PrizeSomeprovided byDistrictrecurring 0 0 100 100Preferencial ParkingPoints ProgramDiscount Transit PassesDiscounted MealsC-45Final Staff Reportwith Appendices for Rule 9410Attachment 6: Tier Two Estimated Costs for Every Menu OptionRule ElementDescriptionofExpenditure Frequency Admin Labor (hours) Admin Labor ($) Employee Labor (Hours) Employee Labor ($) Materials ($) Other Operations ($) Total One-Time Costs ($/yr) Equipment & Installation ($) Annualized ($/yr) Admin Labor (hrs/yr) Admin Labor ($/yr) Employee Labor (hrs/yr) Employee Labor ($/yr) Materials ($/yr) Other Operations ($/yr) Total Recurring Costs ($/yr)One-Time Costs Recurring CostsCapital CostsTOTAL111 0 105Development of policyand proceduresAdmin labor one-time 4 89 89 0 0Outreach to employees Admin labor one-time 2 44 44 0 0Receive entries,drawing, notifyemployeesAdmin labor recurring 0 0 4 8989Prize recurring 0 0 80 80TOTAL133 0 169Notes and assumptionsNumber of employees 350Labor rate for wages,benefits, overhead$22.15Sales tax rate, $/$1.00 0.09Electricity costs $/kwhr 0.15Cost recovery factor forannualized costs0.1627Cost recovery factor forannualized costs (5years)0.26380Material costs includessupplies and smallequipmentcostsPrize DrawingC-46Final Staff Reportwith Appendices for Rule 9410SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Socioeconomic Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 D-1 APPENDIX D

Socioeconomic AnalysisSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Socioeconomic Analysis December 17, 2009

Final Staff Report with Appendices for Rule 9410 D-2 This page is intentionally blank.

## SOCIO-ECONOMIC IMPACT ANALYSIS

PROPOSED RULE 9410 (EMPLOYER-BASED TRIP REDUCTION)



## DRAFT

NOVEMBER 23, 2009

Prepared for San Joaquin Valley Unified Air Pollution Control District

Prepared by Applied Development Economics
100 Pringle Avenue, Suite 560  Walnut Creek, California 94596  (925) 934-8712 2150 River Plaza Drive, Suite 168  Sacramento, CA 95833  (916) 923-1562

www.adeusa.com

## CONTENTS

1. Executive Summary .................................................................................................... 1

2. Introduction................................................................................................................ 3

3. Description of Draft Ru le 9410................................................................................... 5

4. Methodology............................................................................................................... 7

5. Impacted Industries Subj ect To Draf t Rule 9410 ........................................................ 9

6. Socio-eco nomic Impacts.............................................................................................. 17

Appendix A: Long-Term Net Profit Rati os By Industry: Dun and Bradstreet ................ 25

Appendix B: Agricultural Net Prof it Ratios: Dun and Bradstreet.................................... 27

Appendix C: Response to California League of Food Processors and Manufacturers’

Council of the Central Valley........................................................................................... 27Applied Development Economics, Inc. 1 

## 1. EXECUTIVE SUMMARY

The District seeks to adopt Rule 9410 (Empl oyer-Based Trip Reduction) to satisfy the goals of the District’s 2007 Ozone Plan and 2008 PM2.5 Plan. The analysis shows that a wide range of industries are potentially affected by the proposed rule. The analysis concludes that industries in the private and public sectors are not significantly impacted by the proposed rule. Small busine sses are not disproportionately impacted

as well.2 Applied Development Economics, Inc. “This page intentionally left blank”Applied Development Economics, Inc. 3 

## 2. INTRODUCTION

This report describes the socioeconomic im pacts of Draft Rule 9410 (Employer-Based Trip Reduction) dated October 15, 2009. Following this introduction, the report summarizes the proposed requirements an d describes the methodology for the socioeconomic analysis. In Section 5, the report describes the economic characteristics of sources affected by the proposed requir ements. The sixth section analyzes the socioeconomic impacts of compliance costs on the affected sources and the regional

economy.

The report is prepared pursuant to the pr ovisions of AB2051 (Section 40728.5 of the California Health and Safety Code), which requires an assessment of socioeconomic impacts of proposed air quality rules. The findin gs in this report can assist District staff in understanding the socioeconomic impact s of the proposed requirements, and can assist staff in preparing a re fined version of the rule. Figure 1 is a map of the eightcounty region that comprises the San Joaq uin Valley Air Basin. As indicated in the map, Kern County is not co mpletely in the District.

FIGURE 1

MAP OF SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT4 Applied Development Economics, Inc. “This page intentionally left blank”Applied Development Economics, Inc. 5 

## 3. DESCRIPTION OF DRAFT RULE 9410

This section of the report begins by review ing the context within which the District seeks to adopt Rule 9410. Then, this sectio n discusses Rule 9410 as currently written.

Between 2000 and 2020, the population of the San Joaquin Valley is expected to grow by 60%. In contrast, the total population for the state of California is expected to grow 29% over the same time period. Population growth typically leads to increased vehicle activity and increased emissions of ozone precursors, slowing the progress made by regulations that require newer automob iles to pollute less than older models. Furthermore, the Valley’s total vehicle miles traveled (VMT) is increasing at an even faster rate than the population. So the Va lley has more people, and they’re generally driving more.

While the District cannot regulate the vehicles themselves or the fu els the vehicles use,

the District can reduce mobile source emissi ons through other avenues. The District’s Emissions Reduction Incentive Program (ERIP) provides financial incentives to help replace older cars and engines through a few different programs. One program targets cars that have a history of needing smog re pairs, but are currently legally registered

and able to be driven. Based on the results of an emission test, incentives are available for up to $5000 to replace an older car. Other incentives are also given so older engines are replaced with newer, cleaner engines year s before these engines would be required to be replaced through regulation or na tural attrition. The District encourages carpooling, trip linking, and similar activ ities through Healthy Air Living, the District’s principle public outreach effort . Through the District’s Indirect Source Review (ISR) Rule 9510, the added vehicl e miles traveled that results from new development is mitigated through onsite and off-site measures. The District will also reduce vehicle emissions through adoptio n and implementation of Rule 9410, Employer Based Trip Reduction. The Distri ct committed to this rule in both the 2007

Ozone Plan and the 2008 PM2.5 Plan

. Consistent with the District’s plan co mmitments, Rule 9410 would require larger employers (those with 100 or more eligible employees) to establish employee trip reduction programs to reduce VMT, reducing emissions associated with work commutes. The draft rule proposes a menu-based Employer Trip Reduction Implementation Plan (ETRIP) and periodic reporting requirements to evaluate performance on a phased-in compliance schedule. Employers can choose which services and programs work best for their operations and their employees. The goal of the ETRIP is to provide employees with opportunities that make ridesharing and alternative transportation more accessible while not requiring a certain number of participants, as employers cannot legally ma ndate their employees’ activities outside of working hours. The District will make the pe riodic reporting as simple as possible and will allow for electronic reporting. The reporti ng component of the rule will help the6 Applied Development Economics, Inc. employer and the District assess how successful the ETRIP is in facilitating alternative transportation and ridesharin g. The District will provid e guidance documents detailing the various menu options employers may implement to help to reduce employee commute trips throughout the compliance schedule.

The stated purpose of Draft Rule 9410 is to improve ambient air quality by reducing air pollutant emissions that result from vehicle commute trips to worksites with 100 or more eligible employees. The rule requires employers to implement an Employer Trip Reduction Implementation Plan (ETRIP) to provide employees with opportunities that make ridesharing and alternative tran sportation more accessible. Employers with at least 100 eligible employees would be subject to Rule 9410. Exempt employees include the following (see Rule definitions for more information):

Those not arriving at work between 6am-10am
Agricultural workers
Emergency health and safety employees
Employment agency employees
Field personnel

Field construction workers
Independent contractors
Home garage employees
Part-time employees
Seasonal employees

Volunteers
On-call employees

There are three main components of co mpliance in Draft Rule 9410, which are discussed in greater detail in the staff report of September 14, 2009:

Employer registration
Employer Trip Reduction Implementation Plan (ETRIP)
Employee Commute Verification and Annual ReportApplied Development Economics, Inc. 7 

## 4. METHODOLOGY

The socioeconomic analysis involves the use of information provided directly by affected sources, as well as secondary data us ed to describe the industries affected by the proposed Rule 9410. The approach is briefly described below.

Applied Development Economics (ADE) bega n the analysis by reviewing US Census data called Public Use Microdata Series (PUMS). Using PUMS, ADE identified the specific industries in which employees in the eight-county San Joaquin Valley region

who commute between 6:00 am and 10:00 am wo rk. Having identified the industries, ADE then prepared a statistical descript ion of the industry groups of which the affected sources are a part, analyzing data on the number of jobs, sales levels, the typical profit ratios, and other econo mic indicators for each industry.

This report relies heavily on th e most current data available from a variety of sources,

such as the 2002 Economic Census and the State of California’s Employment Development Department (EDD) Labor Mark et Information Division. For purposes of estimating profits, ADE reviewed indust ry-specific financial ratios issued by Dun

and Bradstreet and the US Internal Revenue Services.

With the above information, AD E was able to estimate net after tax profit ratios for sources affected by the proposed amendments . ADE calculated ratios of profit per

dollar of revenue for affected industries. The result of the socioeconomic analysis shows what proportion of profits the comp liance costs represent. Based on assumed thresholds of significance, ADE discusses in the report whether the affected sources are likely to reduce jobs as a means of recouping the cost of rule compliance or as a result of reducing business operations. To the exte nt that such job losses appear likely, the indirect multiplier effects of the jobs lo sses are estimated using a regional IMPLAN input-output model.

When analyzing the socioeconomic impact s of proposed new rules and amendments, ADE attempts to work closely within th e parameters of accepted methodologies

discussed in a 1995 California Air Resources Board report called “Development of a Methodology to Assess the Economic Impact Required by SB513/AB969” (by Peter Berck, PhD, UC Berkeley Department of Agricultural and Resources Economics, Contract No. 93-314, August, 1995). The author of this report reviewed a methodology to assess the impact that California Environmental Protection Agency proposed regulations would have on the ab ility of California businesses to compete. The California Air Resources Board (ARB) has incorporated the methodologies described in this report in its own asse ssment of socioeconomic impacts of rules generated by ARB. One methodology relates to determining a level above or below

which a rule and its associated costs is d eemed to have significant impacts. When analyzing the degree to which its rules are si gnificant or insignificant, ARB employs a8 Applied Development Economics, Inc. threshold of significance that ADE follo ws. Berck reviewed the threshold in his analysis and wrote, “The Air Resources Boar d’s (ARB) use of a 10 percent change in [Return on Equity] ROE (i.e. a change in ROE from 10 percent to a ROE of 9 percent) as a threshold for a finding of no significant, adverse impact on either competitiveness or jobs seems reas onable or even conservative.”Applied Development Economics, Inc. 9 

## 5. IMPACTED INDUSTRIES SUBJECT TO DRAFT

RULE 9410

This section of the socioeconomic analysis describes demographic and economic trends in the San Joaquin Valley region. The first part of this section compares the San Joaquin Valley region against California as a whole, and provides a context for understanding demographic and economic changes that occurred within the San Joaquin Valley region between 1998 and 2008. St arting with sub-section 5.2, the second part of this section narrows the focus of the socioeconomic analysis to industries affected by the proposed Rule 9410. The seco nd part of this section describes the economic characteristics of potentially impact ed industries that might be subject to

these rules.



### 5.1 REGIONAL DEMOGRAPHIC AND ECONOMIC TRENDS

R EGIONAL 

### D EMOGRAPHIC 

### T RENDS
The San Joaquin Valley region experienced tremendous population growth during the 1990s. Many came to this area because of a ffordable housing. As a result, population increased significantly. The eight-county region’s population increased by 24 percent (or approximately 2.2 percent annually), from 3.2 million in 1998 to 3.9 million in 2008. In the last five years, the region ’s population grew by 2.2 percent annually between 2003 and 2008, the same rate of growth over the ten-year period from 1998 to

2008. While the State of California’s population increased by 14 percent (or approximately 1.4 percent annually) between 1998 and 2008, all th e counties in the region experienced faster rates of growth than California over the period, as Table 1 shows. While, by many standards, Madera Co unty continues to be a small county– at 150,887 residents according to the Department of Finance–it still experienced an annual growth rate of 2.8 percent between 1998 and 2008. Betwee n 2003 and 2008, this county continued to grow annually but at a slightly lesser rate of 2.7 percent. In the same five-year period, Kern, Merced, and San Joaquin Counties experienced rapid growth, growing annually by 2.9 percent, 2.4 percent, and 2.2 percent respectively, as Table 1 below shows. As demonstrated in the following section on regional economic trends, the demographic changes that occurre d in the San Joaquin Valley region during the 1990s and into the new century significan tly influenced the economy of this eightcounty region.10 Applied Development Economics, Inc. TABLE 1

POPULATION TRENDS

1998 2003 2008 98-03 03-08 98-08

State 33,225,655 35,652,700 38, 049,462 1.4% 1.3% 1.4% Region 3,192,439 3,540,392 3,956,003 2.1% 2.2% 2.2%

Fresno 781,936 846,485 931, 098 1.6% 1.9% 1.8%

Kern 637,227 708,753 817, 517 2.2% 2.9% 2.5% Kings 120,957 137,411 154, 434 2.6% 2.4% 2.5%
Madera 114,137 131,821 150, 887 2.9% 2.7% 2.8%
Merced 203,181 227,132 255, 250 2.3% 2.4% 2.3% San Joaquin 546,852 616,477 685,660 2.4% 2.2% 2.3%
Stanislaus 428,272 483,705 525,903 2.5% 1.7% 2.1%
Tulare 359,877 388,608 435, 254 1.5% 2.3% 1.9% Source: ADE, Inc., based on Ca lifornia Department of Finance



### R EGIONAL 

### E CONOMIC 

### T RENDS
Economic development practitioners and planners have traditionally divided economies into two broad industrial categ ories—the economic base and local support

industries. Economic base industries are the drivers of local and regional economies in

that these industries draw income into a local economy by selling products outside of the local economy, much like the export in dustries of a national economy. Accrued earnings then circulate throughout the local area in the form of wages and salaries; investments; purchases of fixe d assets, goods, and services; and generation of more jobs and wealth. The economic base is typically comprised of industries within the manufacturing, minerals-resour ce extraction, and agricultural sectors. There are also the “local support industries” such as retail or service sectors, the progress of which is a function of the economic base and demograp hic changes, and more so the latter than the former. As population increases in a gi ven area, demand for services–such as realtors, teachers, and health care–increases, as does demand for basic retail items like groceries, gas for commuting, or cl othing at the local apparel shops.

Agriculture is the economic base of the Sa n Joaquin Valley region by virtue of the amount of goods this sector produces an d exports throughout the nation and the globe. Slightly less than 14 percent of a ll workers in the region are employed by industries within agriculture, as Table 2 shows. In 1998, approximately 13.1 percent of all workers worked in agriculture. By 2003, th is ratio stood at 14 percent. In fact, over the five-year period between 2003 and 2008, employment in agriculture increased at a modest pace of one percent per year.

Between 2003 and 2008, local s upport industries gained in prominence within the San Joaquin Valley region. Service-rendering in dustries employed the most workers as a proportion of total employment in the region . Service-rendering industries comprise 71 percent of all jobs, including public sect or positions. In other words, 932,713 jobs out of a total of 1,317,365 jobs are in serv ice-rendering industries. Excluding the public sector, service-rendering jobs account fo r 52 percent of all jobs in 2008. In 2003, service-rendering industries (excluding the public sector) represented 51 percent of allApplied Development Economics, Inc. 11 jobs, indicating that the transition toward a services economy was in place as early as the mid to late 1990s with the significant incr ease in the number of people during that

time.

Employment increases in service-rendering in dustries are consistent with regional population growth. In the region, local s upport industries of local and private education and health increased annually by 3.0 percent and 2.7 percent respectively

between 2003 and 2008.

Construction and financial services are two other local support industries that grew in accordance with the region’s population surg e; however, with the downturn in the national economy, these industries’ rates of growth have lowered dramatically. Employment in construction grew by a 6.7 pe rcent per year in the five-year period stretching from 1998 to 2003. Between 2003 an d 2008, construction continued to grow but by a slower rate of 0.9 pe rcent per year. Likewise for fi nancial services, which grew annually by 3.9 percent between 1998 and 20 03, and has since grown by a slight 0.9

percent per year.

Close examination of Table 2 shows that th e region experienced modest growth in manufacturing, as employment in this sect or grew annually by 0.9 percent between

2003 and 2008. This modest increase reversed substantial declines experienced between 1998 and 2003, when manufacturing employm ent dropped annually by 0.6 percent. What was a regional bright spot be tween 1998 and 2003, transportation and warehousing experienced negative 1.1 pe rcent declines between 2003 and 2008, as compared to the 2.7 percent annual grow th in the previous five-year period.12Applied Development Economics, Inc.TABLE 2ECONOMIC TRENDS: SAN JOAQUIN VALLEY, 1998-2008EmploymentDistributionEmployment:Annual PercentChange----------------1998--------------- ----------------2003---------------- ----------------2008--------------- -------- 2008 -------- 98-03 03-08NAICS Estab. EmploymentAveragePayEstab. EmploymentAveragePayEstab. EmploymentAveragePayRegion CaliforniaALL 80,398 1,060,454 $33,566 92,231 1,209,849 $40,577 100,414 1,317,365 $39,543 100.0% 100.0% 2.7% 1.7%Ag, Natural Resources 11 7,580 139,953 $18,285 8,646 169,556 $23,354 7,371 178,522 $21,714 13.6%2.5% 3.9% 1.0%Utilities 21 251 9,533 $66,831 213 8,340 $81,309 185 10,512 $82,627 0.8% 0.0% -2.6% 4.7%Mining 22 165 4,231 $72,458 179 5,071 $86,065 1695,618 $81,296 0.4% 0.4% 3.7% 2.1%Construction 23 6,124 49,851 $38,969 6,074 69,065 $46,870 6,705 72,312 $44,716 5.5%5.7% 6.7% 0.9%Manufacturing 31-33 2,998 113,344 $40,989 2,779 110,002 $48,735 2,662 115,153 $43,352 8.7% 9.3% -0.6% 0.9%Wholesale 42 2,749 33,365 $47,7262,722 37,124 $53,053 3,02745,299 $46,510 3.4% 4.6% 2.2% 4.1%Retail 44-45 9,586 121,132 $26,4468,941 132,956 $31,349 8,882143,910 $25,892 10.9%10.8% 1.9% 1.6%Transport Warehousing 48-49 2,306 33,821 $38,946 2,237 38,554 $44,962 1,957 36,514 $40,166 2.8%2.7% 2.7% -1.1%Information 51 653 14,885 $43,401 692 14,257 $53,695625 15,328 $47,417 1.2%3.0% -0.9% 1.5%Finance and Insurance 52 2,637 27,792 $46,709 3,046 30,690 $59,530 3,373 32,027 $50,112 2.4%4.0% 2.0% 0.9%Real Estate 53 2,575 13,180 $26,755 2,607 15,932 $34,144 2,784 15,897 $32,633 1.2%1.8% 3.9% 0.0%Prof Technical Services 54 4,06425,130 $44,216 4,501 31,812 $52,467 4,839 36,411 $46,773 2.8%6.8% 4.8% 2.7%Mgmt. of Companies 55 321 17,997 $52,338 316 13,988 $60,045 288 10,551 $55,323 0.8% 1.3% -4.9% -5.5%Admn and Waste Services 56 2,91044,283 $22,362 2,768 48,182 $28,986 2,947 58,761 $27,165 4.5%6.4% 1.7% 4.0%Private Educational Serv. 61 459 7,107 $25,456 480 9,298 $29,532 497 10,781 $27,407 0.8% 1.7% 5.5% 3.0%Health Services 62 6,082 90,304 $38,243 6,526 110,647 $47,8676,983 126,598 $44,058 9.6%8.8% 4.1% 2.7%Arts, Entertainment, Rec 71 617 10,386 $16,985 621 10,244 $20,192 641 11,172 $17,305 0.8% 1.6% -0.3% 1.7%Food & Accommodations 72 5,050 70,335 $12,860 4,942 78,805 $15,831 5,312 90,404 $14,020 6.9%8.3% 2.3% 2.8%Other Services 81 20,157 41,069 $21,165 30,390 47,370 $25,731 35,629 52,505 $21,606 4.0%4.6% 2.9% 2.1%Unclassified 99 85 199 $38,0331,769 2,534 $26,836 0.2% 0.3%Local Govt. 409 51,325 $45,674437 60,768 $56,307 477 68,469 $51,0515.2% 5.2% 3.4% 2.4%Local Govt., Education 881 90,200 $39,664 1,487 109,087 $48,3041,792 118,716 $78,718 9.0%5.9% 3.9% 1.7%State, ALL 1,464 23,639 $46,0511,166 28,463 $56,515 1,07831,639 $51,222 2.4% 2.9% 3.8% 2.1%Federal, ALL 360 27,592 $52,749 376 29,439 $66,395 424 27,732 $58,9452.1% 1.6% 1.3% -1.2%Source: ADE, Inc., based on California Employment Development Department, LMIDApplied Development Economics, Inc. 13 

### 5.2 DESCRIPTION OF AFFECTED INDUSTRIES

Whereas the previous section described the larger economic context within which the District is contemplating proposed amendmen ts to Rule 9410, this section analyzes trends of industries directly affected by th e proposed amendments. This rule affects a broad array of industries in the private and public sectors. While affecting a broad array of industries, the rule itself applies to work-sites with more than 100 eligible workers. For purposes of this analysis, we assume the rule applies to all businesses employing at least 100 workers. As the table below shows, the bulk of employers in the region employ less than 100 workers, or 67,440 out of 68,959 establishments (97 percent).

TABLE 3

NUMBER OF PRIVATE SECTOR ESTABLISHMENTS IN THE SJV REGION SUBJECT TO DRAFT RULE

9410: EMPLOYER-TRIP REDUCTION PROGRAM

NAICS Industry Code Total

Establishments Establishments Employing

Less than 100 Establishments Employing

100-249 Establishments Employing

Between 250-

499 Establishment Employing

More than

500

Agriculture 7,245 6,932 177 84 52 crop 5,563 5,250 177 84 52
livestock 1,661 1,661 other agriculture 21 21 0 0 0 Mining 367 343 12 8 4
Construction 7,157 7,062 76 14 5 Manufacturing 2,653 2,417 157 50 29
Wholesale 3,318 3,253 57 8 0
Retail 10,198 9,959 199 39 1 Transportation/warehou sing 1,840 1,805 29 3 3

Information 641 620 10 8 3
Finance and Insurance 3,493 3,475 9 3 6
Real Estate 3,094 3,089 4 1 0
Professional and Technical 5,146 5,113 25 5 3 Management of Companies 298 289 3 6 0 Administrative/Support/waste 2,986 2,868 83 24 11

Education 637 628 6 0 3
Health 7,686 7,484 150 16 36

Arts and recreation 705 695 3 3 4
Food and accommodations 5,793 5,737 54 2 0
Other services 5,702 5,671 26 3 2

TOTAL 68,959 67,440 1,080 277 162 Source: ADE, Inc., based on US Bureau of Labor Statis tics (QCEW) and US Census County Business Patterns

Similar to Table 3 above, the table below id entifies the number of workers by industry by size of employers. While almost 97 percen t of the establishments in the region employ less than 100 workers, businesses employing no more than one hundred workers in aggregate employ 60 percent of th e region’s workers. Thus, 40 percent of the workers in the region work for busin esses that employ more than one hundred workers, even though these businesses, as a share of all businesses, comprise three percent of all establishments. With respect to agriculture, the analysis controls for seasonal workers by assuming the employmen t trends for non-seasons represent the14 Applied Development Economics, Inc. baseline case for employment in agriculture. Data for this adjustment come from the Agricultural Bulletin. 1

TABLE 4

NUMBER OF WORKERS BY SIZE OF EMPLOYER S: PRIVATE SECTOR: SAN JOAQUIN VALLEY

REGION: DRAFT RULE 9410: EMPLOYER-BASED TRIP REDUCTION PROGRAM

NAICS Industry Code Total

Number of

Workers Workers In

Establishments

Employing

Less than 100 Workers in

Establishments

Employing

100-249 Workers in

Establishments

Employing

Between 250-

499 Workers in

Establishment

Employing

More than

500

Agriculture 115,528 37,688 19,363 20,530 37,946 Mining 14,563 4,738 2,387 2,726 4,712
Construction 82,323 62,176 11,934 4,770 3,443 Manufacturing 107,556 39,747 24,018 17,035 26,757
Wholesale 47,526 35,701 9,100 2,726 0
Retail 148,189 103, 930 30,283 13,287 689 Transportation/warehousi ng 25,410 16,970 4,923 1,022 2,495
Information 14,021 7,141 2,089 2,726 2,066

Finance and Insurance 33,179 25,657 1,939 1,022 4,561
Real Estate 16,104 14,570 1,193 341 0

Professional and Techni cal 38,750 29,554 4,326 1,703 3,166 Management of Compan ies 7,138 4,050 1,044 2,044 0 Administrative/Support/was te 57,644 27,907 13,128 8,177 8,433
Education 12,395 7,589 1,641 0 3,166
Health 139,342 67, 521 23,123 5,451 43,247

Arts and recreation 15,905 8,977 1,193 1,022 4,712
Food and accommodations 94,538 85,056 8,802 681 0
Other services 40, 308 33,433 4,475 1,022 1,377

TOTAL 1,010,418 612,403 164,962 86,284 146,770 Source: ADE, Inc., based on US Bureau of Labor Statis tics (QCEW) and US Census County Business Patterns

Table 5 below includes estimates on amoun t of revenue generated by businesses in industries affected by Draft Rule 9410. Tota l revenues were estimated using a variety of sources. For industries other than agri culture, the US Economic Census 2002 was a key source for estimating revenue. That source was updated using information from the US Census’ Annual Survey of Manufact urers and the US Census’ Annual Services Report. For agriculture, a key source wa s the annual agricult ural commissioners’ report, which tracks a number of economic data by detailed crop and livestock for each county in California. With the in formation from the variety of sources mentioned above, the consultant then esti mated revenues generated by employers with 100 to 249 workers, 250 to 499 workers, and over 500 workers based on a per worker approach using data from Table 4. Crop farm revenues were based on harvested acreage, not number of workers.

1 http://www.labormarketinfo.edd.ca.gov/?pageid=158Applied Development Economics, Inc. 15 TABLE 5

ESTIMATED REVENUES: INDUSTRIES IN TH E SJV REGION BY SIZE OF EMPLOYER

NAICS Industry Code Total Revenues Revenues Of

Establishments Employing Less

than 100 Revenues of

Establishments Employing 100-

249 Revenues of

Establishments

Employing

Between 250-

499 Revenues of

Establishments Employing More

than 500
Agriculture $23,842,573,927 $8,013,228,993 $4,228, 530,600 $4,398,469, 266 $7,202,345,068 Mining $7,636,745,280 $2,543, 353,212 $1,050,571,840 $1, 558,644,560 $2,484,175,668
Construction $16,846,517,9 75 $12,765,413,704 $2, 672,906,175 $801,715, 863 $606,482,232 Manufacturing $47,990,478,364 $14,488,250,057 $9,390, 077,162 $7,641,317, 916 $16,470,833,229
Wholesale $67,361,388,1 20 $51,814,641,984 $11,790, 415,750 $3,756,330,387 $0
Retail $41,610,992,244 $28, 685,335,874 $9,065,007,887 $3,680,452,220 $180,196,263 Transportation/warehousing $3,495,567,077 $2,270,3 56,037 $618,643,393 $114, 992,313 $491,575,334
Information $4,041,448,39 0 $2,110,907,960 $649,446,26 0 $652,846,622 $628,247,547
Finance and Insurance $17,10 2,196,191 $12,764,149,5 75 $923,726,765 $701,598, 991 $2,712,720,860
Real Estate $3,126,1 31,412 $2,828,755,495 $231, 335,996 $66,039,922 $0
Professional and Technical $5,516,372,671 $4, 207,327,255 $615,870,209 $242,501,554 $450,673,653 Management of Companies $227,883, 647 $129,289,936 $33, 336,600 $65,257,111 $0 Administrative/Support/waste $3,808,312,584 $2,001,245,755 $853,105,572 $469,617,169 $484,344,089
Education $930,316,661 $569,551, 410 $123,161,507 $0 $237,603,744
Health $15,653,142,151 $6, 897,347,337 $2,020,997,406 $696,581,189 $6,038,216,219
Arts and recreation $1,384, 696,858 $736,273,812 $111,338, 998 $102,577,357 $434,506,691
Food and accommodations $4,881,070,94 1 $4,366,851,123 $480,4 28,773 $33,791,045 $0
Other services $5,180,823, 690 $4,223,825,126 $608,937,00 1 $133,080,502 $214,981,062

TOTAL $270,636,658,185 $163,580,014,665 $45,413,967,898 $25,263,047,176 $36,379,628,446 Source: ADE, Inc., based on US Bureau of Labor Statistics (Q CEW), US Census County Business Patterns, USDA Agricultural Commissioners’ Annual Report, 2002 US Census Economic Census, US Census Annual Manuf acturers’ Survey, and US Census Annual Services Report

A critical part of any socioeconomic analysis involves estimating net profits generated by industries and sources affected by proposed rules such as Draft Rule 9410. So as not to overstate net profits and thus understate impacts, the consultant employs long-term averages that attempt to smoothen out y ears when the economy (and industries) generally was doing well from years when the economy was not performing as well. Appendix A lists long-term net profit ratio employed by the consultant for the purpose of this socioeconomic analysis. For agriculture, we employed Dun and Bradstreet net profit ratios for agricultural categories, such as “cash grains”, “field crops”, “vegetables”, “fruit and tree nuts”, “beef cattle (feedlots)”, beef cattle (except feedlots)”, “dairy farms”, and “hogs”. Net prof it ratios for agriculture are also over a long-term period (see Appendix B).

Table 6 includes estimates on amount of net profits generated by industries in the eight-county region. Of the estimated $8. 5 billion in net profits, $3.5 billion is generated by businesses employing more than 100 workers, which as indicated earlier, represent six percent of the overall number of establishments. In other words, six percent of the region’s establishments ge nerate almost 41 percent of the region’s estimated net profits, which underscores the importance of large-businesses in any

economy.16 Applied Development Economics, Inc. TABLE 6

ESTIMATED NET PROFITS: INDUSTRIES IN THE SJV REGION BY SIZE OF EMPLOYER

NAICS Industry Code Total Net Profits ( All establishments ) Net Profits Of

Establishments Employing Less

than 100 Net Profits of

Establishments Employing 100-

249 Net Profits of

Establishments

Employing

Between 250-

499 Net Profits of

Establishments Employing More

than 500
Agriculture $1,126,378,59 5 $374,678,367 $195,805,988 $204,747,443 $351,146,797 Mining $454,386,344 $151,329,516 $62,509,024 $92,739, 351 $147,808,452
Construction $553,127,340 $419,131, 083 $87,760,419 $26, 323,004 $19,912,833 Manufacturing $1,345,379,79 6 $433,280,683 $268,308,311 $201,108,304 $442,682,498
Wholesale $1,336,000, 864 $1,027,657,066 $233, 843,246 $74,500,553 $0
Retail $747,855,297 $517,162,100 $155,586,867 $71,41 2,307 $3,694,023 Transportation/warehousing $157,883,11 3 $102,544,414 $27,942, 060 $5,193,819 $22,202,819
Information $143,471,418 $74,937, 233 $23,055,342 $23,17 6,055 $22,302,788
Finance and Insurance $1, 028,982,138 $767,976,333 $55,57 7,560 $42,212,873 $163,215,372
Real Estate $219,350,221 $198, 484,344 $16,232,076 $4,633,801 $0
Professional and Technical $216,977,32 5 $165,488,205 $24,224, 228 $9,538,394 $17,726,497 Management of Companies $8,963, 423 $5,085,404 $1,311, 240 $2,566,780 $0 Administrative/Support/waste $149,793, 628 $78,715,666 $33,555, 486 $18,471,609 $19,050,867
Education $35,507,086 $21,73 7,879 $4,700,664 $0 $9,068,543
Health $521,771,405 $229,911,578 $67,366,580 $23,219, 373 $201,273,874
Arts and recreation $46,156,562 $24, 542,460 $3,711,300 $3, 419,245 $14,483,556
Food and accommodations $153,753, 735 $137,555,810 $15, 133,506 $1,064,418 $0
Other services $239,526,749 $195,2 81,515 $28,153,187 $6, 152,755 $9,939,291

TOTAL $8,485,265,039 $5,006,881,791 $1,304,466,094 $827,466,704 $1,346,824,300 Source: ADE, Inc., based on Dun and BradstreetApplied Development Economics, Inc. 17 

## 6. SOCIO-ECONOMIC IMPACTS

This section of the report analyzes socioeco nomic impacts, if any, stemming from the proposed draft rule. The first part of this section discusses annual compliance costs. Section 6.2 discusses general business res ponses to compliance costs. Section 6.3 analyzes the socioeconomic impacts of the proposed Rule 9410.



### 6.1 COMPLIANCE COST ESTIMATES

Table 5 summarizes the estimated annualized costs associated with Rule 9410. District staff prepared extensive spreadsheets that detail and itemize how the annual cost were developed. That information is available on the Internet at:

http://www.valleyair.org/tripreduction.htm

Below is a summary of the annual cost st emming from Rule 9410. On average, worksites subject to the rule will spend an estimated $3,190 a year. On November 4, industry stakeholders presented their es timates on annual costs stemming from proposed Draft Rule 9410. The California League of Food Processors and the

Manufacturers Council of the Central Valle y presented their respective annual cost estimate for Tiers 1 and 2, or $6,824 and $10 ,490 respectively. We estimated “Migrant

and Seasonal Worker Protection Act Tier 1” and “Migrant and Seasonal Worker

Protection Act Tier 2” cost in the stak eholder scenario, by combining both the industry stakeholders’ and District’s cost esti mates. Overall, work-sites subject to the proposed rule will spend an estimated $9,972 a year, in the industry stakeholder cost scenario. This $9,972 average a pplies only to manufacturers.

TABLE 7 Average Annual Cost Per Worksite: Stemming from Draft Rule 9410: Industry Stakeholder and District Scenarios

Type of Worksite District: Average annual

cost/worksite

until 2014 Stakeholder: Average annual

cost/worksite

until 2014

Total $3,190 $9,972

Tier 1 $2,310 $6,824

Migrant and Seasonal Worker Protection Act Tier T1 $2,460 $7,267

Tier 2 $3,249 $10,490

Migrant and Seasonal Worker Protection Act Tier T2 $4,741 $15,307 Source: ADE, based on San Joaquin Valley Un ified Air Pollution Control District and

MCCV/CLFP18 Applied Development Economics, Inc. Table 8 below aggregates costs identified in the table above, in order to compare aggregate net profits against aggregate costs. In aggregate, in the Di strict cost scenario,

industries will bear almost $5.5 million in cost each year as a result of Rule 9410, with agricultural sector bearing a disproportionate amount of the costs, at $1.4 million. Table 9 includes cost estimates using indust ry-stakeholder costs. The only difference between the District and industry-stakeholder costs is in the manufacturing line-item. According to the California League of Food Processors and the Manufacturing Council of the Central Valley, manufacturer s in the region will bear $2.4 million in annual costs because of the proposed draft rule. In the industry stakeholder cost scenario, aggregate annual costs amount to $7.1 million for all industries, not just manufacturing.

TABLE 8

AGGREGATE COSTS STEMMING FROM DRAFT RU LE 9410: SAN JOAQUIN VALLEY REGION

INDUSTRIES: DISTRICT COST SCENARIO

NAICS Industry Code Total Number of

Establishments (> 100 workers) Annual Costs for

Establishments Employing 100-

249 Annual Costs for

Establishments

Employing

Between 250-

499 Annual Costs for

Establishments Employing More

than 500

Agriculture $1,399,610 $806,281 $366,826 $226,503
Mining $89,312 $51,035 $25,518 $12,759

Construction $315,782 $255,177 $44,656 $15,949
Manufacturing $765,531 $513,544 $159,486 $92,502

Wholesale $220,090 $194,573 $25,518 $0

Retail $775,101 $647, 512 $124,399 $3,190

Transportation/warehousi ng $124,399 $105,261 $9,569 $9,569

Information $79,743 $44,656 $25,518 $9,569

Finance and Insurance $70,174 $41,466 $9,569 $19,138

Real Estate $28,707 $25,518 $3,190 $0

Professional and Technica l $118,019 $92,502 $15,949 $9,569

Management of Companie s $41,466 $22,328 $19,138 $0

Administrative/Support/waste $392,335 $280,695 $76,553 $35,087

Education $44,656 $35,087 $0 $9,569

Health $660,271 $494,406 $51,035 $114,830

Arts and recreation $47,846 $25,518 $9,569 $12,759

Food and accommodations $194,573 $188,193 $6,379 $0

Other services $111, 640 $95,691 $9,569 $6,379

TOTAL $5,479,255 $3,919,443 $982,441 $577,371

Source: ADE, Inc.

“This section of the page intentionally blank”Applied Development Economics, Inc. 19 TABLE 9

AGGREGATE COSTS STEMMING FROM DRAFT RU LE 9410: SAN JOAQUIN VALLEY REGION INDUSTRIES: INDUSTRY STAKEHOLDER SCENARIO (MANUFACTURING ONLY)

NAICS Industry Code Total Number of

Establishments (> 100 workers) Annual Costs for

Establishments Employing 100-

249 Annual Costs for

Establishments

Employing

Between 250-

499 Annual Costs for

Establishments Employing More

than 500

Agriculture $1,399,610 $806,281 $366,826 $226,503
Mining $89,312 $51,035 $25,518 $12,759

Construction $315,782 $255,177 $44,656 $15,949
Manufacturing $2,353,411 $1,565,616 $498,604 $289,190

Wholesale $220,090 $194,573 $25,518 $0

Retail $775,101 $647, 512 $124,399 $3,190

Transportation/warehousi ng $124,399 $105,261 $9,569 $9,569

Information $79,743 $44,656 $25,518 $9,569

Finance and Insurance $70,174 $41,466 $9,569 $19,138

Real Estate $28,707 $25,518 $3,190 $0

Professional and Technica l $118,019 $92,502 $15,949 $9,569

Management of Companie s $41,466 $22,328 $19,138 $0

Administrative/Support/waste $392,335 $280,695 $76,553 $35,087

Education $44,656 $35,087 $0 $9,569

Health $660,271 $494,406 $51,035 $114,830

Arts and recreation $47,846 $25,518 $9,569 $12,759

Food and accommodations $194,573 $188,193 $6,379 $0

Other services $111, 640 $95,691 $9,569 $6,379

TOTAL $7,067,134 $4,971,515 $1,321,559 $774,060

Source: ADE, Inc.



### 6.2 BUSINESS RESPONSES TO COMPLIANCE COSTS

Industries impacted by the proposed amendm ents may respond in a variety of ways when faced with new regulatory costs. These responses may range from simply absorbing the costs and accepting a lower rate of return, to shutting down the affected business operation altogether and, where pr actical, shift from lower-value to highervalue product and or service. Impacted indust ries might also seek to pass costs to users of services or purchasers of goods. Affected sources may also seek to renew efforts to increase productivity and reduce costs elsewh ere in their operation in order to recoup the regulatory costs and maintain profit levels.

Stakeholders who attended two socioeco nomic workshops expressed concern about the overall state of the economy, wondering if now is a time to adopt measures such as the proposed Rule 9410. In addition, concer n was expressed by representatives from the agricultural sector, who expressed conc erns regarding car-pooling by ag laborers, particularly if legal questions were fully ve tted with respect to the potential for risk. Concern was also voiced that analysts use best available data with respect to ag employment and net profits generated by ag industries, so as to not understate impacts20 Applied Development Economics, Inc. to this sector, particularly because this sect or as a “price taker” is not in a position to

pass costs to consumers.

Dialogue between the District and affected stakeholders led to a number of rule improvements to address stakeholder’s con cerns such as phasing in the rule over several years to provide employers time for planning their individualized approaches to the rule and refining the scope of requir ements in order to avoid conflicts with the federal Migrant and Seasonal Agricultural Wo rker Protection Act. The District also explicitly committed to provide extens ive support to mitigate employers’

administrative burden



### 6.3 IMPACTS ON AFFECTED INDUSTRIES

This section of the report analyzes estimated after tax net profits of affected industries against anticipated costs associated with implementation of proposed Rule 9410.



### S OCIO 

### -E CONOMIC 

### A NALYSIS AND 

### S MALL 

### B USINESS 

### D ISPROPORTIONATE



### I MPACT 

### A NALYSIS 

### : I NDUSTRIES 

### A FFECTED BY 

### P ROPOSED 

### D RAFT 

### R ULE 

### 9410

As Tables 10 and 11 show, annual costs stemming from the proposed project when expressed as a ratio of net profit are belo w the ten-percent threshold used for purposes of determining whether costs are significant. Because the rule is aimed at businesses employing more than 100 workers, this rule also does not disproportionately impact

small businesses.

TABLE 10

SOCIOECONOMIC IMPACT ANALYSIS OF DRAFT RULE 9410: DISTRICT ANNUAL COST

SCENARIO

NAICS Industry Code Cost as Percent

of Net Profits Costs as a

Percent of Net

Profits for

Establishments Employing 100-

249 Costs as a

Percent of Net

Profits for

Establishments

Employing

Between 250-

499 Costs as a

Percent of Net

Profits for

Establishments Employing More

than 500

Agriculture 0.12% 0.22% 0.19% 0.11% Mining 0.02% 0. 03% 0.04% 0.01%

Construction 0.06% 0.06% 0.05% 0.06% Manufacturing 0.06% 0.12% 0.06% 0.05%

Wholesale 0.02% 0. 02% 0.01% 0.00%

Retail 0.10% 0. 13% 0.08% 0.00% Transportation/warehousing 0.08% 0.10% 0.03% 0.18%

Information 0.06% 0.06% 0.11% 0.04%

Finance and Insurance 0. 01% 0.01% 0.02% 0.05%

Real Estate 0.01% 0.01% 0.02% 0.00%

Professional and Technica l 0.05% 0.06% 0.07% 0.10% Management of Companies 0.46% 0.44% 1.46% 0.00% Administrative/Support/waste 0.26% 0.36% 0.23% 0.19%

Education 0.13% 0.16% 0.00%

Health 0.13% 0. 22% 0.08% 0.49%

Arts and recreation 0. 10% 0.10% 0.26% 0.37%

Food and accommodations 0.13% 0.14% 0.04% 0.00%

Other services 0.05% 0.05% 0.03% 0.10%

TOTAL 0.10% 0.22% 0.36% 0.31% Source: ADE, Inc.Applied Development Economics, Inc. 21 TABLE 11

SOCIOECONOMIC IMPACT ANALYSIS OF DRAFT RULE 9410: INDUSTRY STAKEHOLDER ANNUAL COST SCENARIO (MANUFACTURING ONLY)

NAICS Industry Code Cost as Percent

of Net Profits Costs as a

Percent of Net

Profits for

Establishments Employing 100-

249 Costs as a

Percent of Net

Profits for

Establishments

Employing

Between 250-

499 Costs as a

Percent of Net

Profits for

Establishments Employing More

than 500

Agriculture 0.12% 0.22% 0.19% 0.11% Mining 0.02% 0. 03% 0.04% 0.01%

Construction 0.06% 0.06% 0.05% 0.06% Manufacturing 0.26% 0.58% 0.25% 0.07%

Wholesale 0.02% 0. 02% 0.01% 0.00%

Retail 0.10% 0. 13% 0.08% 0.00% Transportation/warehousing 0.08% 0.10% 0.03% 0.18%

Information 0.06% 0.06% 0.11% 0.04%

Finance and Insurance 0. 01% 0.01% 0.02% 0.05%

Real Estate 0.01% 0.01% 0.02% 0.00%

Professional and Technica l 0.05% 0.06% 0.07% 0.10% Management of Companies 0.46% 0.44% 1.46% 0.00% Administrative/Support/waste 0.26% 0.36% 0.23% 0.19%

Education 0.13% 0.16% 0.00%

Health 0.13% 0. 22% 0.08% 0.49%

Arts and recreation 0. 10% 0.10% 0.26% 0.37%

Food and accommodations 0.13% 0.14% 0.04% 0.00%

Other services 0.05% 0.05% 0.03% 0.10%

TOTAL 0.20% 0.38% 0.16% 0.06% Source: ADE, Inc.



### S OCIO 

### -E CONOMIC 

### A NALYSIS 

### : P UBLIC 

### S ECTOR 

### I NDUSTRIES 

### A FFECTED BY



### P ROPOSED 

### D RAFT 

### R ULE 

### 9410

Draft Rule 9410 will affect agencies in the publ ic sector, not just establishments in the private sector. This section of the repor t analyzes socioeconomic impacts on the public sector.

To begin with, it is important to indicate that the public sector is not motivated by profit, for the most part. The public sect or delivers services generally known as “public goods.” In economics, a public good is a good that is “non-rivalrous” and “nonexcludable,” meaning, respectively, that consumption of the good by one individual does not reduce availability of the good fo r consumption by others ; and that no one can be effectively excluded from using the good. In other words, every one equally and fairly accesses public educational service, police protection, local parks, and public

infrastructure such as sidewalks and road s, to name a few public goods. Thus, decisions with respect what costs this sector absorbs (i.e. what public goods/services to render) in large part are budgetary policy decisions not necessarily predicated on whether a service/good is “profitable” as un derstood in the private sector. In this22 Applied Development Economics, Inc. light, costs stemming from Draft Rule 9410 sh ould be compared against public sector expenditures.

The table below presents data on the state of public sector in the San Joaquin Valley region. At the local level, the bulk of pub lic sector establishments are local public elementary and secondary schools. There are 1,780 schools in the region employing almost 110,000 workers. For federal agencies , expenditures are based on federal budget issued by the White House/US Congress in 20 08, as well as US Statistical Abstract. Expenditure estimates for the State of Calif ornia are from the Ca lifornia Legislative Analysts Office. Expenditure estimates for local governments (except schools, hospitals, and utilities) are based ratio of $127,272 per worker. Data for hospitals are based on Economic Census 2002, whereas es timates for utilities are based on Public

Sector Economic Census 2002. School figures come from the socioeconomic impact analysis for the school bus rule, adjusted for inflation.

TABLE 12 Profile of Public Sector: San Joaquin Valley Region, 2008

Establishments Employment Average Employment Aggregate Expenditures (est.)

Federal Agencies/Departmen ts 171 9,258 54 $3,937,895,180

Military/National Security 19 9,674 509 $8,629,450,085

Hospitals 3 1,027 342 $146,981,460

Postal Service 196 6,022 31 $599,598,542

State Agencies/Departmen ts 642 23,155 36 $3,538,375,846

Correctional Institutions 11 15,992 1,454 $2,435,289,935

Hospitals 55 1,886 34 $270,054,572

Elementary and Secondary Schools 2 73 37 $9,077,852

Colleges and Universi ties 355 4,418 12 $350,505,617

Other Agencies/Depar tments 3 328 109 $50,045,971

Local Agencies/Departmen ts 243 26,301 108 $3,587,450,766

Hospitals 14 11,926 852 $1,707,323,274

Utilities 148 3,305 22 $931,005,585

Elementary and Secondary Sc hools 1,780 109,719 62 $13,582,010,590

Junior Colleges 24 10,370 432 $82,959,075

Other local agencies 208 1,886 9 $240,004,545 Source: ADE, Inc., based on US Bureau of Labor Statisti cs, US Economic Census, and US Public Sector Census

The EDD LMID does not release public sect or data by county and region that show how many public sector agencies employ more than 100 worker s. The EDD LMID

does release this information for the state as a whole, although it combines local, state

and federal entities in its da ta set. As the table below shows, 11 percent of all public

sector entities in California employ more than 100 workers.Applied Development Economics, Inc. 23 Table 13

Distribution of Public Sector Esta blishments: State of California, 2008

Number of Businesses by Size Category

Industry Total 0-4 5-9 10-19 20-49 50-99 100-249 250-

499 500-

999 1000+

Federal, State and Local Government 31,896 7,255 4,364 4,677 6,891 5,182 2,322 584 334 287

100% 23% 14% 15% 22% 16% 7% 2% 1% 1%

Source: ADE, Inc., based on EDD LMID Size of Business Data (http://www.labormarketi nfo.edd.ca.gov/?pageid=138)

Based on Table 13 above, we estimate the nu mber of public sector entities employing more than 100 workers. For purposes of a conservative analysis, we assume that all federal military/national security establishm ents, federal hospitals, and local hospitals employ more than 100 workers. As it is, their respective average amounts to 509 workers per establishment (military/national security), 342 workers per establishment (federal hospitals), and 850 workers per local hospitals. Also, elementary schools in the region do not employ more than 100 wo rkers, for example. Thus, the remaining

entities were scaled in acco rdance with the 11 percent factor in the table above. Table 14 below shows that public sector entities ar e not significantly impacted by Draft Rule 9410, as cost to expenditure ratios are well below one percent. Thus, Draft Rule 9410 does not significantly impact the public sector.

“This section of the page intentionally blank”24 Applied Development Economics, Inc. TABLE 14
Socioeconomic Impact Analysis of Draft Rule 9410: Public Sector: District Cost Scenario

Public Sector

Establishments

Employing

More than 100

Workers Aggregate Expenditures (est.) Cost* Cost to Expenditure

Federal Agencies/Departments 19 $433,168,470 $60,004 0.01%

Military/National Security 19 $8,629,450,085 $60,610 0.00%

Hospitals 3 $146,981,460 $9,570 0.01%

Postal Service 22 $65, 955,840 $68,776 0.10%

State Agencies/Departments 71 $389,221,343 $225,278 0.06%

Correctional Institutions 11 $2,435,289,935 $35,090 0.00%

Hospitals 6 $29,706,003 $19,300 0.06%

Colleges and Universities 39 $38,555,618 $124,570 0.32%

Local Agencies/Departments 27 $398,605,641 $86,130 0.02%

Hospitals 14 $1,707,3 23,274 $44,660 0.00%

Utilities 3 $18,871,735 $9,570 0.05%

Middle/High Schools 105 $801,186,018 $334,950 0.04%

Junior Colleges 3 $10, 369,884 $9,570 0.09%

Other local agencies 22 $25,385,096 $70,180 0.28% Source: ADE, Inc., based on US Bureau of Labor Statisti cs, US Economic Census, and US Public Sector Census (*note: annual costs are based on average annual cost (i.e. $3,190 annual cost per establishment) estimate of the San Joaquin Valley Unified Air Pollution Control District)Applied Development Economics, Inc. 25 

## APPENDIX A: LONG-TERM NET PROFIT RATIOS BY

INDUSTRY: DUN AND BRADSTREET

TABLE A-1

LONG TERM NET PROFIT

AVERAGE RECESSION EXPANSION

3.4% 3.2% 3.8% SIC ALL INDUSTRIES 3.4% 3.5% 4.1% 01 Agricu ltural production—crops 2.9% 3.4% 2.9% 02 Agricultural produc tion—livestock and animal specialties 3.5% 3.5% 3.8% 07 Agricultural services 5.1% 5.0% 5.1% 08 Forestry

3.9% 4.9% 3.5% 09 Fishin g, hunting, and trapping 3.0% 1.2% 4.1% 10 Metal mining 3.9% 3.8% 4.0% 12 Coal mining

6.0% 4.7% 7.0% 13 Oi l and gas extraction

5.8% 15.5% 6.3% 14 Nonmetal lic minerals, except fuels

2.4% 2.3% 2.6% 15 General cont ractors and operative builders 3.3% 3.0% 3.5% 16 Heavy cons truction, except building 3.2% 2.9% 3.5% 17 Spec ial trade contractors

2.4% 2.3% 2.4% 20 Food and kindred products

5.2% 5.1% 5.2% 21 Tobacco products 2.2% 2.4% 2.4% 22 Textile mill products

2.5% 2.5% 2.7% 23 Apparel and other textile products

3.1% 3.1% 3.3% 24 Lumb er and wood products

3.1% 3.0% 3.4% 25 Fu rniture and fixtures 3.1% 2.7% 3.4% 26 Pape r and allied products

3.6% 3.4% 4.0% 27 Prin ting and publishing

3.7% 3.4% 4.1% 28 Chemic als and allied products

2.7% 2.2% 3.0% 29 Petrol eum and coal products

3.4% 3.3% 3.8% 30 Rubber an d misc. plastics products 2.8% 2.9% 3.0% 31 Leather and leather products

3.5% 3.3% 3.7% 32 Stone, clay, and glass products

3.4% 2.6% 3.9% 33 Prim ary metal industries

3.6% 3.2% 3.9% 34 Fabr icated metal products

3.7% 3.1% 4.3% 35 Industri al machinery and equipment

3.8% 3.2% 4.3% 36 Electronic & other electric equipment

3.4% 2.9% 3.7% 37 Tran sportation equipment

3.9% 3.3% 4.6% 38 Instrume nts and related products

3.3% 3.4% 3.7% 39 Miscellane ous manufacturing industries

10.7% 8.2% 11.3% 40 Ra ilroad transportation

2.6% 2.6% 2.9% 41 Local and interurban passenger transit

2.3% 2.1% 2.5% 42 Truc king and warehousing

4.0% 3.5% 4.4% 44 Wa ter transportation

3.1% 2.7% 3.3% 45 Tr ansportation by air 26.3% 22.6% 26.3% 46 Pipeli nes, except natural gas

2.0% 1.8% 2.3% 47 Tran sportation services

7.6% 6.2% 11.1% 48 Communication
6.5% 5.8% 7.2% 49 Electric, gas, and sanitary services

2.0% 1.9% 2.2% 50 Wholesale trade—durable goods

1.5% 1.4% 1.6% 51 Wholesal e trade—nondurable goods 2.0% 2.1% 2.2% 52 Building ma terials & garden supplies

2.1% 2.2% 2.1% 53 Gene ral merchandise stores

1.3% 1.2% 1.5% 54 Food stores

1.3% 1.3% 1.5% 55 Automotive dealers & service stations 3.4% 3.3% 3.8% 56 Appare l and accessory stores

2.6% 2.7% 2.9% 57 Furniture and homefurnishings stores 3.2% 3.2% 3.3% 58 Eating and drinking places

2.5% 2.6% 2.9% 59 Mi scellaneous retail

60 Depository institutions

6.0% 6.2% 7.5% 61 Nond epository institutions

3.3% 4.1% 3.7% 62 Securi ty and commodity brokers

63 Insurance carriers 64 Insurance agents, brokers, & service

7.0% 6.0% 8.2% 65 Real estate 6.0% 4.1% 7.9% 67 Holding an d other investment offices

5.9% 5.0% 7.1% 70 Hotels and other lodging places

3.9% 4.0% 4.5% 72 Personal services

3.9% 3.6% 4.7% 73 Business services

3.0% 3.0% 3.4% 75 Auto re pair, services, and parking26 Applied Development Economics, Inc. TABLE A-1

LONG TERM NET PROFIT

AVERAGE RECESSION EXPANSION

3.4% 3.2% 3.9% 76 Miscel laneous repair services

3.6% 3.7% 4.3% 78 Motion pictures

3.3% 3.3% 3.6% 79 Amusement & recreation services

3.3% 2.8% 3.9% 80 Health services

8.5% 7.2% 10.0% 81 Legal services

3.8% 3.3% 4.2% 82 Ed ucational services

3.0% 2.4% 3.4% 83 Social services
8.2% 5.2% 10.0% 84 Museums, bo tanical, zoological gardens

3.8% 2.9% 4.2% 86 Memb ership organizations

3.7% 3.6% 4.1% 87 Engineering & management services

88 Private households
4.5% 4.5% 4.6% 89 Services, nec Source: ADE, Inc.; based on Dun & BradstreetApplied Development Economics, Inc. 27 

## APPENDIX B: AGRICULTURAL NET PROFIT RATIOS:

DUN AND BRADSTREET

TABLE B-1

AG NET PROFIT RATIOS

Description SIC Code Level 10-year

avg. 10-yr

mdn. Recession Growth

UQ 14.2 14.1 14.7 13.7

Wheat 0111 MD 6.6 7.0 5.9 7.1

LQ 2.1 3.0 1.1 2.8

UQ 10.5 9.8 9.7 11.1

Corn 0115 MD 5.1 3.7 3.9 6.0

LQ 1.1 1.2 1.0 1.2

UQ 10.7 12.8 10.7 10.7
Cash grains, nec 0119 MD 4.0 5.3 3.5 4.8

LQ -2.2 0.9 -3.7 -0.2

UQ 16.1 16.1 18.4 14.3

Cotton 0131 MD 8.1 6.5 9.6 6.9

LQ 2.7 1.7 2.5 2.9

UQ 13.5 13.5 13.5
Sugarbeats 0133 MD 10.3 10.3 10.3

LQ 3.9 3.9 3.9

UQ 10.0 8.7 10.0 10.0
Irish potatoes 0134 MD 4.1 3.5 4.0 4.1

LQ -0.2 -0.2 -0.8 0.2

UQ 16.8 15.5 13.4 19.6
Field crops, excp. cash grains nec 0139 MD 6.9 6.6 6.7 7.0

LQ 1.6 1.2 1.6 1.7

UQ 9.2 8.0 10.1 8.5
Vegetables and melons 0161 MD 3.7 2.9 4.3 3.2

LQ 0.2 -0.2 0.5 -0.1

UQ 14.6 14.9 13.3 15.6
Berry crops 0171 MD 7.9 7.7 7.2 8.5

LQ 3.5 3.2 1.5 5.0

UQ 14.1 9.7 17.9 11.1
Grapes 0172 MD 5.5 4.7 6.6 4.6

LQ 2.3 1.9 2.8 1.9

UQ 14.1 12.7 10.3 16.9

Tree nuts 0173 MD 5.8 6.4 3.4 7.7

LQ 0.0 1.0 -4.7 3.5

UQ 11.2 11.7 8.9 13.0

Citrus fruits 0174 MD 4.6 4.7 3.3 5.7

LQ -1.1 -1.9 -3.0 0.5

UQ 8.7 7.2 10.7 7.1

Deciduous tree fruits 0175 MD 3.4 2.4 4.7 2.4

LQ -0.5 -0.4 0.2 -1.1

UQ 9.8 9.0 10.3 9.4
Floriculture and nursery products 0181 MD 3.5 3.3 3.8 3.2

LQ 0.7 0.7 0.8 0.6

UQ 14.9 15.0 12.9 16.6
General farms, primarily crops 0191 MD 5.9 5.0 5.0 6.5

LQ 1.2 1.3 1.0 1.3

UQ 6.0 6.3 4.8 7.0

Beef cattle feedlots 0211 MD 2.7 2.9 2.4 2.9

LQ 1.0 0.8 0.6 1.2

UQ 18.4 18.7 18.6 18.2
Beef cattle, except feedlots 0212 MD 5.6 5.9 6.3 5.0

4.1 LQ -2.3 -0.8 -0.1 -4.1

UQ 9.3 9.9 9.2 9.3
Hogs 0213 MD 2.9 3.6 3.0 2.8

LQ -2.5 -3.6 -3.8 -1.4

UQ 11.1 9.5 12.2 10.2
Dairy farms 0241 MD 3.7 3.0 4.3 3.2

LQ 0.4 0.1 0.5 0.328 Applied Development Economics, Inc. TABLE B-1

AG NET PROFIT RATIOS

Description SIC Code Level 10-year

avg. 10-yr

mdn. Recession Growth

UQ 7.1 6.6 7.0 7.2
Chiecken eggs 0252 MD 2.8 2.7 3.0 2.8

LQ 0.2 0.5 0.6 -0.1

UQ 10.0 9.3 11.2 8.8
Turkey and turkey eggs 0253 MD 5.6 6.1 4.9 6.3

LQ 2.6 2.5 1.6 3.7

UQ 7.1 5.7 7.1
Poultry hatcheries 0254 MD 2.9 3.3 2.9

LQ 0.3 0.8 0.3

UQ 12.0 11.7 11.4 12.6
Animal specialties, nec 0279 MD 5.2 4.9 5.1 5.2

LQ 1.4 1.8 1.2 1.6

UQ 12.0 9.2 19.8 4.3
General farms, primarily livestock/animal specialties 0291 MD 6.4 5.7 9.8 3.1

LQ 2.7 2.2 3.2 2.2

UQ 10.5 11.5 9.3 11.4
Soil preparation services 0711 MD 4.3 4.1 3.2 5.2

LQ 1.1 1.0 0.2 1.8

UQ 9.4 8.3 11.0 8.2
Crop planting, cultivating and protecting 0721 MD 3.7 3.1 4.0 3.4

LQ 1.0 0.7 1.2 0.8

UQ 8.6 8.5 8.2 8.8
Crop harvesting, primarily by machine 0722 MD 2.7 2.6 3.5 2.2

LQ 0.7 0.5 0.4 0.9

UQ 7.9 7.2 8.3 7.6
Crop prep services for market, except cotton ginning 0723 MD 3.1 3.1 3.1 3.2

LQ 4.6 0.7 0.5 7.9

UQ 16.8 16.1 17.6 16.3
Cotton ginning 0724 MD 6.3 5.9 6.6 6.1

LQ 1.4 1.3 1.8 1.1

UQ 11.6 11.1 10.0 12.9
Wines, brandy, and brandy spirits 2084 MD 5.9 4.6 4.7 6.6

LQ 0.1 0.7 0.1 0.1

UQ 11.9 12.6 11.7 12.1
Distilled and blended liquors 2085 MD 7.4 8.1 8.0 7.0

LQ 3.6 2.9 2.4 4.5
10-year avg. 10-yr md n. Recession Growth

UQ 12.5 11.9 12.3 12.7 Crop MD 5.7 5.3 5.5 5.5

LQ 1.0 1.1 0.3 1.4

UQ 10.3 9.6 11.2 9.7

Livestock MD 4.2 4.2 4.6 3.9

LQ 0.4 0.5 0.5 0.4

UQ 11.7 11.1 11.9 11.6 Crop ands Livestock MD 5.1 4.9 5.2 4.9

LQ 0.8 0.9 0.4 1.1

UQ 10.7 10.3 10.9 10.5

Farm services MD 4.0 3.8 4.1 4.0

LQ 1.8 0.8 0.8 2.5 Source: ADE, Inc., based on Dun and BradstreetApplied Development Economics, Inc. 29 

## APPENDIX C: RESPONSE TO CALIFORNIA LEAGUE

OF FOOD PROCESSORS AND MANUFACTURERS’

COUNCIL OF THE CENTRAL VALLEY

MEMORANDUM

To : Nichole Corless, George Heinen, and Scott Nestor

From: Tony Daysog, ADE

Copy: Doug Svensson, ADE

Date: November 19, 2009

Re : Response to Inquiries from the CLFP and MCCV

Applied Development Economics prepared th is memo in response to the questions posed by the California League of Food Pro cessors, which asked, “Of the number of establishments employing at least 100 workers, how many employ 100 ‘qualified’ workers? In a separate me mo, the California League of Food Processors and the

Manufacturers’ Council of the Central Valle y presented annual cost figures higher than what was estimated by the San Joaqui n Valley Unified Air District. In this memo, we respond to these two issues. First we discuss the source of data on businesses and establishments by number of workers. Then, we discuss how we treated the data for purposes of the socioeco nomic impact analysis. We conclude with a socioeconomic impact analysis based on cost figures presented by the California League of Food Processors and the Manu facturers Council of the Central Valley.

Establishments By Number of Work ers: Data Source: County Business

Pattern
In analyzing economic trends in the eight- county San Joaquin Valley region, Applied Development Economics relied heavily on th e US Census Bureau’s annual County Business Patterns. In this publication, the US Census Bureau organizes data by county, industry code, and size of establishm ent in terms of number of workers. The most current data available from County Business Patterns is for the year 2007.

The US Census Bureau obtains data placed in the County Business Patterns in the following manner. Each year, the US Ce nsus surveys businesses across the country through the “Report of Organization Survey .” The US Census distributes findings from this survey across a number of federa l agencies maintaining economic databases. Among the various databases the US Census places findings from the “Report of Organization Survey,” the Census places survey findings in what is called the30 Applied Development Economics, Inc. “Business Register.” Other agencies such as the US Internal Revenue Service place data into the Business Register. Thus, via the Bu siness Register, the US Census Bureau and other agencies generate accurate and consis tent data on businesses throughout the nation. Data for the annual publication called the County Business Patterns come from Business Register.

The US Census Bureau organizes County Bu siness Patterns data according to varying levels of industrial codes. For example, manufacturing in genera l is represented by the two-digit NAICS codes range of “31-33.” A particular group of manufacturers, such as food processors, are grouped under the three- digit NAICS of “311”, which is a sub-set of two-digit “31” NAICS code. Particular food processors such as “breakfast cereal manufacturers” are represented by a more deta iled NAICS code consisting of six digits,

or “311230” in the case of “br eakfast cereal manufacturers. ” NAICS code “311230” is a sub-set of “311”. For purposes of the soci oeconomic impact analysis, the consultant analyzes trends at the detailed six-digit level, and, as appropriate, reports findings at either the six-, two- or three-digit NAICS code levels.

In addition to organizing data by specific in dustry codes, the US Census Bureau also organizes County Business Patterns data by si ze of establishment, which is defined by a range of workers. Thus, the US Cens us Bureau identifies the number of establishments with “1 to 4” workers, “5 to 9” workers, “10 to 19” workers, “20 to 49” workers, “50 to 99” workers, “100 to 249 work ers”, “250 to 499” workers, “500 to 999” workers, “1000 to 2499” workers, “2500 to 4999” workers and “over 5000” workers.

How We Treat Cases Where Businesses Employ More than 100 Workers But
Not More than 100 “Qualified” Workers

As currently stated, proposed Draft Rule 9410 affects establishments employing at least 100 “eligible” workers. Thus, an estab lishment employing 120 workers might not necessarily be subject to the proposed rule, if in this hypothetical case 30 of the 120 workers work night shifts, with the balanc e of the workforce working during hours and conditions covered under the proposed ru le. In this example, the establishment employs 90 “eligible” workers out of a tota l workforce of 120, meaning that this hypothetical establishment would not be subj ect to the proposed draft rule. Because County Business Pattern data do not in dicate how many of the establishments employing between “100 and 249” workers are “eligible” workers per proposed Draft Rule 9410, for purposes of a conservative so cioeconomic impact analysis, we assume that all establishment employing between “ 100 and 249” workers will be subject to the rule. In other words, proposed Draft Rule 9410 may affect fewer establishments than the number in our analysis, but for purposes of a conservative socioeconomic impact analysis, we opted to assume that socio economic impacts stemming from the rule would fall on a greater (rather than lesser) number of businesses within the “100 to 249” size range.Applied Development Economics, Inc. 31 Socioeconomic Impact Analysis of In dustry Stakeholder Cost Estimates

In a November 4, 2009 memo called “Joint Comments from MCCV & CLFP: Employer-Based Trip Reduction Rule 9410,” The California League of Food

Processors and the Manufacturers Counc il of the Central Valley presented their respective annual cost estimate for Tiers 1 and 2, or $6,824 and $10,490 respectively.

We included these costs next to the District ’s initial cost estimates. These costs are presented below, which also includes revi sed cost figures for the Migrant Seasonal

Worker Protection Act. We estimated an average of $9,972 using the stakeholders’

Tier 1 and Tier 2 annual cost estimates.

Annual Cost Stemming from Draft Rule 941 0: Industry Stakeholder and District

Scenarios

Type of Worksite District: Average annual

cost/worksite

until 2014 Stakeholder: Average annual

cost/worksite

until 2014

Total $3,190 $9,972

Tier 1 $2,310 $6,824

Migrant and Seasonal Worker Pr otection Act Tier T1 $2,460 $7,267

Tier 2 $3,249 $10,490

Migrant and Seasonal Worker Pr otection Act Tier T2 $4,741 $15,307 Source: ADE, based on San Joaquin Valley Un ified Air Pollution Control District and

MCCV/CLFP

In an e-mail transmission to the consultant , the California League of Food Processors asked, “Why are the annual total costs so much lower for larger employers? On a peremployee basis they might be somewhat lower, but wouldn’t the total annual costs incurred by an employer with 1,000 employees be greater than one with 100 workers?” When conducting socioeconomic analyses, one of the first thin gs we attempt to discover through our preliminary analysis an d the initial workshops we help facilitate

is whether costs associated with a rule scal e in conjunction with specific factors, or whether costs more or less are fixed regardle ss of the size of busin ess. We concluded that costs stemming from the rule do not ratchet upward in accordance with the number of workers, in part because much of the success of the project relies on various communication approaches the cost of whic h more or less is th e same whether there are 100 or 1,000 employees. While the “services and facilities” element of the proposed Draft Rule 9410 involves hard-costs (see “on- site vending machine” and “on-site break room and kitchenette”), more than likely, companies with more than 100 workers are already providing these hard costs even befo re rule adoption, such that for businesses interested in pursuing these elements of th e project, true impacts stemming from the32 Applied Development Economics, Inc. rule is an incremental fraction above the init ial outlay, with no si gnificant difference in impacts based upon size of establishment. For these reason, we conclude that the District’s $3,190 of industry stakeholders’ $9,972 average (for manu facturers only) are the appropriate unit of analysis to be a pplied against businesses employing more than

100 workers.

The table below shows the aggregate cost impacts based on the $9,972 average absorbed by affected industries and busine sses with more than 100 workers. Below

this table is another one which shows that impacts are less than significant across the

board.

Aggregate Costs Per Industry Stakeholder Cost Estimates: Cost Applies Only to

Manufacturers

NAICS Industry Code Total

Establishments

> 100 workers Establishments Employing 100-

249 Establishments Employing

Between 250-

499 Establishment Employing More

than 500

Manufacturing $2,353,411 $1,565,616 $498,604 $289,190

Source: ADE, Inc., based on US Bureau of Labor Statis tics (QCEW) and US Census County Business PatternsApplied Development Economics, Inc. 33 Comparison of Aggregate Net Profits to Aggregate Costs Per Stakeholder Cost

Estimates

NAICS Industry Code Total Net

Profits > 100

workers Net Profits of

Establishments

Employing

100-249 Net Profits of

Establishments

Employing

Between 250-

499 Net Profits of

Establishments

Employing

More than 500

Manufacturing 0.26% 0.58% 0.25% 0.07%

Source: ADE, Inc., based on Dun and Bradstreet34 Applied Development Economics, Inc. This page is intentionally blank.