CTR Requirements

The Commute Trip Reduction Law is a Washington State law, first passed in 1991. As a CTR-affected jurisdiction, the City of Seattle has adopted a local CTR program, defined in Municipal Code, that sets certain guidelines for participating employers. These guidelines set the minimums for how employers complete their 'good faith effort' and satisfy compliance with the law. 

Seattle Municipal Code related to CTR was updated with the adoption of the 2019-2023 Strategic Plan; you can read the full text of the local code here. Changes included:

  • Acommodating new travel modes: Accounting for the growth in use of Transportation Network Companies (TNCs) as a commuting option, while classifying any single-person TNC trip as a drive-alone trip (e.g. a TNC trip with a driver and one (1) passenger is considered a drive-alone trip).
  • Acknowledging the impact of contract workers: Recommending but not requiring the inclusion of certain independent contractors, based on their hours and tenure at a site, within employers' commuting strategies and CTR programs.
  • Clarifying the exemption process in respect to variably scheduled shift workers and rotating shift workers. The code now states that any employees commuting less than 2 workdays per week during the morning peak throughout the year can be exempted, regardless of whether they rotate or have other scheduling arrangements. 
  • Promoting the most effective trip reduction strategies: The addition of a tiered structure to the trip reduction strategy menu previously within the code, to add structure without making the requirements more onerous. This updated menu divides the strategies into three categories of choices available to employers based on impact and employers must select two strategies from each category. 

These code changes are intended for clarification of the program, making it easier to understand and comply, and do not significantly change the level of effort or financial investment required of companies to remain in compliance. 

An employer with 100 or more employees who report to work at a single site between 6 and 9 a.m. is subject to the law and must:

  • Appoint and maintain an individual to act as an Employee Transportation Coordinator (ETC) to be the primary contact between the employer and the City and to administer and promote the employer's CTR program. The contact information of the ETC must be prominently displayed at each worksite.
  • Submit a program report to the City for review and approval once every two years.
  • Exercise a good faith effort by collaborating with the City in its administration and implementation of the law.
  • Conduct a commuter survey once every two years to measure employees' drive alone rates.

We have updated drive alone rate goals and geographic "networks" or neighborhood groups for all areas of Seattle. Find out what target you're working toward. Employer drive alone rates are calculated by taking the total number of drive-alone trips and dividing them by the total trips made to their location.

CTR employers report progress to the City annually. Employers generally file program element reports on even years and conduct an employee commute survey on odd years. The City of Seattle partners with Commute Seattle to assist with employer reporting and surveying.

What is an employer program report?

Employers are required to submit a regular CTR program report to the City of Seattle that describes the actions is has taken during the preceding year and the actions it will take in the coming year. The City of Seattle requires employers to submit a program report biennially, usually on even-numbered years. The report can be completed online.

What is an employee commute survey?

Employers are required to conduct a baseline measure of employee commute behavior, via the state-provided Employee Questionnaire, within 90 days of becoming a CTR-affected employer. Employers must also measure employee commute behavior every two years to determine their programs towards their drive-alone reduction goals. This survey typically occurs in the fall of odd-numbered years.

The state-provided Employee Questionnaire is available in paper or online format. The ETC distributes and collects the surveys and the state processes them. A 50% response rate is required but a 70% response rate is desired. In lieu of the survey, certain employers can provide equivalent data from other records or surveys, but this must be pre-approved by SDOT and WSDOT.

What if an employer does not meet the basic requirements?

If an employer does not appoint an ETC, distribute information, implement a program or survey employees as required, then the City of Seattle can levy a civil penalty. Penalties for sites that are considered out of compliance are $250 per day. However, this is a rare occurrence as compliance is not a challenge for most worksites.

An affected employer is required to include certain minimum elements in its employee transportation program that demonstrate an effort to support non-drive alone trips.  These include:

  • Distribution of CTR Program information to employees at least twice a year and to each new employee when the new hire begins employment.
  • Program Elements - Each affected employer must select at least two strategies from each category set out below unless granted an exemption:

Category A, employee information and amenities: Implement strategies to ensure employees are well informed and that facilities and programs support non-drive-alone commutes. This may include provision of:

  1. Real time transportation information such as transit schedules and shared transportation information in a prominent space to ensure both employees and visitors are aware of their travel options to and from the site.
  2. "Flexwork": Create policies to allow and/or encourage alternative work schedules and telework for employees with suitable positions. This may include: a) A policy allowing employees to work intermittently, part-time, or full-time at home or at a satellite center. b) Alternative work schedules such as a compressed workweek allowing a full-time employee to eliminate at least one workday every two weeks by working longer hours during the remaining days, resulting in fewer commute trips by the employee. Examples include 9/80, 4/40, or 3/36 schedules. c) Flexible scheduling to shift commute trips by employees outside of the period between 6 a.m. and 9 a.m.
  3. Employee shuttles. This may be a circulator between employer locations, between park-and-ride facilities or transit hubs, or over a longer distance to provide a route for which there is no public transit alternative or capacity and along which there is a density of potential users.
  4. Guaranteed ride home for employees who do not drive, whether via an area-wide program, company vehicle provision, emergency guaranteed ride, rental car guaranteed trip, or taxicab or TNC guaranteed trip.
  5. Rideshare matching to connect employees and promote carpooling and vanpooling.
  6. Bicycle parking facilities and other active commute facilities including but not limited to lockers, changing areas, electric bicycle charging infrastructure, and showers for employees who walk or bicycle to work.

Category B, subsidies and modal support: Implement programs to ensure that non-drive-alone commutes are preferable options. This may include:

  1. Subsidies for transit fares, such as ORCA business products.
  2. Subsidy for carpool and vanpool participation.
  3. Provision of employer vans or third-party vans for vanpooling.
  4. Pre-tax transportation benefits allowing employees to use pre-tax pay for transit passes, bicycle share (or other emerging forms of micro-mobility) payments or passes, or vanpool use.

Category C, parking management: If parking is utilized at the site, implement strategies to appropriately price parking, and/or reserve parking space specifically for sustainable uses (e.g., secure bicycle parking). These include:

  1. Institute or increase parking charges for SOVs. Omit any parking subsidy from employee benefits package and use onboarding processes and regular information sharing to discourage driving to and parking at an employment site.
  2. Provide parking at a daily rather than monthly rate.
  3. Preferential parking and/or reduced parking charges for high-occupancy vehicles, bicycles, and other forms of emerging micro-mobility.
  4. A parking cash out program, providing payment for employees who do not use the parking facilities.
  5. Provide parking space for carshare vehicles or company-owned cars for employee use.

An employer may propose and implement other measures designed and demonstrated to facilitate the use of non-SOV commute modes or to reduce vehicle miles traveled, as agreed upon between the City and the employer.

The Employee Transportation Coordinator (ETC) is the spokesperson, public relations representative and administrator of the CTR program.

The ETC serves two key functions. They are the point of contact between:

  • The employer and its workforce to implement, promote, and administer the organization's CTR program.
  • The employer and the local jurisdiction to track the employer's progress in meeting CTR requirements

Examples of tasks an ETC will perform:

  • Meet with employees to talk about the benefits of carpooling, vanpooling, bicycling or riding transit
  • Assist employees with ride matching to form carpools or vanpools
  • Promote the worksite CTR program to employees by producing and distributing information pieces
  • Coordinate the distribution and collection of biennial CTR surveys to all employees
  • Track employees' participation in specific program elements
  • Complete the CTR Report & Program Description (annual report)
  • Evaluate the CTR program and make enhancements when necessary
  • Brief management on the CTR program's progress

Qualities of a successful ETC:

  • A high level of interest in CTR, the ability to work with other employees, and manage the elements of a worksite CTR program
  • Interest in commute alternatives and environmental sustainability
  • Someone who already commutes by bicycle, carpool, vanpool, walking or transit
  • Access to management and other employees
  • Excellent communications skills
  • Flexibility in work responsibilities and schedule to implement and promote a worksite CTR program