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HomeMy WebLinkAbout007-25 - Ordinance - Commute Trip Reduction Plan ORDINANCE NO. 007-25 AN ORDINANCE OF THE CITY OF PORT ORCHARD, WASHINGTON, ADOPTING AN UPDATED COMMUTE TRIP REDUCTION (CTR) PLAN PREPARED BY KITSAP TRANSIT AS REQUIRED UNDER RCW70A.14.4000 – 70A.15.4100; AMENDING ATTACHMENT A OF ORDINANCE NO. 014-08, CODIFIED IN PORT ORCHARD MUNICIPAL CODE SECTION 10.86.030; PROVIDING FOR SEVERABILITY AND PUBLICATION; AND SETTING AN EFFECTIVE DATE. WHEREAS, the Washington State Clean Air Act (RCW 70A.14.4000 – 70A.15.4100) requires certain jurisdictions to adopt and maintain a Commute Trip Reduction (CTR) Plan to reduce traffic congestion, fuel consumption, and air pollution; and WHEREAS, the City of Port Orchard initially adopted a Commute Trip Reduction Plan in 1999 through Ordinance No. 1760 in compliance with state law; and WHEREAS, the CTR Plan was subsequently updated in 2008 through Ordinance No. 014- 08, which amended Port Orchard Municipal Code (POMC) Chapter 10.86 and adopted a revised CTR Plan as Attachment A; and WHEREAS, the City is a party to a 1997 Interlocal Agreement with Kitsap Transit and other Kitsap County jurisdictions, which designates Kitsap Transit as the coordinating agency responsible for updating each jurisdiction’s CTR Plan; and WHEREAS, Kitsap Transit has prepared an updated 2025 CTR Plan for the City of Port Orchard to reflect current conditions, goals, and the requirements of state law; and WHEREAS, the City Council finds it is in the public interest to adopt the updated CTR Plan to maintain compliance with RCW 70A.14.4000 – 70A.15.4100, support regional coordination, and promote sustainable transportation; now, therefore, THE CITY COUNCIL OF THE CITY OF PORT ORCHARD, WASHINGTON, DO ORDAIN AS FOLLOWS: SECTION 1. Adoption of 2025-2029 Commute Trip Reduction Plan. The City of Port Orchard hereby adopts the 2025 Commute Trip Reduction (CTR) Plan prepared by Kitsap Transit, which shall replace the existing Attachment A to Ordinance No. 014-08 as referenced in POMC 10.86.030. SECTION 2. Severability. If any section, sentence, clause or phrase of this Ordinance should be held to be unconstitutional or unlawful by a court of competent jurisdiction, such invalidity or unconstitutionality shall not affect the validity or constitutionality of any other Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 Ordinance No. 007-25 Page 2 of 2 section, sentence, clause or phrase of this Ordinance. SECTION 3. Corrections. Upon the approval of the city attorney the city clerk, and/or the code publisher is authorized to make any necessary technical corrections to this ordinance, including but not limited to the correction of scrivener’s/clerical errors, references, ordinance numbering, section/subsection numbers, and any reference thereto. SECTION 4. Publication. This Ordinance shall be published by an approved summary consisting of the title. SECTION 5. Effective Date. This Ordinance shall take effect and be in full force and effect five days after publication, as provided by law. PASSED by the City Council of the City of Port Orchard, APPROVED by the Mayor and attested by the Clerk in authentication of such passage this 10th day of June 2025. Robert Putaansuu, Mayor ATTEST: Brandy Wallace, MMC, City Clerk APPROVED AS TO FORM: Charlotte A. Archer, City Attorney PUBLISHED: June 13, 2025 EFFECTIVE DATE: June 18, 2025 Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 City of Port Orchard Commute Trip Reduction Four-Year Plan Update: 2025–2029 Benefits of CTR 1. Describe the local land use and transportation context and objectives. a. Describe the setting in the jurisdiction as it is today or will be in the near future. Port Orchard currently has about 18,728 people and that number continues to grow. Kitsap County is the largest known employer in the city. New apartment complexes continue to be built adding to the population as well as the traffic volume. b. Describe features of land use and transportation facilities and services that affect commuters. Port Orchard’s Comprehensive Plan and Development Regulations encourage mixed-use walkable neighborhoods. The city has adopted several subarea plans which consider Kitsap Transit’s long-term goals and in some instances are drafted in a manner to encourage increased in areas currently underserved by Kitsap Transit. Further the development regulations and subarea plans are drafted in a manner to be responsive to increased transit availability as Kitsap transit continues to modify their transit options and potential services. c. Describe whether and how commuting patterns have changed in the past few years. Commuting patterns have changed significantly over the last few years, in large part because of COVID, and more folks are working remotely or doing hybrid work. While this is great for the environment, it does pose some challenges for CTR and other modes of commuting. Luckily, there are two, foot ferry options from Port Orchard to Bremerton, helping alleviate much of the traffic and giving people an alternative to driving to Bremerton, as PSNS is the largest employer in the county. d. List the most important land use and transportation objectives from your city or county’s plans that commute trip reduction most directly affects. The five comprehensive plans within Kitsap County are each placing zoning that will allow for 70% of the population and employment growth within ½ mile of designated High-Capacity Transit Corridors (HCT). This adjustment will fuel the use of transit services including CTR aspects with reduced parking capacity. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 The reduced capacity will encourage non-SOV travel. Through travel demand modeling, the city has adjusted land use designations and adopted development regulations which encourage walkable neighborhoods and access to existing transit services. Further, subarea planning efforts have been made to encourage increased transit accessibility. e. Describe critical aspects of land use and transportation that should be sustained and key changes that should be considered to improve commute trip reduction’s contribution to the land use and transportation objectives you reference. The aspects of the Puget Sound Regional Council’s Vision 2050 Plan support increased use of CTR services. Concentrating growth along designed transit corridors provides a framework to design communities which require less reliance on SOVs. The communities in Kitsap are implementing the goals through the comprehensive planning process. However, challenges remain. Such challenges are the location of employment centers far from the workforce housing and far from transit services. This leads to requests for CTR services. The services can help but are limited due to the location of the workforce. Adjustments to CTR services such as ride sharing, and vanpools are helping employees access work sites. However, free parking limits the share of employees which will seek CTR services. It’s important that the changes in the comprehensive plans be kept, allowing the expected growth to occur near transit and with reduced parking ratios. This will improve the efficiency of the transportation system. It will encourage expanded use of CTR services while providing benefits to employers. 2. Describe how the CTR program will help achieve the jurisdiction’s land use and transportation objectives. a. Describe how and to what extent your CTR program will help your city or county achieve the land use and transportation objectives referenced in question 1. The CTR Program at Kitsap Transit compliments the local Comprehensive Plans by providing alternatives to driving alone to employment locations, as well as resources, education, and training on commute options through outreach efforts and providing materials both in print and electronic form. Expanding mode options to make walking and biking realistic options and encouraging dynamic parking pricing would also help the city achieve their CTR goals. All of the local Plans specifically call for reductions in drive alone rates to work sites. 3. Describe how the CTR program will help achieve the jurisdiction’s environmental objectives. a. Describe how the CTR program will support jurisdiction greenhouse gas emission reduction efforts. By encouraging less vehicle miles traveled per person there is a benefit to reducing GHG emissions. The program also supports lower parking ratios, and less land is needed for development. This reduces the Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 urban heat island effect to an unknown degree. b. Describe how the CTR program will support jurisdiction environmental objectives in addition to greenhouse gas emission reductions. The CTR Program supports ride sharing, transit, and active transportation. This addresses many goals in the Comprehensive Plans such as public health, storm water, preserving rural lands, etc. 4. Describe how your CTR program will help achieve regional and state objectives. a. Summarize the local, regional, and state benefits that would be gained if you achieve your CTR targets. By addressing the main objectives in the regional and state transportation plans, the potential advantages are much greater by having a CTR Program in place. From improving transit service and frequency, reducing greenhouse gas emissions, and promoting nonmotorized transportation, CTR benefits contribute to the goals of sustainability, mobility, and accessibility. The CTR program also helps achieve regional and state objectives as past data shows that the non-drive- alone trip rate is higher at CTR worksites, which shows having a program in place is having a positive impact at employers in the county that support CTR. The CTR program helps achieve both regional and state objectives by having the same goals of sustainable, equitable, affordable, safe, and an efficient multimodal transportation system. City of Port Orchard Comprehensive Plan: Objectives: • Roadway improvements • Provide more opportunities for pedestrians, bicyclists and transit riders • Provide new nonmotorized transportation system links between residential areas and nearby employment and shopping areas. • reduce automobile dependence within the city • minimize the need to widen roads to accommodate increasing traffic volumes The implementation of the transportation policy element, and by extension, the implementation of a Commute Trip Reduction Program, will provide a safe, dependable, properly maintained, fiscally and environmentally responsible multi-modal transportation system that is consistent with and supports the other elements of the Comprehensive Plan and the objectives stated therein. State CTR Draft Plan Objectives: • Improve delivery of CTR programs • Produce more useful transportation behavior data • Respond to shifting mobility patterns • Reduce greenhouse gas emissions Summary of benefits that would be gained by meeting CTR targets: • Delivery of CTR programs would be improved. The plan to improve nonmotorized Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 transportation system would improve connections for all travel modes, which will allow the CTR actions to be easier to deliver and more productive. • Providing improvements for pedestrians, bicyclists, and transit riders as well as roadway improvements will help could help shift the mobility patterns. When people feel safer and see improvements, they are more likely to make the change. b. List adjacent CTR-affected cities and counties. • Bremerton • Unincorporated Kitsap County c. Describe the top few cross-border and regional transportation issues that affect your jurisdiction. There are several issues that the current Regional Transportation Plan highlights. • SR 16 at Gorst – a major choke point impeding north-south travel patterns. • Distance between housing location and employment location force commuting travel times to increase. • WSF Ferry service disruptions • US Navy employee/service member commute patterns which increase pressure on off-base housing – forcing commute patterns over long distances. d. Describe the strategies you, adjacent cities and counties, and your region have agreed to use to address the top issues described in the previous bullet.  Bremerton – Work with the City’s ETC to expand use of CTR to address SR 16 at Gorst – another major choke point impeding north-south travel patterns, WSF Ferry service disruptions.  Port Orchard – Work with the City’s ETC to expand use of CTR to address, US Navy employee/service member commute patterns which increase pressure on off-base housing forcing commute patterns over long distances and SR 16 at Gorst – another major choke point impeding north-south travel patterns.  Kitsap County – Work with the City’s ETC to expand use of CTR to address WSF Ferry service disruptions, US Navy employee/service member commute patterns which increase pressure on off-base housing – forcing commute patterns over long distances, SR 16 at Gorst another major choke point impeding north-south travel patterns. Performance targets 5. List your jurisdiction’s CTR performance target(s). a. List performance targets that reflect only CTR-affected worksites. Option 1. Weighted average drive-alone rate (DAR) of 60% or less for CTR-affected worksites at the jurisdictional level. b. List any additional performance targets. No additional performance targets other than the recommended Option 1. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 6. List the base value you’ll use for each performance target. a. For each performance target, provide the number you’ll use as the baseline (or starting number). You’ll measure the difference between this number and your results to report performance. I have established a base value using the 2023-2025 survey cycle and will measure progress using 2025-2027 survey results. I’m using the average drive alone rate, weighted by the total employees at each worksite. As of August 2024, CTR Survey Results City of Port Orchard Baseline: Weighted DAR of 73.8% 7. Describe the method you used to determine the base value for each target. a. Provide the source for each base value listed. The source is the CTR Survey. Alex helped provide the weighted DAR. The way to account for this mathematically is calculating a weighted average based on the number of employees. 1. Multiply the total employees by the drive alone rate for each worksite 2. Add those numbers together 3. Divide by the total number of employees for all worksites 8. Describe how you’ll measure progress toward each target. a. List the method you’ll use to measure progress for each target. CTR Survey every two years 9. List your jurisdiction’s CTR-affected worksites. a. List all your CTR-affected sites. 1. City of Port Orchard – City Hall 2. City of Port Orchard – Public Works Shop 3. Kitsap County – Port Orchard Campus 10. List a performance target for each CTR-affected worksite. a. For any performance targets tied to the CTR survey, indicate that you’ll establish performance targets during the 2023-2025 survey cycle. We will use the jurisdictional target of 60% for all the worksites. 11. List the base value you’ll use for each site. a. For any performance targets tied to the CTR survey, indicate that you’ll establish a base value during the 2023-2025 survey cycle. I’ll establish a base value after survey data validation. Services and strategies 12. Describe the services and strategies your jurisdiction will use to achieve CTR targets. In recent years the City of Port Orchard has implemented several strategies to reduce SOV trips and commute trips overall. These strategies include monetary compensation to encourage carpooling, and the adoption of a telecommuting policy to reduce vehicle trips. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 Marketing and Incentives: Outreach Events including promotional materials and incentives. Schedules and printed materials for all services. 13. Describe how jurisdiction services and strategies will support CTR-affected employers. • Host outreach events to help employees with commute options. • Providing subsidies or transportation incentives. • Limit the free parking. 14. Describe barriers your jurisdiction must address to achieve CTR targets. a. Describe how you’ll address these barriers. The overall barrier to reducing SOV trips is based on the lack of commitment by State and Federal government to fund large-scale transit projects, encouraging land use policies which create automobile dependence. Further, societal perception of transit users must change through policy and investments in infrastructure which makes transit affordable, efficient and convenient. Distance between housing location and employment location force commuting travel times to increase. The CTR program allows for people in less dense areas to access transit and jobs through our Vanpool and Rideshare programs. The Scoot program allows transit users to use a free car sharing program to use for errands and appointments. 15. Describe the transportation demand management technologies your jurisdiction plans to use to deliver CTR services and strategies. Kitsap Transit, who implements the program on behalf of the City of Port Orchard, utilizes statewide CTR technology such as Rideshareonline.com, and the CTR Survey Tool to administer the CTR Survey and Program Report. 16. Transcribe or link to your local CTR ordinance. City of Port Orchard 17. Describe your financial plan. a. Describe the estimated average annual costs of your plan. City of Port Orchard has an agreement with Kitsap Transit to implement the CTR program. Below are the estimated amounts for each activity using CTR grant funds. *these are estimates and may fluctuate across the jurisdictions depending on involvement. My CTR funds do involve resource sharing. Activity Estimated average annual cost Employer Engagement*5,000 Commute Trip Reduction 4 2,650 Performance Reporting**3,000 Administration***5,000 Total $15,650 * Includes identifying worksites and employee transportation coordinators, conducting training, providing technical assistance, and reviewing employer CTR plans. ** Includes worksite surveys and program reports. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 *** Includes financial and program management; CTR for city employees; involvement in comprehensive, regional transportation, and transit planning; transportation demand management technical assistance to capital projects. From the City of Port Orchard ETC/Planner: the city has budgeted $1000 annually towards CTR efforts. b. Describe likely funding sources, public and private, to implement your plan. Source of Revenue Estimated average annual revenue Kitsap Transit $11,439 City of Port Orchard $1,000 WSDOT $15,650 Total $28,089 Funding for CTR in the City of Port Orchard comes primarily from the WSDOT CTR grant funding along with local funds from Kitsap Transit and City of Port Orchard’s General Fund. The breakdown from the WSDOT funds is estimated as follows: $199,600 every two years for all of Kitsap County jurisdictions. $31,300 is allocated to City of Port Orchard from WSDOT funds every 2 years. Kitsap Transit’s breakdown of funds is estimated as follows: $427,128 is the estimated 4-year budget from Kitsap Transit. (Funds are from the CTR budget, SCOOT Car budget, and a portion of the Rideshare budget combined) $106,782 per year divided by all worksites ($3813 each) then per worksite in each jurisdiction. $11,439 is City of Port Orchard’s yearly total from that based on having 3 worksites in their jurisdiction. 18. Describe your implementation structure. a. Describe who will conduct the activities listed in your plan. The City of Port Orchard has an agreement with Kitsap Transit to implement the CTR program. Employee Transportation Coordinators within the jurisdiction will work with the CTR Administrator at Kitsap Transit to implement the CTR program and conduct the activities. b. Indicate who will monitor progress on your plan. List job title, department, and name. The City of Port Orchard has an agreement with Kitsap Transit to implement the CTR program. This would be a combined effort with jurisdictional ETC’s and the Commute Trip Reduction Administrator at Kitsap Transit, Lindsay Kuiphoff. This position is in the Service & Capital Development department. 19. List your implementation schedule. a. Provide the timeline for anticipated projects. Aside from the CTR Surveys & Program Reports and WSRO Conferences, I don’t have any solid dates or specific projects planned. Most of my CTR activities are planned as they come up, especially with outreach events, other than Employer Benefit Fairs, but again we schedule them as they come up. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 • Fall 2025 – CTR Program Reports • October 2025 – Washington State Ridesharing Organization (WSRO) Conference • Spring 2026 – CTR Surveys • October 2026 – WSRO Conference • Spring 2027 – CTR Program Reports • October 2027 – WSRO Conference • Spring 2028 – CTR Surveys • October 2028 – WSRO Conference • Spring 2029 – CTR Program Reports • Will schedule outreach events, ETC trainings, meetings throughout each year and as needed. Provided from the City of Port Orchard Planner: The city will be continuously constructing transportation projects with CTR benefits over the City’s 20-year planning period. See the current 20-year TIP (note that a revise TIP will be adopted as part of the 2024 Comprehensive Plan Periodic Update) for a list of projects. 20. Describe the CTR plan for jurisdiction employees. a. Describe the services, programs, information, and other actions your city or county put in place to help its employees reduce their drive alone commute trips. The Employee Transportation Coordinators at each worksite within the jurisdiction are the ones who implement the CTR programs at their respective worksites. The following are the list of ETCs for City of Port Orchard: • Beth Spalding, Human Resources Analyst, City of Port Orchard – City Hall • Beth Spalding, Human Resources Analyst, City of Port Orchard – Public Works Shop • Lee Reyes, Dept. of Admin Services, Kitsap County – Port Orchard Campus They administer the program elements required of the employer including: • Displaying their contact information in an accessible area at each affected worksite. • Attend basic training and any ETC networking meetings offered. • Develop a mix of elements that encourage employees to use commute options • Promote the Guaranteed Ride Home program • Submit a Program Report every two years • Survey every two years • Implementation of the following measures designed to achieve the county’s commute trip reduction goals: o Distribute promotional challenges and campaigns. o Help employees with commute options as needed. o Provide information to employees on the program and its benefits. o Administer CTR surveys and report on the results o Produce their worksite’s CTR program reports. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 21. Describe how the CTR plan for jurisdiction employees contributes to the success of the overall plan. a. Describe how the plan for jurisdiction employees reinforces the success of the jurisdiction plan? By providing jurisdiction employees the opportunities to; telework, opportunities to have compressed and flexible schedule, surveying employees, distributing CTR information, having the city’s worksites located near transit stops, limiting free parking, informing on the guaranteed ride home program, and encouraging participation in regional events, helps encourage employees to not drive alone and choose other options to commute to and from work, helps contribute to the success of the overall plan. Alignment with plans 22. List the transit agencies that provide service in your jurisdiction. Kitsap Transit and Washington State Ferries 23. List the transit plans you reviewed while developing this plan. • City of Port Orchard’s Comprehensive Plan • The PSRC Regional Transportation Plan • Vision 2050 • The PRTPO RTP • Kitsap Transit’s Transit Development Plan • Kitsap Transit’s Long-Range Transit Plan • The Comprehensive Plans within Kitsap County 24. Describe how this CTR plan supports the transit plans. This Plan compliments the Kitsap Transit LRTP by continuing the CTR program to address access to employment. The LRTP is designed around the local comprehensive plans and Vision 2050. These Plans explain where the growth of population and employment will occur in the next 20- years. Our CTR program includes our Worker/Driver bus routes which serve as an employee shuttle to the Puget Sound Naval Shipyard and Bangor Submarine Base. These bus routes (35 total) carry over 1,500 riders per day into the workplace removing SOV trips from the roads. Our other programs accomplish similar results by reducing the need for SOV travel. This can also reduce GHG emissions. The Vision 2050 Plan calls for reduced SOV trips and GHG emissions. It also recognizes that the impacts of COVID-19 and impacts to employment, may continue to delay forward momentum. This CTR local plan also outlines the direction each of our jurisdictions are moving towards and their goals to promote use of public transit. 25. Describe any comprehensive plan updates that are needed and when they will be made. The City of Port Orchard is currently wrapping up their 2024 Comprehensive Plan Periodic Update. They anticipate adoption by the end of November or early December. More information can be found at https://portorchardwa.gov/2024-comprehensive-plan-periodic-update/. Current versions of each element, which are anticipated for adoption, are available from this page. (from James Fisk, Principal Planner at City of Port Orchard). Engagement 26. Describe stakeholder engagement. a. Who did you talk to? Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 Kitsap Transit conducted a CTR scoping survey put out by the Marketing department. The survey was open for 3 weeks and was distributed on the following platforms to reach as many residents throughout the county as possible: • Kitsap Transit’s website • Sent to ETC’s to share with their employees • Rider Alert subscribers • Posted on social media. We received 706 responses. 215 (30.45%) of those respondents said they lived in Port Orchard. The largest percentage of respondents were from Port Orchard. 180 people (28%) said they work in Port Orchard. Jurisdictional contact for plans: Lindsay Kuiphoff, Kitsap Transit b. When did you talk to them? March 2024 via ETC and employer outreach, and again in August 2024 with the CTR Scoping Survey. c. What did they have to say? i. The top 3 most important community issues for people are: Traffic congestion 65.86%, Travel options besides cars 52.69%, and Equity (adequate, safe access to commute options for all) 35.55%. ii. The top 3 activities or investments people think local jurisdictions should focus on through their CTR programs are: Support telework and hybrid work options 48.44%, Build more safe infrastructure for walking and biking 45.61%, Review and update parking strategies and programs 39.24% d. How did what they said influence the plan? The feedback from stakeholders is in alignment with the City of Port Orchard’s transportation plans. 27. Describe vulnerable populations considered. 0.00% 5.00% 10.00% 15.00% 20.00% 25.00% 30.00% 35.00% Where do you live? Responses Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6 All populations were considered with surveying outreach. Each city and the county sent out notice of the survey, as well as at outreach events. If we need to do more targeted engagement beyond this, we can. 28. Describe engagement focused on vulnerable populations. a. Who did you talk to? • Limited English Proficiency (LEP) groups were notified of the scoping survey • Veteran community was notified of the scoping survey • Low-Income and racial/ethnic groups * The way we did outreach didn't allow for specific numbers for each. Had I made provisions to separate out the groups within the survey questions, I would know the breakdown of respondents from each group. Lesson learned for next time. 29. List employers’ suggestions to make CTR more effective. a. Reached out to all ETCs within the jurisdiction to have them give any suggestions to make CTR more effective. I only received one from anyone in the Port Orchard jurisdiction. Here is what she said: “I am not sure how to make things more effective, as right now things are pretty good however, as the world shifts to telework schedules and EV, I realize there is a need to keep better track of hybrid employees and those who are 100% telework. I’d like some ideas on how other employers incorporate this into their CTR plan. In addition, with the EV mandate in Washington state, I’d like to know if there are any incentive packages they are doing to encourage this move amongst employees and their organization. I believe the requirement is 10% of parking spaces are required to provide EV infrastructure and the mandate has all vehicles to be EV in 2030.” 30. Describe results of engagement focused on vulnerable populations that will be provided for use in comprehensive plan and transit plan updates. a. Lots of responses for safer biking/walking infrastructure needed. Policy language exists in the transportation element to implement context-sensitive bicycle facilities through private development and capital projects. b. Increase frequency/geographic coverage of public transportation. Offer later service. c. Lack of knowledge of Guaranteed Ride Home and ride matching help. Docusign Envelope ID: FFC8210D-A96D-4780-9FCB-DC7BD130BEB6