Commercial Ground Transportation at Airports: Best Practices (2015)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

20 Operations of Commercial Ground Transportation in General This chapter provides an overview of commercial ground transportation operations including the responsibilities of the agencies regulating these services and the basic business models used by commercial ground transportation service providers. It also describes the relationships between the com- panies and their drivers, with particular emphasis on the dif- ferences between drivers who are employees versus those who are independent contractors. Roles, Responsibilities, and Resources of Non-Airport Regulatory Authorities Non-airport regulatory authorities include those at the federal, state, and local levels. These authorities establish regu- lations, ordinances, and operating procedures regarding com- mercial ground transportation carriers. There are two types of ground transportation regulations—economic regulations and safety regulations. Economic regulations include, but are not limited to, carrier entry, exit, fares, routes, finances, and operat- ing procedures, while safety regulations pertain primarily to the vehicle conditions and driver qualifications. In general, the economic and safety regulations of many taxicab, limousine, and van services are local in character and thus have local regulations pertaining to their authority to operate, insurance requirements, vehicle safety, number of vehicles permitted, and driver qualifications. Most state legis- latures consider taxicabs, limousines, and van services to be local issues and have delegated responsibility for their regula- tion to local communities. Buses, however, due to their nature of traveling among cities within a state, were economically regulated at the state level for many years and only deregulated by many states beginning in the 1970s when other modes of interstate and intrastate trans- portation such as trucking lines, railroads, and airlines were also deregulated from economic regulations. A small number of states still regulate buses, vans, limousines, and some taxicab and TNC operations. States regulating buses, minibuses, and vans include California, Colorado, Nevada, Pennsylvania, and Washington. Colorado, Nevada, and Pennsylvania also regulate some taxicab operations within their respective states. TNCs are regulated by the state in California, Colorado, Pennsylva- nia, and Virginia. Other states were in the process of developing regulations for TNCs at the time this guidebook was prepared. The state agency most likely to be vested with this regulatory authority is the state’s Public Utilities Commission (PUC) or a similarly named authority. Should any ground transportation carrier, whether a taxi- cab, limousine, or bus, cross a state line during normal opera- tions, they are considered interstate carriers and require federal motor carrier operating authority. At the federal level, however, the regulations are primarily safety regulations pertaining to operating authority, vehicle standards/operating procedures, recordkeeping, driver qualifications or licensing, and hours of service for drivers. Each of these levels of economic and safety regulations by federal, state, and local authorities are discussed more fully herein. Federal Regulations Federal safety regulations pertaining to buses, minibuses, and passenger vans with nine or more passengers including the driver are administered by the Federal Motor Carrier Safety Administration (FMCSA). This agency is responsible for grant- ing operating authority and inspecting vehicles and companies for compliance with FMCSA safety regulations. Due to the large number of these vehicles that may operate at an airport, airport staff should be familiar with the federal regulations pertaining to bus, limousine, and van passenger carriers with capacity between 9 and 15 passengers and their drivers. The agency’s website (www.fmcsa.dot.gov) provides general information regarding the agency and its activities. While it is helpful for airport staff to be familiar with FMCSA C H A P T E R 4

21 regulations and this information may be referenced in an air- port’s rules and regulations, it is not the role of the airport to enforce these regulations, other than making sure that any vehicle operating on the airport’s roadways is properly regis- tered with FMCSA if its route of travel may involve interstate commerce. The Federal U.S. Department of Transportation (DOT) regulation of most concern to airport staff as it pertains to limousine services is the Motor Carrier Act of 1980. Seeking to eliminate the duplicative registrations that some limou- sine companies had to undergo when they sought to serve multiple airports and communities in different states, this bill was passed by the federal government to require states, cities, and other political subdivisions such as airports to recognize the registration, and in some cases the inspection, of these vehicles that other states had already provided. The act does permit airports to charge user fees for the use of airport facilities and a business license fee for conducting business on airport property. State Regulations of For-Hire Passenger Motor Vehicles As previously mentioned, some states continue to regulate buses, commercial for-hire passenger vans, and taxicabs. Cali- fornia, for example, regulates required insurance levels and company and driver entry into the shared-ride van industry by requiring that these companies obtain a PUC license to operate and that individual drivers obtain permits to drive the vans. The PUC’s responsibilities include: • Regulatory and safety oversight of for-hire passenger carriers (limousines, airport shuttles, and charter and scheduled bus operators), moving companies, railroads, light rail transit agencies, and rail crossings. • Authority over intrastate air carriers, for-hire vessel car- riers, interstate passenger and household goods carriers, and intrastate private carriers of passengers is limited to registration of operations and filing evidence of liability insurance. Entry into the passenger transportation industry in Cali- fornia, however, is not restricted. Individuals, as well as com- panies, can apply for PUC operating authority. It is common in California for individual van owners operating as indepen- dent contractors or franchisees of an airport shuttle company to apply for and receive their own PUC operating authority. Thus, California airport staff seek to ensure that all compa- nies involved in transportation of individuals to and from their airports hold approved authority from the California PUC and that drivers are in possession of an approved driv- ing permit. In general, while minibuses and vans are regulated primarily for safety by the FMCSA, there may also be safety requirements established by individual states that these opera- tors must comply with to obtain operating authority within the state. New to the ground transportation industry are regulations pertaining to peer-to-peer TNCs. California was the first state to recognize and regulate these smartphone application based carriers. At the time this guidebook was completed, several companies had received licenses to operate as a TNC in California, Colorado, and several other states, and the regu- lation of these services was still evolving. Chapter 8 Section C provides additional information on TNC regulations. County or City Regulations By far the most common form of regulation of taxicabs, vans, and other commercial vehicles serving airports are those regulations emanating from the cities or counties. If an airport is located within city limits, city regulations generally govern which companies and drivers are permitted to operate at the airport. For airports located outside city boundaries there may or may not be county regulations regarding who can enter the market and what standards these companies, their drivers, and vehicles must adhere to. Several airports (e.g., Piedmont Triad, Minneapolis-St. Paul International, and Washington Reagan National Airports) are served by taxicabs, limousines, and vans from multiple surrounding jurisdictions, each having its own regulations. In several cases, there may be multiple local jurisdictions such as several cities and/or counties from which taxicabs, limousines, and vans may be attempting to serve the airport. Such multiple jurisdictions often present additional service and compliance issues for airport staff and must be considered when airport staff draft the airport’s own ground transportation rules and procedures. Generally, local regulations by a city or county, or in some cases both, include operating authority for the taxicabs and, to a lesser degree, limousines. Typical local taxicab regulations are economic regulations covering entry into a market, fares, financial reporting, vehicle age and conditions, and driver qual- ifications. Cities and counties will typically restrict entry into the market by limiting the number of participating companies and vehicle permits in order to aggregate sufficient demand per vehicle so as to make it financially attractive for taxicab drivers to enter the industry. In return for these restrictions on entry into the industry, the on-demand taxicab industry is required to engage in actions which limit the revenues a company may earn such as charging only set rates, providing service at all times, accepting credit cards as well as cash, and being available to all areas of the city and/or county. Prearranged services such as limousine and van services are typically not economically regulated in the same manner

22 Transportation Network Companies TNCs have dispatch offices but do not own any vehicles, instead relying upon owner-operators to provide and drive their own personal vehicles. TNCs range from small local com- panies to national and global companies. The companies are responsible for marketing and promoting their services and maintaining the software platform that connects prospective customers and available drivers. Shared-ride Vans Shared-ride van companies vary from national brands (e.g., SuperShuttle and GOAirportShuttle) to local owners having a fleet composed of fewer than five vehicles. The shared-ride van companies are responsible for assigning trips to individual drivers, obtaining permits from airports and other regulatory authorities, and marketing the company. The owner-operators of some companies’ vans are considered franchisees of the national brand. The national company or a local affiliate provides these franchisees dispatching, discount insurance, marketing and promotions, and other services. Owner-operators affiliated with other companies have similar, if less formal, relationships. Courtesy Vehicles Courtesy vehicles include vans, minivans, and large buses owned and operated by rental car, hotel/motel, and off-airport parking companies. The operator of the courtesy vehicles is responsible for vehicle maintenance and licensing, establish- ing headway schedules, and other aspects of customer service. Typically the business operating courtesy vehicles will have a fleet of fewer than six vehicles. In some locations hotels/ motels outsource the operation of their courtesy vehicles to a third party. Scheduled Vans/Buses and Charter Buses Scheduled vans/buses may include long-haul buses and vans or public transit buses. Most scheduled buses and vans are operated by a local transit agency, but a few private companies also operate scheduled bus services. These buses include over-the-road coaches having underfloor baggage storage, full-size buses, minibuses, cutaways, and standard vans. Most frequently the charter bus operator owns the bus fleet and employs the drivers. Some charter bus opera- tors do not obtain airport permits for each bus they own, assuming that only a small proportion of their fleet will serve the airport. Private operators are responsible for vehicle maintenance, marketing, and overall operations and scheduling. as taxicabs. Entry into these markets by limousine com- panies is generally not restricted by local regulations, but many jurisdictions mandate minimum fares for chartered limousines or chartered vans to help distinguish these ser- vices, which are considered to be higher quality products than taxicabs. Therefore, it is important for airport staff to become famil- iar with local regulations governing taxicabs and limousines. This is because these local ordinances may serve as a basis from which to develop the airport’s ground transportation rules and operating procedures. Because of this, as regula- tions are updated or developed, it is also important for the airport to be involved in the regulatory process. Roles and Responsibilities of Companies/Providers The following paragraphs describe the roles and respon- sibilities of the various commercial ground transportation companies (or providers) commonly found at airports. Taxicabs In most communities, taxicab companies own few vehicles and employ few if any drivers, but instead rely upon owner- operators who provide and drive taxicabs or upon drivers who lease company-owned vehicles. Frequently the drivers, not the companies, are responsible for obtaining the required permit or medallion from the local regulatory authority. To benefit their affiliated drivers, taxicab companies provide (1) dispatching services, which may be considered less valuable if drivers serve a large volume of airport passengers or street hails, (2) mar- keting and advertising to potential customers including major employers, (3) discount or umbrella insurance policies to the drivers, and (4) vehicle maintenance. Few of these businesses are affiliated with taxicab companies located in other cities— that is, it is unusual for an individual or business to own taxi- cabs in multiple cities. Limousines Limousine companies range from individual owner- operators to companies owning large fleets employing many drivers. Some companies, using franchises, operate on a global basis while others are strictly locally based. Individual drivers attempt to develop their own customers (i.e., “person- als”) while at the same time serving trips booked through a larger limousine company with whom they are affiliated. Many limousine companies own only a few luxury sedans/ SUVs and vans and rely upon the vehicles owned by their affiliates to supplement this fleet when they book a large party or require additional vehicles.

23 • Ground transportation providers who engage independent contractors to provide ground transportation services The relationship between companies and drivers as either employees or independent owner-operators greatly impacts the cost and business structure of ground transportation services. An employer is required to provide their employees with certain benefits which vary depending if the employee works on a full-time or part-time basis and the state and city in which the business is located. These benefits may include contributions to Medicare, social security, unemployment insurance, and at larger companies, health insurance and time off for holidays and vacation. Many commercial ground trans- portation businesses now use independent contractors to drive their taxicabs, limousines, and vans rather than employees. In this case, the independent contractor, not the employer, is responsible for the cost of providing insurance and other benefits. Several states and federal agencies (e.g., the National Labor Relations Board) have issued rulings defining what consti- tutes an employee versus an independent contractor. Thus airport staff must consider the employer-employee relation- ship to stay in compliance with state and federal laws and regulations and the policies of the airport board/local elected officials regarding the living wages/minimum wages and health benefits to be provided to persons working at the airport. These policies have an impact on both the structure of and the opportunities provided to commercial ground transportation services. If a driver, for instance is found to be an employee, certain laws dictate how he or she must be compensated. These laws and regulations exist at the local, state, and federal level. Decisions impacting the determination of these relationships, and thus the costs associated with the service, are found in case law, statutes, codes, and regulations impacting the services. Set forth are a few general considerations and some of the recent cases and administrative decisions related to the employer- employee relationship in ground transportation. There are many factors that contribute to the legal defini- tion of whether a driver is an employee or an independent contractor. The terms and conditions upon which service pro- viders are compensated and managed greatly inform their status as employers/employees. Factors which impact the determina- tion of whether an operator is considered to be an employee include: • Hiring party’s right to control the manner and means by which the product is provided • Skill required • Source of the instrumentalities and tools • Location of the work Competition Among Providers As one might expect there is considerable competition among providers for deplaning airport passengers who have not chosen a ground transportation alternative before their arrival at the airport. Where available, these passengers may select an on-demand taxicab, an on-demand limousine, a shared-ride van, summon a prearranged taxicab or limousine service or a TNC by calling or using their transportation app, or board a scheduled bus/van service. This competition for arriving airline passengers may result in providers taking one of several actions to gain a competi- tive edge. One primary area of competition is positioning on the airport curbside. Both on-demand taxicabs and shared- ride van concessionaires want to be front and center outside the doors from baggage claim so they are visible and easily accessible to potential customers. If taxicabs, limousines, or shared-ride van providers are located next to each other at the curb, airport personnel often need to be present to ensure that customers are not improperly solicited from their pre- ferred service by a competitor. In the case of the on-demand taxicab line, airport staff or a third-party presence is typically needed to ensure that drivers do not turn down short trips, telling passengers to take the next taxicab in line instead. Some prearranged limousine drivers attempt to attract customers by offering transportation to passengers who have not made prior arrangements. This solicitation, which is con- sidered illegal, typically occurs inside or near the baggage claim of the terminal building. Arriving passengers may be asked if they need transportation and those answering posi- tively are ushered out of the terminal baggage areas to a waiting limousine. There is also price competition among the various ground transportation carriers. Shared-ride vans compete on the basis of price with other ground transportation options—often being 60% of the cost of a taxicab to the same destination. Taxicabs are generally more expensive than shared-ride alternatives but less than limousine services. Thus, the airline traveling public will have several commercial ground transportation options available to them at a range of costs and service levels at most airports. Relationships Between Companies and Drivers In commercial ground transportation businesses, there are two primary relationship structures between the companies providing the transportation and their drivers or other key staff: • Ground transportation providers who hire drivers as employees

24 (Order Granting Plaintiffs’ Motion for Final Approval of Class and Collective Action Settlement). As a result of this class action settlement, it was agreed: • By SuperShuttle to pay $12,000,000 into a gross settlement fund as well as pay other fees, and that its contractual doc- uments and operational policies and practices determine that its operators are independent contractors. As a result of this case, SuperShuttle made changes to its franchise operations and provided new franchise agreements and modifications to the existing agreements. The new fran- chise agreements and modifications establish a system that enhances the operators’ entrepreneurial opportunities and independent status. • By the Operators to an independent contractor status mean- ing that SuperShuttle is not required to pay minimum wage, overtime, meal period pay, reimbursable business expenses, or health care. The next phase in the employee vs. independent contractor conversation is the case O’Conner v. Uber Technologies, also a class action suit, which at the time this report was completed was moving through the court system. Uber Technologies requested to dismiss the case by a motion for summary judg- ment stating that Plaintiffs are independent contractors as a matter of law. On March 15, 2015, the United States District Judge signed an Order Denying Uber Technologies’ Motion for Summary Judgment. The argument for denial is based on the ruling that Uber drivers are presumptive employees, and the distinction is a matter of fact whether the drivers are independent contractors or employees and therefore for jury determination. Further, the court’s ruling included an opinion that (1) the tradi- tional test of employment is insufficient when viewed under a “sharing economy” model, and (2) the legislature or appellate courts may eventually be required to refine or revise a test of employment particular to the sharing economy depending on additional cases or this case. Basis of Compensation for Companies and Drivers Compensation for the three primary commercial ground transportation companies and their drivers depends upon the relationships noted in the previous section. Taxicabs Generally, all taxicab drivers are compensated directly from the fares and tips they receive from their customers. As independent contractor drivers or owner-drivers of their own taxicab, they are typically small business individuals or • Duration of the relationship between the parties • Whether the hiring party has the right to assign additional projects to the third party • The extent of the hired party’s discretion over when and how long to work • The method of payment • The hired party’s role in hiring and paying assistants • Whether the work is part of the regular business of the hiring party • The provision of employee benefits • Tax treatment of the hired party While airport ground transportation staff is not usually in a position to impact decisions related to whether or not driv- ers for ground transportation providers are employees of a company or independent contractors, it is important for staff and decision makers to understand the issues related to this question for several reasons: • Whether a driver is an employee or an independent con- tractor impacts the cost structure of the services available to passengers. Utilizing independent contractors enables the provider to make services available at a lower cost to cus- tomers (and provide greater profit to the company owner), but the drivers themselves may have a difficult time making a decent wage when they are responsible for all of the costs of providing a vehicle as well as insurance, maintenance, driver training, and equipment. • Company owners have a more difficult time managing independent contractors than they would employees because of the nature of an independent contractor relationship. The airport must make sure it retains a measure of control over the ground transportation provider and enforce rules, regulations and standards so that it can ensure the level of service, including dependability, convenience, and safety, expected by customers. • If the airport utilizes companies which use independent contractors, the airport may make the resources of its small or Disadvantaged Business Enterprise (DBE) business support or economic development staff available to help small business owners gain access to business development resources such as low-cost loans, affordable health care, and other insurance and business marketing services. • It is important for airport staff to understand the differences in employer-employee vs. independent contractor relation- ships as they may impact the structure, content, or goals of a Request for Proposals (RFP) or RFQ for commercial ground transportation services. The most visible court case involving employer-employee relationships was Kairy v. SuperShuttle (U.S. District Court in Northern California) which was signed in November 2014

25 shuttle drivers is typically in two forms, an hourly rate and gratuities (tips) paid by airport customers. In many shuttle operations, the hourly rate is often minimal but the amount of income earned from tips is considerable. Scheduled and Charter Buses/Vans Scheduled and charter bus/van drivers are typically employ- ees of the bus/van company. Scheduled operators derive their revenues from the fares charged customers, while charter oper- ators are paid for the cost of leasing the entire vehicle, regard- less of the number of customers transported. Capital/Operating Expenses for Companies and Drivers Taxicabs Capital and operating expenses in the airport taxicab indus- try are commonly borne entirely by the driver, but not in all cases. Some taxicab companies provide the vehicle and lease it to a driver. In this case, the capital employed in the vehicle and its annual operating expense is borne by the company with the driver paying only for fuel used. Capital costs of taxicab vehicles used in an open airport system are low in comparison to taxicabs used as part of an airport concession agreement. Many airport taxicab drivers or taxicab companies that lease cabs to the drivers purchase only used vehicles with limited mileage (less than 100,000 miles) on the vehicle. Therefore the cost of these vehicles rarely exceeds $10,000 dollars and often is less. Used state police cars traditionally were a favorite vehicle for taxicabs since they were inexpensive, built for heavy street use, and were comfortable for all day driving. However, when the cost of gasoline passed $4.00 per gallon, it motivated taxicab drivers and taxicab fleet managers to move away from these heavy vehicles in favor of more fuel efficient smaller vehicles. A favorite vehicle of the airport oriented independent owner- operator has been the front wheel drive Chrysler/Dodge mini- van due to its large passenger and cargo area and utilization of a more fuel efficient smaller engine. Unless there is an air- port taxicab concession requiring newer vehicles, the average capital cost of these used vehicles for airport taxicab service is typically in the $6,000 range, with replacement by another used vehicle every 3 to 4 years. If these vehicles are utilized in airport service only, no other capital costs may be neces- sary other than equipping the vehicle with a “taxicab pack- age” which consists of painting, a taxicab meter, a credit card reader, and communication equipment, all of which can be accomplished for less than $1,000 per vehicle. [Note: These costs represent 2014 values.] The primary daily operating expense for the airport taxi- cabs is fuel—primarily gasoline, but with a quickly changing entities that pay a fee for the lease of their taxicab operating authority, insurance, dispatch service, and any marketing support the taxicab company provides. The lease fees they pay to the taxicab company provide the compensation earned by the taxicab company. Shared-ride Vans Airport shared-ride van concessions are performed with either independent contractors who own their own van or with employees of the shared-ride van company. In the case of independent contractors, the driver typically pays the van company for the vehicle lease, insurance, and other fees. The driver must reconcile these costs of operation from the total amount of revenues generated by their vehicle. Thus, the inde- pendent contractor’s compensation is the residual from van earnings after all the fees are paid to the company. Shared-ride van services that have employee drivers would operate as any other employee business. The company col- lects all fares paid by users of the service and pays the driver an hourly rate, regardless of the number of passengers con- veyed. Hourly wages vary from company to company but generally shared-ride van drivers receive considerable com- pensation in the form of gratuities from passengers so their total compensation may be 20% or more than their stated hourly rates. Limousines Limousine companies use both full and part-time employ- ees and some make use of independent contractor drivers when there is prearranged work for them. Unless there is an on-demand limousine concession at the airport, most lim- ousine drivers are paid as either employees or independent contractor drivers. Transportation Network Companies TNC drivers are typically independent contractors who use their own personal vehicle to provide transportation ser- vices. The company retains a portion of each fare for providing and maintaining the TNC app and connecting customers to the drivers. Drivers choose when to work, whether full-time, part- time, or only occasionally, and may drive for multiple TNCs during the same day, operating through whichever app first connects the driver to a passenger. Courtesy Vehicles The drivers of courtesy vehicles are typically employees of the primary business providing the courtesy shuttle service. Compensation for rental car, hotel, and off-airport parking

26 generator of commercial passenger trips for taxicabs, limou- sines, and shared-ride vans in the region, and therefore all drivers and companies want to serve the airport. Thus, it is the responsibility of airport management to provide operat- ing rules and regulations that respond to the airport’s goals of providing the desired customer experience, operating their facility efficiently, meeting regional environmental and sus- tainability goals, preserving airport revenues, and achieving other management objectives. In most cities airport roadways are considered “private roadways” open to the public under the rules, operating pro- cedures, and fees set forth by the airport sponsor rather than as public roadways accessible to all motorists on an equal basis. When they operate outside of the airport, commer- cial ground transportation vehicles and drivers use the same roadways as private vehicles and generally must obey the same laws as private vehicle drivers. However, when operating on an airport, commercial vehicle drivers must obey addi- tional or different rules than the drivers of private vehicles. This is because it is in the traveling public’s interest that they be treated differently for traffic, safety, environmental, eco- nomic, and other reasons. Local Political Interests In many communities, local political interests focus on (1) customer service and serving visitors, and (2) meet- ing the needs of the taxicab and limousine industry, which is often composed of small businesses and drivers who are recent immigrants. These groups typically have direct access to elected officials and a large amount of influence relative to the number of customers they serve. When airports pro- pose changes that the taxicab or limousine industry perceives as negatively affecting their income and businesses, they may lobby the elected officials by citing personal examples of hardship, which may be more effective and influential than the information and recommendations provided by airport staff. Public Transit Proponents and Operating Agencies Airport staff should coordinate with local transporta- tion agencies when a project the airport is undertaking may impact a transit agency, regardless of whether the agency’s approval is required. Conversely, ground transportation staff should be involved in efforts to extend public transit services to the airport or improve existing service. Buses serving air- port passengers typically have different requirements than public transit buses serving only downtown areas. These dif- ferences should be clearly communicated to public transit agencies, and may include peak period service hours that differ from traditional commute hours, reduced vehicle capacities landscape to other fuels such as CNG, propane, and hybrid vehicles such as the Prius. Fuel costs can range from as high as $50 to $60 per day for the traditional retreated police car to as low as $20 per day for the fuel efficient Prius, depending upon fuel prices and distances traveled. Limousines Limousine capital costs are initially more than that of a taxicab, but operating costs are similar to that of a large sedan used in taxicab work. Sedan type limousines can be purchased new for around $30,000 per vehicle or slightly less when pur- chased at fleet sale prices. However, since a limousine travels considerably less miles that a taxicab each year (30,000 miles vs. 60,000 miles) their useful life as a commercial vehicle can be up to 12 years. In limousine services, it is common for the limousine company to assume all variable costs of operation, including fuel, and to compensate the driver as a percentage of revenue received while the driver was operating the vehicle. Transportation Network Companies Since TNCs operate using a driver’s own personal vehicle, some drivers may not have any initial capital costs if they already own a vehicle that meets the TNC’s operating require- ments. The primary operating expense for TNC drivers is fuel. Since drivers may work for a TNC as little as several hours per month or may choose to drive full-time, the mileage put on the vehicle in addition to personal miles driven can vary considerably. Shared-ride Vans Capital costs in the shared-ride van industry are borne by the drivers if the carrier is using owner-operators and by the company if drivers are employees. Vehicle costs for the vans usually range from $15,000 to $25,000 depending on acces- sories and size—for example, 9 vs. 15 passenger vans. Operat- ing costs for the vehicles are relatively high given the low fuel efficiency and high annual mileage of these vehicles. It is not uncommon for shared-ride vans to operate 90,000 or more miles per year. Thus, the useful life of a shared-ride van is typically 5 years or less. Other External Factors Affecting Ground Transportation Operations and Operating Procedures One of the more significant external factors affecting ground transportation operations and operating procedures at airports is that the airport is typically the largest single

27 agencies is important when seeking to implement these types of environmental programs, as the staff of these agencies may have experience with similar projects and be able to provide guidance to airport staff. Occasionally grant oppor- tunities may also be available through these agencies, or they may have knowledge of other funding opportunities for emission reduction programs. Chapter 8 Section H discusses best practices for supporting local and regional environ- mental goals. due to passengers with luggage, and the resulting need for increased frequency of service. Environmental Regulatory Agencies Airport sponsors may establish programs or develop plans to reduce emissions from traffic generated by the air- port, including commercial ground transportation vehicles. Coordination with federal, state, and local environmental