Legal Principles of Environmental Accounting as Means of Identifying Sustainable Development Indicators in Ukraine

The article presents the results of the legal analysis of the formation of environmental accounting as one of the main means of determining the effectiveness of the implemented indicators of sustainable development. It is established that today there are no common approaches around the world to identify sustainable development indicators, including their environmental component. This greatly influences the development of a unified system of environmental accounting, which contains important data on the quantity and quality of natural resources, their legal status, the number of objects and substances that have harmful effects on the environment, financial and other measures taken for the environmental modernization of enterprises , the payment of environmental payments, etc., as such information is a major factor in making further management decisions to achieve sustainability in the environmental field, both locally, nationally, regionally, and globally. tovomu level.

Introduction
The increasing level of environmental pollution, the growth of natural and manmade disasters, the depletion of natural resources make the importance of solving the problems of protection and protection of the environment, the conservation and rational use of natural resources. That is why the state and the environment are becoming more relevant to human development. Not so much the traditional political and socioeconomic problems as the pressing environmental problems are becoming increasingly active. They are caused by both nature and human activity, with the latter being more noticeable. In such circumstances, it becomes obvious that there is a vital need to solve the problems of optimization of environmental management, rehabilitation and environmental protection. Developing a sound state policy on natural resources, environmental security and environmental protection is required. In this regard, there is a growing need for a significant restructuring of environmental accounting, which generates, analyzes and publishes information on these important issues, and serves as an information base for the preparation and decision making of environmentally sound decisions. At the same time, it is an important and effective link to modern governance in the context of the transition to sustainable socio-economic development declared at the United Nations Conference on the Environment (Rio de Janeiro, 1992) and endorsed at the World Summit in Johannesburg (2002). ), the Fifth Pan-European Conference of Ministers of the Environment «Environment for Europe» (Kyiv, 2003), the UN World Summit on Sustainable Development (2015), etc., as it contains important data on the environmental status of the speakers Th indicators of the environmental component of sustainable development. Constructive analysis of scientific results in this subject area allows us to draw conclusions about the materiality of theoretical and methodological scientific developments. At the same time, we find that the issue of establishing environmental accounting as a means of determining sustainable development indicators has not been investigated in both domestic and foreign legal science, and therefore the purpose of this article is to study the existing experience of foreign countries in the formation and operation of such accounting systems to choose the best option for creating your own environmental accounting system that will help ensure sustainability in the environment.

The legal nature of environmental accounting as a means of determining indicators of sustainable development
Sustainable development not only of the state as a whole, but of any region combines three main components -economic, social and environmental. An important problem in the implementation of the concept of sustainable development is the creation of a measurement system for quantitative and qualitative evaluation of this very complex process, the main requirements of which are the informative completeness and adequacy of the presentation of the interconnected triad of components of sustainable development. The development of sustainable development indicators is a complex and expensive procedure (Indicators of Sustainable Development of Russia, 2001). The large number of indicators in the system complicates their use in many countries due to the lack of necessary statistics. A sustainable development indicator should be considered a quantitative indicator that can reflect economic, social and environmental development in a particular region and has such features as ease of interpretation, wide scope, sensitivity to change, quantification, and making forecasts and timely trends. Controlling the achievement of the Sustainable Development Goals, managing this process, making decisions, evaluating the effectiveness of the tools used, and the level of achievement of the objectives set, require the development of appropriate criteria and indicators -indicators of sustainable development. Thus, the main purpose of creating a system of indicators is to monitor the sustainable development of society. Recently, significant work in the field of indicator development has been carried out by a number of collectives at the local, regional and global levels of both sustainable development in general and its individual aspects (Pirikov, 2013;Nesterenko, 2017;Garcia, Staples, and © 2020 The Authors. Journal Compilation © 2020 European Center of Sustainable Development. Chesson, 2000;Kuik and Verbruggen, 2012;Steurer and Hametner, 2010;Schaltegger and Burritt, 2000 etc.). Several options for assessing sustainable development are already being actively developed and are already under way in the world community, the most well-known being a System for Integrated Environmental and Economic Accounting (SIEEA), which aims to take environmental factors into account in national statistics. The system shows the relationship between the state of the environment and the economy of the state (the relationship is expressed through the UN system of national accounts taking into account environmental factors and natural resources). This system includes not only environmental monitoring data, but also information on the environmental performance of enterprises (purchase and use of natural resources, emissions, discharges and disposal of waste, costs of post-emergency measures, including compensation for environmental damage, etc.). Such a system is called ecological accounting (Kozhukhova, 2012;MacGillivray and Zadek, 1995;Carlos Larrinaga-Gonzalez and Bebbington, 2001;O'Donovan, 2001;Jones, 2019). In this regard, environmental accounting (in the general economic sense) is defined as a system for detecting, measuring, registering, accumulating, summarizing, storing, processing and preparing relevant information about an enterprise's activity in the field of environmental management for the purpose of transmitting it to internal and external users for making optimal decisions (Kirsanova, 2004). Based on the same principles as all accounting systems, the environmental accounting system provides an objective picture of the state and dynamics of natural heritage, the interaction between the economy and the environment and the costs of preventive measures, environmental protection and environmental damage. Thus, environmental accounting is the most important tool for implementing the concept of sustainable development, that is, development that does not destroy the resources necessary for the life and development of future generations on Earth. Without reliable and complete information on the state of the environment it is impossible to speak about the proper implementation of other environmental rights of the individual . In recent years, the increasing impact of human activity on the environment at the local and global levels has clearly demonstrated that the environmental costs of the development process can no longer be simply ignored, especially in urban areas, and that specific tools should be used to assess and regulate them. In addition, increased access to information has made environmental data increasingly in demand for policymakers and ordinary citizens alike, which necessitates better regulation of environmental performance. Information support in the field of environmental protection is one of the main elements of the state's obligation to create favorable conditions for life and health of people (Ladychenko, 2018;Yara, 2018). Therefore, legal science has found that environmental accounting combines the information function and the function of environmental management, it is usually associated with natural resources, where such a function, in turn, is defined as the collection and analytical summation of information about the quantity and quality of available natural resources for organization of their rational use, planning of economic and environmental activities, forecasting trends in the development of environmental Published by ECSDEV, Via dei Fiori, 34, 00172, Rome, Italy http://ecsdev.org industries and changes in the environment in the current period and in the future (Lazareva and Milovets, 2008). Calling ecological accounting a system of accounting for environmental activities (Shapinguzov, 1997). Today, such accounting also performs its own functions: 1) optimistic, which is to create the grounds for the best choice of optimal options for environmentally-friendly activities; 2) motivational, which is manifested in providing information to stimulate the implementation of solutions to environmental problems; 3) controlling, which is to carry out control measures for the implementation of environmental costs (Gritsenko, 2016). In this regard, in the environmental legal literature, such accounting is attributed, in addition to the function of environmental management, to the type of environmental information (Brynchuk, 1998).
In Ukrainian environmental law, such accounting is defined as environmental accounting, which includes accounting for natural resources and accounting for objects and substances that adversely affect the state of the environment (Malysheva, 2018). We propose to consider it as a means of ensuring environmental safety, regulated by the system of legal norms, which is realized within the limits of ecological relations, through the purposeful activity of specially authorized state and self-governing bodies, institutions, organizations and economic entities, the purpose of which is to collect, process and submit a summary statistical reporting on the amount of natural resources available in the state that are conserved, as well as those owned or used and their condition; the amount of emissions and discharges of pollutants, as well as the development, review, analysis and evaluation of technical and regulatory documentsecological passport of the enterprise, safety declaration or passport of waste, etc., which allows to establish the level of environmental risk of various types of substances and objects to the requirements of ecological safety and entering them to special state (sectoral) registers (cadastres), which are one of the instruments for preventing emergencies of anthropogenic and natural nature, and therefore an indicator of ecology term component of sustainable development. In fact, in Ukraine today there are such types of environmental accounting (excluding natural resources inventories), such as: 1) state registration in the field of atmospheric air protection, which includes maintenance of: State register of pesticides and agrochemicals authorized for use in Ukraine, State register of veterinary preparations, feed additives, premixes and finished feeds, National inventory of anthropogenic emissions and absorption of steam; 2) state registration of hazardous factors (chemical, physical and biological), by keeping such registers as: State register of dangerous factors; State Register of Ionizing Radiation Sources; Dose irradiation registry; Single registry of licenses issued for conducting activities in the field of nuclear energy use; Register of radio electronic devices and radiation devices that may be used in the territory of Ukraine in the bands of public radio frequencies; State register of genetically modified organisms of varieties of agricultural plants in an open system; State register of cosmetics and medicines containing or derived from genetically modified organisms; 3) accounting for discharge of return (waste) water and pollutants, which today has no special legal regulation and is a component of a more general state accountingaccounting of water use; 4) state registration of objects that have an adverse impact on the environment, within which the state register is kept: State register of potentially dangerous objects, State register of high-risk objects, State register of economic entities carrying out the acceptance and / or dismantling of vehicles, disposed of, State cadastre of radioactive waste repositories, Register of waste disposal, treatment and disposal facilities and Register of waste disposal sites. In case of emergencies at such sites, the State Emergency Service of Ukraine shall also keep records of such emergencies. The diversity of existing types of environmental accounting in Ukraine, on the one hand, confirms the active participation of the state in controlling the level of environmental pollution in its territory, and on the other -defines the need to integrate existing accounting systems into a single, more general, able to comprehensively determine the state of the environment in the state. To find out this possibility, let us turn to the world practice in the formation of similar databases.

Legal principles of formation of ecological accounting at the international and foreign level
It should be noted that initially accounting was not perceived as an environmental management tool, despite the rapid increase in costs and responsibilities of foreign enterprises associated with environmental protection -they were not reflected in the financial statements. The first attempts to reflect environmental parameters in the enterprise accounting and reporting system began to be made in the 1970s (International Standards, 1998;Kovalyov, 1997). In particular, the First International Conference on Environment, convened by the United Nations (hereinafter referred to as the UN), took place in Stockholm in 1972. In accordance with its decisions, a program, UN recommendations on common environmental issues, sustainable nature management and environmental protection of a planetary nature have been developed. Based on this program, the Statistical Office of the Secretariat of the United Nations, after extensive consultations with other international organizations, relevant governments in many countries of the world conducted a study of the problem: what should be the system of environmental indicators, the need for environmental statistics, what methods of its collection and processing, etc. A guide to environmental statistics and a framework (recommendations) for the development of environmental statistics (hereinafter referred to as the FDES) for international environmental and statistical organizations and individual countries has been prepared. For the first time, the Statistics Office of the UN Secretariat has defined the environment statistics as a field of general statistics (Framework for Development, 1985). FDES covered the six major components of the environment: the atmosphere, water (fresh and marine), land (surface and subsoil), flora, fauna and settlements. Each of these components was considered in the light of four categories of information: socioeconomic activity of people and natural phenomena; the effects of these activities and phenomena on the environment; the reaction of society to them; baselines, fixed assets and stocks.
Published by ECSDEV, Via dei Fiori, 34, 00172, Rome, Italy http://ecsdev.org FDES have become the basis for organizing environmental statistics in each country and for interested international organizations. And although they have absorbed some of the experience of some countries, the work of international statistical and environmental organizations, they have not yet been able to act as a complete international form. After all, there were no generally accepted theoretical foundations and standards, common, common units of calculus, etc. The RSRSS were indeed of a recommendatory nature (Kolesnik, 2000;Concepts and Methods, 1992). Therefore, in 1974, at the eighth session of the EU Statistical Commission, the United Nations Secretariat-General's Program for International Activities in the Field of Environmental Statistics, proposed by the Statistical Office of the United Nations, was considered. At the same time, in the early 70-ies of the twentieth century, a complex environmental situation emerged around nature-using enterprises, which are the main pollutants of the environment: on the one hand, public protests against environmentally harmful activities intensified, on the other -intensified, on the other stringent environmental requirements, the failure of which entailed very strict liability measures up to the closure of the enterprise. For example, violating the water quality standards of the U.S. Clean Water Act (as amended in 1972, 1977, and 1987) entailed criminal, civil, and administrative liability. For particularly serious offenses the court was fined $ 2.5 to $ 25,000 for each day of the violation and (or) imprisonment for one year. For less serious offenses fined up to 10 thousand dollars for each day of violation. Administrative responsibility was the right of the Environmental Protection Agency to issue a notice of a registered violation requesting its termination, as well as the right to enter the offending company in the lists of persons with whom federal contracts are terminated or federal aid is terminated. In the highly competitive US market, such administrative sanctions are extremely effective: it discredit the firm, threaten to lose its clientele, and for some entrepreneurs, contract termination or denial of federal aid means financial collapse. Thus, business entities had to urgently take preventative measures to address the situation that threatens their financial ruin (Krasnova, 1992). For example, at one time, the US Environmental Protection Agency identified 27,000 landfills that required $ 1 billion to clean up. However, this did not happen and the costs were not included in the financial statements of the entities responsible. Most enterprises generally refused to acknowledge the extent of their environmental pollution action and to consider the cost of waste treatment, as this would reflect the value of their shares (Serov, 1999 With regard to the public sector, the use of environmental audit was initially sporadic. For example, since the 1970s, the French Ministry of the Environment has submitted reports on public expenditures in the following areas: aspen -cleaning; air; noise; waste; street cleaning; environmental heritage; research and development; environmental management (Gruning and Cohen, 2000). For the first time at the local regulatory level, environmental accounting issues were introduced in Germany in 1973 by developing Guidelines on methods for calculating the volume of costs associated with environmental activities at chemical enterprises, based on the recommendations of the Economics Division of the German Chemical Industry Association (Verband der Chemischen Industrie e.v.) (Matveeva, 1998).
In 1974, the Norwegian Environmental Accounting System was developed with a detailed structure and the necessary information base of accounts for economically strategically important resources, such as oil, gas, electricity, as well as for the volume of emissions into the atmosphere. The system was aimed at reflecting the flows of such substances (Matveeva, 1998). An attempt to develop an expanded environmental accounting system was made in 1976 in Canada. In the same period, France developed a «System of accounting for the natural heritage», which includes information about all the natural resources of the country under the scheme «initial stocks» -«final stocks» -«natural renewal» -«net accumulation» or «annual, possible volume consumption» -«available resources»). These include: impact on the functioning of the natural environment; extraction (use) of natural resources; development of territories; the impact of pollutant emissions and waste production; types of economic activity that pollute the environment, etc. (Grüning and Cohen 2000, 4). In 1986, such a system of data included: a) continental water management (1975)(1976)(1977)(1978)(1979)(1980)(1981)(1982)(1983); b) waste disposal and recycling (1978)(1979)(1980)(1981)(1982)(1983); c) protected natural spaces (national parks (1974-1983), regional parks (1975)(1976)(1977)(1978)(1979)(1980)); d) protection of marine areas (1982); e) hunting (1983) (Gruning and Cohen, 2000). Since 1978, the United States of America (New Jersey) has for the first time created a Pollutant Emissions Register, which has included 155 chemicals and 7,000 reporting organizations. The obligation to maintain such a register by all US businesses was enshrined in 1986 in the US Comprehensive Environmental Protection, Compensation and Liability Act after the Bhopal disaster.
In addition, since 1984, the United States and Canada have for the first time created a system of economic and environmental auditing to gather information on the peculiarities of the harmful effects of various areas of human activity on the environment (Yegorova, 1995). However, ecological accounting has received special attention from the international community only since the early 1990s. In 1991, International Society for Astrological Research (hereinafter referred to as ISAR) developed the first guidance (guidance) for accountants to reflect in the financial statements the environmental impact of an entity's business activities (Tax System, 1997 , which is based on the consideration of the environmental factor in national statistics and is based on adjustment of traditional economic indicators due to two values: estimation of the cost of natural resources depletion and ecological and economic damage from pollution. In 1993, under the auspices of the United Nations Statistics Commission, the London Group on Environmental Accounting was established as a forum for practitioners to share their experience in developing and maintaining natural and economic accounts. Expanding discussions on the concepts and methods of natural and economic accounting, together with the experience of individual countries, has led to a more active convergence of concepts and methods for different SEEA modules (Central basis, 2017). As a result, SEEA-2003 has not been formally adopted as an international statistical standard but recognized as a stand-alone statistical system that, on the whole, has provided a widely recognized and reliable basis for compiling natural-economic accounts and has been used by many countries around the world.
Recognizing the ever-increasing importance of environmental information and the need to include this information in an economic context accessible to central decision-makers, the Statistical Commission agreed at its thirty-eighth session, held in 2007, to launch a second review process with a view to adopting SEEA as an international a statistical standard for natural-economic accounting over the next five years.  CP.11 (2006) provide that the inventory data covers such substance groups as: 1) the direct action greenhouse gases provided for in Annex A of the Kyoto Protocol (carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulfur hexafluoride (SF6)); 2) precursors of greenhouse gases (carbon monoxide (CO), nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOC); 3) any other greenhouse gases whose global warming values have been determined over a 100-year period by the Intergovernmental Panel on Climate Change (IPCC) and adopted by the Conference of the Parties; as well as sulfur oxides (SOx). Given the difference in the intensity of climate impacts, greenhouse gas emissions and their absorption are calculated separately for each gas, in units of mass and carbon dioxide equivalent (CO2eq), depending on the global warming potential. In this case, the direct action emissions data of six greenhouse gases are systematized in the inventory of the six sectors of Annex A of the Kyoto Protocol, which qualify as «key emission categories», with a distinction from the absorption data of these gases, and are submitted to the Subsidiary Body in a standard format. reporting. According to Part 3, 4 Article 3, Part 1, Article 7 of the Kyoto Protocol, the Parties shall also provide the necessary additional information as part of the annual national inventories and national communications. The additional information provided by Ukraine under these requirements relates to the following data: 1) the volume of emissions and sequestration of forest ecosystem reservoirs resulting from activities in the LUCULF sector, according to PP. 3, 4 Art. 3 of the Protocol; 2) the holdings of carbon units; 3) changes in the national greenhouse gas assessment system; 4) changes in the national registry of carbon units; 5) minimizing negative impacts (Prokhorenko, 2012). Another confirmation of the interaction of the above international agreements and conventions in the field of environmental accounting is the provision of the Aarhus Convention and the Protocol on Pollutant Emissions and Transfer of 21 May 2003 that information on the state of the environment and sources of emissions should be communicated to the public. In Art. 1 of the Protocol states that its purpose is to increase public access to information through the creation of consistent, integrated, nationwide emission and transfer registers (ETN) that could facilitate public participation in environmental and environmental decision-making. prevention of pollution and its reduction. Under this Protocol, each Party shall establish and maintain a publicly available national pollutant emission and transfer register that is: (a) maintained separately for specific point source reporting facilities; b) contains data on diffuse sources; c) if necessary, kept separately for specific pollutants or wastes; d) covers different environmental components, distinguishing between emissions into air, land and water; e) contains information about the transfer; (e) It is based on the periodic reporting; (g) contain standardized and timely submitted data, a limited number of standardized reporting thresholds and, if available, a limited number of confidentiality provisions; (g) is logically consistent and user-friendly and accessible to the public, including in electronic form; h) involve the public in its development and modification; and (i) is a structured, computerized database or several aggregated databases maintained by a competent authority. Each Party shall also ensure that the data contained in the register is submitted in both aggregated and detailed form so that emissions and transfers can be searched and determined by: (a) the facility and its geographical location; b) type of activity; (c) the owner or operator and, where appropriate, the company; d) contaminants or waste, where appropriate; e) every component of the environment to which the pollutant is emitted; and (f) the destination of the transfer and, where appropriate, disposal or disposal of waste.
To keep a proper inventory of the emissions, the owners or operators of the sites to be reported shall prepare and submit to the competent authority of the Party the following information on specific sites: a) name, mailing address, geographical location and type or activities of the reporting entity, as well as the name of the owner or operator and, where appropriate, the name of the company; b) name and identification number of each pollutant to be reported; c) amount of each pollutant that is required to be reported to the facility into the environment during the reporting year, both as a whole and by emissions into the air, water or land, as well as underground injection; d) or: 1) amount of each pollutant to be reported transferred beyond the site during the reporting year, with a distinction between the quantities transferred for disposal and disposal, and the name and address of the object to which the transfer occurred; or 2) amount of waste to be reported transferred beyond the site during the accounting year, with a distinction between hazardous waste and other waste, for any recovery or disposal operation with the appropriate «R» or «D» marking if waste is assigned for the disposal or disposal, and, in the case of transboundary movement of hazardous waste, the name and address of the waste disposal or disposal entity and the actual disposal or disposal site to which the transfer took place; e) amount of each pollutant in the wastewater for which reporting is required has been carried beyond the site during the reporting year; and f) type of methodology used to obtain the information, indicating whether that information is based on measurements, calculations or estimates. In fact, it is this Protocol that is the first legally binding international instrument on pollutant emission and transfer registers, and its objective is to make publicly available information on air, water and soil emissions. Today, the Protocol defines the criteria for submitting information on environmental pollutants based on international organizations such as Food and Agriculture Organization of the United Nations (FAO), Eurasian Economic Commission of the United Nations (EECUN), the World Bank, Eurostat, Organisation for Economic Cooperation and Development (OECD), International Energy Agency (IEA), and more. For example, the Food and Agriculture Organization of the United Nations database (FAOSTAT) contains a rather informative set of indicators that characterize the environment. This organization focuses on greenhouse gas emissions research. In addition, it publishes regional statistical yearbooks on a wide range of issues, including the use of natural resources in agriculture, environmental pollution, biodiversity and

Problems of realization of measures for the implementation of environmental accounting in Ukraine
In addition, the OECD has its own database of environmental indicators. It covers 13 areas such as air and climate, air and health, water, waste, mineral, forest and land resources, environmental policy, green growth and other areas. Another system of indicators characterizing the environmental security of a number of countries is presented in the UNDP, including in tonnes of carbon dioxide emissions per capita; depletion of natural resources, as a percentage of gross national income; the percentage of the population living on degraded land; major energy sources, fossil fuels, as a percentage (OECD. Stat, 2019). An analysis of the data provided by the International Energy Agency shows that one of the key areas of the organization is to work on environmental awareness. This activity expands the international understanding of possible solutions to climate change, as well as worldwide engagement through the collaboration of major manufacturers and consumers to develop alternative scenarios to address common environmental issues. The website of the International Energy Agency contains the collection of CO2 emissions from combustion. The data are presented in terms of the following groups: CO2 emissions from fuel combustion; CO2 emissions from fuel combustion by types: coal, oil, gas, oil for maritime transport, aviation fuel; CO2 emissions by sector; total primary energy supply; CO2 emissions to the total primary energy supply; per capita emissions by sector; CO2 emissions per capita, etc. (Global Assessment, 2019). In order to improve public access to environmental information and thus contribute to the prevention and reduction of pollution in the long term, a European Pollutant Emission and Transfer Registry (PRTR), which is an ecological database or a description of the potential chemical hazard, has been introduced in the EU. substances and / or pollutants discharged into the atmosphere, discharged into the water and soil and transferred from one or another territory for processing or disposal. PRTR includes information on the following: (a) who generates potentially harmful emissions and transports the waste to various environmental components; b) what pollutants are emitted and transported; c) how much is emitted or transported over a specific period of time; d) how the emissions and transportation of pollutants are distributed geographically, etc. Having ratified the Protocol on Pollutant Emissions and Transfer Registers on February 3, 2016, Ukraine has committed to implement a nationwide public electronic system for pollutant emission inventories and subsequently join the European E-PRTR system. The EU's experience on this issue shows that the recording of emission sources (installations), as well as the monitoring, reporting and verification of emissions (primarily carbon dioxide as the major by volume), is carried out for installations Due to the setting of these limits, as well as the limitations of the specified directives and regulations by certain activities, such reporting does not cover all sources of emissions that are necessary to reduce anthropogenic greenhouse gas emissions. That is why the EU has a decision 280/2004/EU on a mechanism to control the Community's greenhouse gas emissions and to implement the Kyoto Protocol. It is established that in order to fulfill these obligations, the Government of Ukraine has today adopted the Decree No. 825-p of November 7, 2018 «On approval of the Concept of creation of the national automated system «Open Environment», which provides for the creation of such components of the said system, as the geo-portal of environmental data (with geoinformation / coordinate binding of data on the mapping service) with subsystem of environmental monitoring, emission register and pollutant transfer, geoinformation a register of territories and objects of the nature reserve fund, which will include metadata on the environmental status of other holders of information resources, analytical materials, statistical information, information materials of public environmental organizations (with the consent). The purpose of creating an automated «Open Environment» system is to: 1) give citizens free access to environmental information and environmental risks/threats to safe living; 2) modernization of public administration and digitization of the process of providing administrative services in the field of environmental protection within the framework of integrated implementation of e-government mechanisms and informatization of state and local self-government bodies in the field of environmental protection, rational use, reproduction and protection of natural resources. The Concept is expected to be implemented in 2018-2020, and the process is still ongoing. However, will it solve all existing problems of implementing such a system? In the course of the research conducted by the authors of this work, a number of practical problems were identified during the implementation of the existing legal requirements for environmental accounting, in particular: substances into the ambient air by stationary sources, which led to the lack of reliable data on the number of such entities, and therefore the proper payment of environmental tax; 2) the absence of statutory deadlines for enterprises to inventory pollutants and submit relevant reports to the bodies of the Ministry of Ecology and Natural Resources of Ukraine; 3) absence of a single accounting base of water users who have permits for special water use, etc.

Conclusions
The analysis of the legal bases of environmental accounting as a means of defining indicators of the environmental component of sustainable development, conducted in the course of this study, showed that the system of environmental accounting as a single information base continues to evolve at the international, European and national levels, so to speak about it as a means early. However, today, according to the UN, the ecological and economic component of sustainable development is still in considerable dissonance, reflecting directly on human health and the rapid pace of climate change. This may mean the following: either the environmental accounting system is not showing reliable data and the pollution levels are continuing to increase, and therefore the existing public administration measures in this area are insufficient, or the planet is shifting due to long-term man-made load and natural processes. to a new stage in its evolution. The problems identified by us in the legal support of environmental accounting in Ukraine show its imperfection due to the lack of reliable data on the number of environmental pollutants, which directly affects the results of environmental monitoring and filling the state and local budgets with an environmental tax, the funds of which, in the future, used for environmental measures. In this regard, we emphasize that in order to recognize environmental accounting as an effective means of identifying indicators of the environmental component of sustainable development, each state of the world must conduct an internal audit of existing legislation, its completeness and interconnection, which will allow to build a single effective system. environmental accounting, the information of which will allow us to take adequate and timely measures of environmental management.


Affecting commute mode choice in Southern California: Which employer-based strategies work?

Interest in mandatory employer-based trip reduction (EBTR) programs has been renewed due to increased emphasis on reducing transportation-related greenhouse gas emissions. This paper analyzes survey data from 2004 to 2016 from an EBTR program in Southern California, known as Rule 2202, which allows employers with more than 250 workers to choose among implementing commute reduction strategies to meet performance standards, show evidence of obtaining omissions credits, or pay a fee-in-lieu. We report program statistics and conduct bivariate and regression analyses to determine which land-use and location characteristics, employer characteristics, and mitigation strategies explain cross-sectional differences in average vehicle ridership (AVR) and AVR improvement to understand where future AVR increases might be realized. Decreasing program participation suggests that alternatives to commute-reduction strategies make financial sense to regulated employers, but Rule 2202 employers report higher alternative transportation shares than the region as a whole. AVR is found to be highest at smaller worksites, in transit-supported and pedestrian-friendly neighborhoods, and where employers support vanpool programs. Multivariate analyses indicate that AVR gains were also highest in commercially dense neighborhoods, for retail businesses, and where guaranteed ride home programs were offered, showing promise for future AVR gains.

Introduction
Travel demand management (TDM) is defined a set of strategies intended to maximize traveler choices and reduce vehicle miles traveled (VMT) in order to reduce congestion, air pollu-tion, greenhouse gas emissions, and promote community integration (USDOT 2019;Salon, Boarnet, Handy, Spears, & Tal, 2012). The TDM strategy highlighted in this paper is employer-based trip reduction (EBTR), a longstanding program in some regions requiring employers to measure employee commutes, incentivize alternative commute modes, and mandating a fee payment which can be reduced if a target such as average vehicle ridership (AVR) is met. Extant analyses of EBTR policies have generally found at least some evidence of program effectiveness in fostering alternatives to single-occupant vehicle (SOV) commutes (Dill & Wardell, 2018;Kneisel, 2001;Zuehlke & Guensler, 2007). Southern California's South Coast Air Quality Management District (SCAQMD) has had an EBTR program since the 1980s. Its current program is known as Rule 2202-On-Road Motor Vehicle Mitigation Options and requires all employers with more than 250 employees at a worksite to implement a program, submit emissions credits, or pay a fee-in-lieu if a certain AVR threshold is not met (Dill, 1998). Based on the Southern California Association of Governments' (SCAG) estimate, as of 2016 Rule 2202 applies to roughly 1340 employers and 1.2 million workers in the region (roughly 15%). The scope, goals, and popularity of EBTR programs have fluctuated since their inception. Fearing undue burdens to employers, the state of California decreased the scope of SCAQMD's mandatory EBTR program when it raised the employee size threshold from 100 to 250. The purpose of EBTR has also been questioned when, for example, a survey of Atlanta employers showed limited support for the principles of EBTR (Dill, 1998;Zuehlke & Guensler, 2007). More recently, the benefits of EBTR have grown beyond their original goals of congestion management and air pollution reduction. As the connection between land use and transportation choice becomes more attenuated, AVR increase is also a goal of newer greenhouse gas (GHG) reduction targets such as those contained in California's SB375 or "Smart Growth" legislation which mandates that metropolitan planning organizations (MPOs) craft land use, housing, and transportation strategies to meet future GHG emission reduction targets (Skelton, 2008). Additionally, recent California state legislation mandates that employers of 50 or more in Los Angeles County provide similar commute benefits to their workers. While this does not include the same compliance and fee payments as Rule 2202, it is indicative of gradually shifting political attitudes surrounding TDM following the advent of smart growth legislation and GHG targets.
The objectives of this paper are to (1) understand the participation rates, characteristics, and spatial distribution of the large employers subject to Southern California's EBTR program, (2) to use land-use and location characteristics, employer characteristics, and mitigation strategies to explain differences in AVR,and (3) to see which of these factors are most related to change in AVR over 2004-2016 in order to understand where future AVR increases (and associated VMT and GHG emissions reductions) might be realized. This paper proceeds by reviewing relevant literature on EBTR and TDM and providing additional background on the SCAQMD's program. We provide summary statistics and trends from the SCAQMD survey results which cover program participants from 2004-2016. Geographic Information System (GIS) is used to associate employer sites with surrounding land-use and transportation characteristics derived from MPO and Census data. Finally, we use regression analysis to analyze which locational characteristics and mitigation strategies are associated with AVR as well as year-over-year AVR changes. We then summarize findings and provide recommendations for future policy.

2
Literature and background

EBTR research
Senate Bill (SB) 375 represented a dramatic shift in regional planning in California and placed a broad mandate on MPOs to investigate and advance land-use and transportation strategies which reduce GHG emissions. For example, SCAG's most recently adopted Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) models the impact of several strategies on future travel demand including TDM, regional bikeway networks, car sharing programs, sidewalk upgrades, zero-emission vehicle availability, and efforts to promote active transportation (SCAG, 2016). Furthermore, land-use strategies such as promoting growth in job centers and pedestrian-friendly areas may be longer-range in nature but complement transportation improvements in an effort to satisfy SB375's mandate for a 19% GHG emission reduction below 2005 levels by 2035 in Southern California. While neither SB375 nor SCAG's plan directly involves EBTR, it could be an important complementary tool for GHG reduction. EBTR programs are generally strategies for criteria air pollutant management and predate collective action addressing GHG emissions. While considerable legislative and planning effort has been placed into SB375 in the last decade, EBTR's fate has been varied. In 1995, during a period of intense probusiness legislation, California prohibited EBTR programs from applying to employers of below 250 employees, citing implementation costs (largely the cost to employers of surveying their workers' travel behavior), limited effectiveness, inconsistent enforcement, and the perception that it represented a violation of the employee-employer relationship (Dill, 1998). Zuehlke and Guensler (2007) report similar findings in their survey of employer perceptions toward Atlanta's EBTR program-generally negative reactions that employers see minimal benefit to the programs, employees lack interest, and upper management does not provide support.
Empirical research has taken up the question of whether EBTR programs are effective at changing workers' commuting patterns. In a 2004 survey of employers in the Denver, Houston, San Francisco, and Washington DC, Herzog et al. reported that financial incentives including transit pass subsidies, carpool coordination, bicycle facilities, and liberal telework policies were associated with a 15% reduction in trips and VMT (Herzog, Bricka, Audette, & Rockwell, 2006). Nonfinancial strategies, which consisted of marketing programs and informational campaigns as well as perceptions of a company's focus on alternative commute options, still showed a 7% reduction in trips and VMT compared to a control group. This suggested that while actual compensation induced greater behavioral change, nonfinancial strategies were still effective.
Analyses of EBTR in California have suggested that modest trip reduction resulted from Rule 2202. Kneisel uses the employee size threshold change in 1997 as a natural experiment, finding a modest decline in AVR at employers who were no longer subject to the rule (Kneisel, 2001). Despite the dip in overall performance, AVR showed no change at employers who had previously elected to implement a commute reduction strategy under Rule 2202. This suggests that performance is more closely linked to employer motivation than the rule itself; however, it may have been the rule which "nudged" certain employers to actively promote alternatives. Dill and Wardell conduct an evaluation of the Portland, Oregon area's 50-employee-and-above EBTR law (Dill & Wardell, 2018). The authors conduct crosssectional models of commute mode share, finding that a variety of locational and programmatic considerations were related to transit, walking, or biking share. Having a downtown location, high nearby retail density, good street connectivity, and proximity to light rail or frequent bus service were significant predictors of lower SOV shares. In addition, offering discounted transit passes, a guaranteed ride home program, flextime, or compressed work week options increased transit ridership region-wide. However, the authors note the difficulty in inferring causality in their cross-sectional model. Furthermore, the fact that the strongest predictor of non-SOV share was whether or not an employer was located in Portland's downtown suggests that improving this measure can only be addressed by promoting business relocation toward downtown.
No studies of which we are aware investigate changes in AVR to measure elements of EBTR program effectiveness or for the purpose of identifying supportive employer or land-use and location characteristics. While land use is only minimally treated in extant EBTR programs, its impact on travel demand is complex and involves both local and regional factors (Ewing & Cervero, 2010). While local activity clustering can reduce trip length and promote mode substitution, regional connectivity can aggregate labor demand in specific intraurban areas-downtowns or job centers-and increase transportation options even for longer trips. Since most travel data are home-based rather than work-based, the contribution of worksite land-use characteristics on travel is less frequently analyzed but may still be important. Additionally, advances in GIS analysis have increased the feasibility of using improved measures of neighborhood space-e.g., parcels or blocks plus those within a certain distance -to better characterize the environment surrounding a point in urban space (Clark, Anderson, Östh, & Malmberg, 2015;Hipp & Boessen, 2013).

Southern California's EBTR program today
The SCAQMD offers three compliance options for the region's large employers. The first option is the Employee Commute Reduction Program (ECRP), which involves deploying an annual survey to all workers asking how they traveled to work each day during the past week. This is used to calculate an employer-level measure of AVR which takes into account telecommuting, compressed work weeks, the size of a carpool, and any other commute type. Following the SCAQMD's guidelines AVR is calculated as the number of employees arriving at the worksite between 6-10am divided by the number of vehicles arriving during the same time. An employer's AVR is compared to a target threshold based on the worksite's intraurban location (see Figure 1), a delineation of three zones which recognizes an employer's land use and transportation context, though fairly minimally. Employers in Zone 1-which is downtown Los Angeles-have an AVR target of 1.75 consistent with the area's high density and variety of nonvehicular commute options. The vast majority of the region is in Zone 2 and has a target of 1.5, while the outlying desert portions-many of which are not urbanized areas-have a target of 1.3. An employer who misses the target can comply by undertaking approved commute mitigation strategies. The menu includes 26 strategies-15 of which must be selected to receive full credit. Of the 15, five strategies each must be chosen from the basic, marketing, and direct strategy lists. These include a variety of parking incentives, rideshare and vanpooling systems, bicycling support, flex/compressed schedules, guaranteed ride home programs, transit subsidies, and several others. A small number of employers who conduct the AVR survey but do not wish to implement mitigation strategies can pay a fee for the difference between their target and actual AVR, referred to as an "offset" strategy.
The second option is the Air Quality Investment Program (AQIP) which, as of July 2018, charges the employer a fee of $46.73 for each employee who arrives during the peak window. Fee revenues are used to fund mobile emission projects. No survey is required, thus detailed data are unavailable. The final option allows an employer to satisfy Rule 2202 requirements by purchasing emission credits in California's carbon market and is referred to as Emission Reduction Strategies (ERS). This option also does not require employee surveys or the submittal of commute reduction strategies for review and reinvests the funds to promote energy efficiency elsewhere. Affecting commute mode choice in Southern California: Which employer-based strategies work?

Data
The principal data for this project come from a public records request from SCAQMD on the Rule 2202 program over 2004-2016. To investigate the factors that may influence the effectiveness of the EBTR programs, the dependent variables we use are AVR and year-over-year AVR change. The explanatory variables include employer characteristics, land-use characteristics, and mitigation strategies selected by an employer. Table 1 summarizes the description and data source of the dependent and explanatory variables.
We analyzed a total of 2,450 unique, geocoded worksites in the SCAQMD region. In any individual year, between 1,341 and 1,519 worksites in the region with 250 or more employees were included. The full sample includes 18,300 survey results alongside the number of employees and the Standard Industrial Classification (SIC) code, which we aggregate into six categories: (1) Agriculture, Mining, Construction, and Manufacturing, (2) Wholesaling, Transportation, and Utilities, (3) Retail, (4) Finance, Insurance, and Real Estate (FIRE), (5) Services, including hotels, businesses services, repair services, and education, and (6) Public Administration.
Data are also reported for the mitigation strategies which employers undertake. Many, but not all employers who have met their AVR targets also elect to report mitigation strategies they've undertaken even if the strategies aren't required for compliance with Rule 2202. Since the strategy menu is always changing, complete longitudinal data are not available so employer-level mitigation options are aggregated into three broad groups of strategies: flextime, guaranteed ride home programs, and vanpool incentives. Guaranteed ride home programs provide a company vehicle, rental car, taxi, or other means home in the event of overtime, inclement weather, or personal emergency. Vanpool support strategies cover vehicles owned or leased by the employee, employer, or a third party and whether or not the employer provides fuel, maintenance, insurance, or a cash subsidy for users. Flextime was counted as a mitigation strategy since it permits employees to adjust their work hours to accommodate transit schedules or transportation alternatives.
We also analyze the land-use and transit characteristics of the urban environment around employer locations. A cross-sectional (2010) measure of pedestrian node connectivity was gathered from the US EPA's Smart Location Database at the Census block group-level (Ramsay & Bell, 2014). This was augmented with block group-level 5-year American Community Survey (ACS) samples and decennial Census data from 2000, 2011, and 2016 and appended to the employer-year observation nearest in time measuring population density. A unique value for these variables is generated for each point based on the block group in which it lies plus all other block groups within ½-mile, consistent with concepts of egocentric neighborhoods or "egohoods" (Clark et al., 2015;Hipp & Boessen, 2013).
We use the same egocentric approach to measure the share of land use within 1/8-mile of each worksite to capture its immediate built surroundings. 2008 and 2012 parcel-level land-use data are available from SCAG; the share of nearby land that is residential, single-family residential specifically, commercial, commercial/industrial, or open space is joined to each worksite using the closest available point in time (SCAG, 2016). While analyses such as Dill and Wardell rely on downtown proximity to analyze the urban density gradient, missing from the extant discussion of EBTR has been the local landuse contribution. Finally, we include whether or not a worksite lies within a High-Quality Transit Area (HQTA), defined by SCAG as within ½-mile of passenger rail or bus service with 15-minute or better peak service frequency. Rail station proximity (1/2-mile) is also included.

Findings-SCAQMD data
The number of worksites for which the ECRP option was taken-and thus for which survey results are available-was 7,555 over our 13-year sample. However, the share of employers who choose this option decreased from a high of 51.1% in 2004 and has been consistent at 35% since 2013 ( Figure 2). Only 481 employers completed the AVR survey during 2016. The various ERS options increased in popularity from 2004-2011. The data also show that 47.9% of worksites in Zone 1 (in and around downtown Los Angeles) choose the ECRP survey option, but only 40.7% of worksites in other zones choose this option (difference significant at p<0.0001). Mode shares have remained relatively consistent over time, with the SOV share between 66.8% and 70.2% across the study period-the highest point representing 2016. Carpool shares declined fairly consistently from their 2004 peak of nearly 21% to below 15% in 2016. The transit mode share decreased noticeably since 2013 when the percentage of respondents selecting bus or rail dropped from 8.1% to 6.6%. However, the share of respondents walking or bicycling to work increased from roughly 2.5% to a 2015 high of 4.4%. The highest shares of active transportation are in Zone 2 and not Zone 1 as might be expected, possibly reflecting the fact that Los Angeles' downtown labor pool is typically drawn from afar.
While the SCAG region encompasses more land area and population than SCAQMD's boundaries, SCAG's 2016 RTP/SCS non-teleworking mode shares provide a basis for comparison: 80.3% drive alone, 10.8% carpool, 4.3% take public transit, and 4.6% use a form of active transportation (SCAG, 2016). This suggests that employees at large worksites are substantially more likely to carpool and take transit and less likely to drive a single-occupant vehicle.
We also analyze AVR across six broad industrial classifications (Table 2C). While AVR varies slightly across categories, all are between 1.29 and 1.39. Using an analysis of variance (ANOVA), retail worksites have significantly lower AVR than those in FIRE, service, and public administration while public administration worksites have significantly higher AVR than those in construction /manufacturing, wholesale/transportation, and retail. In terms of mitigation options, Table 2A indicates that in most years, over 2/3 of ECRP employers offered some kind of guaranteed ride home program. While flextime data were unavailable after 2013, prior to that, rarely did over 10% of employers use this strategy. The share of employers offering vanpool increased from 16.5% in 2004 to 20.7% in 2010 and remained relatively constant until a substantial increase was seen in 2016 during which an additional 34 employers began offering vanpool benefits. The commute survey also asks how many individual respondents take an electric vehicle-a share which has increased dramatically but which by 2016 remains just below 1%. Parking cash out programs, which refund subsidized parking to employees who choose alternative transportation, have been recorded since 2012 though participation is extremely low (see Table 2B).  Simple Pearson's correlation coefficients provide an initial look the relationship between AVR and land-use and locational characteristics. Whether an employer has single-family residential or overall residential land nearby is immaterial to its AVR-correlations are slightly negative but insignificant, suggesting that a strategy which promotes land-use mixing is not associated directly with AVR here. However, worksites with more nearby commercial land use have higher AVR (r=0.162). Jobsites with more open space nearby have lower AVR (r=-0.102), which is likely indicative of farther-flung worksites far from other urbanized land use-which tend to be less amenable to alternative transportation. The pedestrian friendliness of the surrounding area is weakly positively correlated with AVR (r=0.110); whether high-quality transit is present is strongly positively correlated with AVR (r=0.206). Unexpectedly, being near a rail station tends to be associated with lower AVR (r=-0.149).

Findings-Multivariate analysis
The purpose of this analysis is to determine which land-use characteristics, employer characteristics, and compliance strategies explain differences in AVR and AVR change across large worksites in Southern California. While panel data allow for rich longitudinal analysis, three challenges arise. First, survey results are only available for employers who participated in ECRP. Therefore, the universe of this analysis is the (decreasing) share of large employers who have signaled a commitment to sustainable commuting in this manner. Second, ECRP employers who meet their AVR target are not required to engage in or report mitigation strategies. While many still do, these variables are only robust for employers who are below the target necessitating a binary variable to this effect to aid in robustness. Third, while the dependent variable exists in all years, certain explanatory variables (e.g. land use, HQTAs, and pedestrian friendliness) only exist in certain years which would result in an unbalanced panel. To minimize the risk of model misspecification with panel methods, we use a simpler pooled cross-sectional model which combines all 13 years' worth of employer-year observations into a single sample (Dielman, 1983). Two model forms are specified: (1) where AVR t is the average vehicle ridership in year t, LOC t is a matrix of locational characteristics in year t (or the closest available year) which includes a binary variable indicating whether the worksite is in an HQTA, the level of pedestrian connectedness, the population density (pop/acre), and the percent of nearby commercial land use. EMP t , represents employer characteristics, includes the (log-transformed) number of workers, a control variable indicating whether the employer met its AVR target, and five dummy variables covering six industry categories. MIT t is a matrix of binary variables representing the ECRP mitigation options chosen in each year: guaranteed ride home, vanpool, or flextime as well as a control variable for whether or not these strategies were actually used for compliance versus voluntarily reported (not shown). YR t is a matrix of dummy variables of each year (2004)(2005)(2006)(2007)(2008)(2009)(2010)(2011)(2012)(2013)(2014)(2015)(2016) and allows other covariates to be interpreted independently of time. The reference category is 2004 and YR t estimates are not reported since they do not have a substantive interpretation. (2) In contrast to the pooled cross-sectional model in Equation 1, Equation 2 evaluates a pooled sample of year-over-year AVR change between years t and t+1. For example, the change in AVR between 2004-2005 would be explained using 2004 locational and employer characteristics and mitigation strategies. The sample size decreases in Equation 2 from 6,647 to 5,402 since there is no AVR change evaluated in the first year of the sample and it is restricted to employers present in both t and t+1. While AVR and AVR change are strongly correlated (r=0.455), conceptually they are very different outcome measures. Empirical analyses of regional economic growth provide some context: growth in GDP can be positively or negatively impacted by the level of GDP (Barro & Sala-i-Martin, 1992). Similarly, if capacity for further AVR gains is exhausted, we might expect a different sign in AVR versus AVR change models.
Both models are solved using ordinary least squares (OLS) regression with cluster robust standard errors-this is done to guard against the fact that employers are observed multiple times in the data and we take care to rely principally on statistical test results rather than coefficient estimate magnitudes to draw major conclusions. Since SCAQMD's zone-based AVR targets are generally reflective of regional density and land-use differences, we chose to run four regressions for either equation: one for all employers and one for each SCAQMD compliance zone. Zone 1 is a homogenous area with high job concentration, features the area's best regional transit connectivity, and until recently had very little residential land. Zone 3 is made up of the farthest reaches of the SCAQMD region including Santa Clarita and the Coachella Valley. Since the vast majority of large employers are in the large and varied Zone 2, the all zone results are expected to be closest to Zone 2 results but we anticipate coefficient estimates in Zones 1 and 3 may differ notably.

Equation 1: Explaining AVR
Results for all eight specifications are found in Table 3. Goodness of fit ranges from R² = 0.197 for the small Zone 3 model to 0.517 for the Zone 2 model. Employer size has an inverse relationship to AVRvehicle ridership is higher for smaller employees in Zone 1 and overall. While the sample includes only employers of 250 and above, this indicates that smaller relative employer size is associated with better AVR, thus an expansion of EBTR to even smaller employees may be beneficial. This relationship is no longer significant in Zones 2 and 3, indicating the importance of downtown LA in this result.
In the Zone 2 model, variables for three industry types are related to significantly lower AVR compared to the reference category, which includes agriculture, construction, and manufacturing. FIRE is most negatively associated with AVR, followed closely by retail, then public administration. In the all employers model, only retail is significantly associated with lower AVR. Industrial category is found no difference in Zones 1 or 3. The density of the residential population within ½-mile of a worksite has minimal discernable effect on AVR. This result is anticipated since commercial sites suitable for large employers may not be near residential land. The percent of commercial land use within 1/8-mile may be a better indicator of the character of the nearby built environment. The effect of this is positive and significant across all employers, although it is not significant in the zone-specific models indicating that commercial land-use share varies strongly by zone (the mean value is 80.7%, 53.9%, and 29.1% in Zones 1, 2, and 3 respectively).
Being in a high-quality transit area is the most consistently strong predictor (p<0.01) of AVR across all samples except Zone 3 in which only one worksite is in an HQTA. While this result doesn't indicate causality, i.e., that HQTA location causes higher AVR, this strong association provides evidence that employers choosing to locate in HQTAs might expect higher AVR. Pedestrian connectivity is a strong predictor of AVR in Zone 2 but is not significant elsewhere. While we might expect this relationship to be strongest in Zone 1, most of that zone already has high levels of pedestrian connectivity and low variance (mean=12.6, std.dev.=2.5). In contrast, it is in Zone 2 where the more highly variable level of pedestrian connectivity (mean=11.3, std.dev.=4.7) is a strong predictor of an employer's AVR.
As expected, the control variable for whether the AVR target was met is positive and significant and allows for improved inference on mitigation strategy variables. Participation in guaranteed ride home programs shows a negative, yet insignificant relationship with AVR while flextime is positively though insignificantly associated with AVR. Of the strategies able to be analyzed, only vanpool shows a significant relationship with AVR-weakly positive, and only in Zone 2.

Employer Characteristics
Employees (

Mitigation Strategies
Guar. The structure of Model 2 allows us to investigate the effect of a policy on any changes found by the next year's employee commute survey-an outcome measure which has frustrated prior research efforts. As this model investigates change, variances on the dependent variable and model fit are expected to be lower (R² values of 0.037-0.086 as shown in Table 2), though a number of variables are significant predictors of AVR increase. In Zone 1, downtown Los Angeles, we find that smaller employers are significantly more likely to experience bigger increases in AVR. While FIRE employers were associated with lower AVR, they are most strongly and consistently associated with AVR gains. Being a retail employer is associated with improved AVR only in Zone 2 and follows closely behind FIRE in magnitude. Service employment also shows significant reduction potential relative to the reference category-about 60-70% the magnitude of FIRE. Public administration, transportation/wholesale/communications, and agriculture/manufacturing/construction round out the list of industry categories by AVR reduction potential.
Residential population density is negative but is only significant (weakly) in Zone 1, an area which has only recently seen substantial residential construction near the core employment center. This would indicate that the less residentially dense areas near downtown LA experience greater AVR gain. Further investigation of specific sites may be required to fully understand why this is the case. The share of commercial land use nearby is a positive and significant driver of AVR gain only in the all employers model providing evidence that AVR improvement is more likely to occur in areas that resemble commercial districts rather than those mixed with other land uses-especially when downtown LA is included in regional totals. While high quality transit was a very strong predictor of AVR, it has no significant relationship with AVR increase. Pedestrian connectivity is also statistically unrelated to AVR change. That these two variables are strongly related to high AVR; however, on the margin, further AVR improvement may be challenging in areas which may have maxed-out potential AVR gains.
Encouragingly, undertaking a guaranteed ride home strategy is significantly associated with AVR increases in the large Zone 2 sample. While vanpool strategies show a relationship with AVR itself, that guaranteed ride home programs associated with AVR improvement shows promise for untapped potential-especially in the varied, low and medium-density landscapes of much of Zone 2. However, vanpool and flextime strategies show no significant relationship to AVR change in these models, though this could be impacted by flextime data limitations.

Discussion and conclusions
The objectives of this study were to understand the participation rates, characteristics, and spatial distribution of participants in Southern California's EBTR program and to analyze which land-use and location characteristics, employer characteristics, and mitigation strategies were related to average vehicle ridership and change in average vehicle ridership over 2004-2016. This is the first study of which we are aware which analyzes these three drivers of work travel behavior over a long time horizon using program data. While EBTR programs were originally intended to reduce commute-based air pollution, since SB375's passage in 2008 travel demand management (TDM) now has an additional motivator: regional GHG emissions reduction targets. That legislation's linkage between land use and transportation planning also suggests that EBTR programs and TDM should consider the land-use context more strongly. Employer participation in SCAQMD's ECRP option has decreased since 2004, suggesting that the cost of fee payments and the availability of emissions credits for purchase may have become financially or administratively more attractive than engagement with employees' commutes. While emissions credits and re-invested fee payments to SCAQMD fund other forms of pollution mitigation, only ECRP can be considered a TDM strategy capable of stimulating behavior change-something which appears decreasingly attractive. Results for employee mode share are somewhat consistent with concerns over the recent "VMT rebound;" they also indicate that larger employers who choose the ECRP option have lower drive-alone shares. Despite a long-term decline in carpool share, car/vanpools at large employers show some promise. They tend to be easier to coordinate at large worksites. As the results show, carpool rates are higher at ECRP employers than overall, the number of ECRP employers offering vanpool benefits in 2016 increased substantially, and across much of the study area vanpool support is related to higher AVR. However, if increasing AVR is a program's explicit goal, offering guaranteed ride home programs shows the most promise. Rather than coordinating daily car/vanpools or altering work hours, guaranteed ride home programs may be less "invasive" since they are used infrequently, and can provide peace of mind to risk-averse workers such that they switch to non-SOV commuting. Given the rise of transportation network companies such as Uber and Lyft, providing guaranteed rides home may become cheaper and easier.
These findings are somewhat consistent with Herzog's multi-region finding that nonfinancial incentives for VMT reduction could be effective as well as Dill and Wardell's finding that flextime and guaranteed ride home programs are effective in Portland. However, the latter study is unable to comment on AVR change, and differences in program administrative details and urban geography severely hamper interregional comparison.
Models also suggest that smaller employers are more likely to achieve AVR gains and even those below 250 employees deserve consideration. This is consistent with the objectives of the recently passed AB2548 which mandates tax-free transit, carpool, and vanpool deductions be made available to Los Angeles County employers of between 50-249 workers. While this law will not enable a bona-fide EBTR program and covers a smaller spatial extent than Rule 2202, this paper's results suggest that well-placed and well-advertised incentives may be effective in promoting sustainable commuting.
Finally, results indicate the land-use and transportation context near an employer matters. Good pedestrian connectivity in suburban areas is important, as is high quality transit. While HQTAs were associated with AVR and not AVR change, the strength of the result for AVR suggests that if future landuse strategies can promote employer location in those areas, AVR improvement will likely follow. Additionally, AVR improvement is more likely in areas that resemble commercial districts than in mixed-use neighborhoods. Since the study only investigates large employers, we cannot exclude the possibility that smaller workplaces providing residential services may demonstrate high AVR in mixed-use neighborhoods. But our results do suggest that promoting job centers or worksite concentration in places with good connectivity could show more promise than land-use mixing.
FIRE and retail sectors are associated with lower AVR, but also with AVR increase. Both categories might be considered residential-serving industries, in particular since the region's FIRE employment is known to be heavy on real estate finance. While FIRE and retail may be promising areas of future AVR gains, this sample is restricted to worksites over 250 employees, which is not consistent with the smaller, dispersed stores and offices which typically characterize residential-serving businesses.
This study has shortcomings principally due to the nature of Rule 2202 and the limited sample for the employee survey, which may suffer from some selection bias. Our understanding of mitigation options is limited by aggregated program data and further investigation into why specific options are chosen is needed. However, the sample investigated is large, comprehensive, and longitudinal and allows us to measure performance improvement over time. While programs which provide incentives for commute behavior change without an option for fee-in-lieu payments are stronger forms of TDM, the declining popularity of survey and mitigation options suggests that future study should consider employers' financial incentives more closely, with a focus on employers who voluntarily promote sustainable commuting through ECRP or their own programs. Location and built environment characteristics also need to be taken into account, as well as job clustering and the spatial extent of the employer's labor pool which contribute to the viability of non-SOV commuting and mitigation strategies. Nudging workers and their employers toward sustainable transportation choices is a multi-faceted, long-term effort, but EBTR in its current and improved future form deserves a major role in the planner's TDM toolkit and shows promise for helping regions meet GHG reduction targets in addition to congestion and air pollution reduction.