COMMENTS: Proposed USDOT greenhouse gas tracking and reduction rule

October 12, 2022 The Honorable Pete Buttigieg Secretary U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, DC 20590 Re: Docket No. FHWA-2021-0004 Secretary Buttigieg: Thank you for proposing this rule to require states and regions to track emissions of greenhouse gases (GHGs) from surface transportation. We strongly support this proposal and encourage the Department of Transportation (USDOT) to finalize it quickly, with the modifications suggested below.

The Coalition for Smarter Growth (smartergrowth.net) is the leading organization in the Washington, DC region dedicated to making the case for smart growth. Our mission is to advocate for walkable, bikeable, inclusive, and transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all.

Transportation is the largest source of GHG emissions in our region at 42%, and 60% of those emissions are from cars and trucks.1 Responding to pressure from the public and local officials, our MPO, the National Capital Region Transportation Planning Board (TPB) this year set a strong GHG reduction target for on-road transportation of 50% by 2030, relative to 2005 and adopted an initial set of strategies to achieve this. TPB had already been tracking GHG emissions in its transportation plans, and this was critical for our region to understand the role of local transportation decisions in our climate progress.2 However, many other regions are not taking these steps and may need technical assistance - which is why the USDOT rule and technical assistance are important. For our region to have a safe climate, we also need other regions to take these steps to track GHGs from on-road transportation and set goals and policies to reduce them.

Record amounts of federal taxpayer funds from the Infrastructure Investment and Jobs Act (IIJA) could help or hurt climate stability depending on how states and MPOs use them. USDOT 1

MWCOG 2030 Climate and Energy Action Plan, 2020.

An important TPB study was its Climate Change Mitigation Study of 2021, https://www.mwcog.org/tpb-climate-change-mitigation-study-of-2021/, which showed that only a mix of strategies that both reduced per capita VMT (e.g., transit-oriented land use, improved ped and bike facilities and access to transit, reduced-fare transit and improved transit travel times, TDM, road and parking pricing, telework) and achieved rapid EV adoption could meet our region’s climate plan reductions for on-road transportation. Necessary light duty VMT reductions were in the range of 15-20% below 2030 baseline levels accompanied by EV adoption above 50% of light duty sales by 2030.

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should require transparency and accountability with regard to climate change and the actions taken by state DOTs and MPOs. Analysis by the Georgetown Climate Center concluded that: “IIJA could be an important part of the U.S. response to climate change. Or it could lead to more greenhouse gas pollution than the trajectory we are currently on. Where the actual outcome falls within that range will depend on the decisions made by state, federal, and local governments about how to spend the money made available by IIJA.”3 Now is the time to require federal grantees to measure and manage GHG emissions from transportation plans and programs. Only by tracking these emissions can we begin to understand and address the long-term impact that transportation investments are having on our communities and our climate. The proposed rule would empower state and local leaders to better connect their transportation decisions with climate goals.

The Coalition for Smarter Growth asks that USDOT strengthen the proposed rule with the following modifications: ● States and MPOs should be required to track emissions from travel on all roads and set targets for reducing them, not just those on the National Highway System. The NHS represents only about 5 percent of total U.S. roadways, and just over 50 percent of vehicle miles traveled.4 Limiting the rule to the NHS means that nearly half of the miles driven - and the associated GHG emissions - will remain unaccounted for. ● States and MPOs should be required to take specific actions if they fail to meet the targets they set, such as committing to use their federal funding only for emission-reducing projects until the target is met. Alternatively, incentives could be provided for those states and regions that meet their targets, such as providing extra points in competitive grant programs. ● Both states and MPOs should be required to report every two years on the GHG performance metric and set longer-range targets, rather than limiting MPO reporting to every four years as proposed. MPOs have significant impact on transportation investment decisions in metropolitan areas and should be as transparent as states in this regard.

Moreover, both states and MPOs should be required to set 8- and 20-year targets for emissions reduction in addition to 2- and 4-year targets, to provide greater visibility and accountability for long-term plans. ● States and MPOs should be required to track Vehicle Miles Traveled as well as Electric Vehicle adoption for vehicle classes (light, medium, heavy-duty). Numerous national and local studies show that electric vehicles, while essential, are not enough to meet our climate targets and that the U.S. must also reduce per capita Vehicle Miles Traveled (VMT). RMI estimates that the U.S. must reduce per capita light duty VMT by 20% by 2030 compared to

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“Issue Brief: Estimating the Greenhouse Gas Impact of Federal Infrastructure Investments in the IIJA,” Georgetown Climate Center, December 2021, https://www.georgetownclimate.org/articles/federal-infrastructure-investment-analysis.html.

4 Federal Highway Administration statistics, https://www.fhwa.dot.gov/policyinformation/statistics/2020/hm18.cfm and https://www.fhwa.dot.gov/policyinformation/statistics/2020/vm3.cfm.

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the pre-pandemic level in addition to rapid adoption of electric vehicles to achieve the Biden administration’s greenhouse gas reduction goal.5 ● USDOT should commit to providing technical support to states and MPOs, and this should include supportive land use and housing policies that are essential for effective transportation policies. This includes developing tools and best practices for modeling the emissions impacts of various types of projects and land use policies to ensure that state and local transportation planners have the information they need to select emissions-reducing projects and coordinate supportive land use planning with local and regional jurisdictions. ● USDOT should commit to publishing regular reports on states’ and MPOs’ progress toward their targets. Accessible, user-friendly data will help state and regional policymakers and other stakeholders assess the impact of transportation decisions on emissions and adjust policies and programs if needed.

Twenty-four states are already measuring GHG emissions from their transportation plans.6 This commonsense practice should be adopted nationwide. We ask you to incorporate the recommendations above and issue a final rule without delay.

Sincerely,

Bill Pugh, AICP CTP Senior Policy Fellow Coalition for Smarter Growth

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RMI, 2021. Scaling US Climate Ambitions to Meet the Science and Arithmetic of 1.5°C Warming, https://rmi.org/insight/scaling-us-climate-ambitions/ 6 “U.S. state greenhouse gas emissions targets,” Center for Climate and Energy Solutions, 2021, https://www.c2es.org/document/greenhouse-gas-emissions-targets/.

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