CSG comments on state DOT draft Carbon Reduction Strategies


Chris Berg, Director of Sustainability, VDOT
Emma Cross, Air Quality Planner, DDOT
Shawn Kiernan, Senior Program Manager for Strategic Climate Initiatives, MDOT 

From:  Bill Pugh, AICP CTP, Coalition for Smarter Growth

Cc:  Erin Morrow, TPB; Kanti Srikanth, TPB; TPB Board Chair and Vice Chairs; state DOT TPB representatives 

Date:  October 25, 2023

Re: Comments on VDOT, MDOT and DDOT draft Carbon Reduction Strategies

The Coalition for Smarter Growth respectfully asks your consideration of these comments as you refine your Carbon Reduction Strategies (CRS) prior to submittal to FHWA next month. These comments build on our October 17 letter to the National Capital Region Transportation Planning Board. 

The VDOT, MDOT, and DDOT Carbon Reduction Strategies should:

  1. Reflect TPB and national findings that reducing VMT is essential to meeting minimum GHG targets – The TPB Climate Change Mitigation Study of 2021 and other national studies have found that states must reduce per capita passenger Vehicle Miles Traveled on the order of 20% by 2030 (compared to pre-pandemic levels) with further reductions in later years, in addition to rapidly transitioning to electric vehicles, to meet greenhouse gas reduction targets. For example, California, which has the most ambitious EV adoption program in the country, has found that the state must also “Achieve a [passenger vehicle] per capita VMT reduction of at least 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045.” to meet its greenhouse gas reduction targets. (2022 Scoping Plan, California Air Resources Board) 
  1. Include quantified targets for per capita VMT reduction and electric vehicle adoption – CSG applauds the strong mode share targets in DDOT’s plan and that all three plans include vehicle travel reduction strategies. However, for measuring progress and performance, all three DOTs need to include quantified targets for per capita VMT and EV adoption to meet relevant interim and longer-term greenhouse gas reduction targets.
  1. Address the increased greenhouse gas emissions from state highway capacity expansion plans – Virginia and Maryland have extensive planned highway and arterial capacity expansion projects that will counteract their carbon reduction strategies. Studies show that road widening typically results not only in more driving but also more emissions.  Reducing traffic congestion can lower a car’s tailpipe pollution per mile driven, but expanding highways and roads generally induces more people to drive more miles and offsets those carbon emissions benefits – worsening our climate problem.  The CRS need to show how they will either scale back highway expansion projects or quantify how they will offset the induced demand and lifecycle emissions impacts through more ambitious implementation of carbon reduction projects.
  1. Virginia CRS needs to incorporate a comprehensive on-road transportation decarbonization strategy – The intent of the federal Carbon Reduction Program is to help states develop overall strategies for reducing on-road transportation sector emissions. The MDOT and DDOT plans show, through reference to detailed climate action planning and metrics, these overall strategies with quantified goals. At the October 18 TPB meeting, Chris Berg, VDOT Sustainability Director, said that the Virginia draft CRS is “narrowly focused on one federal funding source” and is “not a roadmap for across the board decarbonization.”  This proposed approach would be a missed opportunity for Virginia, its MPOs, and rural communities. Transportation is the Commonwealth’s largest emitter of climate pollution. If VDOT does not have a decarbonization strategy for the on-road transportation sector (with quantified metrics and specific recommended actions to achieve them), then its CRS should include timely development of such a strategy to be effective. 
  1. Further consultation with the public, TPB, and other MPOs – We appreciate the submittal by MDOT and DDOT of their draft CRS to TPB. We also appreciate the VDOT public input survey on its CRS and reporting the results in its presentation to TPB. We encourage all three DOTs to engage the public and MPOs on refinement, implementation and updates to their CRS and on project prioritization for state Carbon Reduction Program funds.