Comments on draft Priority Climate Action Plan (CPRG PCAP)

Office of Air Data Analysis and Planning
Virginia Department of Environmental Quality
PO Box 1105
Richmond, VA 23218

To whom it may concern,

The Coalition for Smarter Growth (CSG) appreciates the opportunity to comment on Virginia DEQ’s draft Priority Climate Action Plan, prepared in conjunction with the Commonwealth’s Climate Pollution Reduction Grant from the US EPA. Thank you for your work collaborating with EPA to take advantage of this important program.

CSG is a 27 year-old organization dedicated to making the case for smart growth in Northern Virginia and the wider Washington DC region. Our mission is to advocate for walkable, bikeable, inclusive, and transit-oriented communities as the most sustainable and equitable way for the region to grow and provide opportunities for all. CSG also supports smart growth policies that enable communities throughout Virginia to thrive.

Please consider these comments on DEQ’s draft Priority Climate Action Plan and recommendations for the agency’s follow-on Comprehensive Climate Action Plan.

In summary:

Measure 2, reduction of vehicle miles traveled (VMT), is a critical component and needs to be strengthened
State agencies should add smart growth land-use strategies and projects to the PCAP and CCAP
Measure 1 needs to specify adequate targets for electric vehicle adoption
PCAP needs to show accountability with 2045 net zero and interim-year GHG reduction targets
Need for more proactive VDOT role given the transportation sector’s share of emissions

Detailed comments for each of these are provided on the following pages.

1. Measure 2, reduction of vehicle miles traveled (VMT), is a critical component and needs to be strengthened

VMT reduction is critical to meeting GHG reduction targets

CSG commends DEQ for including this measure. Numerous studies show that U.S. states and regions must shift trips to sustainable modes of travel and reduce the need for long car trips in addition to achieving a rapid transition to electric vehicles to meet greenhouse gas reduction targets. Indeed, we are glad to see the draft PCAP appendix cite the National Capital Region Transportation Planning Board’s Climate Change Mitigation Study of 2021. This study found that to achieve the minimum on-road transportation sector GHG emissions of the MWCOG 2030 Climate and Energy Action Plan, the region must both:

Achieve a reduction in per capita light duty VMT of 20% by the year 2030 and 25 to 30% by 2050 (in addition to per capita VMT reductions already forecast under the currently adopted transportation plan); and
Rapidly adopt EVs (reach 50% sales of light duty vehicles by 2030, with additional progress in medium and heavy-duty trucks, and achieving a full transition in subsequent years).

The PCAP’s proposed implementation level for Measure 2 VMT reduction is not sufficient to meet Virginia’s GHG target and most communities’ 2030 targets

DEQ’s recommended implementation level for Measure 2 is not enough to sufficiently lower transportation emissions to meet the Commonwealth’s 2045 GHG reduction target and science-based 2030 GHG reduction targets (consistent with pathways to limit warming to 1.5 degrees Celsius) that have been adopted by many communities throughout Virginia (e.g., 50% reduction in GHGs by 2030 from 2005 levels).

DEQ assumes a 13% reduction in light duty VMT below the future 2050 baseline. This level is not adequate to achieve greenhouse gas targets and is below what other states have adopted. For example:

Maryland’s climate plan and Department of Transportation have set a target to reduce per capita VMT by 20% by 2050.
Minneota has also adopted a goal to reduce per capita VMT 20% by 2050.
California’s statewide climate plan (CARB 2022 Scoping Plan), in addition to very ambitious vehicle electrification, found that the state must: “Achieve a per capita VMT reduction of at least 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045.”

The PCACP and CCAP need to set targets for VMT reduction

CSG is glad to see that per capita VMT is listed as a potential metric. DEQ should make this a formal metric and provide a numeric target for guidance and accountability.

Based on what’s needed to meet Virginia’s 2045 GHG target and science-based targets for interim years, Virginia should set a target to reduce per capita VMT by 25% by 2050, with an interim year target of 20% per capita reduction for 2030 or 2035.

VMT reduction through mode shift and demand management has significant co-benefits

RMI’s Smarter Modes Calculator estimates that a 25% per capita VMT reduction in Virginia by 2050 would achieve the following co-benefits compared to forecast baseline VMT growth:

Save each household $1,723 a year from reduced automobile fuel, maintenance, and depreciation costs.
Improve vehicle crash outcomes and alleviate mortality risks from air pollution and inactivity health outcomes, saving over 1,165 lives per year.
By 2050, the road safety benefits add up to $73 billion in savings from avoided medical expenses, damages, and productivity losses.
Lower energy demand by 52 TWh due to reduced electric vehicle charging. This would alleviate strain on the electrical grid to provide reliable service.
Saving residents 501,017 cumulative years of congested travel time between 2024 and 2050.

2. State agencies should add smart growth land-use strategies and projects to the PCAP and CCAP

CSG is glad to see that Measure 2, p. 29, “includes land-use and development changes” to reduce VMT. This is very important to reduce transportation emissions and provides other co-benefits (e.g., access to jobs, services, lower household costs, open space preservation and sequestration, etc.). However, the PCAP omits strategies and projects. This is a missed opportunity.

Examples of state programs in supporting climate-friendly smart growth land use

State-level agencies have many programs, policies and investments that shape land use patterns and if done thoughtfully can help achieve climate change and numerous other state policy goals. These types of greenhouse gas mitigation strategies tend to have significant co-benefits for equity, affordability, efficient use of infrastructure and provision of government services, livability, and climate resilience.

Some examples of past programs and potential new ones:

SMART SCALE transportation funding prioritization – which by statute (2014) and regulation seeks to tie transportation projects to land use with an original goal of supporting more efficient land use that reduces driving demand.
Urban Development Areas (2007) – are required to be identified in jurisdiction comprehensive plans with a goal (but not a requirement) to focus growth and infrastructure investment in these areas. VDOT supported the concept with their Transportation Efficient Land Use guide.
Water and sewer grants – Virginia can decide to prioritize these grants to existing communities to repair and upgrade systems and support infill development where infrastructure exists.
Transportation spending in general – Virginia can decide to focus these investments on transit, walking, biking, local street networks to support walkable, transit-oriented development instead of spending on exurban/rural highway expansion to support new greenfield development.
School acreage requirements – Virginia can create flexible standards rather than require very large land set asides for school buildings and playing fields. They can support two and three story schools instead of one story schools, so that schools can be located within walkable communities, reducing land consumption, school busing costs, and driving.
Hospital facility licensing – these can be designed to favor health facilities located in cities, towns, and walkable centers with good transit access instead of greenfield locations
Affordable housing prioritization – affordable housing advocates and developers have supported state policy to prioritize state grants to affordable housing built near transit and services.

GHG reduction benefits of smart growth land use

Recent analysis by RMI shows the magnitude of benefits of meeting the need for housing in Virginia communities and encouraging construction in convenient, well-connected, amenity-rich locations. For Virginia, it found significant annual reductions:

Direct emissions avoided in 2033 from reduced driving: 1.1 MMT CO₂
Direct + indirect vehicle lifecycle emissions avoided in 2033: 1.6 MMT CO₂
Direct + indirect vehicle emissions + non-transportation emissions avoided in 2033: 2.3 MMT CO₂

Development of strategies and projects for the CCAP

CSG looks forward to providing input on and proposing smart growth land use strategies and projects for the CCAP.

3. Measure 1 needs to specify adequate targets for electric vehicle adoption

CSG is glad to see the multiple strategies for Electric Vehicles and looks forward to further development of these in the CCAP. The Appendix does not specify the level of EV adoption assumed in the estimated emissions reductions. Please clarify and also identify feasible and necessary levels of EV adoption for light, medium and heavy-duty vehicles to achieve 2030 and 2045 GHG reduction targets.

4. PCAP needs to show accountability with 2045 net zero and interim-year GHG reduction targets

The PCAP lacks accountability in showing the degree to which its proposed measures and their implementation levels will help achieve the Commonwealth’s adopted 2045 net-zero greenhouse gas target. We ask that the PCAP provide total emissions reductions from the identified measures estimated for 2045 and for milestone interim years.

The PCAP should also identify a reductions target for 2030 or a similar interim year that is necessary for Virginia’s contribution to limiting global warming to 1.5-degrees C.

The CCAP needs to develop a set of policies and implementation levels that can achieve net-zero emissions by 2045 as well as 2030 or similar interim year reductions consistent with a 1.5-degree C pathway.

5. Need for more proactive VDOT role given the transportation sector’s share of emissions

It is surprising that the plan only includes one VDOT project and does not cross-reference and summarize VDOT’s Carbon Reduction Strategy. This coordination is critical because transportation is the number one source of state GHG emissions, and cars and truck emissions comprise most of those. We hope that DEQ and VDOT collaborate to develop strong strategies and projects under Measures 1 and 2 in the CCAP.

Thank you for the opportunity to comment and for your work collaborating with the US EPA on this important program.