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Green Light for Climate Action: Unveiling the impact of the GHG Emissions Measure rule

By mandating emissions tracking and target setting, the GHG Emissions Measure addresses an urgent need for climate action. And while this popular rule is an important first step, its success hinges on immediate and effective action at the state and local levels, which would signify a shift towards a cleaner, and greener, transportation landscape.

The United States Capitol building. (John Xavier via Flickr)

On November 22, 2023, the Department of Transportation released the Greenhouse Gas (GHG) Emissions Measure rule, requiring state DOTs and metropolitan planning organizations (MPOs) to measure and report their transportation-associated emissions, as well as set targets to lower these emissions. This rule is long overdue, with a period of public comment on the rule having closed over a year ago in October 2022. More than 60,000 comments were received by the Federal Highway Administration (FHWA), with comments in favor outweighing those opposed by more than 3,000 to 1, demonstrating overwhelming support from government agencies, and transit and advocacy groups, for progress on emissions reduction. 

What does this mean for state DOTs and MPOs?

With the passage of the rule, all 50 states, as well as the District of Columbia and Puerto Rico, are mandated to measure GHG emissions associated with on-road mobile sources on the National Highway System (NHS) within their geographic or planning area boundaries. Additionally, state DOTs will need to establish 2 and 4-year emissions reduction targets, and MPOs will need to establish 4-year targets. State DOTs are expected to submit their first targets on February 1, 2024, signifying the administration’s endorsement of an aggressive and rapid policy rollout in the right direction. Both state DOTs and MPOs will need to consistently provide updates to report their progress in meeting their targets. 

The GHG rule expands on important work in setting declining GHG emissions targets that already exist and has been implemented in 24 states and the District of Columbia. Crucially, the new rule provides a national framework and recommended method that standardizes how emissions should be calculated. A uniform calculation methodology allows for consistency across the board in emissions data that is currently produced and will be produced, and the ability to uniformly compare progress through timely updates.

State DOTs and MPOs are awarded a high degree of flexibility in setting their own declining GHG targets and pathways for achieving them, allowing alignment with their respective policy priorities. This also means that there is no incentive to set competitive targets, and there are no penalties imposed for failures to meet these set targets either. While the rule brings sunlight to progress on emissions targets, the absence of an enforcement mechanism implies that it may not drive substantial action in shifting the status quo.

Moreover, it is important to note that the emissions mandated for tracking and reporting by this rule pertain only to travel on the National Highway System (NHS), not all roads. As of 2020, the NHS represented only 5.3% of total mainline miles of roadway in the US. By solely focusing on NHS-related travel, more than 46% of the total vehicle miles traveled in the US are overlooked.

From awareness to action

The Infrastructure Investment and Jobs Act (IIJA) is channeling historic amounts of federal funding into states for transportation projects aimed at reducing carbon emissions. Among its programs is the Carbon Reduction program which provides funding for state projects focusing on carbon emissions reduction. These dollars hold unprecedented potential for investment in transportation projects that create climate-resilient and reliable transit networks. However, there is also the possibility that this money may continue to be invested in highway widening projects, leading to the opposite outcome of actually increasing emissions. Constituents deserve to know that their taxpayer money is going where it needs to go.

The new law arms the public with an important advocacy and transparency tool to assess whether the administration is fulfilling its promise of delivering on sustainable and equitable transportation options. This accountability encourages states and local leaders to align their work with their constituents’ goals and prioritize projects accordingly. 

Confronting the climate crisis demands urgency. Changing climate conditions across the country are increasingly threatening the connectivity, efficiency, and safety of our transportation systems, impacting communities’ abilities to access daily necessities and get where they need to go. With adverse weather events impacting reliable service and recently witnessed air quality crises, the administration could not afford to delay decisive action any longer.

The science on this has also never been clearer. The Sixth Assessment Report by the Intergovernmental Panel on Climate Change (IPCC) emphasizes the unequivocal need to implement transformative change in the transportation sector. The transportation sector is the largest source of GHG emissions in the United States, and aligning climate goals with transportation agency goals is pivotal to moving closer to achieving the nation’s ambitious net-zero goals. Ultimately, the GHG performance measure should pave the way for more aggressive and ambitious climate mitigation and adaptation policies. 

The GHG rule is not a silver bullet 

T4A’s director, Beth Osborne, wrote in our statement on the rule that “these decisions have benefits beyond reducing emissions, like providing people with more opportunities to travel outside of a car, which enhances safety and mobility.” It is important to remember that achieving climate targets and creating equitable communities hinges on breaking free from car dependency.  Electrification and vehicle efficiency, on their own, will not lead us out of the climate crisis. Our report, Driving Down Emissions, underscores the importance of accounting for factors like induced demand and shifting away from car-oriented land use in efforts to reduce emissions. 

The GHG rule is a valuable, first step on a long path towards ensuring climate accountability and transparency in our transportation system, but we must continue to capitalize on this momentum to ensure that our transportation agencies move in the right direction. While we applaud the release of the new rule, it is evident that we need immediate and effective implementation and investment in greener forms of transportation, if the law will have the much-needed impact it intends.