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Will EPA’s proposed emissions rule go up in smoke?

A cloudy haze of smoke surrounds back-to-back vehicles in stand-still traffic

The EPA’s proposed tailpipe regulations could reduce carbon emissions across all types of vehicles over the coming decades. While reducing emissions produced on the road can only be part of our national climate strategy, the EPA’s rule could be a boon for communities thanks to the benefits of zero emissions vehicles. However, recent opposition means this rule’s future could be at risk.

A cloudy haze of smoke surrounds back-to-back vehicles in stand-still traffic
Photo from Transportation & Environment

On April 12th, 2023, the Environmental Protection Agency (EPA) announced an update to federal vehicle emissions standards that could accelerate the ongoing transition to a clean vehicle future. While these new measures are an essential step forward, addressing vehicle emissions at the exhaust pipe alone is no silver bullet. As we found in our Driving Down Emissions report, we need to combine vehicle electrification strategies with transportation alternatives, like transit, walking, and biking, to make the most of the clean vehicle switch. The EPA has since released the text of the proposed rule, with comments closing soon—July 5, 2023.

When combined with another proposed rule that closed comments in mid-June, this rule would require that by 2032, two-thirds of cars and light trucks, 46 percent of medium-duty vehicles (such as delivery vans), half of all buses, and a quarter of all heavy-duty trucks sold would need to be zero-emission vehicles. The rule does not specify the fuel source to reach zero emissions, leaving the industry room to experiment with new solutions. 

The EPA estimates that just the new light-duty tailpipe regulations alone could cut down the U.S.’s carbon emissions by 15.5 percent. These sweeping regulations on new vehicles would take effect in 2027 and build off a decade of standards implemented by the EPA. 

The third and final phase

This recent regulation is the last phase of a three-step strategy to support the United States’ international commitments to limit emissions and slow the progress of climate change. The first two phases of the EPA’s tailpipe emission standards focused specifically on medium- and heavy-duty vehicles. Phase One (2011) of the greenhouse gas emission standards targeted medium- and heavy-duty vehicle (MHDVs) models to be made in the years 2014-2018 and set fuel efficiency and emissions standards for manufacturers, while Phase Two (2016) set even stricter standards for MHDVs for the model years 2019-2027. 

With the years of lead time provided, these regulations gave automotive manufacturers adequate time to slowly ramp up the production of cleaner vehicles. At the same time, they introduced standards that reduced both CO2 emissions and consumers’ fuel costs by increasing efficiency within the physical limits of traditional internal combustion engines.

Understanding the impact

Phase Three standards are heavily influenced by the rapid uptake of electric vehicles. Recent innovations in electric vehicle technology and the record federal investments in EV infrastructure in the 2021 infrastructure law and Inflation Reduction Act make the ambitious new standards a viable goal. 

The EPA estimates that Phase Three standards could save 7.3 billion tons of CO2 emissions from light duty vehicles between 2027 and 2055 and avoid 1.8 billion tons of CO2 from heavy-duty vehicles through 2055. That’s the equivalent of eliminating all greenhouse gas emissions from the entire current U.S. transportation sector for an entire year. Overall, the EPA estimates that the value of benefits, such as improved health outcomes and mitigated emissions, would exceed total costs by at least $1 trillion over the course of its existence. These improvements could only be made possible through widespread adoption and production of electric and other zero-emission vehicles, which the rule functionally requires.

The ongoing electrification transition is an opportunity to make equitable investments across all communities. You can take a look at our vision for America’s electric future in Sparking Progress, our report produced in collaboration with the Coalition Helping America Rebuild and Go Electric (CHARGE).

Let EPA know if you support cleaner vehicles

Despite the benefits these changes could bring to the nation’s overall health, air quality, climate, and communities disadvantaged by heavy-duty vehicle emissions, some powerful interests oppose the new rule. In May, 151 members of the majority party in the US House of Representatives signed on to a letter to denounce the new standards. Later, on June 7, 2023, Florida Senator Marco Rubio sent a letter to the U.S. Securities and Exchange Commission referencing the rule and arguing, contrary to the evidence, that EVs could pose a threat to the electric grid.

These attacks on clean air come at a crucial time, as the EPA is seeking comment on the rule through July 5, 2023. A strong tailpipe emissions rule, coupled with our recommendations to reduce vehicle miles traveled in the Driving Down Emissions report, could be a powerful force to combat climate change and increase the efficiency of the transportation system.

Ready to submit comments, but not sure what to say? Take a look at sample comments from NUMO and the California Air Resource Board.

Advocates call for White House council to track and reduce emissions

A man rolls a stroller down a wide sidewalk along a tree-lined street with a painted bike lane and crosswalk

While NEPA exists to protect the environment and communities, it has long fallen short of addressing climate emissions and protecting disadvantaged communities. In response to a call for comments about new guidance on climate change and greenhouse gas emissions, Transportation for America joined a nine-member working group to urge the White House to address transportation’s role in climate emissions and historic injustices. Read the full comments here.

A man rolls a stroller down a wide sidewalk along a tree-lined street with a painted bike lane and crosswalk
Streets like this one allow for multiple modes of travel, helping to reduce emissions from personal vehicles. Flickr photo by Billie Grace Ward.

On January 6, 2023, the White House Council on Environmental Quality (CEQ) released Guidance on Consideration of Greenhouse Gas Emissions and Climate Change, directing federal agencies to improve the evaluation of climate impacts in environmental reviews as part of the National Environmental Protection Act (NEPA) process. 

The CEQ, created in 1970 with the passage of NEPA, is a body that oversees federal agencies’ implementation of NEPA-required environmental assessments of federally funded projects. As the lead body for the NEPA process, the CEQ’s Guidance determines the scope of scrutiny that projects must undergo through the NEPA process. However, for decades, the NEPA process and the CEQ have ignored or understated the significant role that federally approved transportation projects play in contributing to climate change emissions and overburdening Black and Brown communities.

The current approach from CEQ allows agencies like the Federal Highway Administration (FHWA) to sign off on faulty traffic models that fail to account for the role increased highway capacity has in increasing car usage and the associated CO2 and fine particle pollution that follows. Inaccurate models used today often project, paradoxically, that new highways will reduce harmful emissions. But decades of previous experience have consistently shown that these projects worsen the congestion problems they were built to solve, while harming the communities they go through.

New highways, roads, and lanes are proven to induce more driving, a process called “induced demand.” Read more on induced demand and its impact on emissions here.

In response to the White House’s call for public comments on the CEQ interim guidance and in partnership with Coalition for Smarter Growth, Elders Climate Action, Equiticity, Institute for Transportation Development Policy, National Association of City Transportation Officials, Sierra Club, RMI, and the Southern Environmental Law Center, Transportation for America called for the CEQ to improve its Guidance to accurately measure, report, and minimize the production of greenhouse gasses from the transportation sector, one of the nation’s most polluting sectors. To do so, the coalition urged CEQ to take the following actions:

  • Ensure that transportation agencies’ actions and plans reduce emissions in order to meet the country’s international commitments to cut greenhouse gas emissions. 
  • Direct FHWA and states to include realistic assessments of how transportation infrastructure investments could contribute to or reduce greenhouse gas emissions
  • Devise criteria in the NEPA process that prioritizes actions to reverse damage to community health from transportation infrastructure projects.

By taking into account these comments and other points included in the working group’s response to the Guidance, the CEQ can align the NEPA process with national climate policy. More detail on why the Council on Environmental Quality should consider these goals and how they would achieve them is included in the full comments document.

Read the full comments

Mining public funds for (minimal) private gain

A line of electric trucks wait to be charged in a wide, half-empty parking lot

Lawmakers in Nevada have recently introduced legislation to set aside Carbon Reduction Program funds—about $3.9 million per year—for medium- and heavy-duty vehicle (MHDV) electrification. Although MHDV electrification is essential, assembly bill AB184’s method for doing so is inefficient, ineffective, and unnecessarily generous to private actors at the expense of taxpayers.

A line of electric trucks wait to be charged in a wide, half-empty parking lot
Flickr photo by National Renewable Energy Lab

When the 2021 infrastructure law was passed, it included a number of new formula and competitive transportation programs. The focus of these funds ranged from culverts and wildlife crossings to set-asides for state and regional level Complete Streets planning. Among them was the Carbon Reduction Program (CRP), which was authorized to disperse $6.4 billion on projects that—as the program’s name would suggest—reduce carbon emissions. It is the first federal program created within the national highway program explicitly focused on reducing carbon emissions and most of the eligible uses for the funds are focused on getting more efficiency out of the transportation system by moving trips to less polluting modes.

Unfortunately, even this small amount of funding dedicated to shifting travel to emissions-free modes is under threat. As we wrote last summer, this formula program has a significant loophole in it that could allow up to half of its funds to be spent on projects that actually increase emissions. And now, a group of Nevada state legislators want to require over one-third of the funding to be reserved for truck electrification only.

Nevada lawmakers set a low floor

Introduced last month, Nevada assembly bill AB184 would stipulate that 35 percent of CRP funds—or approximately $3.9 million dollars per year—that Nevada receives would go into a newly created funding pot called the Account for Clean Trucks and Buses. With money in this account, medium- and heavy-duty vehicle (MHDV) purchasers could receive a subsidy for buying electric versions of these vehicles, so long as they meet minimum criteria for how they’re operated.

Electrifying MHDVs does not violate the CRP. Deployment of alternative fuel vehicles is indeed one of the thirteen types of projects that these funds can be used for, and it is an important use: over one-fifth of transportation emissions come from MHDV emissions. In addition, electrifying MHDVs would have significant public health benefits for communities across the country (especially those living near ports, both inland and waterway). It is for these reasons that the Coalition Helping America Rebuild and Go Electric (CHARGE)—which Transportation for America co-leads—outlined MHDV electrification as one of three principles that should guide the electrification of our automobile fleet. However, AB184 has flaws in its execution and its decarbonization logic that ensures it would be no more than mining public funds for (minimal) private gain.

Click here to read CHARGE’s recent report on how electrification investments (including electrification of MHDVs) can advance climate goals.

As it is written, AB184 has three requirements for contractors to receive a rebate for their purchase. First, they must agree to operate or store their electric MHDV in Nevada for at least five years. Second, they must agree to operate said vehicle for at least 5,000 miles or 1,000 hours per year. Third, at least 75 percent of the time the vehicle is in operation must be in Nevada. This means that, in order to receive a rebate, purchasers would only have to operate an MHDV for 18,750 miles or 3,750 hours in Nevada. According to Department of Energy (DOE) data, this is less than one-third of the amount that an average Class 8 truck travels. If the taxpayer is going to help pay for these trucks to displace gas-powered emissions then these trucks should be used to the maximum extent possible throughout their useful lives.

Robbing driving reduction to pay for driving electrification

Electrifying the vehicle fleet across the country is absolutely essential. It must be done. But it is just not sufficient to meet our climate goals (much less our equity, public health and economic goals). Just like we couldn’t make HVAC systems maximally efficient while keeping the windows in buildings open and still meet our emissions goals, we can’t electrify the fleet and force people to drive more, farther every year, and meet our climate goals. The CRP is an important element in allowing people to move in more efficient modes.

The CRP has thirteen eligible use categories—including public transportation capital projects and building active transportation infrastructure—but there are multiple other programs specifically intended to electrify MHDVs. These include the Bus and Bus Facilities Grant, the Clean School Bus Program, and the National Highway Freight Program. Importantly, many of these provide for the construction of public infrastructure, such as recharging facilities, that will induce private actors to purchase electric MHDVs on their own. More effective than incentives are efforts like in California to simply require newly-purchased drayage trucks to be electric starting in 2025, with all registered trucks being zero-emission by 2035. In addition, the infrastructure law and Inflation Reduction Act (IRA) provide further investments in port electrification, as well as a tax credit explicitly for qualified commercial vehicles that simply hasn’t been implemented yet.

AB184 doesn’t address reducing how far people need to drive or giving their constituents access to more low-emissions travel options. As CHARGE, Transportation for America, and the Climate and Community Project have all noted, any proposal to electrify existing transportation infrastructure without significant reductions in how far people need to drive is fundamentally insufficient. If Nevada already has a strong plan to ensure that the state isn’t cutting into the gains made by electrification with investments that cause more vehicle travel overall, then it might be time to dip into CRP funds as they have proposed. If not, the state DOT and legislators need to consider whether the emissions benefits of this diversion is sufficient to justify it.

Considering that the rebate program as currently formulated would provide at least $175,000 (with potential increases for purchasers who meet additional criteria, such as being a minority- or veteran-owned business, AB184 could only be used for buying about twenty-two electric Class 8 vehicles. When combined with the DOE data, this means that the standards for this rebate are so low that they might only replace eight Class 8 trucks. The question for Nevada lawmakers is whether that benefit is enough to justify taking this funding from other needs that might be hard to fund any other way.

The bottom line

The central flaw of AB184 is simple: there is no consideration of whether there are better uses for CRP funds today or in the future. There is no consideration of other needs such as improving transit or active transportation and whether the state has access to sufficient funding elsewhere to address these needs before a portion of this funding is diverted. Additionally, Nevada lawmakers are creating a program that could be exploited by those who want to expand their MHDV fleets on the taxpayer’s dime without having to demonstrate sufficient use of those vehicles or emissions reductions.

The half-promise of the Carbon Reduction Program

Bike lane ends next to highway lane

This post was written by Mollie Dalbey and Stephen Coleman Kenny, members of the Transportation for America policy team.

The Carbon Reduction Program (CRP), a new formula program released by the Federal Highway Administration (FHWA), provides states with $6.4 billion over 5 years for projects and strategies to reduce carbon emissions. However, thanks to a costly loophole, the program could end up making emissions worse.

Bike lane ends next to highway lane
Funds for the CRP could support more active transportation systems like protected bike lanes, but right now, it looks like spending is likely to be diverted to other projects. Flickr photo by Bart Everson.

The $6.4 billion Carbon Reduction Program (CRP), created under the new infrastructure law, is a substantial investment in carbon reduction. Under the program, each state must create detailed plans for how they will reduce transportation emissions. The money must be used to create and expand systems for public transit, active transportation (walking, biking, and rolling), congestion pricing, and other strategies to reduce emissions.

The CRP presents states with an opportunity to have a real impact on limiting greenhouse gas emissions. However, it’s important to note that this is just a small pile of cash compared to the other major funding streams in the infrastructure law, many of which states have traditionally used to make emissions worse. To effectively deliver on climate, states will have to move away from the status quo approach of building more and more roadways that increase emissions. That means they will need to make proper use of CRP funds and other federal dollars at their disposal.

Unfortunately, as we’ll cover below, there is little accountability to ensure states follow through, which means the FHWA will have a lot of work to do if it wants to get the most out of the CRP.

A high-emissions loophole

The CRP allows states to avoid using program funds for their intended purpose. State DOTs can flex up to 50 percent of CRP funds to other transportation projects including ones like highway expansions that increase emissions, as long as they records a reduction in carbon emissions.

Unfortunately, state reductions don’t have to be linked to any particular target. The FHWA is still developing their methodology for what emissions reductions will qualify for flexing funding out of the CRP, but all signs point to leniency. In other words, states that see reductions in their greenhouse gas emissions will be able to use carbon reduction funds to increase emissions. At the moment, the FHWA has not stated a specific level of carbon reduction required prior to flexing funds, which means states can start flexing funds to high-emissions projects after recording minuscule emissions reductions.

States are already spending their CRP dollars despite the fact that carbon reduction strategies (CRS), the plans they should be using to appropriately utilize CRP funding, are not due to the FHWA until November 15, 2023, nearly halfway through the infrastructure law’s funding timeline. These strategies can take up to 90 days to review and could still take rounds of adjustment before they are accepted by the FHWA. States without a reviewed CRS cannot adequately plan CRP spending, so there are no guarantees that the program will be able to meet its goal of reducing emissions.

A complimentary tool for transparency and accountability

The FHWA might be able to leverage a proposed regulation it rolled out for comment on July 15 to get the most out of the CRP. The proposed greenhouse gas (GHG) emissions measure would require states to measure the total amount of GHG emissions produced by transportation and reduce them to half of 2005 levels by 2030 and reach net-zero emissions by 2050. Because of these declining targets, the new rule might incentivize states to use their CRP money to reduce emissions. However, that depends on how closely states adhere to the emissions measure guidance. 

So far, climate-unfriendly states have not been too keen on listening to the FHWA. Enforcement of the GHG emissions measure will take diligent administrative action, which is uncertain even in administrations friendly to climate action like the Biden administration. Congress could ensure the success of the CRP by holding states accountable for failing to meet GHG emissions measure targets.

The bottom line: FHWA must add some chutzpah to the CRP

In order to make this program consequential for reducing transportation emissions, the FHWA needs to make changes. We won’t be able to reach our nation’s carbon reduction goals if even the programs aimed at reducing emissions are making our emissions worse. To start, they must require CRP funds to be used solely for the purpose of carbon reduction until states have hit benchmarks similar to those in the GHG emissions measure. 

After states hit the target level of carbon reduction (based on emission per capita and per economic unit), states should only flex funds into projects which will not counteract those reductions (e.g. transit and rail). Congress can also nudge the FHWA towards this by clarifying the intention of the program as only allowing states to flex money out if they are making real progress on transportation emissions.

The FHWA must also outline an adequate timeline for the completion of carbon reduction strategies, requiring states to demonstrate how they plan to use their funds and that they have reached the benchmark prior to flexing to other programs. Climate change is an ever-growing problem, and half measures will not help us reach our goals. The FHWA must provide more structure to this program, or else billions of dollars in climate funding could be spent in vain.

Transportation for America members have access to exclusive resources that provide further detail on this topic. To view memos and other members-only resources, visit the Member Hub located at t4america.org/members. (Search “Member Hub” in your inbox for the password, or new members can reach out to chris.rall@t4america.org for login details.) Learn more about membership at t4america.org/membership.

We’ll never address climate change without making it possible for people to drive less

With transportation accounting for the largest share of carbon emissions in the U.S., we’ll never achieve ambitious climate targets or create more livable and equitable communities if we don’t find ways to allow people to get around outside of a car—or provide more housing in places where that’s already an option. Our new report shows how we can reach those targets while building a more just and equitable society. 

Join us on October 28th for a short online discussion about what’s in Driving Down Emissions. We’ll be walking through the report briefly and sharing some stories about how one state has had some success—and the limitations of electric vehicles. Register here.

It seems like climate-focused policymakers have a single-minded obsession with the silver bullet solution of everyone in America buying a brand new electric car, while ignoring an underlying system that requires everyone to drive further every year, kills people walking in record numbers, and creates communities that cuts people off from jobs and opportunities. Yet the simple truth is that we’ll never achieve our ambitious climate targets or create more livable and equitable communities if we don’t find ways to allow people to get around outside of a car. 

We need a different set of solutions to pair with one day being able to convert our current gas-powered vehicle fleet to electricity.  Driving Down Emissions, a new report from Transportation for America and Smart Growth America, explores how our land-use and transportation decisions are inextricably connected, and unpacks five strategies that can make a significant dent in the growth of emissions while building a more just and equitable society:

  • Getting onerous government regulations out of the way of providing more homes where people naturally drive less;
  • Making safety the top priority for street design to encourage walking, biking, and shorter driving trips;
  • Instituting GHG reduction and less driving as goals of the transportation system;
  • Investing heavily in other options for getting around, and;
  • Prioritizing access to destinations. 

Reducing transportation emissions and reducing the distance we drive is both needed and possible. The vast majority of Americans are clamoring to spend fewer hours behind the wheel, not more. Only a cynic would declare that Americans want to drive more and more each year to accomplish all they need to do each day. Polling and consumer preference research has consistently shown that millions would prefer to live in walkable, connected places where trips are short and there’s a menu of options for getting around.

Yet that demand is going unmet, and some of the biggest obstacles to meeting it are onerous government regulations and policies (at all levels) that make it nearly impossible to build more housing in places that fit this bill, or to retrofit streets to make more areas safe to walk or bike in. These factors combine to make existing housing in walkable places unaffordable and unattainable.

Let that sink in: millions of Americans would love to live in places that guarantee shorter trips, fewer trips, more ways to get around, and less emissions—whether climate change is their motivating factor or not. But millions can’t find a place they can afford because of zoning requirements that make it either incredibly difficult or downright illegal to meet this demand, and because transportation designs and objectives that make it dangerous to try to get around elsewhere without a car. 

If lower-income Americans can’t afford a car then they have no choice but to limit the possibilities for their lives to what can be reached on dangerous streets by foot or bike, or via infrequent buses or trains on underfunded transit systems that fail to connect them to opportunity, even if the emissions are low. Finding ways to put more housing in places where people can drive less—and making those homes attainable and affordable—will be a key aspect of transitioning to a low-carbon economy without placing a new burden on lower-income Americans. 

This report shows that reducing emissions from transportation is entirely doable—which is a good thing, because there are other areas where making significant reductions will be far more difficult. While we don’t want to repeat the economic conditions of the COVID-19 pandemic, the massive drops in traffic and emissions during the shutdown showed us the potential benefits of lowering driving rates, even if just a modest amount. And while we have no idea how to completely electrify our fleet of vehicles or how long that transition will even take, we can absolutely lower emissions in a short timeframe by meeting the demand for more housing in smart locations—helping millions of Americans who want to live in places where they can emit less and drive less find ways to do so. 

The urgency of our climate crisis requires it.

Do climate plans do enough on transportation?

Climate change has become a top issue for Americans, so how do the top Democratic candidates plan to reduce emissions? Here’s a brief look at what some of the presidential candidates are proposing when it comes to emissions from transportation.

A recent poll found that most American teenagers are “frightened” by climate change. It is no surprise then that candidates for president and members of Congress are releasing their plans to combat the climate crisis. So what do the Democratic presidential candidate front-runners say about transportation in their climate plans? Not nearly enough.

Virtually every plan released to date focuses on promoting electric vehicles (EVs) and strengthening fuel efficiency (CAFE) standards. While EV adoption and increased efficiency are essential for reaching any ambitious climate target, they will not be sufficient on their own to decarbonize the transportation sector.

T4America Director Beth Osborne explained why recently in the San Francisco Chronicle:

Transportation is now the largest single source of climate pollution and the vast majority of those emissions—83 percent—come from the cars and trucks that people drive to the grocery store or school or that deliver our Amazon orders. All that driving is why transportation pollution keeps increasing, despite gains in fuel efficiency standards and the adoption of electric vehicles. Between 1990-2016, despite a sizable 35 percent increase in the overall fuel efficiency of our vehicle fleet, national emissions rose by 21 percent. Why? Because those improvements were accompanied by a 50 percent increase in driving. Cleaner and electric vehicles are essential, but they’ll only ever be a small part of the solution. For one, it takes a long time for the vehicle fleet to turn over. Even if Americans purchased nothing but electric vehicles starting today, gas-powered cars would still be on the road for at least another 15 years.

Emissions won’t drop fast enough if we pin all our hopes on EVs. We need to reduce the amount and distance people drive through better land use and by promoting transit, walking, and biking. Today, our federal policy incentivizes high speed, long distance driving—rewarding states that increase both with more money—and makes it far too difficult to build communities which provide people with transportation choice.

Even the Green New Deal fails to adequately address the need to reduce driving and rethink our land use decisions.

The climate plans & transportation

We took an in-depth look at the climate plans from the top eight presidential candidates (according to RealClearPolitics polling data as of November 1, 2019) for the Democratic Party nomination. We’ve also included Jay Inslee in our analysis, despite the fact that he dropped out of the race, because his climate plan is widely considered to have set the standard for climate plans.

There are some candidates running for the Republican nomination for president, but none of them have released climate plans. The closest thing President Trump has to a climate plan is the “Affordable Clean Energy” rule which could actually increase pollution.

Note: Investments, quantifiable targets, or policy proposals below are bolded; broad value statements or acknowledgements of an issue without a proposal to address it are not bolded.

PollingCandidateElectrify vehiclesReduce drivingPromote bikeable/walkable communitiesInvest in transitSupport passenger rail
n/aBiden's unity task forceSupport “cash-for-clunkers” style approaches to incentivize accelerated adoption of zero-emission passenger vehicles. Provide incentives for manufacturers to build new factories or retool existing factories in the United States to assemble zero-emission vehicles or manufacture charging equipment.“Encourage states to prioritize allocation of transportation funds for public mass transit, and pedestrian and bicycle infrastructure, and ensure transportation options and infrastructure meet the needs of tribal, rural, and urban communities to fully participate in zero-emissions transport.”“Encourage states to prioritize allocation of transportation funds for public mass transit, and pedestrian and bicycle infrastructure, and ensure transportation options and infrastructure meet the needs of tribal, rural, and urban communities to fully participate in zero-emissions transport. Make major improvements to public transit and light rail. Preserve and grow the union workforce within the rail, transit and maritime sectors.”

“We commit to public transportation as a public good, including ensuring transit jobs are good jobs.”
Invest in high speed passenger and freight rail systems, while reducing pollution, helping connect workers to quality jobs with shorter commutes, and spurring investment in communities more efficiently connected to major metropolitan areas and unlocking new, affordable access for every American.
1Biden500,000 new public charging outlets by the end of 2030 and restore the full electric vehicle tax credit.Altering local regulations to eliminate sprawl and allow for denser, more affordable housing near public transit would cut commute times for many of the country’s workers while decreasing their carbon footprint. Communities across the country are experiencing a growing need for alternative and cleaner transportation options, including transit, dedicated bicycle and pedestrian thoroughfares, and first- and last-mile connections. Ensure that America has the cleanest, safest, and fastest rail system in the world and will begin the construction of an end-to-end high speed rail system that will connect the coasts.
2WarrenZero emissions in all new light and medium duty vehicles by 2030.Expand and improve public transit across our country.
3Sanders100 percent electric vehicles powered with renewable energy.For too long, government policy has encouraged long car commutes, congestion, and dangerous emissions. Create more livable, connected, and vibrant communities.$300 billion investment to increase public transit ridership by 65 percent by 2030.$607 billion investment in a regional high-speed rail system.
4ButtigeigAll new passenger vehicles sold be zero-emissions by 2035.Switching from individual vehicles to public transportation not only reduces traffic congestion, but also reduces emissions while improving air quality.$100 billion over 10 years, which will include installing bike and scooter lanes.$100 billion over 10 years, which will include modernizing subways and other transit systems and deploying electric commuter buses and school buses.
5Harris100 percent zero-emission vehicles by 2035.Incentivize people to reduce car usage and use public transit...focusing our transportation infrastructure investments toward projects that reduce vehicle miles traveled and address gaps in first mile, last mile service. Funding robust public transportation networks to bring communities together.
6YangRequire all models from 2030 on to be zero-emission vehicles.$200 billion grant program to states to electrify transit systems.
7GabbardWhile Gabbard has not released a climate plan, she has introduced legislation in the U.S. House that would require all new vehicle sales to be 100% electric by 2035.
8O'RourkeRapidly accelerate the adoption of zero-emission vehicles.$1.2 trillion through grants and other investments, including: Transportation grants that cut commutes, crashes, and carbon pollution — all while boosting access to public transit.
--Honorable Mention: Jay InsleeInvest federal moneys and expand effective public policies linking community-based economic development to housing affordability and mobility. Promote vibrant communities, more healthy and walkable neighborhoods, and both the preservation of existing affordable housing and construction of new affordable units.Invest in expanding public transit and connecting people in communities through safe, multi-modal transportation options. More than double annual federal investment in public transit systems and incentivize expansion of transit networks.Provide major new federal investment in electrifying passenger and freight rail throughout the country, and offering federal investment to states and regional partnerships to expand ultra-high-speed rail.

Politicians think EVs will solve our transportation problems

It’s telling that each candidate has ambitious targets for EV adoption but largely lack policies and investments for other forms of transportation. While EVs will go a long way toward reducing transportation emissions, they don’t go quite far enough. As we’ve written about previously, an all electric vehicle fleet won’t reduce emissions enough to reach our climate targets.

Not only will EVs fail to address the climate crisis, but they will do nothing to address the larger shortcomings of our current transportation system.

EVs won’t make our communities more walkable, bikeable, or transit-oriented. We’ve designed many of our roadways and communities so that it’s almost impossible to get around without a car. People often have no choice but to sit in traffic to get to work and the grocery store. Electrifying everything won’t change this. Nor will it help those who can’t afford a vehicle in the first place, regardless of how it’s powered. We need holistic transportation solutions that make it safe, affordable, and convenient to get people where they need to go.

The elephant in the room

These plans are all missing any meaningful discussion and understanding of how land use and transportation are inextricably linked, likely because we tend to think that the federal government plays no role in land use decisions.

But federal transportation policy drives local land use decisions. Where we build roads and highways influences where developers build houses and stores. When we give states a blank check to build a new highway while giving them a minuscule amount for transit (if they can jump through all the regulatory hoops we apply to transit funding), we’re encouraging more sprawl. As houses, businesses, parks, and other daily destinations spread farther apart, people are forced to drive farther and farther, increasing our emissions in the process.

Federal transportation policy has an essential role to play in reducing transportation emissions and making our transportation system work for everyone. How we spend federal transportation money should reflect this and keep climate goals in mind. So far, it seems as though most Democratic presidential candidates don’t quite understand this.

What to watch for in Tuesday’s transportation and climate change hearing

The intersection between climate change and transportation will be on full display during a committee hearing in the U.S. House of Representatives. But will members of Congress take the opportunity to examine the critical role that federal transportation policy has played in creating the climate crisis? Here are six things we’ll be looking for during the hearing.

On Tuesday, February 26, at 10 a.m., the House Transportation and Infrastructure (T&I) Committee will hold a hearing entitled, “Examining How Federal Infrastructure Policy Could Help Mitigate and Adapt to Climate Change.” This hearing will give members of Congress a unique opportunity to discuss the merits and flaws in our transportation system.

When this topic has come up in the past, Congress has often focused exclusively on the role of auto manufacturers in improving fuel economy and the oil industry in reducing the carbon content of gasoline. But will the T&I Committee take advantage of this opportunity to ask probing questions about its own role in reducing GHG emissions by the way it funds the transportation system?

To help the committee inform its discussion, we recently produced two fact sheets outlining the links between transportation and climate change and some solutions.

Here are six things we would like to hear from today’s hearing:

1. A real conversation about the links between transportation and climate change

Transportation is now the single largest source of greenhouse gases (GHG), contributing 28 percent of the United States’ total GHG emissions, surpassing electrical generation. While many other sectors have improved, transportation is headed in the wrong direction. Driving represents 83 percent of all transportation emissions and these emissions are rising—despite more efficient vehicles and cleaner fuels—because people are driving more and making longer trips.

2. Focus on policy, not technology

EV’s will not solve the climate crisis alone: The State of Minnesota recently found that, “the average Minnesotan would have to drive an estimated 1,500 fewer miles per year” to achieve its climate goals. The State of California found that, even after a ten-fold increase in the number of zero emission vehicles, it would have to reduce vehicle miles traveled (VMT) per capita by 25 percent to achieve its climate goals. Hawaii came to a similar conclusion. Electric vehicles alone will not be sufficient to reduce transportation sector emissions, even if we replaced every gas car on the road with an electric one tomorrow.

3. A discussion about whether federal policy should continue to disproportionately subsidize driving over all other modes

80 percent of federal transportation formula funding is for roads. Though they are permitted to, states rarely use these funds for other purposes and there is no requirement to prioritize maintenance first. Funding for new roads is guaranteed through the highway trust fund. Funding for new transit is discretionary and has been repeatedly targeted for cuts or outright elimination. The federal government will only cover up to about 50 percent of the cost of new transit projects, while covering around 80 percent of the cost of new roads.

With new roads subsidized by the federal government, localities struggle to stay ahead of development that spreads further from the center of metro areas, forcing people to travel further to access jobs and services. Often, state and local authorities use funding intended to make walking or bicycling safer to build roadways instead. The resulting growth in driving and congestion leads to a demand for more roads, which induces even more driving. The U.S. has added lane miles faster than our population has grown. This strategy has failed to “solve” traffic congestion and has significantly increased greenhouse gas emissions, offsetting the modest gains made in vehicle efficiency and cleaner fuel.

4. An acknowledgment of the perverse incentives in the current system

States are rewarded with more federal funds if they burn more fuel, increase vehicle miles traveled, and build new lane-miles. That’s one example. There are scores of others.

5. Call out the role of speed in degrading safety, increasing pollution and congestion

Because free flowing traffic is considered the gold standard, roads are built to ensure traffic flows quickly. This means that a long-distance commute where a car moves very quickly (even over a very long total trip time) would be considered more successful than a far shorter commute at a slower speed in traffic. Designing roads with speed as the highest goal is what leads us to more and wider roads, and more and longer trips. Instead, roads should be considered as part of a network which is judged on whether people can reach jobs and services by any mode of travel, not the simplistic measure of whether some of them travel at high speed when driving.

6. A discussion about measuring progress (or failure), and holding states accountable

In 2012, Congress gave states more discretion over spending in exchange for a weak, opaque system of accountability in which states are required to set targets for transportation safety, state of repair and traffic movement. These targets can be negative (e.g., a safety target of increasing roadway deaths) with no rewards for hitting targets nor penalties for missing them. After seven years most of those targets are still not public. There are also no requirements for states or communities to measure and report the GHG emissions and VMT per capita effects of their transportation investments.

Congress got snowed by the states.

Looking for solutions?

A conversation along these lines above would be new and an important step forward, but we also need to start talking about some thoughtful solutions. With driving responsible for 83 percent of all transportation emissions—which are growing despite more efficient vehicles and cleaner fuels because people are driving more and making longer trips—it is critical for Congress to make major changes to the federal transportation policy that’s making it all possible.

What will the committee members propose? We have some ideas:

  • All modes should receive the same federal share: Currently, the federal government will fund up to 80 percent of a road project (even 90 percent in limited cases), while it will only fund up to 50 percent of a transit project.
  • Reform federal funding distribution: Currently, each state receives dedicated road funding through the highway trust fund formulas, which increases as states increase their VMT. New public transit, bike, and pedestrian infrastructure funds are either discretionary (transit Capital Investment Grant program), or an underused option within roadway funding (eg. Transportation Alternatives Program and Surface Transportation Block Grant). Congress could organize the formula funding around efficiency goals and create more parity between the modes.
  • Prioritize maintenance with formula road funding: Historically, states have used this formula funding for new road construction, encouraging far-flung auto-oriented development that increases the length and number of car trips. The program should focus on getting greater efficiency from the roads we have already built.
  • Measure the right things: Communities need accurate tools to make informed choices. So what should we measure and replace?
    • Measure GHG, and VMT per capita: States and communities should measure and report the GHG emissions and VMT per capita effects of their transportation investments.
    • Measure how well the transportation system connects people to destinations: Roadways are designed to move cars quickly with the assumption that there will always be more traffic, a self-fulfilling prophecy that leads to more and wider roads. Instead of measuring speed and traffic flow on roads, we should measure how the system, and any new investment, connects people to jobs and services by all modes of travel.
  • Set climate goals and penalties for failure to achieve goals: Just measuring our impact won’t quite cut it. The federal government should set GHG and VMT per capita reduction goals and require all states to implement policies to achieve these goals. States failing to achieve their goals should be penalized. States that exceed goals should be rewarded.
  • Align new construction with GHG goals: In the transit program, new capacity projects have to compete for funding and successful projects must demonstrate that they advance national and local goals, including environmental benefits and economic development. There is no such standard for new highway projects. Congress should require funding for new highway capacity to compete for funding, and preference should be given for projects that reduce GHG emissions and VMT per capita.

We must address the climate crisis—which requires changing transportation and land use

Good news! Since the time Beth wrote this, we put our money where our mouth is and wrote a Green New Deal for Transportation. You can check it out here.


The transportation sector is the largest source of greenhouse gasses in the United States and it’s also the one that federal officials have the most control over with the power of the purse. Yet the Green New Deal is largely devoid of the bold reimagining of federal transportation spending which encourages more roads, more driving, more sprawl, and more emissions.

Yesterday, Rep. Ocasio-Cortez (D-NY) and Senator Markey (D-MA) introduced the much anticipated Green New Deal resolution. The brains behind the Green New Deal (GND) should be commended for treating the climate crisis as the existential threat it is. As a policy framework, the GND acknowledges the need to use cleaner fuels and invest equitably. But like most conversations around climate change, it gives only a glancing mention to the transportation system and completely ignores the role development patterns play in driving the climate crisis.

Transportation is the single largest source of greenhouse gases (GHG), outpacing the power sector and comprising at least 28 percent of the United States’ total GHG emissions. Surface transportation represents 83 percent of transportation emissions, and transportation has now surpassed electrical generation as the top emitter. Pollution from transportation comes from three drivers: the efficiency of vehicles, the carbon content of fuels, and the distance people travel. And transportation emissions keep climbing in spite of the fact that vehicles are getting more efficient and fuels are getting cleaner because people are driving more and further.

Why is that? Our surface transportation program is designed to keep people in their cars. For example, Congress distributes transportation funding to states based on how much fuel is burned. The more gas burned in a state, the more money that state gets. It should hardly surprise us that states have built systems tailored to driving or that this system has pushed people to drive more over the past 60 years. Moreover, the transportation program dedicates 80 percent of those funds to highways and only 20 percent to transit—and the highway funding is guaranteed over multiple years while transit funds are on the chopping block every year. Further, if you build a new highway, a transportation agency has to come up with a 20 percent local match. But if you want to build new transit, you have to come up with at least 50 percent. Is our priority clear yet?

Back in 2012, Congress gave state departments of transportation more flexibility over how they spent federal transportation funds. In exchange, they created a performance management system to establish some accountability over that spending. That system requires states—most of which are organized around building highways and have very little staff focused on less polluting modes of travel—to set targets for their performance in safety, state of repair, and traffic flow. Strangely, Congress allowed them to set targets in these areas to do worse every year. And even in this embarrassingly weak “accountability” system, efficiency measures and GHG emissions were completely left out.

Considering the GND is a statement by Congress about what we should do to make every sector more efficient and less polluting, it would be nice if they would look at their own spending (i.e. federal dollars) and consider aligning it with their climate priorities.

Underlying these transportation challenges is the fact that our local governments are pushing housing further and further from the jobs and services that people need. And they have been doing this since the beginning of the highway era. It turns out that if houses are spread out and placed far away from all the things people need then they will have no choice but to drive more often and further.

While the development rules that create these patterns were set by the federal government in the 1920s, the federal government likes to pretends it is a purely local issue and that they have no role in the solution. Of course, many federal programs today continue to support and even encourage this spread out development that predictably creates long car trips and traffic congestion.

If the supporters of the GND are serious about addressing GHG emissions, they are going to have to spend time on the sector that is going in the wrong direction—a sector they have more direct responsibility for than any other. Without that, it looks like they are throwing stones from a glass house.

USDOT is trying to eliminate a new requirement to track carbon emissions from transportation

USDOT is attempting to rescind a federal requirement for states and metro areas to measure their carbon emissions as part of a larger system of accountability for federal transportation spending.

This is from last year’s campaign about the measure for congestion, but the principle holds here: If buses are prioritized because of emissions targets, for example, a road can move more people more efficiently and with fewer emissions.

Update: The comment period has closed and we submitted a large batch of letters to USDOT. Check the blog for updates.

The 2012 transportation law (MAP-21) required transportation agencies to begin using a new system of performance measures to govern how federal dollars are spent and hold them accountable for making progress on important goals, like congestion, traffic fatalities, reliability, road/bridge condition, mode share and carbon emissions. For two years, USDOT worked to establish this new system, soliciting reams of public feedback, and finalizing the measures in January of this year.

Climate impacts aside, tracking carbon emissions is one of the best ways to judge how efficiently we’re moving people and goods. More on that in a minute.

The Trump Administration is attempting to repeal this carbon emissions measure. Take action and provide an official comment to USDOT in support of keeping it intact. (Official notice here)

TAKE ACTION

You may have been one of the thousands of folks who joined our coalition to successfully push USDOT to revise their measure for congestion and put value on providing transit, shared rides and safe walking or biking — rather than just incentivizing the construction of more expensive road capacity in every case in a vain attempt to “solve” congestion. During that process, we also succeeded in pushing USDOT to consider and include a carbon emissions measure to track the percent change in CO2 emissions generated by on-road mobile sources on most of our bigger roadways.

After first attempting to rescind the rule directly by fiat, USDOT was sued by environmental groups, and rightly so — once federal rules are implemented, they can only be undone by Congress or by a new rulemaking process that allows public feedback. So USDOT backed down and is going through the official channels, which means opening up a new comment period where interested groups and citizens can weigh in and urge them to preserve this CO2 rule as part of the new performance measure system.

But we’ll have to act fast — we need to have your letters by Monday, November 6, at noon, so we can deliver them before the deadline.

Measuring carbon emissions is a good yardstick for how efficiently a state or metro area is moving people and goods. Emissions will almost certainly go up if you’re only building new highways and not providing a wide range of transportation options in a congested corridor or region. Agencies should be encouraged — or at least rewarded — for finding ways to invest their transportation dollars so that trips can be taken on transit, on foot or by bike, or coordinated with land use so that trips can be shorter altogether. Measuring carbon emissions doesn’t give you the entire picture, but it is another valuable piece of the puzzle for evaluating the effectiveness of the spending decisions made by states and metro areas.

If USDOT manages to dump this measure, we will lose an important metric for determining who is using their funding to most efficiently connect people with destinations and move goods to market. Shouldn’t states and cities be aiming to move people more efficiently, emitting less carbon per trip? Or, if they decide that less efficiency is the way to go, shouldn’t taxpayers at least have a mechanism for tracking that and holding them accountable?

This administration is attempting to let transportation agencies make decisions while hiding the emission impacts from the public, removing a valuable metric for assessing how they’re spending your dollars. Let them know that we, the people who are paying for the transportation system, deserve to know what we are getting.

Comments are due by the end of the day on November 6. Click here to sign a letter that we’ll produce and deliver on your behalf.

For those of you who prefer to submit comments on your own, you can do so through the official rulemaking on Regulations.gov here and you can grab the letter text from our page here to paste in.

USDOT rewrites congestion rule in response to outpouring of feedback

At long last, USDOT has finalized new requirements for how states and metro areas will have to measure traffic congestion and in the final rule — responding to the outpouring of comments they received — they backed away from most of the outdated measures of congestion that were proposed.

Updated 1/26/17: See the bottom of this post for a video of our webinar explaining this rule and the rest of the final package of performance measures. – Ed.

Wait, what congestion measures? First, let’s take a moment to catch up on what’s happening here, since it’s been months since this was in the news.

For two years, USDOT has been working to establish a new system of performance measures to govern how federal dollars are spent and hold states and metro areas accountable for making progress on important goals, including how states and cities would have to measure (and address) traffic congestion. (Why does how we measure congestion matter? Read some background here.)

As first written, USDOT’s proposed measures would, as we said back in early 2016, “induce sprawl, harm the economic potential of our main streets by treating them like highways, punish cities investing in public transportation, completely ignore people walking, biking, carpooling or telecommuting, and push local communities of all sizes to waste billions of dollars in vain attempts to build their way out of congestion.”

So back in August 2016, we delivered letters from nearly 5,000 individuals and 150 organizations — including dozens of local chambers of commerce and elected officials — opposing USDOT’s flawed proposal and urging them to rethink their approach.

Here’s what 5,000 letters looks like next to a terrific book about Complete Streets for scale purposes since USDOT allows digital submissions.

We’ll be reviewing this newly-released 300-plus page measure in closer detail in the days to come, but our first take upon reviewing it is that FHWA heard the extensive feedback on a complex rule and responded positively to most of the requests that we made.

“Tens of thousands of commenters, through campaigns from T4America, the American Heart Association, and others, raised concerns about the vehicle-focused nature of the eight measures proposed in the NPRM,” FHWA wrote in their comments accompanying the new rule.

The changes are complicated and difficult to quickly enumerate, but four changes are worth highlighting quickly here.

First, we complained that FHWA’s singular focus on delay “paints an incredibly one-dimensional picture of congestion. Focusing on average delay by simply measuring the difference between rush hour speeds compared to free-flow 3 a.m. traffic fails to count everyone else commuting by other modes, rewards places with fast travel speeds at the expense of places with shorter commutes and less time spent behind the wheel overall, and completely ignores how many people are actually moving through the corridor.”

In response, FHWA dumped this peak travel reliability measure, more commonly expressed through the Texas Transportation Institute’s travel time index (TTI), which mostly is a measure of the difference between speeds in the middle of the night and rush hour. This peak travel time measure is gone.

Secondly, they added a “person-hours” measure of delay, which will consider how many people are using the road instead of just how many vehicles are delayed. This was one of our primary critiques of the draft rule, because simple vehicle delay is blind to how many people a corridor is actually moving — it only looks at the number of vehicles. If one corridor moves three times the amount of people as another corridor because of a carpool requirement or a lane dedicated to high-capacity transit, it shouldn’t score the same for congestion just because the travel speed or average delay is the same.

This is a significant change. This means that a congested road that’s full of single-occupant vehicles will never be viewed the same as a corridor that is congested but also multimodal or otherwise carrying more people.

Thirdly, and responding clearly to feedback, FHWA added a new carbon dioxide emissions measure to track the percent change in CO2 emissions generated by on-road mobile sources on most bigger roadways. (Specifically roads on the National Highway System, which, as this graphic reminds us, aren’t always just highways.)

Fourth and lastly, on the topic of multimodal corridors, “…after reviewing these comments, FHWA has decided to include a new multimodal measure — the portion of non-single occupant vehicle travel.”

How did FHWA explain their reasoning to add a measure requiring states and metro areas to set a target for moving people via modes other than single-occupant vehicles?

“Because transportation in urbanized areas is inherently multimodal, it is important to account as much as possible for the options that are available to travelers in those urbanized areas.”

How we measure congestion does matter. It is important to look at congestion and its connection to economic activity. This post from a department within FHWA on Twitter today highlights this connection and it isn’t what most elected leaders and transportation officials believe. Congestion is bad for economic success, right?

Especially after the collapse of the recent Bakken-fueled oil boom of the last few years there, do you think that North Dakota’s leaders would trade ten minutes on their average commute times for ten percent of New York State’s GDP? Does the lack of congestion equal economic success?

This final performance measure from FHWA and USDOT would suggest otherwise.  They are to be applauded, and it wouldn’t have happened without your support. By FHWA’s own admission, the letters that you and thousands of others sent were responsible for pushing FHWA on these critical points.

Stay tuned for more, and sign up for email from T4America to get this kind of news straight to your inbox, including news about a detailed webinar about the new rules happening soon.

Updated: Here’s the video of our webinar about the new performance measures. Read this post for more information.