From transportation agencies tasked with long-range transportation plans (LRTP) to Metropolitan Planning Organizations (MPO) developing Transportation Improvement Plans (TIP), we constantly see agencies struggle with prioritizing the right projects and measuring their success to truly advance goals. Our new framework can help agencies establish clear priorities and select projects based on transparent, outcome-driven performance measures.
Transportation agencies and MPOs often create ambitious goals around job access, congestion reduction, safety, cost-efficiency, and livability. While all are important priorities, they are often immeasurable, vague, and conflated goals that don’t breed success, leaving staff scratching their heads wondering why residents still face delayed buses, dangerous roads, increased traffic, and few multimodal facilities. Why have a goal if you don’t have a way of measuring its success?
To help agencies better identify and assess their transportation goals, we compiled a framework for the best practices for transportation project selection and performance measurement.
Our recommendations help agencies prioritize goals and get more specific with measuring outcomes. If an agency has too many goals, particularly if they contradict each other, it complicates the process and the public at large will believe that the process is entirely about political influence, not merit.
No transportation agency will ever have the resources to complete every project on their list. But, if you try to prioritize everything, you are prioritizing nothing. To genuinely improve access and connectivity across your region, you need a way to choose projects that generate the greatest benefits.
We urge other agencies to read through our recommendations, along with our previous Guide to Performance Management and Practical Solutions Memo to begin crafting performance measures that align with your community’s needs. Agencies of all sizes in all regions will benefit from our straightforward processes that aim to maximize transportation access for all users.
The State Smart Transportation Initiative just released its new framework, Innovative DOT. This comprehensive framework offers specific recommendations designed to support state transportation officials in positioning their agencies for success in today’s evolving transportation landscape.
Developed with input from top transportation professionals—including T4America— and state DOT staff from across the country, the State Smart Transportation Initiative’s new framework highlights innovative approaches that leaders are adopting to enhance transportation system efficiency, government effectiveness, and constituent satisfaction. Learning from peers can help state transportation officials tackle shared problems without reinventing the wheel.
This comprehensive resource covers everything from planning to operations and agency culture. It shows how your agency can build a path to resilience while implementing policies and practices that prioritize people over cars.
It also highlights one of our principles, fix it first, and calls on states and local governments who aren’t already doing so to advocate for dedicated funding streams to invest properly in a state of good repair, focusing on maintenance rather than expanding existing transportation infrastructure.
We encourage transportation professionals, policymakers, and stakeholders to explore this valuable resource to continue innovating and improving their organizations to address contemporary challenges state DOTs are facing.
The State Smart Transportation Initiative (SSTI) is a joint program of Smart Growth America and the High Road Strategy Center at the University of Wisconsin.
Ask anyone at a state department of transportation, and they’ll tell you that safety is their top priority. Despite these good intentions, our streets keep getting more deadly. To reverse a decades-long trend of steadily increasing pedestrian deaths, state DOTs and federal leaders will need to fundamentally shift their approach away from speed.
7,522 people were struck and killed while walking in 2022, an average of more than 20 deaths per day. These numbers represent the harsh reality many Americans see on a day-to-day basis: in most places across the U.S., there are few options to travel safely and comfortably outside of a vehicle. When that’s the case, a simple walk to school, work, or the grocery store can mean risking injury or death.
Some of the deadliest roads in the nation are state-owned—often wide, high-speed roadways that place an emphasis on vehicle travel, even as they cut through places where people frequently walk, bike, or roll. However, design changes on these deadly roadways often face pushback from state DOTs—even when those same DOTs claim that safety is their number one priority.
There is a logical disconnect between the way our leaders describe the goals of our roadways and the way our roadways are designed. Despite the stated goal of safety, engineers’ actual top priority is moving cars quickly—as evidenced by measures and models like value of time and level of service.
Years of research have shown that when roads are designed for vehicles to drive as quickly as possible, there are serious consequences for the safety of all other travelers. Yet the same design changes that would improve safety also come up against barrier after barrier to progress.
The change we need from state DOTs
The unfortunate reality is that our traffic engineers have been taught for decades that most problems can be solved with wide, high-speed lanes. Changing that thinking requires a real culture shift, starting at the very top. State DOTs require strong leadership and support to tailor projects to a well-defined problem and evaluate the outcomes of their decisions.
A willingness to rethink old models and reckon with the fact that the go-to solution hasn’t solved many of our transportation problems can go a long way in bringing about a safer travel environment. The good news is that alternative solutions are out there—if state DOTs are willing to give them a try. A select number of state DOTs have already started to implement change by, for example, navigating opportunities to utilize a Complete Streets approach on rural highways or trying out a quick-build demonstration project to boost engagement.
The typical approach to designing our roadways has left safety behind. We can’t curb the danger with more of the same. Going forward, state DOTs will need to think outside of the box to protect everyone traveling on their roads.
Our federal leaders have to be part of the solution
Guidance and regulations from USDOT often set standards that prioritize high-speed vehicle travel, but these same regulations also allow state DOTs to make safer choices if they wish. Unfortunately, practitioners at state DOTs don’t always seem to know they have this flexibility, and even if they are aware, they face additional barriers if they want to use it.
When state DOTs use extra time and effort to overcome these barriers and test out a new safety feature, this gets no notice from the federal government—even if it results in improved safety. In fact, if a state DOT does nothing and allows more people to die on their roadways, that DOT receives the same level of funding and attention as those making effective safety improvements. This creates a system where it is far more practical to maintain the deadly status quo than it is to implement proven safety methods.
Recently, our colleagues at Smart Growth America wrapped up a series of technical assistance projects to build partnerships between local communities and state DOTs and advance safety on state-owned roadways. T4A Director and VP of Transportation and Thriving Communities Beth Osborne reflected on the experience:
We’ve heard through our years of work, including most recently with participants in this program, that state DOT staff often feel left on their own to determine whether a non-traditional safety treatment they may like to try out is permitted by USDOT…even if it has a proven track record of improving safety. There is a great opportunity for federal leaders to work with states, local leaders, and safety and public health partners to foster and support more learning through demonstration projects with proactive new guidance.
For state DOTs to truly prioritize safety over speed, system-wide change is necessary—and they can’t do it alone. USDOT can help by providing affirmative guidance that promotes safety strategies that actually achieve results. Future legislation must also hold states accountable for choosing safety over speed.
It’s Safety Over Speed Week
Click below to access more content related to our first principle for infrastructure investment, Design for safety over speed. Find all three of our principles here.
It will take years to unwind decades of dangerous street designs that have helped contribute to a 40-year high in pedestrian deaths, but quick-build demonstration projects can make a concrete difference overnight. Every state, county, and city that wants to prioritize safety first should be deploying them.
Ask anyone at a state DOT, and they’ll tell you that safety is their top priority. Despite these good intentions, our streets keep getting more deadly. To reverse a decades-long trend of steadily increasing pedestrian deaths, state DOTs and federal leaders will need to fundamentally shift their approach away from speed.
Our roads have never been deadlier for people walking, biking, and rolling and the federal government and state DOTs are not doing enough. If we want to fix this, we have to acknowledge the fact that our roads are dangerous and finally make safety a real priority for road design, not just a sound bite.
T4America used artificial intelligence to find out how states are spending money from the Infrastructure Investment and Jobs Act (IIJA). Two findings are clear: More money alone will still fail to produce change, and it’s far too complicated to figure out where our transportation dollars are going.
In negotiations over the 2021 infrastructure law, the Senate discarded most of the ambitious policy improvements in the House’s INVEST in America Act, instead opting to create scores of new good but small discretionary grant programs for lowering emissions or investing in transportation options while increasing funding overall for the same flexible pots of money that states can spend with few restrictions. Still, the White House and many senators assured us that this bill would lead to a climate victory—often pointing to the small pots of money set aside for emissions reduction efforts.
As the infrastructure law continues to fund thousands of projects, we’ve developed new tools using artificial intelligence to individually categorize project descriptions to categorize how that funding is being spent. And while our methods for analyzing federal transportation spending have evolved into the 21st century, state spending is firmly stuck in the last one, devoting more than $33 billion from the IIJA (so far) to highway expansion. It turns out that giving state DOTs more money with few strings attached results in even more of the same: emissions-increasing highway widenings.
According to recent news coverage, our analysis has struck a chord:
While new discretionary grant programs have been able to offset some of these emissions, relying on cities, transit agencies, and localities to pursue small amounts of funding to offset this massive influx of emissions has produced limited results.
It shouldn’t take dedicated national nonprofits to sort out this information
The simple truth is that it’s incredibly complex to find out where the money from IIJA is being spent by states, and even then, results in a relatively limited view. How can the public have a chance to decide if the $1.2 trillion in new infrastructure money in the IIJA was a smart decision when it’s so difficult to find out where that money is being spent?
While this analysis shines a light on more than 57,000 projects, it’s only the tip of the iceberg. While federal dollars are eventually tracked on USASpending.gov, state-funded projects are not tracked in any central location. There are billions of dollars that this analysis cannot account for, programmed away in over 50 different formats within their State Transportation Improvement Programs (STIPs) that spell out state spending plans across the country.
Federal sources could be improved as well. Of the projects we looked into, 56,106 were from the FHWA, which does a much better job of reporting and obligating funds to states compared to the FTA. And this dataset is changing every month. Already, over 2,000 new projects have been added to our initial USAspending.gov query since our first analysis—and we plan to revisit it in the future.
As a taxpayer, these federal dollars are coming out of your pockets. Yet the lack of transparency on how this money gets spent leaves much to be desired. Even more alarming than the lack of transparency is where the money is going. The new and widened roads that states built with the funding will not lead to freedom from congestion, but instead, might have just consumed dollars that could have been invested in alternatives to road congestion and the existing network of roads and sidewalks. Next time, if we want better outcomes for climate, connectivity, and the economy at large, our leaders need to be clear about how they’re spending our money. That means stronger policy in the next reauthorization, and better reporting as soon as possible.
Our analysis on state transportation spending isn’t over. Stay tuned for additional updates.
Despite the transportation sector being the biggest emitter of U.S. greenhouse gasses, our AI-powered analysis of over 57,000 infrastructure law-funded state projects shows that over a quarter of the law’s formula dollars are funding highway expansion projects that will drastically increase emissions. Will states reverse course with the last two fiscal years of funding?
In a recent briefing with the American Association of State Highway and Transportation Officials in Washington, DC, Delaware Senator Tom Carper took to the stage and reflected on the 2021 infrastructure law (also known as the Infrastructure Investment and Jobs Act or IIJA), and its importance in the fight against climate change. While several Democratic senators have touted the IIJA as important for reducing emissions, as it currently stands, the landmark legislation has not made a positive impact.
While it is true that the IIJA gave states an unprecedented opportunity to use formula program dollars towards emissions-reducing projects, state DOTs also retained the flexibility and authority to invest in traditional, unsustainable road-building projects. Climate researchers found that states are key in determining if the infrastructure law would reduce emissions or use the new funding to make the current problem that much worse.
Keeping these two potential outcomes in mind, we set out to determine how states are actually using the IIJA’s historic funding. With the help of Artificial Intelligence (AI), we categorized thousands of infrastructure law federal award project descriptions (here’s an example) in line with the Georgetown Climate Center’s Transportation Investment Strategy Tool. We now have a picture of how states are using their federal program funding.
Through the analysis, we categorized over $130 billion in funding that has been reported as obligated (or designated to be spent) using IIJA funding from over 56,000 Federal Highway Administration (FHWA) projects, over 1,200 Federal Transit Administration (FTA) grants, and dozens of grants from the Office of the Secretary and Federal Railroad Administration.
While we’re still just scratching the surface of this massive data set, what we found does not paint a pretty picture.
Our findings
Instead of using the historic funding levels to give people alternatives to congestion, pollution, and car dependency, our analysis finds that states have designated over $33 billion in federal dollars (over 25 percent of analyzed funds) toward projects that expand road capacity, doubling down on a strategy that has failed time and time again. Worse still, states and authorities are slow to designate funds for transit and other emissions-reducing projects and even slower to outlay (actually spend) funds relative to FHWA dollar spending, even as we’re running out of time to reduce emissions in the face of climate change. Only about 20% of FTA formula apportionments from fiscal year 2022 to 2024 are reported as obligated in this dataset, while 64% of FHWA formula apportionments are reported obligated, in line with reporting from USDOT. There is also concern that if IIJA funds are not obligated/designated to be spent within a specified period of time, they could expire (or lapse) and become unavailable for use.
To maintain just the literal surface of the nation’s massive inventory of roads, nearly 28% of analyzed funding has gone to highway resurfacing, a strategy that the Georgetown Climate Center’s Transportation Investment Strategy Tool found to help reduce emissions. Considering other infrastructural work unrelated to on-road emissions, we found that road maintenance accounts for more than half of all FHWA formula spending.
Our analysis includes only the information provided by the federal government on USAspending.gov. State DOTs and federal agencies are slow to update project spending data, and many discretionary awards are not yet uploaded to USAspending.gov, so this analysis does not reflect all of the IIJA’s spending. Instead, we intend this analysis to shine a light on how states are using the largest, most flexible, and often least understood chunk of federal funding—federal highway formula funds. Without federal guardrails on states or a drastic change in spending priorities, our analysis predicts a substantial increase in GHG emissions if current trends persist.
We’re only just approaching the midway point for the IIJA, which is set to expire on September 30, 2026. If states continue to fund and advance projects in the same way that they’ve done so far, the IIJA will have an alarming impact on the climate. If states do not change course, the IIJA is on track to produce an additional 178.5 million tonnes of CO2e GHG over baseline emissions by 2040. According to the EPA, this is the emissions equivalent of running 48 coal-fired power plants for a full year.
While the IIJA could have been a win for the environment, across the country, states have instead used this once-in-a-generation level of funding to expand roadways the same way they’ve been doing for years. Considering the billions of federal dollars already spent on highway expansion projects, it’s going to take more than self-congratulation over the bill’s historic funding to undo the environmental harms. In light of our findings that state spending continues to undermine climate goals, the administration cannot compromise on reducing transportation emissions and must explore every means available. Congress needs to get real—the largest and most growing sector of emissions is transportation. If we want to tackle congestion and the climate crisis, instead of offering platitudes, the next transportation bill needs to offer clean mobility options, like transit, car share, active modes, and electrification—not just the same strategies that got us in this position in the first place.
United States Reported Obligation Strategy Breakdown
AI-assisted analysis based on data reported to USAspending.gov, updated 2/15/24.
The GHG emissions measure will require U.S. states and territories to measure and report transportation-related emissions on federal roadways.
WASHINGTON, D.C. (Nov. 27) — Last Wednesday (11/22), the Biden Administration released the U.S. Department of Transportation’s greenhouse gas (GHG) rule. The rule requires all 50 states, as well as the District of Columbia and Puerto Rico, to track greenhouse gas emissions associated with travel on the parts of the National Highway System that lie within their boundaries and sets a unified standard for reporting emissions.
Transportation is the leading contributor to GHG emissions in the U.S. and the performance measure is an important first step to advance climate goals by bringing sunlight to states’ progress on emissions targets, allowing states and MPOs to better align their work with climate goals, and demonstrating to policymakers and taxpayers what they are getting for their transportation investments.
“We thank USDOT for its leadership in requiring states to measure GHG emissions from transportation,” said Beth Osborne, Director of Transportation for America. “Because transportation is responsible for nearly a third of climate emissions nationwide, and as much as half in some metro areas, determining the impact of transportation investments on climate emissions is essential for understanding how well the transportation system is performing. It is hard to think of a way that states could participate in a solution without articulating the current problem and setting targets for achieving them.”
“This rule is a crucial first step toward climate accountability in transportation and very simple for the states to implement, but we must go further by investing in public transportation and location efficiency to allow people to reach the things they need without being forced to drive more and more each year,” continued Beth. “These investments have benefits beyond reducing emissions, including public health benefits and providing people with more opportunities to travel outside of a car, which enhances safety and economic mobility.”
“Transportation for America stands ready to support the rule’s implementation and we look forward to continuing to advocate for increased transparency and aggressive climate change mitigation policies and investments.”
This GHG rule is final and is now in effect. The first milestone requires State DOTs to establish and report targets on February 1, 2024, necessitating a rapid rollout and immediate implementation measures from federal and state governments alike.
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Transportation for America is an advocacy organization made up of local, regional, and state leaders who envision a transportation system that safely, affordably, and conveniently connects people of all means and ability to jobs, services, and opportunity through multiple modes of travel. T4America is a program of Smart Growth America.
The predicted traffic levels on which transportation planners base their decisions are erroneous and rooted in obsolete methods. Here’s how transportation models fail to accurately predict future traffic, and how you can call out their misuse.
The 26-lane Katy Freeway in Houston had worse traffic after its widening than before. Were the traffic models wrong? Photo: Wikimedia Commons
You’ve seen it before. A state DOT claims they must widen a highway through your community to reduce congestion and accommodate future traffic. The transportation agency points to traffic projections that we all take at face value. They might even claim that widening the highway will improve traffic flow thereby reducing emissions. You don’t want the highway widening in your community, but what can you do in the face of experts saying it is necessary and pointing to data that “proves” their case?
Transportation agencies use transportation models to predict future traffic and plan the roadway system accordingly. But the underlying algorithm for these models was developed in the 1980s when the computers in use were less powerful than today’s smartphones. Due to this past limitation in computing power, travel demand models use a simplified approach that doesn’t accurately represent how people make travel decisions.
T4America experts collaborated with our partners to look inside the black box of transportation models (also sometimes called travel demand models or traffic models). We submitted a memo to the US Department of Transportation asking them to apply more accountability to agencies using these models to correct them.
Some of the transportation models’ specific flaws
The proof that transportation models are failing us is plain to see in the long term trends. Over the last 20 years, congestion has increased in every single U.S. metropolitan area regardless of how much they’ve expanded their highways and regardless of whether their population grew or shrank.
In what way have transportation models misled us? It largely has to do with the underlying approach which is too simple, chosen because of limited 1980s computing power. Transportation models use a Static Traffic Assignment (STA) algorithm which is a sort of snapshot in time of how much traffic is on each roadway in a region at a given moment. This static algorithm is problematic, since people make decisions on different factors every day, often in the moment. People are dynamic not static.
What’s more, STAs do not properly account for bottlenecks, or constrain forecasts based on roadway capacity. No roadway can ever carry more cars than its maximum capacity, any more than a coffee mug can hold 110% of its coffee capacity. Yet agencies routinely and confidently make claims like, “without this expansion, the roadway will be at 110% capacity.” If you point out that a roadway can’t handle more cars than it has capacity for, they say that extra 10 percent is “latent demand.” In other words, they are certain that there’s exactly 10 percent more cars and trips out there that must be served.
We call this induced demand—demand created by the new road itself—a concept those same agencies often claim doesn’t exist. (But which the public absolutely understands, as our brand new national polling shows.) By trying to sell the project on all that “latent” demand, they can claim a traffic nightmare if nothing is done without admitting that the project will actually create more traffic—and more greenhouse gas emissions, fine particulates, etc. [USDOT and the Environmental Protection Agency support that approach for some unfathomable reason, never asking if the models used to justify federally funded projects have been right.]
In reality, as congestion increases toward that 100% capacity mark, people make different travel decisions, change their routes, choose to travel at a different time, use a different mode or choose a closer destination to fulfill the same need. If there is a crash, people delay their trip or consult Google maps and choose a different route. But transportation models using the STA approach unrealistically assume people will blindly keep driving a congested roadway, no matter what is happening or how long their trip will take.
Not only does the model assume no changes in behavior, but it will also output results that show drivers stuck at one bottleneck, while simultaneously allowing them to magically pass through that one to also be stuck at another bottleneck downstream.
Compounding these issues, planners rarely, if ever, look back at their past work to see if their predictions were correct. Did the traffic materialize? We’re stuck with decades-old models that are never tested or upgraded to reflect reality, as shown here:
This graphic from the Frontier Group combines past federal projections of future growth in vehicle miles traveled. Every year a new optimistic projection was made that ultimately didn’t pan out, but they kept on predicting the same thing.
How to question your region’s model
We’re hopeful that USDOT will eventually provide accountability to upgrade the state of practice on transportation modeling, but you can also ask questions about the transportation models used to promote road widenings in your community. Here are some things you can ask your local transportation planners to illustrate the flaws of using transportation model results to justify road widenings:
Does your model use Static Traffic Assignment?
What is the maximum volume to capacity in your model runs, and how is that realistic? (If they give a volume over 100%, ask how a road can carry more than its capacity. And ask if latent demand will fill the new capacity they are building then what good will this investment do?)
How does your model account for dynamic changes in commuting patterns, responses to crashes, or the threshold at which people shift to other modes?
What is your protocol for evaluating the accuracy of your past traffic projections and using that to improve upon the model? Where is it published?
Getting our transportation models to better reflect reality will help planners make better decisions about where to invest our tax dollars. Calling on USDOT to upgrade standards for transportation models, and calling out their misuse locally in the meantime will help us turn the corner to more sensible improvements to transportation in our nation.
Cities across the world are arriving at the same conclusion: the only acceptable number of pedestrian crash-related deaths is zero. How can state departments of transportation be part of the solution? In this third part of our blog series, we explore the seven E’s state DOTs should consider when making pedestrian safety infrastructure improvements.
When you are driving down a road that looks like the one above from Memphis, TN, what are you most likely to do? Increase your speed or drive slowly? T4America photo by Forever Ready Production
Changing roadway safety in design will take a change of culture in how Americans view pedestrians from behind the wheel. An essential part of this change in culture will come from how practitioners design our nation’s roadways. Who are we truly designing our roads for? For vehicles or for people?
This post is part III of a blog series, Eliminating driver error doesn’t work. What does? See parts I and II.
The Seven E’s
A comprehensive strategy is necessary to change our approach to road design. To guide state DOT safety efforts, some transportation professionals have suggested seven guidelines, or seven E’s. In part I of this blog series, our post covered the downfalls and areas of improvement for two of those E’s—education and enforcement. While education and enforcement have their place in roadway safety, they cannot be the top priority in a DOT’s approach. The remaining five E’s, evaluation, engagement, engineering, encouragement, and equity, are vital to our roadway’s safety-centric transformation.
Proper evaluation of America’s roadways is required to create a foundation for change. Currently, there are no national standards for data collection and reporting of pedestrian crash-related deaths that are comprehensive and set tolerable safety goals. Without proper data collection standards, state DOTs are not able to fully comprehend the severity of the issue, or have insight into where the most dangerous roads are located.
Community engagement has the potential to create inclusive, equitable grassroots movements that are fundamental in igniting the reform of state DOTs to create safer roads for all users, including pedestrians. When state DOTs engage with the local communities identified in their evaluation efforts, a more inclusive design process can evolve to meet the needs of those specific communities, in addition to their safety.
An example of effective community-generated programming is the 11th Street Bridge Park project. Throughout that project, which will build a pedestrian bridge over the Anacostia River, community engagement has been the central focus of the District’s DOT (DDOT). DDOT brought community members in from the very beginning and factored their feedback into the design process. The resulting community-generated programming of the pedestrian bridge includes outdoor performance spaces, playgrounds, urban agriculture, an Environmental Education Center with classrooms to teach students about river systems, public art that tells the rich history of the region, and kayak and canoe launches.
The engineering of roads and streets directly impacts pedestrian safety and crash-related deaths. While there are myriad factors involved in these pedestrian crash deaths, our streets are designed to move many cars quickly at the expense of the safety of everyone who uses them. Roadway design strongly impacts how people drive, and it’s often more influential on driver behavior than the posted speed limit.
Smart Growth America’s Dangerous by Design report clearly outlines the American epidemic of deaths while walking and its direct relationship to the design of our roads.
Some DOTs, like NYCDOT, have been spurred on by the Vision Zero movement (read more about that movement in this prior blog post) and started implementing design-centered solutions to traffic deaths. NYCDOT’s recent report includes evaluations of specific design interventions and their impact on pedestrian safety. The image on the left recommends design schemes engineered to improve pedestrian safety and reduce crash-related deaths.
Road designs that are engineered with safety as their priority complemented by transparent data reporting on their related reduced crash deaths are likely to encourage adoption across cities and states. Additionally, federal and state governments could financially incentivize the adoption of such road designs to further encourage safety improvements.
Last and most definitely not least is the common thread that connects all of these themes together: equity. Everyone, no matter where they live, their income level, or the color of their skin should be safe while walking. When our streets are dangerous, the heaviest burden falls on communities of color. SGA’s Dangerous by Design report found that Black Americans and Indigenous Americans are particularly affected by unsafe roads for pedestrians, indicative of the road safety inequities these populations experience in their communities. To address these equity concerns, DOTs should prioritize change in communities that are most at risk.
What’s next?
State DOTs need to reprioritize how they think about public safety and the purpose of road design. Moving vehicles quickly at the expense of human life is not acceptable. The seven E’s can be repeated and contextualized across state DOTs, creating a framework for evaluating and responding to the endemic of pedestrian deaths. Collecting insights transparently, using the collected data to inform road design and safety improvements, and doing so in a systematic way, while prioritizing equity in all solutions, will help bring needed change.
You can learn more about how state DOTs can help create a transportation system that works better for everyone in Smart Growth America’s report Building a Better State DOT.
Last month, the US Department of Transportation (USDOT) proposed a new rule that will require states to measure and set goals for reducing greenhouse gas emissions associated with highways. This is a critical tool to foster accountability and steer infrastructure investments toward better climate outcomes. It’s essential for the USDOT to finalize this rule and for states to lead the way in realizing its full potential.
The Greenhouse Gas Emissions Measure (GGEM), would require state DOTs and metropolitan planning organizations (MPOs) to measure and reduce greenhouse gas emissions tied to highways on the National Highway System (i.e. Interstates and US Routes). This proposal is a key action that Evergreen, Transportation for America, and other advocates have called for. Because the transportation sector emits more greenhouse gas pollution than any other sector of the American economy, data collected from this measure will be a vital tool to support investments in alternative transportation modes, better protect disadvantaged communities, and advance President Biden’s climate goals.
Following the enactment of the critical climate and infrastructure investments contained in the Inflation Reduction Act (IRA) and the Infrastructure Investment & Jobs Act (IIJA), Congress and the Biden administration must each play a role in ensuring that these resources are implemented effectively and equitably. At the same time, increased ambition at the state level and bold executive action are essential in order to attain further emissions reductions. New federal rules that enable states to push the envelope are needed to tackle the largest sources of climate pollution, and that includes our transportation sector.
So what is this rule all about?
In 2012 Congress passed the Moving Ahead for Progress in the 21st Century Act (MAP-21), a two-year transportation authorization bill following nearly 3 years of stop-gap extensions. MAP-21 represented a tentative step towards accountability for the billions of dollars the federal government allocates to states every year for transportation, by codifying seven different performance categories for federal highway programs. The Federal Highway Administration (FHWA) created performance measures and subsequently required state DOTs to set performance targets aligned with these goals.
But a new and improved version of this measure is back, under the Biden administration. In early July, the FHWA proposed a new draft rule for a GGEM that would establish a method for state DOTs to calculate greenhouse gas emissions. Rather than a one-size-fits-all target set by the USDOT, states would be permitted to set their own unique declining targets that collectively lead the US towards net-zero emissions by 2050. Critically, the draft GGEM rule would require these targets to continuously decrease, to cut emissions over time in each state. The proposal is a big step forward from the status quo, but still limited in scope. For example, states face no penalties for failing to meet their established targets.
Here are the four actions the Biden administration and state DOTs must take for this proposal to be successful:
1. The Biden administration must finalize a strong performance measure rule ASAP
While the IIJA is not a transformative climate bill, states have a wide berth in deciding how to allocate formula funding under IIJA. The law also establishes new categories of climate mitigation funding, like the Carbon Reduction Program, and expands the kinds of investments eligible under legacy programs like the Congestion Mitigation and Air Quality Improvement Program. In short, governors and state governments will determine, through the decisions they make about what to build, whether or not the IIJA leads to reductions in climate pollution. However, without the proposed rule, the public has no way to hold states accountable for reducing emissions with the windfall of infrastructure money from the IIJA.
Right now, the FHWA has opened a public comment period for the proposed rule through October 13, 2022. Just like in 2017, this rule is already meeting fierce resistance, from both industry and Senate Republicans.
Some stakeholders are falsely claiming that this proposed rulemaking is outside the scope of the performance measures set forth by Congress in MAP-21. Many congressional leaders who were involved in passing that legislation have set the record straight, emphasizing that this proposal will “fulfill the original congressional intent…” There is plenty of flexibility for states built into the existing rule and the Biden administration must finalize a strong performance measure.
2. The Biden administration should factor in state performance when evaluating other competitive grant programs, and FHWA should improve its performance dashboard
Although most federal transportation funding is formula-based, the USDOT can influence policy significantly through discretionary funds like the Secretary’s RAISE grants or the Reconnecting Communities Program. To ensure the greenhouse gas performance measure doesn’t just “sit on the shelf,” the department should assess the relative ambitions of state greenhouse gas reduction targets and progress states achieve as it awards competitive funds. The Biden administration should also incorporate implementation of the measure into criteria for new programs created by the Inflation Reduction Act, including the Neighborhood Access and Equity grant program and the EPA’s new Climate Pollution Reduction grants.
Moreover, because of the non-binding nature of the performance measure proposed, it’s essential that the emissions data and targets of each state are properly advertised and disseminated. This will allow the data to facilitate increased accountability. Right now, the FHWA’s dashboard for state performance data is buried on its website and the information is not frequently discussed or publicized. Going forward, the FHWA and the Office of the Secretary should reinvigorate the dashboard and regularly update stakeholders and the broader public regarding the progress states are making in setting and reaching their declining targets.
3. States should incorporate performance measures in state policy and go beyond USDOT’s proposal
Washington State’s Move Ahead Washington program invests in public transportation and other sustainable travel options. Flickr photo by SounderBruce
Because the targets required by the draft GGEM would be non-binding, it will ultimately be up to states to make their greenhouse gas targets meaningful in a local context. Going forward, states must better prioritize climate in transportation policy and funding decisions. Many states are already measuring greenhouse gas pollution in the transportation sector in some capacity and tailoring their long-range plans, short-term capital plans, and overall investment strategies accordingly. The following model policies should be considered as states move forward with accessing IIJA/IRA funding and implementing the performance measure.
Colorado: The Colorado Transportation Commission recently approved a new rule that will set mandatory greenhouse gas reduction goals for each MPO. These goals must be incorporated into investments identified in each region’s short and long-term transportation plans. The regional goals can be achieved by reprioritizing planned projects or investing in new mitigation strategies. In most cases, this will mean shifting investments away from the construction and expansion of highways and towards public transit and improvements to pedestrian and bicycle infrastructure.
Minnesota: Even as demand for electric vehicles has grown and the Biden administration acts to raise fuel efficiency standards for cars, vehicle miles traveled (VMT) in the United States continue to increase. States have a tremendous opportunity to act where the federal government has not and institute policies that tackle auto dependency. Minnesota recently adopted a statewide goal to reduce VMT statewide by 20 percent by 2050. More states need to look beyond electric vehicles and work towards shifting travel towards the most sustainable and equitable modes of transportation.
Washington: Washington State DOT is not waiting for the federal government and has already implemented a performance measure for greenhouse gas pollution associated with the National Highway System infrastructure inside the state. Emissions and targets are reported to the federal government biennially. Earlier this year, Washington also enacted Move Ahead Washington, a significant transportation funding package that invests heavily in public transportation and other sustainable modes aimed at reducing car travel.
4. States should implement an equity-first approach to meeting targets
States will have significant discretion when deciding how and where to spend transportation-related IIJA funds, and they should ensure they deploy federal funds with a focus on communities that are already impacted by transportation planning and pollution. Black, Brown, Indigenous, and low-income communities suffer the most from vehicle pollution and are historically least likely to receive government investments. By prioritizing these underserved and overburdened communities, states can ensure they are supporting their most vulnerable populations while reducing pollution.
Additionally, state policymakers need to pay careful attention to wealth disparities between white users of the transportation system and people of color, which impact both mode choice and job access. States should consider new incentives for used electric vehicles to supplement the credit for used vehicles contained in the Inflation Reduction Act, and also need to take significant steps to build out networks of Complete Streets and make public transportation more reliable and affordable. Finally, state departments of transportation should prioritize investments that begin repairing past racist policy decisions that were meant to intentionally divide neighborhoods.
Key takeaway
The transportation sector is the largest source of greenhouse gas pollution in the United States. Because most transportation investment decisions are made at the state level, the USDOT’s new Greenhouse Gas Emissions Measure is a critical tool to foster accountability and steer infrastructure investments away from expanding highways and towards vehicle electrification, public transportation, and improvements for other sustainable modes of travel like biking and walking. It’s essential for the USDOT to finalize this rule and for states to lead the way in realizing its full potential.
