This was the second letter we sent to the Colorado Department of Transportation (CDOT) to advocate for equity in the greenhouse gas rulemaking process.
The undersigned members of the Denver-based Land Use Work Group (LUWG), including nonprofit advocacy organizations, nonprofit developers, Business Improvement Districts (BIDs), and residents tracking and amplifying local efforts while advocating for policy change to reflect the nexus of housing and transportation and ensure that investments in the built environment reduce racial disparities, maintain community, build a culture of health, and respond to the climate crisis.
Thank you CDOT for undertaking the project on Rules Governing Statewide Transportation Planning Process and Planning Regions and providing the opportunity for public comment. We appreciate the changes that have been incorporated into the revised rule and for the chance to further improve the rule to ensure we remain on track to meet the state’s climate goals and address the needs of communities that have been disproportionately impacted by climate change.
The rule thoughtfully addresses the importance of multi-agency modeling, ensures mitigating measures stay local among road projects, explicitly acknowledges the role of induced demand, and many other modifications to mitigate transportation pollution. Nevertheless, the current rule still fails to adequately promote climate-friendly land-use policies and center people and environmental justice.
The following recommendations seek to create a more equitable approach to reducing greenhouse gas emissions while centering the needs of Colorado’s most disproportionately impacted communities (DICs):
Center People and Climate Justice: It is imperative that the rule is centered around communities that have been the most disproportionately impacted by the effects of transportation pollution. While the revised rule acknowledges the importance of mitigation investments that provide localized benefits to DICs, it fails to directly provide explicit measures for community benefit and does not emphasize the need for public engagement within decision-making processes. To strengthen climate justice and advance equity the rule should incorporate the following:
Reduction targets for VMT: Reducing VMT serves as one of the best ways to permanently reduce transportation pollution. To meet the state’s climate goals, the rule should include explicit and measurable VMT reduction levels required by each planning region. Allowing three consecutive years of non-VMT reduction among MPO areas prior to conducting revisions, will not achieve VMT reductions that are necessary to meet state goals. Furthermore, we cannot consider VMT reductions without including smart land use strategies. To increase knowledge of the undoubtable connection between smart land use strategies and VMT reduction CDOT should:
We appreciate your commitment and efforts to reduce greenhouse gas emissions from the transportation sector, improve air quality, and provide more travel options throughout Colorado, and your consideration of these recommendations.
Mile High Connects
Denver Streets Partnership
All In Denver