Greenhouse Gas Emissions Rulemaking – Centering Equity in the Process 2.0

11/18/2021

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:

• Immediate adoption of a transportation equity framework must be a priority for CDOT. The framework should be vetted by community, modifiable to meet the unique needs of different communities, and equity measures should address community-voiced needs. Equity assessments should be used to inform the transportation equity framework by collecting and analyzing community-shared information related to harmful transportation project development and pollution.
• Establishment of a Community Advisory Committee or Steering Committee comprised of community residents, organizations, youth, etc. charged with reviewing equity assessments submitted by community.
• Increased opportunities for community engagement and outreach to identify disparities among community. Community input should shape the specific equity metrics and outcomes used to measure the direct/project benefits related to improve air quality and mobility options and access among DICs.
• Resources for community informed processes to assess and co-create solutions that mitigate the health impacts of GHG emissions in DICs.
• Consider funding opportunities for Community Benefit Agreements among DICs based on project location and potential impact. OR provide funding for building capacity amongst community benefits groups.
• Elevated needs and benefits of equitable transit-oriented development, prioritizing projects that increase access to transportation, education work, food, goods, and services, etc. this move the needle enough to create real change and meet the statutory requirements?

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:

• Consider local land use and development patterns and the extent to which they contribute to VMT per capita reductions for the proposed transportation project.
• Prioritize projects that incorporate additional smart growth strategies such as up zoning, mixed[1]use infill development, adaptive re-use, and transit-oriented development.
• Create a bonus for projects that advance equity by incorporating affordable housing and TDM programs that lower the combined housing and transportation costs for low-income households.
• Act swiftly to expand mitigation measures should any region fail to achieve the 2025 GHG or 2030 reduction targets. The reductions are cumulative – the lessons of climate change indicate that early action is the cheapest action.
• Ensure that RTD and other regional transit authorities are explicitly funded by name to guarantee certainty in service delivery going forward

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.

Sincerely,

Mile High Connects
YIMBY Denver
Denver Streets Partnership
All In Denver
JJK Places

Download a copy of the letter in PDF here.