So right off, that points to an avenue for comment in the survey on the work plan.
One need to highlight then is: Make sure ODOT commits to implementation and commits to VMT reduction. Make sure ODOT doesn't sabotage, slow walk, or otherwise water down the project. They are nearly certain to need to be pushed. (And a little more on that below.)
Already in the work plan is worrisome language about "balance."
|The balance loophole|
And besides, doesn't our Pandemic and its Recession/Depression point to profound failures in our current economic arrangements?
So another point for comment is not to let the false idol of "balance" with economic development undermine climate action.
As for the work plan, again, it leads with "reduce vehicle miles traveled per capita." That is great and praise-worthy, but it could be strengthened also to "reduce total vehicle miles traveled," since that is the part that actually reduces the carbon pollution sent into the atmosphere. We could have significant per capita reductions and still increase total emissions, and that would count as a failure, not as a success.
|From the Every Mile Counts brochure (highlighting added)|
One of the recommendations is a Statewide Trip Reduction Policy, and they are also realistic about it: "The rulemaking effort is likely to be time and staff intensive, and is likely to be controversial." This is great! This is reality-based analysis and planning! That also means it needs additional support. Supporting work for a Statewide Trip Reduction Policy is another item to comment on, then.
|Statewide Trip Reduction plan|
- More robust Transportation Planning Rules
- Scenario and GHG Reduction Planning at the MPOs
- GHG Reduction Performance Measures
Additionally, one omission on "Consider GHG in Decision-making" is ODOT itself. Ask for every highway project to be evaluated for GHG emissions and induced demand. Why isn't ODOT evaluating their own projects? GHG assessment isn't just for the MPOs!
|At the OTC:|
Not super engaged at the highest level of ODOT -
Nothing on VMT reduction
and only "access" to "options" for carbon reduction
A good carbon pollution strategy will need stronger action and more decisive engagement from ODOT. They need to know "Every Mile Counts" isn't a directive on counting more lane miles!
So here is what I see particularly as worthwhile avenues for comment:
- Make everything stronger, especially a commitment to reducing total VMT not just VMT per capita
- Make sure ODOT commits to the project
- Make sure ODOT evaluates their own highway projects for emissions
- Make sure "balance" with economic development isn't used to weasel out of the work
- Support a Statewide Trip Reduction Policy
- Support Parking Reform and Parking Policy
- Support more robust Transportation Planning Rules
- Support Scenario and GHG Reduction Planning a the MPOs
- Support GHG Reduction Performance Measures with accountabiliy