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HomeLWVCO Climate Emergency Transportation Team Action Alert

The Transportation Commission is receiving comments on revisions to CDOT rules for transportation planning to reduce greenhouse gas emissions from the transportation sector. The proposed rule was UPDATED on October 19, 2021. The deadline for written comments has been extended to November 18.


The main changes include:

  • Broadens objectives to include all kinds of air pollution, not only GHG. 
  • Expands previous listing of GHG pollutants.
  • More focus on reduction in VMT. New: MPO and CDOT to report VMT per capita annually.

  • Detailed language relevant to “societal co-benefits” of reduction in VMT.

  • Removes references to baseline values for determining GHG reduction levels. 

  • Removes Table 2 … Projected Number of Light Duty EV 

  • Requiring anticipation of mitigation investments earlier in the processes and inclusion in project plans.

  • Adds some additional illustrative examples of mitigation measures: transit resources in rural; encouraging adoption of changes in parking; encouraging adoption of demand management; encouraging adoption/expansion of school bus programs, carpools to reduce private cars.

The rules, original version, will:

  • Establish greenhouse gas (GHG) pollution reduction planning levels for transportation
  • Require CDOT and the Metropolitan Planning Organizations (MPOs) to establish plans that meet GHG transportation reduction targets in the GHG Pollution Reduction Roadmap that recognizes that making changes to transportation planning and infrastructure to reduce growth in driving is an important tool in reducing GHG pollution.
  • Demonstrate through travel demand and air quality modeling that statewide and regional aggregate emissions from plans do not exceed specified emissions levels in total
  • Include an analysis of how the Statewide Transportation Plan will align with Colorado’s climate goals in HB19-1261, Concerning the Reduction of Greenhouse Gas Pollution and Establishing Statewide GHG Pollution Reduction Goals.

Transportation planning can incorporate one or more GHG mitigation measures into each of their plans in order to reach the Regional GHG Planning Reduction Levels. GHG Mitigation Measures may include, but are not limited to:

  • Rapid Transit (bus and light rail) to displace Vehicle Miles Traveled (VMT) by car
  • Pedestrian and bike access to safe pathways
  • Bike sharing programs and electric bikes
  • Encouraging local adoption of more effective forms of vertical development and zoning [i.e., density] plans that integrate mixed use in a way that links and rewards transportation project investments with the city making these changes.
  • First and final mile access to transit
  • Safety and accessibility (ADA compliance) of crosswalks
  • Changes to parking policies to encourage walking and transit
  • Vehicle electric charging infrastructure
  • Hydrogen refueling infrastructure
  • Clean project construction using materials with lower GHG emissions and lower truck emissions
  • Enhanced tree cover that captures carbon pollution
  • Transportation demand management practices to reduce VMT

Commenters might consider the following prompts:

  • Support for setting a GHG reduction rule that meets Colorado's HB-1261 climate targets
  • Personal experience with any of the example mitigation measures
  • The costs & benefits of mitigation measures for local communities; consider prioritizing benefits to Disproportionately Impacted Communities
  • Personal concerns about Climate Change
  • Failure of state agencies to give reducing VMT sufficient priority/importance, for example, in dropping a proposed Employee Traffic Reduction Program (ETRP) requirement.

“IF YOU BUILD IT, THEY WILL COME”  --- But at what cost?

Click the following link for information concerning the Transportation Commission soliciting comments on revisions to CDOT rules for transportation planning to reduce greenhouse gas emissions from the transportation sector.  Written comments are due by November 18.
https://www.codot.gov/programs/environmental/greenhousegas.   


Your comments are expressions of your own opinions and experience. 
Individuals should not represent the LWVCO.



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