Tell DOT to Protect the Environment, as Required by Law

I just reviewed the U.S. Department of Transportation’s draft 5-year strategic plan, posted on Monday.

There is nothing green about the plan, despite the fact that my heart jumped when I spotted the word “environment” under the first objective of the first goal. The mention turned out to be mostly about laying pavement faster, not protecting natural resources.

In fact, there is very little about improving the performance of our transportation system in terms of environmental outcomes such as reduced air pollution, reduced water pollution and protection of open spaces such as wildlife habitat and farmland. The only mention occurs as a “BTW” in a line about a strategy of cutting the environmental review process (yes, that old saw again): “while safeguarding our communities and maintaining a healthy environment.”

In stark contrast, safety is listed as a separate goal and has a set of 7 very specific, measurable strategies for performance improvement, including “promot[ing] the use of performance based safety standards and measures.”

Environment deserves comparable treatment. In fact, current law requires that “environmental sustainability” be a goal of federal policy, not a throwaway line in a strategic plan. Specifically, Title 23, § 150 of U.S. Code lists 7 national goals for the Federal Highway Administration: Safety, infrastructure condition, congestion reduction, system reliability, freight movement and economic vitality, environmental sustainability and reduced project delivery delays (emphasis added).

Disregard for the environment in the plan is reminiscent of the department’s foolish proposal to repeal the greenhouse gas performance standard promulgated in January. So in addition to telling DOT that its plan gives the environment short shrift in spite of what’s required by law (click here to do so), I urge you to push back against that proposal too.

Unfortunately it, too, has a short comment period, which closes on Monday, November 6th.

To give you a head start on writing your own letter, here’s a model you can copy, paste, edit to add in your own words why you feel strongly about retaining the rule and submit at this link. And I do urge you to spend some time personalizing it, remembering that “ethos, pathos and logos,” Aristotle’s tried-and-true principles for effective writing, hold true to this day. The Secretary of Transportation needs to hear clearly why each of us values this commonsense rule.

Dear Secretary Chao:

Thank you for the opportunity to comment on the proposed rule to revoke the Percent Change in Tailpipe Carbon Dioxide Emissions on the NHS performance metric (known as the GHG rule). I oppose any effort to repeal the rule.

Here is why I strongly oppose this proposal:

The need for urgent action: Since the original performance metrics rule, this nation has experienced record shattering hurricanes, heat waves, and wild fires made worse by the effects of climate change. Transportation is now the largest contributor of greenhouse gases, which means we must measure and improve its performance in order to tackle dangerous climate change.

Single metric/multiple benefits: Measuring greenhouse gas emissions is a critical way for local and state agencies to understand the long-term impacts of their transportation decision making on public health, environmental, congestion management and economic development issues.

Exceedingly modest cost: The cost of implementing this measure as estimated in your proposed repeal is exaggerated given the ease of compliance with a four-step calculation that relies on existing data. And even if the agency’s guess at the cost were correct, it’s just four ten-thousandths of one percent (you read that right—0.0004%) of annual spending on transportation.

Feasibility and innovation: The Federal Highway Administration has developed scenario and performance-based planning to help transportation agencies harness new technology for better results and higher performance. It’s already cheap to crunch these numbers, and thanks to improving technology and techniques, costs of data collection, analysis and reporting will keep dropping.

A federal measure is needed: Rather than a patchwork of the state approaches, a unified approach supports coordination across broader regions, and information sharing.

I urge you to keep the greenhouse gas measurement in the final set of performance metrics.


That’s it. Once you’ve added your own personal touches, please submit your comment by Monday, November 6th to the docket, which is right here.

Thanks for taking action!

About the Authors

Deron Lovaas

Director, EEFA, Resilient Communities, Healthy People & Thriving Communities Program

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