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Metro’s failing climate strategy

Metro’s Climate Smart Strategy, adopted in 2014, has been an abject failure

Portland area transportation greenhouse gasses are up 22 percent since the plan was adopted: instead of falling by 1 million tons per year, emissions have increased by 1 million tons annually, to more than 7 million tons, putting us even further from our climate goals.

Metro’s subsequent 2018 RTP has watered down the region’s climate effort far below what is needed to comply with Oregon’s statutory greenhouse gas reduction goal, based on the assumption that 90 percent of emission reductions would be accomplished with cleaner vehicles.

All of Metro’s key assumptions about transit, vehicle turnover, technology adoption, and driving, have been proven wrong.

The plan has set a goal for reducing vehicle miles traveled that is actually weaker than the reductions the region achieved in the decade prior to the adoption of the “Climate Smart Strategy.”

The agency has not acknowledged the failure of its climate efforts, and is at the same time moving forward to allow the Oregon Department of Transportation to build a series of freeway widening projects that will add more than 140,000 tons of greenhouse gasses per year.

Metro, Portland’s regional government, talks a good game when it comes to climate. It has adopted a so-called “Climate Smart” strategy, and a regional transportation plan that it claims will lead to a reduction in greenhouse gasses. But a close analysis of the Metro’s planning documents and other independent information shows the plan is failing, and is far too feeble to come anywhere close to achieving the state’s adopted legal goal of reducing greenhouse gasses by 75 percent by 2050.

1. We’re going in the wrong direction:  Portland transportation GHG up 22 percent

The clearest measure of failure is the one million ton increase in annual greenhouse gas emissions in Portland over the past few years. Carbon emissions accounting is technical and complex, but for Portland, for the past five years, when it comes to transportation greenhouse gas emissions, and whether we’re making progress, there are just three numbers you need to know:  6, 5, and 7.  In 2010, (the base year for Metro’s Climate Smart Plan), the tri-county area produced about 6 million tons of greenhouse gasses from transportation.  The plan set a goal of reducing transportation greenhouse gasses by about 63 percent by 2035 (the plan’s terminal year), which means that to be on track, the region would need to lower its emissions to about 5 million tons of transportation GHGs by 2017.  But the data from the DARTE national transportation greenhouse gas inventory shows that the region’s emissions increased to more than 7 million tons.  So instead of reducing greenhouse gasses by at least a million tons, we’ve actually increased greenhouse gasses by more than a million tons.  We’re not just “not making progress,” we’re going rapidly in the wrong direction.  Since 2010, we’ve fallen about 2.5 million tons behind the path we need to be on in order to meet the goal laid out in Metro’s Climate Smart Strategy.  



Metro’s monitoring report, prepared as part of the 2018 Regional Transportation Plan, fails to acknowledge that the region is manifestly failing to reduce GHGs.

2. Metro’s 2018 Regional Transportation Plan doesn’t even propose to get us to the adopted state GHG Goal

Metro’s climate plans are spelled out in two documents, a “Climate Smart Strategy” (CSS) adopted in 2014, which proposed a 20 percent reduction in vehicle miles traveled, and a subsequent 2018 Regional Transportation Plan (RTP).  The adopted 2018 Regional Transportation Plan borrowed much of the rhetoric from the 2014 Climate Smart Strategy, but without any announcement or fanfare, radically watered down the region’s greenhouse gas reduction objective.  The CSS set a goal of reducing GHG’s by 63 percent by 2035; the 2018 RTP modified this to a GHG reduction of only 19 percent by 2040 (RTP Table 7.31 “Projected Mobile Source Greenhouse Gas Emissions by Investment Strategy.).

The following chart shows the difference in the two plans. The starting dates for the two plans are set to the base years for their climate calculations (2010 for the CSS, 2015 for the RTP).  The glide slope lines are computed as the average annual percentage reduction in greenhouse gases needed to reach the end year target.

Metro’s Climate Smart goal falls far short of what’s needed to meet Oregon’s statutory greenhouse gas emissions reduction, and even further short of meeting Governor Brown’s Climate Emergency Executive Order—which calls for an 80 percent reduction in greenhouse gas emissions by 2050.  Metro is relying as its justification for these goals a claim that is following guidance from LCDC.  But in fact, Metro is planning for a reduction in vehicle miles traveled than is only one-fifth as much as called for in state regulations (see #4 below), and our analysis shows that overly optimistic assumptions used by LCDC mean that VMT reductions actually need to be much larger than specified in the LCDC targets (Appendix B).  Not only is it failing to comply with the LCDC regulations (as explained here), those regulations have set planning goals that are now inadequate.  Also:  LCDC’s regulations don’t supersede or repeal the state statutory mandate to reach a 75 percent reduction in GHG by 2050, and Metro’s Climate Smart Strategy and 2018 Regional Transportation Plan are inadequate to put the region on track to do its share to achieve the 2050 goal of a 75 percent reduction in transport greenhouse gas emissions.

3. Metro’s plans assumes other people will reduce transport GHGs, not Metro, and its assumptions have been proven wrong

Both the Regional Transportation Plan and the earlier Climate Smart Strategy rely almost entirely on optimistic assumptions about vehicle fuel economy, electrification, fewer trucks and SUVs, and cleaner fossil fuels. Roughly 90 percent of the reduction in per capita greenhouse gasses claimed by Metro come from actions over which it has no control. Its strategy is far less about what it will do to address climate change, and almost entirely wishful thinking about what others will do.

Metro’s 2014 Climate Smart Strategy was based on assumptions that other entities (some unspecified combination of the federal government, state government, auto makers, car buyers) would take actions that reduce greenhouse gas emissions per vehicle mile traveled by 38 percent between 2010 and 2035.  Metro’s plan actually contains no actions that influence per vehicle mile vehicle emissions.

(Source: Metro Climate Smart Strategy (2014).  Right hand column data supplied by City Observatory; sources noted in Appendix B).  

Similarly the 2018 RTP is based on even more aggressive assumptions about cleaner vehicles, drawn from the Oregon Department of Transportation’s Statewide Transportation Strategy.

None of the key assumptions in Metro’s climate plans are being realized. Federal fuel economy standards are being watered down, SUV and light truck sales are more than double market share assumed in Metro’s modeling, older, dirtier vehicles are lasting longer and being driven further, and vehicle electrification is proceeding too slowly to achieve adopted goals.  Further data for each of these points is provided in Appendix B.

  • Metro assumed that average vehicle fuel economy would more than double. Actual fuel economy has barely moved in the past decade.
  • Metro assumed that people would buy new cars more often, and scrap old cars more quickly causing average vehicle age to decline (get newer) by 25 percent, with average age declining from 10 years to 8 years.  Instead, average vehicle life has increased to almost 12 years.
  • Metro assumed most people would buy more small and efficient passenger cars, and fewer trucks and SUVs.  Metro assumed that lighter more efficient passenger cars would make up 70 percent of the market, outselling trucks and SUVs more than 2-to-1.  The opposite has happened:  the market for passenger cars has collapsed to less than 30 percent market share.
  • Metro didn’t make explicit predictions about vehicle electrification, but data from ODOT show that by 2029, no more than 3 percent of the state’s light duty vehicle fleet is expected to be electric.

4. Metro has a feeble and ever-shrinking goal for reducing vehicle miles traveled.

There are basically two ways to reduce greenhouse gas emissions:  Cleaner cars or less driving.  Metro policies have almost no influence on cleaner cars; in contrast, Metro’s policies, including land use planning, permitting more road capacity, and assuring alternatives, like biking, walking and transit, can all influence the amount of driving.

It’s a bit of a simplification, but these two concepts can be reduced to two measures:  Grams of carbon per vehicle mile (cleaner cars), and vehicle miles traveled (less driving).  As discussed above, Metro’s RTP is overwhelmingly counting on “cleaner cars” as providing roughly 90 percent of the reduction in transportation GHGs through 2040, and counting on less driving to provide only about 10 percent of greenhouse gas reductions.

For any given level of pollution per mile, increases in vehicle miles traveled result in increases in greenhouse gas emissions.  Transportation planners focus on “vehicle miles traveled per capita” to measure the level of driving in a metropolitan area.

Metro’s initial plan, the 2014 Climate Smart Strategy, set a goal of reducing per capita VMT by 20 percent by 2035.   As presented in the original Climate Smart Strategy, Metro identified a goal of reducing VMT per capita by 20 percent from 2010 levels, from 20 miles per person per day to 16 miles per person per day. (This is from page 65 of Metro’s 2014 Climate Smart Strategy).

In the 2018 RTP, Metro changed the yardstick and twice moved the goalposts on VMT reductions.  First, it changed the yardstick, measuring  VMT per capita in a much narrower way (looking only at miles traveled by regional residents inside the metropolitan planning area).  The new yardstick looked at a base of 13 miles per person per day, compared to 20 miles per person per day.  This new system of measurement excludes looking at about one-third of all vehicle travel in the Portland region.

Second, it retroactively changed the reported goals for the Climate Smart Strategy, lowering the baseline level of travel to 19 miles per person per day, and raising the 2035 “monitoring target” to 17 miles per day.  So while the as published 2014 Climate Smart Strategy visualized a 20 percent reduction in VMT from 20 to 16 miles per day; the 2018 RTP reported that the Climate Smart Strategy envisioned only about a 10 percent reduction in VMT, by two miles per person per day, from 19 to 17 miles.

Third, the 2018 RTP presented the 10 percent reduction as a goal, but then substituted the new yardstick (i.e. 13 miles per person per day in the base year, now 2015, and pushed out the terminal year for reaching the new goal of 12.4 miles per person per day to 2020.  2018 RTP (Chapter 7 “Outcome Measures”) and Appendix J “Climate performance monitor”).


But while Metro proclaimed as its goal reducing vehicle miles traveled by 10 percent, the plan’s analysis concluded that the measures included in the RTP would only reduce driving by a fraction of that amount by 2040.  The climate analysis contained in the 2018 RTP called for reducing VMT by 10 percent per capita, but the performance monitoring report in Appendix J of the 2018 RTP concludes that full implementation of the RTP would result in a decrease of more than 5 percent, “not reaching the target.”  The actual figures shown in the report (a decline from 13 miles per person per day to 12.4 miles per person per day) amounts to a 4.6 percent decline in VMT per capita.

Elsewhere, the RTP concedes that the plan will reduce per capita VMT by about 4 percent.

The reductions in vehicle miles traveled anticipated in the 2018 RTP are far smaller than needed to comply with LCDC regulations guiding climate planning.  Metro would need to achieve VMT reductions of about 20 percent per capita to comply with these guidelines.  The projected 4 percent decline in VMT/capita envisioned in the 2018 RTP is less than one-fourth the progress needed to meet the state guideline.  In addition, as explained in Appendix B, the state target  for VMT reduction is far too low to achieve the state’s greenhouse gas emission reduction requirements because state and local agencies have dramatically over-estimated likely progress in reducing vehicle emissions.

Actual Performance Compared to Metro Goals

To evaluate the VMT goal, it is necessary to put the vehicle miles traveled per person per day statistic in context.  Metro, using data from the Federal Highway Administration has produced a data series showing historical VMT per capita for the Portland area going back to 1990.

Vehicle Miles Traveled, a core measure of transportation activity, which has been trending down since the late 1990s, has essentially stopped declining. In the decade before the Climate Smart Strategy was adopted, Portland area VMT per capita was declining at a rate of about 1.2 percent per year. The Climate Smart Strategy failed to even plan for continuing that trend; according to Metro’s own estimates, since 2014, VMT per capita has almost flat-lined, declining just 0.15 percent per year.  The 2018 RTP has even lower expectations, lowering VMT by just 4.6 percent over the 25-year period from 2015 to 2040, which works out to an annual decline of  0.2 percent per year.  

Metro’s 2018 RTP predicts that the agency’s policies will produce a far slower rate of VMT reduction that the region accomplished over the period 2004-2013 (prior to the adoption of the first Climate Smart Strategy).  The 2018 RTP lowers the VMT reduction goal set in the 2014 CSS by more than 75 percent, from a 20 percent reduction over 25 years to a 4.6 percent reduction.  That’s not enough of a reduction in driving to meet the targets called for in LCDC regulations, nor is it enough to achieve the state’s goal of reducing greenhouse gas emissions to 25 percent of their 1990 levels by 2050.

Summary of Metro Area VMT Reduction Performance and Goals

5. Transit Ridership, a key factor in reducing GHG, is failing to meet projections.

One key strategy to reduce greenhouse gas emissions is to shift trips from private automobiles to mass transit.  Metro’s regional transportation plan calls for reducing vehicle miles traveled and decreasing greenhouse gas emissions by increasing the share of the region’s trips taken by bus and light rail.  Each successive regional transportation plan since 2004 has projected that transit ridership levels under the plan will double in the next ten to twenty years.  

Metro’s transit ridership projections have been grossly overstated in every Regional Transportation Plan, and TriMet’s operating plans show it has no intention (or ability) to carry as many passengers as the RTP assumes in order to make progress.  The RTP assumes transit ridership will more than double between 2015 and 2040, from 250,000 originating riders to more than 600,000 originating riders, which shows no signs of happening.  Even prior to the Covid pandemic, transit ridership was falling, down 7 percent from its peak in 2012.  Rather than growing at more than three and a half percent per year—pre-pandemic—ridership has been declining at about one percent per year.


Every RTP has consistently predicted high levels of transit growth that have not materialized.  The 2004 RTP predicted 2020 ridership would be 383,000, the 2010 RTP predicted 2020 ridership would be 349,000, the 2014 RTP predicted ridership in 2020 would be 326,000; actual ridership (as noted) is about 250,000 (pre-Covid).

The consistent failure of the region to realize the gains in transit ridership called for in the last four RTPs suggests that we will need to do much more to reduce VMT and greenhouse gasses.  It also suggests that Metro’s transit ridership model is biased and inaccurate.

6. Approving more highway capacity would increase greenhouse gas emissions

Even though its climate plan is failing, Metro is giving the Oregon Department of Transportation the greenlight to spend billions of dollars expanding area freeways that are likely to lead to huge increases in greenhouse gas emissions. The RMI induced travel calculator, calibrated based on award-winning, peer-reviewed research from the University of California, Davis, estimates that the Rose Quarter Freeway widening project will produce an addition 40,000 tons of greenhouse gasses per year and the revived Columbia River Crossing will likely produce a further 100,000 tons of greenhouse gasses per year.

The Induced Travel Calculator shows that revived Columbia River Crossing project (now rebranded as “I5 Bridge Replacement Program“) would produce an additional 155 to 233 million miles of travel annually, leading to burning an additional 11 million gallons of gas.  That in turn  would translate into additional annual greenhouse gasses of about 100,000 tons (at roughly 20 pounds of CO2e per gallon of gas).


The same calculator shows that the proposed widening of I-5 at the Rose Quarter will likely produce 60 to 90 million additional vehicle miles of travel per year, lead to burning about 4 million additional gallons of gas per year, and generate about 40,000 tons of additional greenhouse gases.

7. Metro isn’t pursuing pricing, which has been proven to be effective

Metro has taken no action to implement any of the pricing options that its own research rates as “highly effective” in reducing greenhouse gas emissions, including road pricing, gas taxes, vehicle miles traveled fees, parking charges and pay as you drive insurance. It’s gone out of its way to gainsay effective pricing measures, and used its public relations budget to promote false claims about vehicle idling.

One key reason for the increase in driving since 2014 has been the significant decline in oil and gasoline prices.  Metro’s model, calibrated based on behavioral responses to the earlier higher prices, and the assumption that declining prices wouldn’t affect demand for travel, have failed to predict the increase in driving.

8.  Metro has done nothing to fix its failing climate strategy

In spite of the failure to advance its goals, Metro has proposed no new or stronger measures to reduce GHGs, even though its climate smart initiative says it will do so.  Metro’s 2014 Climate Smart Strategy (on page 1) promised to periodically check to see whether progress was being made toward the goals it laid out.  If further promised:

If the assessment finds the region is deviating significantly from the Climate Smart Strategy performance monitoring target, then Metro will work with local, regional and state partners to consider the revision or replacement of policies, strategies and actions to ensure the region remains on track with meeting adopted targets for reducing greenhouse gas emissions.

Similarly, the 2018 RTP (Appendix J) makes the same commitment on page 10.

The data from DARTE show that Metro is plainly not meeting the initial greenhouse gas reduction goals set in the initial Climate Smart Strategy, nor is it on track to meet the much watered-down goal laid out in the 2018 RTP.  Similarly the “fleet and technology assumptions” built into both the CSS and the RTP have been proven wrong.  Yet the Metro has not acknowledged either of these basic facts, nor has it proposed any additional steps to reduce current high levels of greenhouse gasses to get them back on track.  Instead, it is going along with proposals from the Oregon Department of Transportation to spend billions widening area highways—which will add to Metro area greenhouse gasses.  (As explained in Appendix B, both the Land Conservation and Development Commission and the Oregon Department of Transportation have likewise failed to acknowledge increasing transportation greenhouse gas emissions, and have failed to update their incorrect modeling assumptions, and to revise policy targets, as both have committed to in their plans and regulations).

Appendix A.  Sources, Data and Methodology

Metro’s description of its climate strategy is taken from the 2014 Climate Smart Strategy and the 2018 Regional Transportation Plan.

Data on Portland area transportation greenhouse gasses are from the DARTE national transportation greenhouse gas emissions inventory, which contains estimates covering the years 1990 through 2017 at a very fine geographic scale.  DARTE is the most comprehensive and uniform national estimate of local transportation greenhouse gas emissions. We report DARTE data for Clackamas, Multnomah and Washington counties, the geography most closely corresponding to the Portland “metropolitan planning area” used in Metro’s 2018 RTP.  For purposes of comparison, we factor up Metro’s figures by 18-20% (depending on year) to be directly comparable to the larger geography of the DARTE database.

We compute emission reduction trajectories needed to meet state greenhouse gas requirements, and trajectories implied by Metro’s plans by computing a constant annual (negative) growth rate—or “glide slope”—needed to move from base year to final year emissions levels.  For example, in 1990, Portland area transportation GHGs were 5.7 million tons; a 75 percent reduction from that level (to meet the state goal) implies a 2050 level of emissions of 1.4 million tons.  To reach that level from 2013 actual emissions of 6.0 million tons requires a reduction of 3.8 percent per year for each year from 2013 through 2050.  We compute glide slopes for other plans (ODOT’s STS; Metro’s RTP) in the same fashion.

The 2018 RTP contains two conflicting estimates of how much reduction the plan will actually provide.  Chapter 7 of the RTP says that the 2015 level was 13 VMT per capita per day, and that the plan would reduce this to 12.3 VMT per capita per day by 2040.  The Climate Smart Appendix to the report, Appendix J, says that the 2015 baseline level was 12.7 VMT per capita per day, and would be reduced to 12.3 VMT per capita per day by 2040.  Chapter 7 figures imply a 4.6 decline in VMT by 2040; Appendix J implies the decline will be only 2.3 percent.  We assume that the correct level of VMT in the base years is 13 VMT per person per day, corresponding to a 4.6 percent decline in VMT by 2040.

Appendix B:  Metro and State incorrect assumptions about cleaner vehicles

Guided by state rules, Metro’s emissions modeling assumes “cleaner cars” through a combination of improved fuel economy (higher MPG standards), faster vehicle turnover (replacing dirty old cars with cleaner new ones), and smaller, more efficient vehicles (more cars, fewer trucks and SUVs).  None of these assumptions have been realized in the time since Metro and state climate plans were published.

1. Fleet fuel economy has not measurably improved.  Modeling for the climate smart initiative assumed rapid and prolonged improvements in vehicle fuel economy, due to rising federal fuel economy standards.  But the impact of increased new car standards on actual levels of real-world fuel efficiency have been modest.  Here is the data on actual average fuel economy through 2019. Average fleet economy was about 22.2 miles per gallon in 2019, far short of the targets set in the Metro modeling.

2. Average vehicle age is 50 percent older than assumed modeling.  According to the Bureau of Transportation Statistics, the average age of an automobile in the United States is now 11.9 years, up from 10 years in 2004.  The Metro Climate Smart Plan assumed that the average age of a vehicle would decline by about 25 percent, from 10 years to 8 years; instead, the average age of a vehicle has increased by almost 20 percent, from 10 years to almost 12.  The average vehicle today is now 50 percent older than assumed in the Metro climate plan.

3. Trucks and SUVs are displacing passenger cars, not the other way around.  A critical assumption in the Climate Smart Plan and the RTP is that consumers would buy more and more passenger cars, and fewer trucks and sport utility vehicles.  In fact, the opposite has happened:  since 2015—when sales of cars and SUVs/Trucks were roughly equal—it’s now the case that truck/SUV sales account for roughly 75 percent of all new vehicle sales.

4. Vehicle electrification is occurring very slowly
.  Many like to assume that electric vehicles will quickly and easily reduce carbon emissions.  Yet electrification is happening too slowly and on far too small a scale to materially affect transportation greenhouse gas emissions. ODOT’s October 2019 revenue forecast predicts the size and composition of Oregon’s light duty vehicle fleet through 2029.  They forecast that in 2029 Oregon will have about 3.9 million light duty vehicles, but only about 120,000 of them (total) will be electric vehicles.  That’s just 3 percent of the fleet; 97 percent will still be internal combustion engines.  The slow adoption of electric vehicles, as depicted in ODOT’s official revenue forecasts, means the agency believes that its efforts to promote EVs won’t have a significant effect on the state’s greenhouse gas emissions any time in the next decade, at least.

5. State forecasts of future vehicle emissions have been proven wrong.  A critical part of any transportation greenhouse gas emission strategy is assumptions about the improvements in the cleanliness of future vehicles.

Metro’s climate planning is based, in part, on rules adopted by the State Land Conservation and Development Commission (LCDC) directing metropolitan planning organizations around the state to work toward complying with the state’s adopted greenhouse gas emission goals.

In 2017, LCDC produced a report detailing its analysis of how these planning organizations were to plan for reducing transportation-related greenhouse gas emissions.  As directed by the Legislature, the planning process was to give local planners guidelines on the proportion of reduction in greenhouse gasses that could be expected from changes in vehicle efficiency and electrification.

LCDC based its rules on emission reduction assumptions taken from the Oregon Department of Transportation’s 2012 State Transportation Strategy (STS).  LCDC constituted a technical committee and retained Brian Gregor (formerly of ODOT) to prepare a technical analysis, drawing on the STS to estimate how much reduction in greenhouse gasses could be expected from improving technology and changing vehicle mix.  Gregor’s analysis predicted that vehicles would become dramatically cleaner over the next several decades, with a reduction in greenhouse gasses per mile traveled of more than 80 percent by 2050.  Gregor’s analysis concluded that LCDC should assume that emissions per vehicle mile would decline by 67 percent by 2035, the terminal year for local land use plans.  Importantly, LCDC wrote Gregor’s assumptions about future vehicle emissions into its administrative rules (OAR 660-044-0020).

Gregor’s analysis assumed that average vehicle emissions would decline to about 90 grams per mile by 2050.  Gregor reached these conclusions by assuming that fuel efficiency and zero emission vehicle regulations would steadily improve new vehicle emissions, and that over time, these would change overall fleet emissions. The report assumed that average vehicle age would be 11 years, and that  average fleet vehicle economy in any year would be equal to the average new car fuel economy for vehicles sold 11 years earlier.  Gregor’s calculations imply a base level of emissions of about 520 grams per mile in 2005.  New cars would be assumed to achieve 100 grams per mile in 2035, and the fleet as a whole would achieve 100 grams per mile in 2046, and about 90 grams per mile by 2050. Gregor summarized his assumptions in this chart:

As Gregor writes:

Average vehicle emissions rates would need to decline by a little over 4% per year from the 2010 estimated average in order to achieve the recommended level in 2050.

It is now 2021, and we have roughly a decade of data on the actual rate of improvement in new vehicle emission rates.  According to the Environmental Protection Agency, average emissions for new light vehicles have fallen from about 450 grams per mile in 2005 to about 348 grams per mile in 2021.  By Gregor’s approach, at that rate of improvement, average fleet efficiency in 2032 (eleven years from now) will be about 348 grams per mile.  In the past decade (2010 through 2021), the number of grams per mile has declined at about a 1.1 percent annual rate.  This is roughly only one-fourth the rate of improvement assumed in Gregor’s calculation and LCDCs target rules.

The following chart shows the difference between Gregor’s estimate of the path of vehicle emissions (blue), and the actual improvement in emissions between 2010 and 2021 (green).  The red dashed line shows the trend in vehicle emissions based on the 2010 to 2021 growth rate of -1.1 percent per year extended through 2050.

At current rates of improvement, per mile emissions are likely to be almost three times higher in 2050 than forecast in Gregor’s model, i.e. almost 300 grams per mile, rather than less than 100 grams per mile.

Achieving a reduction in greenhouse gas emissions is driven by the combination of cleaner vehicles and less driving.  If vehicles become cleaner at a slower rate, then bigger decreases in driving (VMT/capita) are needed to achieve state goals. Gregor creates an equation showing how these factors determine the expected reduction in emissions.

Gregor estimates that we need to reduce per capita emissions to 28 percent of base levels (i.e a 72 percent reduction).  He assumes that cleaner vehicles will do the lion’s share of this work.  His assumed 66 percent reduction in the rate of emissions per mile, means miles per capita need to be reduced about 20 percent.

The much lower rate of improvement in cleaning up vehicle emissions that we’ve actually experienced means that proportionately more of the task of reducing greenhouse gasses will need to be met, per Gregor’s own methodology, by reducing vehicle miles of travel. At the current rate of improvement of vehicle emission reduction, in 2035, the average vehicle will still emit about 336 grams per mile, just a 25 percent reduction from base levels.  In order to meet the state’s target of reducing per capita emissions to 28 percent of base levels by 2035, that means per capita vehicle miles of travel need to fall by 66 percent.  (The following table uses Gregor’s Equation 2 to compute the needed “target” level of VMT reductions consistent with various rates of improvement in vehicle emissions).

As show in the final line of the table, even if the annual rate of improvement doubles from its current rate to 2 percent per year from now through 2035, we would have to reduce vehicle miles traveled per capita by more than 50 percent.

In effect, the dramatic shortfall between Gregor’s 2016 report, and the actual 1.1 percent improvement in GHG/mile is the combined effect of the factors described in this section (a heavier, truck and SUV oriented fleet, slow improvements in fuel efficiency, slower vehicle turnover and slow electric vehicle adoption.

LCDC and ODOT have failed to re-examine their policies in light of forecast errors

It is difficult and uncertain to make reliable and accurate projections about the future.  That is why analysts typically couch their predictions in terms of the assumptions made to produce them, and why policies and reports relying on such forecasts frequently promise to revise their estimates as more and better information becomes available.

It’s important to note that Gregor’s predictions are based only partially on current law or policy, and rely heavily on assumptions that federal and state governments will devise, adopt, implement and enforce a whole series of new and more stringent policies to reduce vehicle emissions.  Gregor’s report made it clear that assumptions about improving vehicle economy were based on optimistic speculation about future federal and state policy.

The members on the Core Tech Team from the Departments of Environmental Quality and Energy agreed that the STS “trend line” is a reasonable reflection of goals that California, Oregon, and other states participating in the multi-state ZEV standards wish to achieve. They caution, however, that this planning trend does not reflect recent trends in vehicle fuel economy. Substantial efforts on the part of states and the federal government will be necessary to make this planning trend a reality. [Emphasis added].

A footnote on page 30 of the report makes this point even more clearly:

It is important to note that these ‘trend lines’ represent the trend in the model results given the vehicle assumptions in the STS recommended scenario. They do not represent an extrapolation of past trend. [Emphasis added].

The LCDC report relying on Gregor’s estimates implicitly acknowledges the need to update these forecasts as better information becomes available.  The LCDC goals were developed over several years from 2011 through 2016; The final rules were revised from earlier drafts explicitly because of the availability of additional information on vehicles and vehicle emission rates.  LCDC elected to tie its estimates of vehicle emission rates to those in ODOT’s STS for consistency with state efforts, and so that as the STS was updated, so too would be expectations about local targets.

If the STS is adjusted to account for changing assumptions to vehicles, fuels, and technology, the targets can be similarly adjusted to compensate for the updated assumptions.  (page 9).  [Emphasis added].

However, while the responsible state agencies (ODOT and LCDC) acknowledged the need to change targets as new information became available when targets and the STS were first prepared a decade ago (in 2011 and 2012), they’ve done little since to respond to new information.  ODOT prepared its first STS Monitoring Report in 2018 and found that progress on fleet, fuels and vehicle technology was much less than what it had forecast in the STS in 2012, and as a result that the state was way behind in meeting emissions goals.  Since that finding ODOT has done nothing to either revise its estimates of future vehicle emissions rates to reflect this new information or, more importantly, identify actions needed to get the state back on track.  Instead, ODOTs Monitoring Report obliquely concludes that unspecified state policy-makers will need to decide what to do next.     

LCDC’s decision to tie its targets to the STS—a decision which at least promotes consistency—means that ODOT’s failure to update the STS means LCDC policy remains based on outdated, inaccurate estimates until ODOT chooses to update the forecasts in the STS—something not on ODOTs schedule, despite Governor Brown’s Executive Order which directs the agency to do everything in its power to implement the STS.  LCDC has also failed to follow its own administrative rules which require it to re-appraise the validity of the emissions assumptions on which the rules were predicated:


Review and Evaluation of Greenhouse Gas Reduction Targets

(1) The commission shall by June 1, 2021, and at four year intervals thereafter, conduct a review of the greenhouse gas emissions reduction targets in OAR 660-044-0020 and 660-044-0025.

(2) The review by the commission shall evaluate whether revisions to the targets established in this division are warranted considering the following factors: . . . 

(e) Additional studies or analysis conducted by the Oregon Department of Transportation, the Department of Environmental Quality, the Oregon Department of Energy or other agencies regarding greenhouse gas emissions from light vehicle travel, including but not limited to changes to vehicle technologies, fuels and the vehicle fleet; [Emphasis added].

ODOT’s own STS monitoring report concedes that vehicle technologies, fuels and the composition of the vehicle fleet are not changing as anticipated in the STS, making the assumptions underlying LCDC’s rules invalid.  LCDC (and ODOT) have both ignored data from “other agencies”—in this case, the US Department of Energy, sponsor and publisher of the DARTE transportation greenhouse gas database—showing that Oregon greenhouse gas emissions have increased, rather than decreasing, as called for in both agency’s plans, and state statute.


Drive-thrus are ruining cities and helping kill the planet

Your 12 ounce latte comes with a pound of carbon emissions, just from the drive-thru.

How convenience for cars makes cities less livable for everyone, and contributes to climate change.

Last week, twitter user Maris Zivarts posted this telling image of 20 car queue wrapping around the block of a Starbucks, all lined up to go through the store’s drive-thru.  It shows how the store’s driveway and parking lot taking up vastly more space than the store itself, and how the backup from the drive-thru window spills out onto adjacent streets, creating congestion and a safety hazard for others.

As Zivarts observes, 20 people showing up at a coffee shop on foot, by bike or transit is no problem.  The same 20 headed for the drive-thru window is a disaster.  It’s clearly a blight on the neighborhood as well.

And more than that, it’s bad for the environment.  Those cars idling while they wait in line are burning gasoline and creating pollution, including greenhouse gases.  How much, you might ask?  Well, we’ve studied queueing and service at coffee shops before (to create our Cappuccino Congestion Index), so we have a pretty good handle on this.  We would estimate that the average wait would an average of and ten minutes to handle all the cars in a queue like this.  (This assumes that the store can produce an order about every 30 seconds).

The US Department of Energy tells us that a typical large US car burns about a third of a gallon per hour at idle.  A gallon of gas produces about 20 pounds of carbon when burned.  So that means that in ten minutes of idling would produce about a pound of carbon (10/60 * 20 * .33 = 1.1).  So, in addition to their twelve-ounce latte, each customer is producing another 16 ounces or so of carbon to be added to the global total, just from the time spent idling in their car, waiting to be served their coffee.   And, of course, this doesn’t count any of the emissions from driving to and from the coffee shop to get served, which by the same math works out to about another pound per mile.

Louisville’s financial disaster: Deep in debt for road capacity that will never be used

Louisville’s I-65 bridges:  A huge under-used roadway and hundreds of millions in debt for their kids—who will also have to cope with a climate crisis.

Their financial plan kicked the can down the road, saddling future generations with the cost of paying for unneeded roads.

The two states mortgaged future federal grant money and borrowed against toll revenues, which are falling dramatically short of projections.

Louisville’s Ohio River Bridges are a monument to the epic policy, financial and generational failure that is the US highway system.  Ohio and Indiana spent more than a billion dollars on doubling an interstate highway bridge, that thanks to very modest tolls, is utilized at less one-fourth of its capacity.  Meanwhile, through a series of “creative” financial maneuvers, it passed the bill for the highway onto future generations, who, as it turns out will have to actually pay for the bridge at the same time the climate crisis hits in full force.  The almost empty freeway bridges show the folly of “asphalt socialism”—wasting vast amount of public resources on roads that their users don’t value enough to pay even a fraction of their cost.

Earlier, we wrote about one aspect of the I-65 bridge project in Louisville.  It turns out that just by charging a $1 to $2 toll, Kentucky and Indiana were able to entirely eliminate traffic congestion on I-65.  Traffic plummeted from around 130,000 vehicles per day to about 60,000.  Now, even at the rush hour, I-65 is almost empty.


I-65 crossing the Ohio River at Louisville


And after the tolls went into effect, traffic on I-65 fell by half.  Here’s the average daily traffic count on I-65, according to data tabulated by the Indiana Department of Transportation.  In the years just prior to the tolling, traffic was in the 135,000 to 140,000 vehicles per day level.  But as soon as tolling went into effect, traffic dropped to barely 60,000 vehicles per day (with a very slight further decline due to Covid-19 in 2020).


While there’s a hopeful lesson here—one that highway engineers are studiously avoiding—that road pricing can eliminate congestion, there’s a financial horror story that should be a warning to everyone thinking about highway expansion projects.  The two states spent over a billion dollars on doubling bridge capacity in downtown Louisville, and their financial plans show how through combination of cynicism, incompetence or saddled future generations with the cost of this boondoggle.

Ostensibly, the justification for widening the bridges was the notion that traffic was already too congested and was growing rapidly.  The project’s environmental impact statement claimed that the I-65 bridges were “over capacity” in 2012, and predicted that traffic would grow from 120,000 vehicles per day to more than 180,000 by 2025, leading to hours and hours of traffic delay.

The trouble with these forecasts is that they were both simple-minded and wrong, especially given the need to pay for this project—in part—by actually charging the users for a portion of its construction cost.  Like so many state highway department predictions, this one was flat out wrong—traffic was nearly flat-lining on I-65 before the project was built.

State DOT traffic forecasts were wrong

Surely, you must be thinking, the state DOTs knew that charging a toll would reduce traffic.  Before the project was completed, Kentucky and Indiana hired consultants—CDM Smith and Steer, Gleaves, Davie—to estimate future toll revenues from the project.  CDM Smith predicted that future traffic levels on newly expanded and tolled I-65 bridges would be 92,000 vehicles per day in 2020, growing to 102,600 in 2030..  That was a dramatic over-estimate.  Actual traffic levels in 2019 (i.e. the year prior to the pandemic) were just 62,000 vehicles per day.  Whereas CDM Smith predicted that tolling would produce about a 27 percent decline in traffic from pre-tolling levels, the imposition of tolls actually led to a 50 percent decline in traffic.  CDM Smith overestimated the amount of toll-paying traffic that would cross the I-65 bridge by 50 percent.  The direction and magnitude of that error is all too common in toll traffic forecasts, and has led to defaults and bankruptcies for other tolled projects.

Creative Finance:  Sending the bills to future generations.

Tolls are only paying for a small fraction of the costs of the project.  Both states borrowed substantial sums. Kentucky borrowed deeply to pay for its share of the project, using “Garvee” bonds—essentially mortgaging future federal grant money—to the tune of $300 million in principal repayment and $138 million in interest payments.  In addition, Kentucky’s tolls are pledged to pay of both Kentucky revenue bonds of $272 million and a Federal TIFIA loan of $452 million.  The debt service for these two borrowings is back-loaded, i.e. is very low in the first few years of the project, but then steadily escalates.

This back-loading means the financial plan for the I-65 bridges project essentially sends the bill to the region’s future residents.  Essentially, Kentucky has borrowed most of the money to construction the project and arranged for a loan with a series of “balloon payments,” in later years.  Kentucky “back-loaded” the repayment of principal on both its own revenue bonds and its borrowings from the federal government’s TIFIA program.  It pays interest-only or just a token amount of the principal for these loans in the first few years, and then required payments steadily escalate in later years.  Debt-service obligations start at less than $10 million per year, and then balloon to more than $80 million annually in the early 2020s.

In theory, the escalating repayment can be met by growing toll revenues, from some combination of toll rate increases and growing traffic.  Toll rates have increased steadily at 2.5 percent per year, but as the traffic counts show, volume has flat-lined.  The artificially low repayments in the first few years of the project create the illusion that toll revenues are sufficient to cover debt service payments, but as required payments steadily escalate over the next few years, the Kentucky will find it increasingly difficult to meet its repayment obligations.

This looming mountain of debt service obligations has already prompted Kentucky to refinance part of its debt, essentially kicking the can further down the road for repayment of the cost of the I-65 bridges.  The refinancing plan essentially doubles down on earlier back-loading strategy, borrowing more money now to make these payments, and extending the period for repayment further.  Instead of paying off its “first tier revenue bonds” in 2045, they’re extending the term of the repayment by 8 years, to 2053.  And like the initial borrowing, these refunding bonds are mostly “interest-only” for the next 25 years, with nearly all of the principal being repaid after 2045.  As a result, the borrowers will pay almost as much in interest charges ($182 million over the life of the loan) as they pay in principal ($192 million).

Traffic on I-65 will never get back to pre-tolling levels

Whether toll revenues will be sufficient to repay these bonds hinges on whether you believe the latest forecast from Kentucky’s consultant, Steer & Company, prepared as part of the latest re-financing plan.  This new forecast now predicts  that total annual transactions (the number of vehicles using the project) will increase from about 30 million today to about 48 million by 2053.  What this means is that the I-65 bridges will effectively never recover to the level of traffic they had before the crossing was widened.  Currently, as noted above, the bridges are carrying about 60,000 vehicles per day.  The latest Steer forecast is that traffic will increase from that level by about 60 percent over the next three decades (48 million = 1.6 x 30 million).  This means that in 2053, the bridges will be carrying about 96,000 vehicles (which, ironically, is about the same level that the other toll consultants, CDM Smith predicted for 2020 in the projections that were originally used to justify project financing).  On the following chart, the red line is the FEIS traffic forecast for I-65, the black line is the actual level of traffic according to INDOT, and the blue line is the growth in traffic forecast by Steer & Company for the refinancing plan).


Comparing these new refinancing estimates with the rosy projections used to justify the project in the first place show the profound gap between highway boosters and reality.  The project was sold based on an environmental impact statement forecast that in the “no action” scenario (with just the single six-lane Kennedy Bridge), traffic on I-65 across the Ohio River would grow to 178,600 vehicles per day, exceeding its “capacity” by 142 percent.  This estimate implies that the capacity of the 6 lane Kennedy Bridge was 125,000 vehicles per day.  (As traffic expert Norm Marshall has shown these “over-capacity” estimates amount to forecasting the impossible, but neatly serve the interests of highway advocates).

Doubling the size of the I-65 crossing was needed, according to the project’s supplemental EIS in order to assure that the project could carry about 185,000 vehicles per day when completed:

Specifically, the combination of new bridges in the Downtown and Far East corridors would result in the Kennedy Bridge operating at 74 percent of capacity in 2025.

With a capacity of 250,000 vehicles per day (double the 6-lane Kennedy Bridge), the 74 percent of capacity implies a forecast level of travel of 185,000 vehicles per day in 2025.  Now, based on the impact of tolling, it’s doubtful that the bridges will ever carry more than a third of their designed capacity, and the much lower level of traffic on I-65 predicted for the 2050s shows that the project was a colossal blunder, wasting a billion dollars.  It’s a blunder that future Louisville area residents will be paying for—for decades to come.




Oregon DOT’s Real Climate Plan: Keep on polluting

The Oregon DOT’s “Climate Action Plan” claims that the agency wants to decrease greenhouse gases, but its financial plans show otherwise

The agency’s revenue projections show it is planning for gasoline consumption not to decline at all, meaning that carbon emissions don’t decline

ODOT’s fuel tax projections imply that cars and trucks will continue to produce about 19 million tons of greenhouse gases through then end of this decade, an amount 60 percent larger than consistent with achieving the Governor’s greenhouse gas reduction goals.

ODOT has used these fuel consumption projections to convince private investors to buy bonds to be repaid from future gas tax revenues; the financial projections, not the climate PR, represents the agency’s real position.


The Oregon Department of Transportation is telling anyone who’ll listen about their supposed deep concern about climate change, and all the actions they’re taking to reduce greenhouse gas emissions.  It’s a splashy PR campaign, with a newly minted “climate office” and a “fig leaf” logo.

But that’s not the real story.  The real story is told, not in the agency’s PR documents, but in its financial plans and projections.  It’s told in the byzantine “official statement” it provides to bond markets.  That real story is that the agency is planning on Oregon’s transportation system continuing to emit just as much greenhouse gases for the next decade as it does today.  Its financial plans hinge on Oregonians buying, and burning enough gasoline and diesel into the 2030s to produce nearly 20 million tons of CO2 a year—roughly 20 percent more than was emitted in 1990, and nowhere near the state’s official target of cutting greenhouse gas emissions by 80 percent by 2050 (and far below interim targets established by Governor Brown).

Oregon Governor Kate Brown’s  climate emergency order calls for reducing greenhouse gas emissions by 45 percent from 1990 levels by 2035; ODOT is counting on fuel consumption that will produce greenhouse gas levels of 19.4 million tons in 2030; nearly 20 percent higher than in 1990, and 70 percent higher than the amount needed to be on track to meet the Governor’s stated goal.

This department’s revenue forecast belies claims that any of the actions it’s hoping for, including electric vehicle adoption or more efficient internal combustion vehicles will do anything in the next decade to reduce Oregon’s transportation greenhouse gas emissions.

ODOT predicts we’ll continue buying and burning 1.7 billion gallons of taxable motor fuel every year, through 2030.  This coupled with other transportation fuels, in turn, will produce 19.4 million tons of greenhouse gases annually through 2029.

Here’s ODOT’s latest (April, 2021) forecast of quarterly taxable motor vehicle fuel sales.  (This doesn’t include sales of diesel fuel for large, over the road trucks which pay the state’s weight-mile tax).  As you can see, these quarterly figures show long term consumption of motor fuels stabilizing at a bit more than 440 million gallons per quarter (about 1,760 million gallons annually) through the remainder of the decade.

Source:  Oregon Department of Transportation Revenue Forecast, April, 2021.

Burning gasoline and diesel fuel translates directly into more greenhouse gas emissions. It’s very straightforward to estimate the greenhouse gas emissions that result from burning a gallon of gasoline.  Each gallon of gas, when burnt, produces 8.87 kilograms (almost 20 pounds) of CO2.  That means burning 1.75 billion gallons of gasoline will result in about 15.6 million metric tons of carbon dioxide (1,750,000,000 * 8.87).  Burning diesel fuels accounts for most of the rest of the 19.3 million in emissions (see further discussion of diesel fuel consumption, below).

The continued burning of all this fossil fuel is completely inconsistent with Oregon’s stated climate goals. As illustrated by the green line in our first chart, Governor Brown’s Executive Order 20-04 implies a much more rapid and dramatic decline in greenhouse gases, and therefore, fossil fuel consumption. This same point has been made by the Oregon Global Warming Commission, which has sketched out the path to meeting the state’s 2050 goal of reducing greenhouse gases to no more than 20 percent of 1990 levels.  (See the yellow dashed lines).

It’s worth noting, as we’ve pointed out before at City Observatory, that the most effective means of reducing gasoline consumption (and greenhouse gases) was higher fuel prices.  Fuel prices which rose steadily from 2004 through 2008, and which remained high until 2014, had the effect of reducing Oregon’s total gas consumption by almost 10 percent.  When gasoline prices plunged by almost 40 percent in 2014, following the collapse of global oil prices, Oregon’s gasoline consumption surged from about 400 million to about 470 million gallons per quarter (seasonally adjusted).  This was the principal reason that the state saw big increases in greenhouse gas emissions from transportation over this time period.

Although it doesn’t explicitly say so, presumably these official ODOT forecast reflect the net effects of improving vehicle efficiency, increasing numbers of electric vehicles, and ODOT’s much vaunted “operational improvements” (i.e. electronic sign boards along highways).    What ODOT’s official revenue forecasts are telling us is that the agency fully expects us to be generating just as much greenhouse gases from driving in 2030 as we are today; indeed, the agency is counting on it, to pay its bills.

If the agency seriously believed in its climate strategy, then it would be planning for and predicting a steady decline in gasoline consumption, as we adopted more efficient vehicles, electrified and “made every mile count.”  But as its financial projections make clear, the agency has no faith that any of these measures will make any substantive difference to gasoline consumption (and therefore, greenhouse gas emissions).

Diesel Emissions

And gasoline-based CO2 emissions are just part of the puzzle.  The ODOT taxable motor fuels forecast exclude diesel fuel burned by vehicle subject to Oregon’s weight-mile tax, which is applied to heavy over-the-road trucks. The Oregon Department of Environmental Quality reports that these sources represent about 23 percent of transportation greenhouse gas emissions:

In addition to the health effects, combustion of diesel fuel is a significant source of greenhouse gas emissions. Transportation accounts for approximately 40 percent of all statewide greenhouse gas emissions in Oregon. This represents the largest source of emissions and a source that has seen increased emissions in recent years. While heavy-duty trucks and buses, which typically are fueled by diesel, only account for four percent of vehicles on the road nationally, they are responsible for nearly 25 percent of total transportation sector greenhouse gas emissions nationally, and 23 percent in Oregon. Emissions from trucks are one of the fastest growing sources of greenhouse gas emissions, and the number of truck miles traveled on the nation’s roads is projected to continue to grow significantly in the coming decades.

In its 2018 inventory, DEQ estimates that burning distillate fuels (of which diesel is the bulk), account for about 7 million tons of greenhouse gases per year; equal to about 50 percent of the amount generated by burning gasoline in cars.

ODOT also has a prediction for these weight-mile taxes, which suggests that they, too will not decrease materially between now and 2030.  That means that greenhouse gas emissions from diesel trucks will also not materially decline.  ODOT predicts that weight-mile transactions will stabilize at 2019 levels through 2025 and then increase thereafter (Figure 18).  In short, ODOT is saying that diesel truck emissions will likely remain at or above their current levels indefinitely.

And, no EVs will not save the day; By 2030, only 3 percent of Oregon vehicles will be electric, according to ODOT

The favorite dodge of highway apologists is to argue that electric vehicles will obviate the need to reduce driving at all.  Never mind that the production and operation of electric vehicles isn’t zero carbon, best estimates are that life-cycle emissions from building EVs and their batteries and charging them will produce about 30 to 50 percent of the emissions of greenhouse gases as cars.

But ODOT doesn’t expect electric vehicles to be more than a token part of the fleet in the next decade. The agency’s October 2019 revenue forecast predicts the size and composition of Oregon’s light duty vehicle fleet through 2029.  They forecast that in 2029 Oregon will have about 3.9 million light duty vehicles, but only about 120,000 of them (total) will be electric vehicles.  That’s just 3 percent of the fleet; 97 percent will still be internal combustion engines.  The slow adoption of electric vehicles, as depicted in ODOT’s official revenue forecasts, means the agency believes that its efforts to promote EVs won’t have a significant effect on the state’s greenhouse gas emissions any time in the next decade, at least.

There’s a naive and wrong-headed argument going around among highway apologists, arguing that they don’t need to worry about climate change because vehicle electrification will somehow solve the problem.  These data show that won’t happen fast enough, and in all likelihood won’t happen at all, as we continue to burn 1.7 billion gallons of taxable motor fuel a year in Oregon.

Financial projections show ODOT’s real priorities:  More greenhouse gas pollution

As Upton Sinclair observed, “It is difficult to get a man to understand something, when his salary depends on his not understanding it.”  What ODOT is saying, implicitly, is that their salaries depend on continued massive production of greenhouse gases.

In simple financial terms, ODOT is counting on—is planning on—Oregonians not doing anything to significantly reduce their consumption of fossil fuels between now and 2030.  Its plans to pay for building new highways are based on the assumption that we reduce total fuel consumption by no more than a few percent in the next decade–at exactly the time when scientists (and our adopted climate plans) tell us we need to be making the most progress toward preventing climate catastrophe.

There’s a striking contrast between the precise and hard-nosed projections of ODOT’s revenue forecast (they’re counting on us buying and burning 1.7 million gallons of taxable motor fuel every year through 2030), and the vague, PR-infused, fuzziness of Oregon DOT’s Climate Action Plan.  Part of this plan is an “Every Mile Counts” initiative, which, despite its name, doesn’t actually include any counts of vehicle miles traveled, any hard plans for reducing VMT, or any specific goals for 2030.  Instead, it’s just a vague exhortation to maybe, if you’d like, drive a bit less.  But there’s no serious plan to make that happen.

If you read the fine print of the agency’s climate plan, it’s also clear that their real priority is getting more money and building more roads.  The climate plan contains no stated goal for reducing greenhouse gas emissions from transportation (or VMT), but does specify as goals, assuring the agency has plenty of revenue and can keep building roads.

The agency’s real plan is reflected in its revenue forecast.  ODOT is planning to spend billions widening highways, and is counting on us to buy just as much fossil fuel through the next decade as we’re buying now.

If you want to know what ODOT really cares about, and the future it’s really planning for, don’t be taken in by the gauzy and performative claims to care about climate, look at the agency’s financial plans.  Money talks, and at ODOT it’s effectively saying, “we’re going to do nothing to significantly reduce greenhouse gases in Oregon, and we’re going to keep spending money to widen roads and encourage people drive more.”

Disobeying the Governor’s climate order

Oregon DOT’s financial plans show that the agency has no intention of even trying to comply with Governor Kate Brown’s Climate Emergency Order.

In 2020, the Governor ordered state agencies, including ODOT, to develop plans to reduce emissions to 45 percent below 1990 levels by 2035.  According to DEQ, Oregon’s 1990  greenhouse gas emissions from transportation fuel consumption were 16.1 million tons.  That implies that by 2035, the state’s total emissions from transportation fuels should be no higher than roughly (.55 * 16.1) 8.9 million tons.  The pathway or glide slope required to reach that level of emissions requires roughly a 4.9 percent annual decrease in from 2018 through 2029.  This glide slope implies that in 2029, emissions would need to be just under 12 million tons to be on track to meet the 2035 goal.

ODOT’s forecast makes it clear that through 2029, emissions from light duty cars and trucks (not to mention all other sources of transportation emissions, such as railroads, ships and aircraft) will be 60 percent greater than that amount—19.3 million tons.

Section 4(c)(2) of the executive order makes it clear that the 45 percent reduction applies separately to transportation fuels (e.g. gasoline and diesel fuel); the Department of Environmental Quality is directed to come up with rules that will achieve these reductions separately for transportation fuels.  Agencies like ODOT can’t claim that they’ll be able to pollute more because other sectors of the economy will somehow make even larger reductions in greenhouse gas emissions.

In effect, ODOT is keeping two sets of books:  Except that one set of books, doesn’t actually have any hard information, just vague and unverifiable claims about values and a lot of noble intent.  The real books—the ones with dollars and cents—and millions and millions of tons of greenhouse gases locked-in—are hidden in plain sight.  And the agency’s climate plans make no mention of how inconsistent the agency’s real financial plan is with its purported climate goals.  It’s a fraud and deception, pure and simple.

Appendix:  Transportation Fuels and Greenhouse Gases in Oregon

As noted, Oregon DOT forecasts taxable motor fuels sold and weight-mile transactions (a proxy for total weight mile truck volume) through 2029.  Motor fuels, when burned, produce greenhouse gases.

We’ve estimated average transportation emissions from gasoline and diesel in Oregon based on the historic relationship between the ODOT taxable motor fuels volume estimate and the DEQ annual transportation sector greenhouse gas estimate for on road gasoline and diesel fuel consumption.  On average,between 2004 and 2019, the consumption of 1,000 gallons of taxable motor fuel (as estimated by ODOT) was associated with an estimated 11.07 metric tons of transportation fuel carbon dioxide (as estimated by DEQ).  We apply this relationship to ODOT’s 2021-2029 projections to estimate greenhouse gases associated with transportation fuel consumption.

These figures likely underestimate CO2 emissions, inasmuch as ODOT projects weight-mile activity and associated diesel heavy truck emissions to increase faster than taxable motor fuels activity through 2029.  In addition, it’s worth noting that the DEQ sector estimates are considerably lower than those used in the evaluation of Oregon’s Clean Fuels Program (CFP).  The CFP requires that gasoline and diesel fuel in Oregon be blended with ethanol and biodiesel to reduce the total carbon content of fuels burnt.  The methodology used to calculate emissions under the CFP is a “well-to-wheels” metric, that counts all of the carbon emissions associated with production, refining and transport, as well as combustion, as opposed to the EPA factor which is a “tank to wheels” metric, counting just the carbon from combustion.  The CFP well-to-wheels emission factor is about 12.3 kilos of carbon per gallon of conventional gasoline, compared to the EPA “tank-to-wheels” emission factor of 8.78 kilos of carbon per gallon of conventional gasoline.  If the “well-to-wheels” approach is actually correct, this may mean that current estimates used by DEQ in its sector inventory substantially understate the relative contribution of transportation fuels to Oregon’s greenhouse gas emissions.

ODOT’s forecast only explicitly included taxable motor fuel sales, i.e. gasoline and diesel fuel used to power cars and light and medium sized trucks.  Sales of diesel fuel to larger over the road trucks is exempt from this tax, as these trucks pay the weight-mile tax instead.

The Oregon Office of Economic Analysis computes the carbon intensity of gasoline and diesel sold in Oregon under the Clean Fuels program.  It estimates that the total net effect of the program has been (which blends 10 percent ethanol with conventional gasoline, and a similar amount of biodiesel with conventional diesel), is to reduce greenhouse gas emissions from fuel consumption by an aggregate of about 5 percent, based on a “well-to-wheels” analysis.  The potential for increasing biofuels is limited; nearly 90 percent of gas-powered vehicles on the road today can only burn a maximum of ten percent ethanol.  Increasing ethanol production would have serious negative environmental impacts.

ODOT forecasts that taxable motor fuel sales in 2029 will be 1,751 million gallons.  That’s slightly more than the average fuel consumption for the years 2004 through 2019 (about 1,723 million gallons per year).  DEQ estimates that total transportation emissions from motor gasoline and distillate fuel (chiefly diesel) were about 19.6 million tons in 2019, about 22 percent above their 1990 level of 16.1 million tons.  The following chart shows estimated carbon emissions from motor gasoline and diesel fuel in Oregon, grown at the rate of increase of taxable motor fuel sales, for the period 2021 through 2029, per the ODOT Forecast.

Editor’s Note:  Thanks to Daniel Porter of ODOT and Michael Kennedy of OEA for sharing in spreadsheet form the data contained in their estimates.  This commentary revised on December 13 to correct a the percentage by which estimated 2029 emissions will exceed the amount needed to achieve the reductions called for in Governor Brown’s Executive Order.

The Week Observed, December 17, 2021

What City Observatory did this week

The financial fallout from Louisville’s I-65 boondoggle.  As we showed earlier, Kentucky and Indiana both wasted a billion dollars on doubling the capacity of I-65 across the Ohio River, and also showed how to eliminate traffic congestion.  The $1 to $2 tolls it charges I-65 users slashed traffic in half, and led to essentially none of the expensive new capacity they built being used.  But tolls don’t cover anywhere near the cost of building the widened crossing.  The two states borrowed heavily against future federal grants and hoped for toll revenues, as well as pledging their own resources.

They used creative finance to “backload” the repayment of the debt–keeping payments artificially low in earlier years–hoping that higher tolls and more traffic will bail them out. Already, it’s clear that strategy is failing–traffic is so far below projections, that Kentucky has had to refinance its debt, extending the period of repayment by almost another decade, and adding tens of millions of additional interest cost.  The latest projections show the I-65 crossing will never carry as much traffic as it did before it was widened, and that future generations will be paying off the project’s debt, even as they increasingly suffer the consequences of climate change.

Must read

1. House Bill would force states to address transportation emissions.  The fate of the “Build Back Better” legislation is very much in the balance.  The Washington Post examines one of the bill’s key provisions would create incentives for states to spend federal transportation dollars in ways that reduced greenhouse gas emissions.  State highway departments bristle at the thought, arguing that climate change isn’t their responsibility–notwithstanding the fact that transportation is the largest source of greenhouse gas emissions in the nation.  Their efforts to dodge responsibility prompted the Center for American Progress’s Kevin DeGood to comment “It is farcical to suggest that state DOTs do not deeply influence greenhouse gas emissions from the transportation sector.”

The Post’s story highlights the growing grassroots recognition that transportation is a huge, and largely unaddressed aspect of the climate crisis.  In Portland, young climate activists have been protesting at the headquarters of the Oregon Department of Transportation, calling for an end to freeway widening to save the planet.  The Post quotes 15 year old Adah Crandall:

“As a high-schooler, my peers and I shouldn’t have to be spending our time organizing against freeway expansions because we’re worried about the climate impact. That’s pretty ridiculous,” she said. “I feel a responsibility to do that because I’m afraid of the decisions that will be made if we don’t keep showing up.”

2. Are Seattle’s affordable housing fees resulting in fewer townhouses?  For the past several years, Seattle has been implementing its Mandatory Housing Affordability (MHA), which requires most multi-family developers to either dedicate a portion of their units to low or moderate income households, or pay a fee.  A new report from a group of smaller scale developers in Seattle claims that the fee has eliminated most new townhouse construction in the city.

Townhouse under construction — The Seattle Times)

Townhouses, which are often duplexes, are the kind of gentle density that creates somewhat more affordable housing in expensive cities like Seattle.  The fact that developers have to pay the average $32,000 per unit fee up front, prior to construction, is especially onerous.  In theory, the MHA program gives developers a “density bonus” allowing them to build more square feet of housing than under prior zoning rules, but for townhouses, the economic value from adding a fourth walk-up floor on a townhouse doesn’t necessarily offset the cost of the fee. The group points out that townhouse permit applications have fallen 67 percent in the past two years.  Fewer townhouse units being constructed means even more competition for the existing housing stock, which is likely to make the city’s affordability problems even worse.

3. Austria stops building freeways.  Greens formed a coalition government with conservative parties in Austria, and bargained for key cabinet positions, including the transportation portfolio.  The new minister for transportation announced that henceforth, the country will stop expanding road capacity as a means of meeting its greenhouse gas reduction obligations. “More roads mean more cars and more traffic,” Transport Minister Leonore Gewessler told the AFP news agency.

New Knowledge

Price elasticity of demand for travel.  How much do changes in prices, especially the price of fuel, matter to how much, and by what modes people travel?  That question is one of the microeconomic keys to understanding urban travel demand, and not incidentally, to addressing climate change.  A new paper from University of Florida economist Javier Donna sheds new light on the answer, using a novel and detailed methodology aimed at overcoming the problems with earlier estimates.  His key finding:  in the long run (periods more than a year) travel behavior is much more responsive to gasoline prices and previously estimated.  Donna reports that with respect to gas prices, travel is elastic:  a one percent change in gas prices generates more than a one percent change in automobile travel.  This suggests that pricing can be a much more powerful and effective tool than previously thought.

This is not the first study to estimate price elasticity of demand for travel–there’s actually a substantial literature.  But many of these estimates are confounded, ironically, by the high volume of data about gas prices.  Gas prices fluctuate on a weekly and sometimes daily basis (usually driven by fluctuations in the global oil market).  Travel behavior responds to prices, but individual consumers/travelers face what economists call “switching costs”–for example, if you’re a regular car driver, riding the bus requires learning the bus schedules and routes.  In the face of minor and frequent ups and downs in gas prices, consumers exhibit considerable inertia, and its usually the case that only fairly large and seemingly permanent (or at least long-lasting) price changes prompt many people to change behavior.

What that means as a practical matter is that simple-minded statistical measures that simply look at the gross correlation between weekly fuel prices and vehicle travel volumes find only a modest (in economic terms “inelastic”) effect on travel patterns.  The short term noise tends to obscure finding any long term effects, and, as with most economic goods, elasticities are greater in the long-run than the short-run.

Donna’s paper constructs and calibrates a model that explicitly incorporates switching costs.  It uses data gathered in the Chicago area from 2001 through 2009, to look at how shifts in gas prices influence demand for travel (measured by the volume of cars on Chicago area roads and transit ridership).  For comparative purposes, Donna also constructs two other models that mimic the structure of earlier modeling efforts (myopic and static) to show how his more complex and realistic dynamic modeling produces different results. The key estimates are shown below.

Donna estimates that the elasticity of travel with respect to gas prices is about .5 in the short run and about 1.3 in the long run.  This means a 10 percent increase in gas prices is associated with about a 5 percent decline in travel in the short run, and a similar increase is associated with about a 13 percent decrease in travel in the long run. These measures are for permanent or sustained increases in prices, not daily or weekly fluctuations.  The the “long-run dynamic” estimate–the one that matters most for policy–is considerably higher than the estimate from either the myopic or static models (which fall into the range of estimates produced by other studies.

Donna’s paper suggests that prices can an even more important role in supporting good transportation policy than previously thought.  His finding that travel demand is actually elastic with respect to price (a one percent increase in gas prices decreases driving by more than one percent), means that pricing will change travel behavior, a fact, unfortunately, that many transportation planners are simply in denial about.  Perhaps, no longer.

Javier D. Donna, Measuring Long-Run Gasoline Price Elasticities in Urban Travel Demand”, RAND Journal of Economics, forthcoming, and

Donna, Javier D., Measuring Long-Run Gasoline Price Elasticities in Urban Travel Demand (May 10, 2021). Available at SSRN:

In the news

Willamette Week featured our analysis of Oregon Department of Transportation financial plans showing the agency has no expectation of complying with the state’s greenhouse gas reduction goals.
StreetsblogUSA re-published our commentary on Oregon DOT’s duplicity around climate.

The Week Observed, December 10, 2021

What City Observatory did this week

1. ODOT’s real climate strategy:  Pollution as usual.  Oregon’s highway builders are keeping two sets of books, one claiming that it cares about climate issues, the other shows that its financial plans depend on never reducing greenhouse gas emissions.  The Oregon Department of Transportation has a glossy, highly promoted and hopelessly vague “climate strategy,” replete with statements of concern, palliative suggestions and a green fig-leaf logo.  But the agency’s true plans are reflected in its budget and financial documents.  The agency’s revenue forecast shows that its planning for—and counting on—burning just as much gasoline, and creating just as much greenhouse gases at the end of this decade as it does now.

These financial projections—which ODOT presents to bond markets as evidence of its best estimate of future conditions—show that Oregon transportation emissions won’t decrease at all through 2029, and will fall vastly short of the greenhouse gas emission reductions pledged by Governor Brown and mandated by state law.  These financial projections show that this agency is cynically keeping two sets of books when it comes climate:  one, for public consumption that pretends to care, and a second set, that reflects its real intent to continue polluting as usual.

2. Drive-thru restaurants are making cities less livable and killing the planet.  Drive-thru’s for restaurants, coffee shops, banks and other retail establishments are some of the most city-soul crushing infrastructure imaginable.  They take up space, create a desolate and pedestrian hostile environment, and cement car-dominance.  And more than that, idling while waiting to pull up to the window and receive your order produces pollution.  We estimate that your twelve ounce latte, dispensed at a drive-in window generates as much as a pound of carbon.

Must read

1. Our self-imposed scarcity of nice places. Strong Town’s author Daniel Herriges nails it in this essay:  our urban problems in the US stem from a profound shortage of nice places, a problem that is almost entirely self-inflicted:  We’ve made it illegal, through zoning, lot setbacks and by making urban spaces safe for cars, to build the kinds of places American’s most prize (dense, interesting, walkable, mixed use neighborhoods).  The fact that such neighborhoods are so rare makes them expensive:  They’re prized and in short supply, which tends to drive up their prices.  Herriges:

In fact, our shortage of nice places is almost totally self-imposed. And it’s precisely because 98% of the North American built environment is so blah that the 2% of places that are really well-designed environments quickly get bid up by the rich and become inaccessible to the rest of us. The solution to this isn’t to stop creating such places, but to create vastly more of them.

And that correlation between great urban places and high prices has gotten so fixed in the mind of many that there’s a tendency to equate neighborhood improvement with gentrification.  The irony, of course, is that many of today’s great urban neighborhoods were originally constructed as middle class working man’s housing; it’s only because it’s not possible to build more such housing today that such places are unusual and therefore expensive.  The solution to our affordability problems is to legalize dense, mixed use urban neighborhoods so that everyone has access to them.

2. More cycling would reduce traffic congestion, lower greenhouse gas emissions, improve health and create jobs.  A study of London looked at the likely impacts from raising that city’s cycling mode share from its current 2 percent to 14 percent.  It found that this would generate a number of benefits, creating more local jobs in the cycling sales and service.

 It would also reduce car driver trips by around 4 billion vehicle km by 2030 and associated greenhouse gas emissions by nearly 680,000 tonnes. This increase in cycling will produce wider economic benefits of the order of £4.8 billion by 2030. As well as bikes replacing car passenger trips, cargo and e-cargo bikes have the potential to replace up to 7.5% of van mileage by delivery and service companies, and associated carbon, pollution and congestion. A cycle mode share of 14% by 2030 would also create over 25,000 additional green jobs. . .  and these are jobs that can be created quickly.

Rather than building more freeway capacity, if cities were to invest in more cycle infrastructure, more shared cycle systems, and incentives for e-bikes, they’d make vastly greater progress in reducing greenhouse gases, and making cities healthier, more prosperous and more livable.

New Knowledge

Parking and transportation behavior:  A natural experiment.  We’ve long know that the shape of the built environment (density, transit access, parking availability) influences travel decisions.  But simply observing that people in say, denser neighborhoods walk, bike or take transit more often than others isn’t necessarily compelling that density is a cause; it could just be that people who like to walk, bike and ride the bus choose to live in denser neighborhoods.

The research gold standard for ferreting out the cause-and-effect connections between such phenomena, is the randomized trial.  In general, it’s hard to do randomization, but a housing lottery for affordable apartments in San Francisco provided just such a random pool for researchers to study.  Thousands of people entered the lottery for these newly built units, and were assigned randomly to apartments with varying housing and neighborhood characteristics (density, transit access, available parking spaces, etc).  Researchers surveyed these lottery winners about their travel habits to estimate how different aspects of the built environment of each apartment correlated with travel patterns.

Their core finding amplifies the work of Donald Shoup:  The price and availability of on-site parking had the largest observable effect on car ownership.   The car ownership rate for households living in buildings with no on site parking is less than half what it is for apartment buildings with one or more parking space per unit–the standard required by zoning in many communities.  

They conclude that parking is a powerful, and under-appreciated policy lever for improving transportation and livability in urban settings:

Our findings suggest that the potential for fewer private automobile trips is large and does not depend on car-free households relocating to car-free buildings, or on people who like to ride transit moving to transit-rich neighborhoods. We show that household decisions on car ownership and travel depend on transit accessibility and walkability, but even more so on parking supply. . . . Where streets are relatively walkable and transit service is frequent, parking emerges as the key factor shaping household travel behavior — and parking is a factor that is highly amenable to low-cost policy reforms that can rapidly provide benefits.

The author’s also tackled another claim:  That those without easy access to parking (and therefore ability to commute by car) would be disadvantaged in pursuing employment opportunities.  The researchers found no correlation between parking availability and employment outcomes for survey participants.

Adam Millard-Ball, Jeremy West, Nazanin Rezaei, Garima Desai, “What Do Residential Lotteries Show Us About Transportation Choices? Actually, quite a lot., Transactions, Issue 8 | December 2021

In the news

At the Oregonian, Ted Sickinger writes that “Oregon will fail its climate goals if ODOT acts on big freeway projects.”  The article quotes City Observatory research documenting the Oregon DOT financial projects showing that the agency has no intent or expectation that its efforts will produce any reduction in transportation greenhouse gases through 2029, in violation of Governor Kate Brown’s environmental executive order.  Sickinger also notes that OregonDOT has simply ignored Governor Brown’s direction to evaluate road pricing as a way to avoid expensive, unnecessary freeway projects and to reduce greenhouse gas emissions.

Lloyd Alter, writing at, quotes Joe Cortright’s analysis of the positive health, safety and environmental impacts of higher gas prices in his story “Gas is too cheap.”

The Week Observed, December 3, 2021

What City Observatory did this week

How Portland powered Oregon’s economic success. After decades of lagging the nation, Oregon’s income now exceeds the national average. While some seem to think its a mystery:  It’s not.  It all about a flourishing Portland economy, especially in the central city of the region.  This success has been powered by an influx of talent, especially well-educated young adults drawn to close-in urban neighborhoods.

Income growth in Multnomah County accounts for essentially all of the net improvement in Oregon incomes relative to the nation over the past decade or more.  Rising incomes, especially in the city, have markedly reduced racial and ethnic income gaps. The secrets of economic success:  talent, quality of life, urban amenities, and knowledge industry clusters.


Must read

The inequity and economic irrationality of urban freeway construction.  In a precise and trenchant analysis for the Toronto Globe and Mail, Todd Litman eviscerates the economics and rationale for expensive urban freeways.  The province of Ontario is proposing to spend billions to widen major highways in the Toronto region, in the futile attempt to reduce congestion, which as Litman shows, can never be accomplished by adding more capacity.

Litman’s analysis cuts through to two key economic facts:  Wider urban roads cost vastly more than any of their users would willingly pay or their use.  As he points out:

Also, new highways are far more expensive than most people realize, typically costing tens of millions of dollars for each kilometre of lane. Considering land, construction and additional operating expenses, the cost-recovery price for additional highway capacity – the toll required to repay its incremental costs – is typically 50 cents to $2.00 per vehicle-kilometre, far more than what motorists pay in fuel taxes.

As we’ve pointed out at City Observatory, any time highway users are asked to pay even a small fraction of the costs of these roads, demand evaporates.  In a very real sense, the only reason people use new freeway capacity is because somebody else pays for it.  In the aggregate, freeway widening is a value-destroying proposition:  the costs of additional capacity exceed, by perhaps an order of magnitude the value the users place on capacity.  This is the real “equity” problem in transportation:  taxing everyone to provide a largely illustory benefit to a few.  Again, Litman:

As a result, projects such as Highway 413 represent a huge public subsidy to a relatively small number of future users. Although the Ontario government provides no economic analysis, these projects are likely to cost billions of dollars to build and benefit only a tiny portion of Ontario residents. Anybody who will not drive regularly on these new facilities should protest this inequity.

Freeways are still destroying urban neighborhoods.  The role that freeway construction played in destroying city neighborhoods, and especially the homes of people of color is oft-told, but it’s often treated as something that occurred in the distant past.  Writing the LA Times, Liam Dillon shows that the highway onslaught is ongoing, and that new and expanded freeways have wiped out tens of thousands of homes.

. . .  that widenings, extensions and other freeway construction continue to take a significant toll on communities even now.  More than 200,000 people have lost their homes nationwide to federal road projects over the last three decades, according to a Times analysis of federal transportation data. The actual total is higher because many states fail to report how many homes are taken annually.

It’s also worth remembering that the direct destruction of homes and businesses due to freeway construction is just the first effect.  The added volume of traffic makes these neighborhoods more polluted and less livable.  Academic research has shown that population loss continues for decades after freeway construction in urban neighborhoods.

New Knowledge

Subsidies for homeownership encourage sprawl and damage cities.  For decades, the US has offered generous subsidie to homeownership, and granted preferential treatment to new housing. These benefits have not flowed similarly to renters or to existing housing.  As a practical matter, the subsidies disproportionately benefit new suburban greenfield development (as has highway construction).  The result is that public policy is tilted highly toward sprawl.  A key component of this is the favorable tax treatment provided to homeownership.

The study takes advantage of a kind of natural experiment afforded by the repeal of a German homeownership subsidy in 2005.  Up until that date, homeowners could qualify for a special tax credit for the purchase of a home which provided, over eight years, a subsidy equal to about one-sixth the price of a home.  Because—as in the US—owner-occupied housing, especially newer units, is located in suburban rather than city locations, the availability of the credit pushed households to choose more suburban locations.  The authors show that when the credit was repealed, there was an immediate and noticeable re-centralization of population.

Germany’s cities have re-centralized conspicuously ever since the subsidy was repealed. Controlling for distance from the city center and for various fixed effects, population in every central ring (i.e. a ring among the third of rings closest to the center) grew by 5% between 2005 and 2017; while population in every peripheral ring (i.e. a ring among the two thirds of rings closer to the urban fringe) contracted by 2% over the same period.

The author’s estimate that repeal of the homeownership subsidy resulted in about 200,000 fewer housing units in suburbs and about the same amount of new housing in cities, over a period of a years.  Subsidies for homeownership, given the nature of the housing market, are anti-city.  This evidence puts the lie to claims about suburbs (and homeownership) representing the revealed preference of consumers.  Instead, it shows that public policies, especially the tax code, push people to choose suburban locations, and undermine cities.

Daminger, Alexander; Dascher, Kristof (2021) : Homeowner Subsidy Repeal and Housing Recentralization, Beiträge zur Jahrestagung des Vereins für Socialpolitik 2021: Climate Economics, ZBW – Leibniz Information Centre for Economics, Kiel, Hamburg

In the news

City Observatory’s Joe Cortright is quoted in the Oregonian’s story, “Oregon will fail its climate goals if ODOT acts on big freeway projects, environmentalists say,”  “