Earlier, we branded Portland Metro’s proposed Regional Transportation Plan (RTP) a climate fraud because in falsely claimed the region was reducing greenhouse gases, and falsely claimed its transportation investments were on track to meet adopted state climate goals. Metro’ staff has responded to these critiques, but  proposes only to fix these mistakes at some vague future time, and more importantly, make absolutely no substantive policy or investment changes to the RTP.
In essence, the staff response puts the lie to the claim that climate/GHG reductions are the “controlling measure” in RTP system planning.  Whether Metro is on track to achieve its committed GHG reductions or not has no bearing on any of the substantive policy and spending decisions in the RTP.
Moreover, this is a straightforward violation of the policies enacted in Metro’s 2014 Climate Smart Strategy (and reiterated in the 2018 RTP, and current RTP draft), to continuously monitor progress in GHG reduction and undertake additional measures if we were not making adequate progress.<
Metro staff treats GHG estimates as a perfunctory and irrelevant codicil to the RTP, and continues to rely on fanciful and speculative assumptions about the future vehicle fleet and an extraordinarily aggressive state pricing policy, to allow it to simply ignore taking any further steps to reduce GHG, or stop widening highways.

City Observatory recently published two detailed commentaries examining the climate analysis and policies contained in Portland Metro’s proposed Regional Transportation Plan (RTP).<
The RTP claims that the region is “on track” to reduce greenhouse gas emissions as required by state law, and that it can afford to spend more than ten billion dollars on highway widening projects and meet its stated climate objectives.
In reality, transportation greenhouse gases in Portland are increasing, not decreasing, illustrating the failure of existing climate policies; the models Metro uses to estimate future GHG reductions are flawed (based on demonstrably incorrect vehicle age and fleet composition assumptions), and the policies in the RTP do nothing to prioritize policies and investments that would actually reduce greenhouse gas emissions.

As part of its review process, Metro staff has prepared its rejoinder to these comments.  In this commentary, we show that Metro’s analysis ignores many of City Observatory’s  comments, mis-states others, and suggested changes do nothing to correct the deficiencies we identified.

For clarity:  both state law and adopted regional plans call for a significant reduction in greenhouse gas emissions.  Oregon law (ORS 468A.205) , and Metro’s adopted 2014 Climate Smart Strategy call for an 75 percent reduction in greenhouse gas emissions from 1990 levels by 2050.  The RTP fails to comply with these policies.

Metro:  “Yes, our climate analysis is wrong, but we’re not going to change our policy or spending”

The analysis contained in the RTP mis-states actual trends in greenhouse gas emissions from transportation (they are increasing, not decreasing), and falsely claims that the region is on track to meet that legislatively adopted goalMetro acknowledges City Observatory’s comment that it has failed to include accurate GHG inventory information in the RTP, and that transportation GHGs in Portland are increasing, rather than decreasing (as shown by DARTE, DEQ and Multnomah County inventories). It proposes, at some unspecified future time, to include more accurate information on transportation GHGs.<
Specifically Metro says it will “amend” its analysis at an unspecified future date and “discuss the potential impact of these trends on RTP achieving climate targets.” (Metro Staff Response to Comment #210).

Metro’s proposed changes to the RTP labeled “Climate Tools and Analysis”  makes it clear that this will not have any effect on the current RTP, and that corrected inventories and trend analysis will be deferred to an unspecified later date:

“use the updated assumptions as the basis of future climate analysis.”

Elsewhere, the RTP concedes that the region is not on track to meet its Vision Zero safety goals.  The RTP needs to have a definitive statement that the region is not on track to meet its climate goals, either.  And while that’s a necessary first step, the RTP must go further.

Admitting error, but doing nothing to fix it

The issue here is not simply whether the RTP contains correct emissions inventories and trend analyses; The actual issue is that Metro has falsely portrayed the progress (actually backsliding) on transportation emissions. The fact that emissions are increasing demonstrates that adopted measures since the 2014 Climate Smart Strategy are failing, and that much more powerful and effective steps need to be taken to achieve stated Metro and State climate goals. Metro needs to both correct its inventory data, and modify its policies and investments to achieve these greenhouse gas goals. It is not sufficient to simply admit we are going rapidly in the wrong direction; Metro needs to change course. Acknowledging that the inventories and trends are wrong, and doing nothing violates the policy commitment in the CSS to periodically adjust the strategy to reflect actual progress. If the RTP is not on a path to achieving climate targets then the policies and investments contained in the plan need to be changed.

The proposed changes in the “Climate Tools and Analysis” include no substantive changes to further reduce greenhouse gas emissions from transportation to compensate for the errors and false assumptions in the RTPs current climate analysis.


As City Observatory pointed out, the climate analysis of the RTP can be summarized briefly as claiming that because the overall RTP is “on track” to meet the 2050 goals, that there is no need or obligation to either prioritize projects and investments that reduce GHGs, or to analyze the GHG increasing impacts of projects, particularly highway expansions. The climate analysis contained in the RTP represents a fraud on the public. Despite labeling greenhouse gas reductions “a controlling measure” in system planning, the RTP fails to achieve adopted state and regional greenhouse gas reduction goals, fails to prioritize expenditures and policies that would put us on a path to reduce greenhouse gas emissions as it has pledged, and fails to strengthen its policies or change its investments in light of its demonstrated failure to achieve promised progress.  The climate analysis is not a “controlling measure” if major flaws in the climate analysis don’t immediately necessitate a revision to RTP policies and investments.

A double standard for pricing

As City Observatory has pointed out, road pricing (tolls, road user fees and congestion charges) are an essential component to achieving the RTP’s purported GHG reductions.  But Metro has a blatant double standard for pricing: It assumes that the state will achieve dramatic GHG reductions by enacting widespread pricing (a carbon fee, a very high road user fee, nearly universal congestion pricing on throughways), and yet it fails to incorporate the effects of those pricing measures on the need/justification for billions in highway widening projects. Pricing roadways will reduce or eliminate the need for capacity expansion.  For example, Metro ignores City Observatory’s comment noting that ODOT’s own analysis of Regional Mobility Pricing (RMPP) pricing would obviate the need for additional lanes in the $1.9 billion I-5 Rose Quarter project.

Metro also fails to analyze the negative greenhouse gas effects of major RTP projects. The blatant double standard in the RTP is obvious in the treatment of major capacity projects (the IBR, Rose Quarter and I-205 widening projects). As Metro has acknowledged, adding lane capacity will induce additional travel, and additional greenhouse gas emissions. The only aspects of these projects which moderate or reduce greenhouse gas emissions are the potential tolls that may be used to pay for them. Yet Metro’s RTP fails to acknowledge that tolling/pricing alone would be more effective in both moderating the growth of traffic and reducing GHGs, and would obviate the need for additional capacity. In that same vein, Metro ignores City Observatory’s comment that ODOT’s own analysis procedures manual denies the existence of induced travel and bars use of the scientifically based induced travel calculator.

Whether the state will actually impose high and widespread road pricing as as assumed in the STS and Metro’s climate analysis, or even imposes tolls, for example, on I-205, is still uncertain and speculative. But the RTP commits to building this additional capacity, regardless of whether these GHG (and traffic) reducing measures are actually implemented. An honest and accurate GHG analysis would also show what would happen to regional VMT, GHG and congestion if these speculative and uncertain pricing measures aren’t enacted.

In essence, the RTP pretends it will achieve state GHG goals because of the imaginary and speculative pricing policies described in the State Transportation Strategy (STS). In contrast, the RTP provides a regional commitment to spend billions on freeway widening, which—absent pricing—will certainly make our already bad transportation GHG trajectory much worse.

Hiding behind ODOT’s flawed policies and modeling

City Observatory’s analysis documented the significant deficiencies in the ODOT modeling used to predict future transportation greenhouse gas emissions, and also showed the speculative nature of assumed pricing policies. ODOT’s STS has Metro asserts that the RTP complies with state law and the Climate Smart Strategy because they are consistent with the state’s Climate Friendly and Equitable Communities (CFEC) regulations.

  1. CFEC compliance does not assure that either the Climate Smart Strategy goals or ORS goals are met.
  2. CFEC rules are the minimum required to comply with state land use laws. The state’s GHG gas reduction law and Metro’s own climate smart strategy predate and supercede the CFEC rules.
  3. Nothing in CFEC precludes Metro from doing more to reduce transportation GHG emissions; in fact, Metro’s own Climate Smart Strategy independently commits the region to a larger reduction in VMT and greenhouse gases.

It’s clear that Metro staff are trying to shift the blame for their flawed greenhouse gas analysis to their colleagues at the Oregon Department of Transportation, who developed the State Transportation Strategy (STS), and have prepared their own greenhouse gas estimates.

Failure to correct policies and investments is climate fraud

Metro’s adopted Climate Smart Strategy, adopted nearly a decade ago, committed to monitoring progress and taking additional steps if fell behind.  Metro pledged to monitor transportation greenhouse gas trends, and:

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.

While Metro has acknowledged that it has overstated progress, but is proposing no additional regional actions, no changes in policy, no different investment strategy, despite the demonstrable failure of its current efforts.
Metro staff’s response to comments confirms the toothlessness and irrelevance of the climate commitments in the RTP. The staff admits that the GHG analysis in the RTP is simply wrong—that it ignores trends of increasing transportation greenhouse gases, and that modeling is based on demonstrably flawed assumptions about fleet turnover and composition—and that this means that the region will definitely not meet its climate commitments. But then, in the staff’s view, these errors and failures necessitate no substantive change to the RTP; no imposition of new policies, no shift in investments. The climate analysis is not, in reality, “controlling” in any way of the RTP. Whether the RTP is on track to meet greenhouse gas reduction targets or not matters not at all to the policy substance or investment choices in the RTP. This is simply climate fraud.