Metro’s Regional Transportation Plan (RTP) claims it will meet state and regional climate objectives by slashing vehicle travel more than 30 percent per person between now and 2045.

Meanwhile, its transportation plan actually calls for a decrease in average travel of less than 1 percent per person.  Because population is expected to increase, so too will driving.

Rather than reducing driving, and associated greenhouse gas emissions, Metro’s RTP calls for accommodating more than 5 million additional miles of driving a day—a 20 percent increase from current levels.

The RTP climate strategy asserts the Portland area will drive 20 million miles a day and meet our greenhouse gas reduction goals.  But Metro’s transportation modeling shows the RTP is planning for a system that will lead to 25 million miles per day of driving.

This disconnect between Metro’s climate modeling, and the modeling it’s using to size the transportation system, and make investments violates state climate rules.

The Portland region is a self-styled environmental leader.  Oregon has a legislatively enacted goal to reduce greenhouse gases 75 percent from 1990 levels by 2050.  Metro, the regional government, adopted a “Climate Smart Strategy” in 2014, calling for taking steps to achieve that goal by reducing driving.  A new, federally required (and state regulated) “Regional Transportation Plan” is supposed to spell out how the region will manage its transportation system and spend its limited resources over the next couple of decades to stay on a path to achieve that goal and other regional priorities.

Unfortunately, the Metro region is nowhere close to achieving its climategoal, is actually headed in the wrong direction, and the new Regional Transportation Plan will likely make things worse.  As we previously documented at City Observatory, the RTP’s climate analysis left out the inconvenient fact that Portland area transportation greenhouse gas emissions are actually increasing, rather than decreasing as the plan assumed–indicating that our efforts are actually failing. In addition, the climate policies in the plan give a pass to a ten-billion dollar plus program of freeway expansion that will lead to more driving and more pollution.  That’s bad enough.

But there’s more:  A close look at the technical analysis that is the foundation for the RTP shows that Metro has two completely different sets of “books” for assessing transportation.  When it comes to demonstrating compliance with state climate laws and regulations, Metro has produced a set of projections showing we’ll hold total driving in the Portland area to its current level—in spite of increase population—by reducing per capita driving by almost a third.  But when it comes to sizing the transportation system—and in particular—justifying investments in added highway capacity, Metro has a second set of books, that assume per capita driving doesn’t change at all, and that as a result, we end up driving about 5 million miles more per day in the Portland area than assumed the climate analysis.  These two estimates are completely contradictory, and they mean that the Regional Transportation Plan doesn’t comply with state climate laws, and that if we actually followed through on our stated climate strategy of holding driving to its current level of about 20 million miles per day, we wouldn’t need to spend any more on expanding highway capacity.

Under state law and regulations, Metro has an affirmative legal obligation to monitor and report its performance—something it simply hasn’t done.  At the state’s land use regulator, the Land Conservation and Development Commission is required to review and approve their climate work and policy.  LCDC should reject the Metro climate plan and RTP as out of compliance with these state regulations, and send Metro back to the drawing board to produce a transportation plan that is consistent with professed climate goals and state law.

The key problem here is two sets of books:  An ambitious climate plan that would dramatically reduce average driving (and comply with state regulations), and a second set of books that is a “driving as usual” projection, that’s being used to fuel a highway spending spree.  The difference is 5 million miles a day—and vastly more carbon pollution.

Ambitious climate rhetoric:  We’ll reduce per capita driving 31 per cent compared to 2020 levels

Metro’s current RTP purports to put the region on a path to reducing greenhouse gas emissions by making investments in the transportation system that reduce driving.   And when it comes to its climate analysis, the RTP makes a bold claim that the region will cut driving by more than 30 percent from current levels.  The Climate Analysis (Appendix J, page 9) makes this claim:


But that’s the climate portion of the plan.

Reality:  We’re going to drive 20 percent more, and per capita driving will decline less than one percent

A separate portion of the report offers metro’s “system performance measures” for judging the overall operation and success of the region’s transportation system.  Here, the RTP uses its transportation demand model to estimate how much we’ll drive in the future under various scenarios.  These are the numbers that are used to select projects, estimate traffic delays, and guide investments.  And the picture here is very different.  According to this modeling, per capita driving in the Oregon portion of the metropolitan area will decline by just two-tenths of one percent from current levels.  And these performance measures indicate that the RTP investments make almost no difference in reduced driving:  the RTP “constrained” scenario, representing billions of dollars in spending, reduced driving by only one-tenth of a percent more below current levels compared to doing nothing.  Either way, the Metro performance measures suggest almost no change in per capita driving, and as a result, total travel in the region will increase by more than 5 million miles per day—making it that much harder to reach the region’s and the state’s climate objectives.

These data are contained in Appendix I:  Performance Evaluation Documentation

This duplicity is important, because in Appendix J, Metro has concocted an almost entirely fictitious scenario, in which the state government imposes very high per mile fees  fees on driving.  Metro’s climate analysis uses these assumptions to pretend per capita driving will decline sharply.  But the rest of the RTP makes no such assumptions; it plans for a world where we won’t charge drivers much more than they pay today, aside for some tolls, and that we’ll invest in big capacity expansion projects, like the Interstate Bridge and the I-5 Rose Quarter freeway widening.  In reality, as Metro’s performance measures report shows, the region has no intention or expectation of meeting state climate goals, and is going to continue building car infrastructure as if it were 1950, rather than to head off a devastating climate crisis by 2050.

As we pointed out, Metro uses its climate analysis, with its dubious assumptions, to assert that it doesn’t need to worry about the polluting effects of spending billions of dollars expanding highways.  It claims because we’ll only drive 20 million miles a day, we’ll meet state climate targets, and therefore there’s no need to even examine how much widening roads will increase driving.  But the agency’s own transportation modeling—which it uses to justify these expenditures, and select investments—is planning for a world where we drive 25 million miles a day, with arguably 25 percent more pollution, no matter how “green” vehicles are in 2045.

Make no mistake, Metro planners are really counting on their 25 million mile a day forecast.  They only include the 20 million mile projection as a fig leaf, to be able to assert that they’ll meet climate objectives.

If Metro really believed its climate forecasts, and planned accordingly, it would create a plan that provided for no increase in total driving in the region above today’s levels.  But they clearly have no intention of planning for such an outcome.  They—and the Oregon Department of Transportation—are pushing forecasts claiming we’ll drive vastly more miles and that congestion will only get worse, unless we do something—in this case, spend billions on expanded highways.

Having two completely inconsistent travel forecasts–really two sets of books–is effectively perpetrating a climate fraud.

Metro is failing to comply with state law showing it is making progress

Metro has had a climate plan for nearly a decade.  It adopted its Climate Smart Strategy in 2014, and at the time, as an integral part of that plan, pledged to monitor progress—i.e. whether its efforts were leading to the needed reduction in greenhouse gases.  Since then Land Conservation and Development Commission has adopted further rules that direct Metro to plan to achieve statewide climate goals, and again, periodically report on their progress.

OAR 660-044-0060

(1) Metro shall prepare a report monitoring progress in implementing the preferred scenario including status of performance measures and performance targets adopted as part of the preferred scenario as part of regular updates to the Regional Transportation Plan and preparation of Urban Growth Reports.
(2) Metro’s report shall assess whether the region is making satisfactory progress in implementing the preferred scenario; identify reasons for lack of progress, and identify possible corrective actions to make satisfactory progress. Metro may update and revise the preferred scenario as necessary to ensure that performance targets are being met.
(3) The commission shall review the report and shall either find Metro is making satisfactory progress or provide recommendations for corrective actions to be considered or implemented by Metro prior to or as part of the next update of the preferred scenario.

Metro’s Regional Transportation Plan fails to demonstrate whether the region is making progress, and makes no effort to say that it is making “satisfactory progress.”  In fact, emissions inventories show that actual greenhouse gas emissions from transportation have increased by between 1.4 percent and 5 percent per year since 2014.

When presented with these facts, Metro’s only response is kicking the can down the road—saying it will revisit this entire subject in its next Regional Transportation Plan (to be adopted in 2028).  That fails to comply with OAR 660-044-0060, which requires the progress report do gauge progress as of now.

Instead of acknowledging the failure of current actions, and proposing stronger and more effective policies, Metro has simply chosen to embrace a new set of assumptions that we’ll make even faster progress by the adoption or enforcement of as yet un-enacted policies in future years.

Metro acknowledges that it is wrong about current GHG trends, but isn’t making any substantive changes to the current Regional Transportation Plan.  Instead, it says it will use the updated as the basis of “future climate analysis.”  In its response to comments made on the RTP dated October 18, 2023, Metro staff says it will:

2. Update RTP climate assumptions in Chapter 7 and Appendix J to:
a. Describe which state assumptions are required to be used in the RTP climate analysis and why.
b. Document state assumptions in more detail, including a table describing key state assumptions (e.g., vehicle fleet turnover rate, share of SUV/light truck vs. passenger vehicles, share of electric
vehicles), as well as current trends with respect to these assumptions and discussions of state policies, programs or other actions the state is taking to support the state assumptions used in the RTP climate analysis.
c. Describe that the region will not meet its targets if the state assumptions used in the analysis are not met, along with the results of the RTP 23+AP scenario, which quantifies how much the region falls short of its targets if the Statewide Transportation Strategy (STS) assumptions are not included in the analysis.
d. Describe current trends in GHG emissions, both in the region and state, and nationally, based on DARTE and other inventory sources.
e. Use the updated assumptions as the basis of future climate analysis.

Part 1 to Exhibit C to Ordinance No. 23-1496
MTAC Recommendation to MPAC on Key Policy Topics, October 18, 2023
(Emphasis added)

These changes to the RTP do not put the document in compliance with OAR 660-044-0060:  They do not include the required status of performance measures, they do not identify whether the region is making “satisfactory progress”—it isn’t: transportation greenhouse gases are increasing when the plan said they would be decreasing—and it doesn’t explain why we’re not making progress or identify actions that would be corrective.  Instead, Metro has in effect, deferred all of these obligations until the next update of the RTP (scheduled for 2028).  And, notably, Metro is not proposing to do anything to reconcile the conflicting assumptions about future vehicle travel in its environmental analysis (Appendix J), with the 25 percent increase in vehicle travel it says it is planning for in its transportation plan (Appendix I).  As we’ve said:  This is a “Don’t Look Up!” climate plan.

As a result of these failings, the Metro RTP isn’t in compliance with OAR-044-0060, nor is it in compliance with Metro’s own adopted Climate Smart Strategy (which similarly pledged to report progress in reducing emissions, and take additional steps as needed).  As shown above, the RTP has two separate sets of books and actually contemplates a future where total vehicle miles traveled in the Portland area expands by 20 percent—completely inconsistent with achieving climate goals, and exactly the opposite of what Metro asserts in its claims that it is complying with state law.