Oregon’s highway agency rigs its projections to maximize revenue and downplay its culpability for climate challenge

ODOT has two different standards for forecasting:  When it forecasts revenue, it says it will ignore adopted policies–especially ones that will reduce its revenue.  When it forecasts greenhouse gas emissions, assumes policies that don’t exist–especially ones that will magically make greenhouse gas emissions decline.

Revenue forecasts are “purely based on historical data” and don’t include adopted policies.  Greenhouse gas emission forecasts are based on “goals” and “wishes” and are explicitly not an extrapolation of past trends.

The inflated revenue forecasts are used to justify (and help fund) highway widening; the greenhouse gas emission forecasts are used to absolve the agency from any responsibility to reduce driving related greenhouse gas emissions.

As we’ve pointed out, the Oregon Department of Transportation keeps two sets of books when it comes to climate emissions.  It tells the public that it cares about climate and greenhouse gas emissions in its largely performative “Climate Action Plan,” but when it comes to the agency’s budget, it tells financial markets it’s counting on Oregonians burning just as much gas—and creating just as much carbon pollution—a decade from now as they do today.

ODOT’s officials have defended their revenue forecasts as being merely passive representations of current trends, unaffected and unfiltered by state policy objectives.  Somehow these actions that produce revenue are beyond either their control or responsibility.

But when it comes to the agency’s climate plan, they’ve gone out of their way to make highly speculative assumptions that all kinds of other actors—consumers, automobile manufacturers, the federal government and other state agencies—will make radically different decisions or implement entirely new policies that lead to reductions in greenhouse gases.

ODOT has a double-standard for forecasting—when it comes to forecasting climate, and especially establishing its responsibility for greenhouse gas emissions—it will make elaborate and speculative assumptions about other people doing things that will make the problem go away.  When it comes to estimating its own revenue (which it then uses to justify building new roadways and borrowing for more), it assumes that nothing will change and that it can safely ignore already adopted legal requirements to implement congestion pricing and limit greenhouse gases—both of which will reduce gas tax revenue.  It’s a deceitful, inconsistent and self-serving approach to forecasting.

ODOT Revenue Forecasts:  We assume nothing will change and ignore our own adopted laws.

Earlier, we pointed out that ODOT’s revenue forecasts are utterly at odds with claims it will reduce transportation greenhouse gas emissions, as mandated by state law, and directed by Governor’s executive order.  ODOT representatives defended their forecasts in the media by saying that the agency’s forecasting approach was merely to extrapolate existing trends, and that its forecasts were in no way a reflection of its policy objectives.

Here’s ODOT spokesman Don Hamilton responding to Willamette Week.

“ODOT revenue forecasts are based purely on consumer patterns and historical data,” says ODOT spokesman Don Hamilton. “They are not based on what we want to see.”

The forecasts also don’t take into account the reductions in driving that may come with “congestion pricing” or other ODOT initiatives, Hamilton says.

“As Oregon executes many of its climate-focused programs, we expect gas sales to decline, and we will revise our gas sales forecasts to reflect those changes as they occur.”

Oregon Public Broadcasting’s Dave Miller pushed the agency’s top planner, Amanda Pietz to explain the discrepancy:

Dave Miller: . . .  I want to focus on a new critique that I’m sure you’re aware of. It came about a week and a half ago from the frequent ODOT critic Joe Cortright, the economist. He put out a report digging into the agency’s estimates given to financial markets about expected gasoline tax revenues through the end of this decade. This was his summary: “What ODOT official revenue forecasts are telling us is that the agency fully expects us to be generating just as much greenhouse gasses from driving in 2030 as we are today. Indeed,” he wrote, “the agency is counting on it to pay its bills.” Amanda Pietz, how do you explain this?

Amanda Pietz: I think it goes back to the earlier statement I was making. When we do our revenue forecasts it’s often looking back at the trends then and projecting those forward without necessarily seeing some of the interventions take hold and create those changes.[Emphasis added].

Dave Miller: I’m slightly confused by that, and that jibes with what an ODOT spokesman said when there was an article about it this week in Willamette Week. But aren’t you supposed to give bond markets a projection that is as accurate as possible? If the whole point is [to say] “trust us, we’ve got revenue coming in, we can back these bonds and here’s our estimate for how the money is going to be coming in,” why don’t you factor in all the things you say you’re going to be doing so economic markets can know to trust you?

Amanda Pietz: Part of what is done when we look at things is [that] we have to rely on something very solid – a clear policy change, a solidified investment that’s been amended into our investment strategy in a way that’s very clear, it’s solid. I think what you’re seeing is an agency that’s recognized that we’re a contributor to the problem in the last year and [is] starting to make some changes and modifications. Now when those take hold and the degree to which they’re solidified [so] that we can roll them into our financial assumptions, my guess is another six months to a year before you start to see some of those. Another key example of that is DEQ has its Climate Protection program which will set limits on fuel sales that will have a big impact on that revenue forecast. That’s in draft form, not finalized. When that’s finalized, becomes implemented, and there’s clarity around what that looks like, that’s when it gets rolled into the financial assumptions. Similar things for us, too. I mentioned we’re investing over $50 million dollars in transportation electrification. We should see fuel sales drop as a result of that. Until we figure out exactly where we’re placing that, how we’re going to leverage with our private partners to put those in the right locations, [that’s when] we can factor that into our revenue forecast.[Emphasis added].

ODOT Climate Forecasts:  Wishes and speculation, including magical policies that don’t exist

When it comes to making forecasts about future automobile emissions, and whether the agency will need to do anything to curtail the growth of driving in order to achieve the state’s statutory greenhouse gas reduction goals ODOT has an entirely different approach to forecasting.  It makes heroic assumptions about things that might happen, if somebody else does them.  It pretends that policies that don’t exist will be adopted and aggressively implemented. And all of these assumptions are skewed in a very particular way, i.e. to reduce or eliminate any need for ODOT to take responsibility for cutting greenhouse gases from cars and driving in Oregon.

These assumptions are built into the State Transportation Strategy (STS), developed by ODOT to sketch out how Oregon might reduce transportation greenhouse gases in the decades ahead.  In a memo prepared for the Land Conservation and Development Commission, explaining the STS modeling, Brian Gregor, who was ODOT’s modeler, explained ODOT’s approach to estimating future greenhouse gas emissions from cars.

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 LCDC 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 contrast couldn’t be sharper:  when it comes to estimating an elevated level of future revenue, ODOT discounts anything that will reduce driving or pollution, and won’t even consider the impact of policies, like congestion pricing, which were approved by the Legislature in 2017.  But when it comes to optimistic speculation about technologies or policies that might lower future vehicle emissions—absolving ODOT of the need to act—the agency will definitely count on policies that haven’t been adopted by anyone.  It’s a clear and calculated strategy to avoid responsibility for doing anything to address climate change.

Clearly, ODOT’s current revenue forecasts are counting on the failure of the state’s climate efforts.  They’re assuring financial markets that Oregon will collection hundreds of millions of dollars in motor fuel tax revenues with which to repay bonds it will use to expand the state’s highways, encouraging and subsidizing more driving and greenhouse gas emissions.  It may seem like an arcane detail, but it’s the kind of technocratic climate arson that’s routinely practiced by state highway departments.