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Highways & Climate Change

Questions and Answers

Click on the questions below to find more information on highways and climate change.

  1. How could State DOTs and MPOs integrate climate change considerations into their transportation planning processes?
  2. What State requirements are there on GHG analyses for transportation plans, programs, and projects?
  3. Does FHWA have examples of GHG analyses for transportation projects and programs?
  4. What was the 9th Circuit Court decision in Center for Biological Diversity v. National Highway Traffic Safety Administration (2007)?
  5. What tools and methods are available to analyze GHG emissions from transportation sources? What can the tools do well and what are their limitations?

  1. How could State DOTs and MPOs integrate climate change considerations into their transportation planning processes?

    Climate change should be addressed in the planning process from both a mitigation and an adaptation perspective. The broad geographic scope and time scale of the planning process makes it an appropriate place to consider GHG emissions and the effects of climate change.

    SAFETEA-LU Section 6001 requires State DOTs and MPOs to consult with State and local resource agencies when developing long-range statewide or metropolitan transportation plans and to include a discussion of potential mitigation activities and potential areas to carry out these activities. Including climate change mitigation and adaptation discussions in the consultation process for statewide and metropolitan transportation plans will improve planning and project-level decision-making, reduce vulnerability from legal challenges to the NEPA process, and foster cooperation among transportation, resource and land use agencies.

    For more information and examples of integrating climate change and energy considerations into the transportation planning process, see the FHWA funded study Integrating Climate Change into the Transportation Planning Process.

    FHWA and FTA issued a joint memo to clarify that metropolitan and statewide planning funds are eligible to be used to address the integration of transportation, land use, and climate change.

  2. What State requirements are there on GHG analyses for transportation plans, programs, and projects?

    Several States have specific requirements regarding GHG emissions analysis for transportation plans, programs, and projects. Following are some examples; this should not be considered a comprehensive list:

    New York. The State's Energy Plan requires an energy and GHG analysis for MPO transportation plans and TIPs and for all regionally significant projects and other projects that may lead to large increases in vehicle miles traveled. The environmental documents for those proposed projects typically include an analysis of projected CO2 emissions associated with construction and operation of each alternative.

    Massachusetts. Certain projects subject to the Massachusetts Environmental Policy Act are required to include a quantification of GHG emissions as well as consideration of measures to avoid, minimize or mitigate such emissions.

    Washington. The WSDOT Environmental Procedures Manual states that climate change, including effects of projects on on GHG emissions, should be discussed in EAs and EISs.

    California. California SB 375 requires the State's MPOs to include "sustainable communities" strategies in their regional transportation plans for the purpose of reducing GHGs.

  3. Does FHWA have examples of GHG analyses for transportation projects and programs?

    NEPA Documentation Examples

    New York. New York State DOT includes a quantitative CO2 emissions analysis in environmental documentation per State requirements. Many examples are included on NYSDOT's website.

    Oregon and Washington. The Columbia River Crossing Draft EIS includes GHG and climate change discussions in its energy, air quality, and cumulative effects sections.

    Utah. The I-15 Corridor Utah County to Salt Lake County Final EIS (Chapter 3, pages 282-283) provides some general background information on climate change, a summary of Federal and State-level activities to address the issue, and a comparison of emissions at the global level, the State level, and in the corridor being examined in the NEPA document.

    Transportation Planning Examples

    San Diego Association of Governments (SANDAG). SANDAG considers climate change in the trends, challenges, goals, and strategies of its transportation plan. In compliance with the California Environmental Quality Act, SANDAG prepared an Environmental Impact Report (EIR) (60 MB) for its 2030 Regional Transportation Plan. In the EIR, SANDAG analyzes the plan's climate change impacts, identifies them as "significant and unavoidable," and establishes mitigation measures to address them. A few examples of mitigation measures SANDAG included are increasing the number of vanpools, analyzing pricing strategies for reduced transit fares and tolling, and examining a variety of electric transportation initiatives. The EIR also quantifies the GHG emissions resulting from the plan.

    Sacramento Area Council of Governments (SACOG). SACOG incorporates climate change mitigation in the trends and challenges and policies of its Metropolitan Transportation Plan (MTP). The EIR for the MTP analyzes the plan's global warming impacts and proposes mitigation measures. Examples of mitigation strategies SACOG included are adopting a transportation pricing policy, creating an alternative fuel vehicle and infrastructure toolkit for local governments, and creating a public education program on individual transportation behavior and climate change. The SACOG also released a Preferred Blueprint Scenario as part of the MTP. The document depicts a way for the region to grow through the year 2050 promoting climate-friendly strategies such as compact, mixed-use development and more transit choices. The Preferred Blueprint Scenario serves a guide to local governments for growth and transportation planning.

    Connecticut, Oregon, and Houston-Galveston Area. The Connecticut Transportation Plan, the Oregon Transportation Plan, and the Houston-Galveston Area Council 2035 plan all include discussions on climate change adaptation, including safety, operations, and maintenance related to potential sea level rise, land subsidence, hurricanes, and storm activity.

    For more information and examples of integrating climate change considerations into the transportation planning process, see the FHWA-funded study Integrating Climate Change into the Transportation Planning Process.

  4. What was the 9th Circuit Court decision in Center for Biological Diversity v. National Highway Traffic Safety Administration (2007)?

    In November 2007, the Ninth Circuit Court found that NHTSA had violated the Energy Policy and Conservation Act (EPCA) by proposing Corporate Average Fuel Economy (CAFE) standards for light-duty vehicles, SUVs, and mini-vans that were lower than those for cars and excluding larger heavy pick-up trucks from any regulation. NHTSA was also found to have violated NEPA, because the EA that accompanied the rule did not take a hard look at the GHG emission implications of the rule making; the cumulative impacts evaluation of the rules effects on CO2 was inadequate; and the EA failed to consider a broader range of alternatives. The Ninth Circuit also took the unusual step of ordering NHTSA to prepare an EIS assessing CO2 emissions attributable to the new standards, as well as the actual environmental effects associated with climate change. On August 18, 2008, the Ninth Circuit revised its opinion, leaving to NHTSA's discretion the level of environmental review (i.e., an EA or an EIS) to conduct rather than mandating the preparation of an EIS.

    NHTSA's FEIS, developed in response to the court decision, was published October 10, 2008.

  5. What tools and methods are available to analyze GHG emissions from transportation sources? What can the tools do well and what are their limitations?

    Energy consumption, particularly fossil fuel consumption, is the principal driver of motor vehicle GHG emissions at this time. Energy consumption and GHG emissions are dependent on a number of characteristics of vehicle fleet makeup and vehicle activity. Important variables related to vehicle fleet makeup include the age distribution of vehicles and the mix of passenger cars, light trucks, heavy trucks, and other vehicles in the fleet, both of which affect the average fuel economy of the fleet. Vehicle activity variables that affect energy consumption and GHG emissions include VMT and speed. For more information, visit EPA's Transportation and Climate: Tools, Analysis and Publications website.

    Most energy and GHG analyses use VMT as a surrogate for energy consumption, either by multiplying VMT by a fixed energy-consumption or emissions rate, or by dividing VMT by a fuel economy estimate in miles per gallon. This is the most simplistic approach to energy analysis and does not account for some of the variables noted above.

    The EPA's MOVES model represents a significant improvement over MOBILE6.2 for energy and GHG analysis. The MOVES model develops energy consumption and emissions estimates based on speed and vehicle power output, and also has the ability to perform some lifecycle analyses. (For example, MOVES can calculate the "upstream" energy and emissions associated with fuel production and delivery, in addition to the energy and emissions associated with burning the fuel in vehicle engines.) The 2007 version of MOVES (MOVES Demo) has already been used by several State and local agencies for GHG analyses. EPA plans to add additional energy and GHG enhancements for future versions of MOVES.

    California's EMFAC model also estimates CO2 emissions, and it corrects estimates for speed. However, since EMFAC reflects the California fleet and emissions control programs, it is only suitable for use in California. The techniques described above are useful for estimating operational energy consumption and GHG emissions.

    The techniques described above are useful for estimating operational energy consumption and GHG emissions. However, there are other important components of energy consumption that should be addressed in a comprehensive energy analysis. These include the energy/emissions associated with constructing projects, and the impact of individual projects on other roadways in the network and on land use in the project area. Analyses conducted in New York show that construction emissions typically represent around 5 percent of emissions associated with projects, on an annualized basis. Thus, construction emissions could be an important consideration in build/no-build analyses, where the changes in operational energy/emissions are usually smaller. Likewise, analyses should consider not only operational energy/emissions on the roadway in question, but also any positive or negative impacts on other roadways affected by the project, and the energy/emissions impacts due to changes in land use as a result of the project. These impacts are easier to capture in regional-scale analyses than at the project level.

    The consideration of life-cycle emissions is an emerging area of study related to energy analysis. In the past, life-cycle considerations have been used to perform cost-benefit analyses for projects or to inform decisions about pavement selection, but practitioners are beginning to apply these considerations to energy analyses. Life-cycle emissions calculations can provide information on payback periods (at what point do the energy benefits of a project offset the energy required to construct the project?) and other information useful for decision makers. The methodologies employed by New York and Washington State include some of the elements of lifecycle analysis; for a comprehensive overview, see the document Energy Requirements for Transportation Systems.

    Any of these techniques can be applied at either the regional or project level. However, given the global nature of climate change, an analysis at the broader, regional level is likely to yield more meaningful results than at the project level.

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