This post was written by guest contributor James Brasuell. 

Across the nation, many state-level elected officials talk about reducing transportation emissions but the agencies they nominally oversee plan and fund automobile infrastructure that increase emissions anyway. (Oregon’s State Highway Department, “ODOT,” shows one of many ways state governments use to cook the books and say one thing while doing another.) Recently, the State of Colorado is instead starting to move toward matching rhetoric with investment. Last year, the state implemented a new statewide rule that rearranges regional capital investment plans to prioritize the transportation modes that most effectively reduce greenhouse gas (GHG) emissions: public transit, walking, and biking. 

The new rule has already resulted in real-world changes – or at least, changes to plans, including by the biggest Metropolitan Planning Organization (MPO) in the state. In 2022 the Denver Regional Council of Governments (DRCOG) scrapped its plan to expand Interstate 25 and C-470, and will use the money it saved to fund a suite of new bus rapid transit projects. 

While advocates warn that much more work will be necessary to meet the state’s climate goals, Colorado’s GHG rule and subsequent funding decisions provide a blueprint that other states should follow, if they are sincere in fulfilling their pro-climate rhetoric.

A Groundbreaking New Rule

A new era of transportation planning in the Centennial State began when the Transportation Commission of Colorado adopted the GHG Transportation Planning Standard in December 2021. The GHG Transportation Planning Standard requires each of the state’s five metropolitan planning organizations (MPOs) and the Colorado Department of Transportation (CDOT) to set emissions reduction targets for 2025 and each subsequent decade until 2050. 

Under the GHG Transportation Planning Standard, MPOs failing to meet greenhouse gas targets (GHG) targets are required to develop  mitigation action plans. These mitigation plans require funding what Jenny Gaeng, transportation advocate for Conservation Colorado, refers to as “good projects,” those which reduce the need for people to drive or provide alternatives to driving (yes, that includes reducing reliance on electric cars, too). This important new emphasis on mode shift to meet the overall goal of reducing vehicle miles traveled (VMT) follows the advice of climate activists, like Carter Rubin, transportation technical strategist for the National Resources Defense Council (NRDC). “Mode shift and helping people get around without vehicles is an important component of a holistic transportation approach that focuses on climate, equity, and affordability,” Rubin explained.

Most importantly, dollars matter. While many states’ climate plans are completely separate from their actual expenditure plans, the mode shift required by Colorado’s GHG Transportation Planning Standard will be enforced with tangible fiscal penalties–a degree of financial consequences not achieved by other laws around the country, such as California’s SB 375. A blog post by Matt Frommer, senior transportation associate of the Southwest Energy Efficiency Project (SWEEP), explains that if CDOT falls short of the GHG targets, the agency must award a larger percentage of its 10-Year Vision Plan dollars to projects that reduce emissions. MPOs are also required to allocate funding from federal funding for projects that cut emissions. If they fail, CDOT has the authority to redirect those funds.

Colorado is a car-centric state, so the political effort required to implement the Greenhouse Gas Transportation Planning Standard required developing allies beyond the usual pro-transit suspects. The benefits of access and transportation alternatives at the local level drove the political messaging that helped build political support for the rulemaking process. Gaeng, of Conservation Colorado, credits the simplicity of the message that people should have more options for how to get along for building community support. “It was easy to rally grassroots folks around that even if they didn’t understand every nuance of the rule itself,” says Gaeng.

The scope of the political coalition that supported the process might surprise outside observers–extending even to the state’s many rural communities. Nearly every level of government in the state–from the administration of Governor Jared Polis, state legislators, and local governments–ended up backing the legislation and rulemaking required to achieve the I-25 victory. All of the advocates that spoke with TransitCenter also called attention to the variety of communities–urban, rural, and suburban–that contributed to the adoption of the GHG Transportation Planning Standard. According to Gaeng, “There are advocates for transit everywhere and advocates for bikes everywhere–people want to be able to get from mountain town to mountain town on their bikes.” Some were health-oriented organizations, some were oriented toward justice, others focus on a better life for seniors or youth. 

That doesn’t mean support was unanimous. “There are a lot of people who have a hard time envisioning a future that works better for all of us,” said Gaeng. Political leadership in some conservative parts of the state, like Weld County, opposed the rule, for example. And, “Not all of the Metropolitan Planning Organizations were equally thrilled about having to comply with this rule,” explains Gaeng, who credits CDOT with building consensus and support among the MPOs. Political opponents were able to prevent some of the equity considerations that advocates like Gaeng had targeted during the rulemaking process. A coalition of environmental groups including Conservation Colorado pressed for a requirement that 30-40 percent of the state’s transportation investments be directed into those disproportionately impacted communities. “The final rule has some language taking disproportionately impacted communities ‘into consideration,’ but did not ultimately do anything enforceable for investment to good projects in those communities,” according to Gaeng.

While the equity component didn’t end up in the standard, Gaeng says that CDOT has committed to developing a transportation equity framework, so opportunities for equity wins will continue to present themselves. Reform advocates will continue to watchdog the state’s implementation of the promises of this new approach. 

Mode Shift in Action

Before the Greenhouse Gas Transportation Planning Standard nixed the project, DRCOG and CDOT were intending to expand I-25 in the middle of Denver, razing homes in the community of Sun Valley, already disproportionately impacted by poor air quality rates and home to a relatively large number of low-income residents. Like all other urban highway expansion projects, it undoubtedly would have induced more traffic and emissions, regardless of what the flat-earth society and other state DOTs choose to ignore about the reality of induced demand. 

But this story isn’t just about the demise of another questionable highway expansion project–it’s also about what that money will fund instead, namely five bus rapid transit (BRT) projects around Denver on Colfax Avenue, Federal Boulevard, Colorado Boulevard, and others. Fiscally, the rule amounts to a “two-fer,” which not only takes a dollar away from bad projects and also awards that dollar to a good project. 

“The most exciting thing we’ve seen in the Denver region so far is the shift in funding from the proposed expansion of I-25,” according to Molly McKinley, policy director at the Denver Streets Partnership. McKinley lists the benefits of better transit access to the local community among the primary benefits of the project. The Federal Boulevard BRT route, for example, will run along the western edge of Sun Valley. “Communities that have really been separated from the rest of Denver because of I-25 now will have better access to places they need to get around the city,” explains McKinley.

Familiar challenges to implementation remain, typical of the slow delivery schedules and bloated budgets of transportation infrastructure projects in the U.S. generally. One of the eight BRT projects favored by local advocates, the Colfax Avenue project, has been in the works for eight years and is not scheduled to open to the public until 2028, even though it would have been accomplished far faster in other modern countries. Fourteen-year project timelines aren’t going to serve riders well, or help the state reach its GHG targets on schedule. Projects are also likely to encounter new political opposition and NIMBYism as they proceed through the planning process. In November, Denver officials announced a plan to accelerate the East Colfax Bus Rapid Transit project timeline by 18 months, to 2026, in the process provoking a fresh round of opposition from the local political representatives. 

McKinley and Denver Streets Partnership plan to build on the victory achieved by stopping the I-25 expansion. “The fact that that expansion is not happening is a really meaningful line in the sand for those communities, and I think will just only help build more momentum for projects and to say ‘enough is enough.’” And in saying enough is enough to highway expansion, they’ll simultaneously be recognizing that transit needs more funding, which will provide a much higher return on investment, environmentally and economically and socially.