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Climate Action Plan for Transportation Investment (CAPTI)

Climate Actions for State Agencies: Public Comment Period Closing Today

California's Climate Action Plan for Transportation Investment (CAPTI) keeps facing pushback from people who just want more roads.

The California State Transportation Agency (CalSTA) presented a draft list of actions to align transportation investments with state climate goals to the California Transportation Commission (CTC) last week. This update to the Climate Action Plan for Transportation Investment, or CAPTI, is necessary because state agencies have substantially completed the thirty-plus early actions it had originally outlined in the first go-round.

Comments on the draft CAPTI update are due by December 13 to capti (at) calsta.ca.gov.

Last week's presentation focused on strategies that would be the responsibility of the CTC, specifically for programs that are funded by S.B. 1, the state gas tax.

CAPTI was created in response to several executive orders from Governor Newsom calling for solid climate action and strategies "to advance more sustainable, equitable, and healthy modes of transportation, such as walking, biking, transit, and rail, as well as accelerate the transition to zero-emission vehicle technology." CAPTI only applies to discretionary funding - a small portion of overall transportation funding - within several state-funded programs. Some of these, such as the Active Transportation Program, already include a focus on reducing greenhouse gas emissions. Others, including the Solutions for Congested Corridors Program (SCCP), State Highway Operations and Protection Program (SHOPP), and Trade Corridor Enhancement Program (TCEP) are aimed at solving other issues, and the CAPTI framework is meant to help them meet their goals without undermining state climate goals.

California has slowly been coming to terms with the realization that, in order to meet climate and environmental goals, it will have to find a way to encourage people to drive less. For that reason, several of the strategies CAPTI recommended have to do with reducing vehicle miles traveled, or VMT. It just means reducing the total amount of driving.

The proposed actions to be led by the CTC include:

  • Change TCEP guidelines to state that goods movement projects that mitigate impacts from more driving (of passenger cars, not freight) are more competitive for funding
  • Require SCCP projects to be "VMT neutral"
  • Rewrite SB1 program guidelines to better account for the environmental justice impacts of projects

In studying impacts from the previous version of CAPTI, project lead Darwin Moosavi said at last week's CTC meeting, "We found that we were very close to being VMT neutral already," so that goal should not be much of a stretch.

But not according to some of the people who weighed in at the CTC meeting, objecting to the idea that a transportation funding program needs to be "VMT neutral." One speaker from the city of Corona, far from the only one expressing these ideas, complained that the residents of that city "can't leave their homes or go anywhere because there are already too many cars on the roads." Her solution was not to support strategizing how to reduce driving, but to build more roads. "If you codify this," she said, "you make it impossible for us. Don't kill our region."

Too many people still believe, like this speaker, that adding highway capacity is the only reasonable solution for congestion, despite decades of evidence that it doesn't work and in fact only ends up increasing driving, congestion, and pollution.

The proposed requirement could "tie the hands of the CTC," and "chill development of projects that are critical for rural regions," said other commenters. Others tried to make it a false choice between building needed housing and reducing driving, seeming to believe that the current "drive until you qualify" state of affairs actually works for people, and that the solution to housing and transportation is to continue to build sprawl and more highways.

The California Transportation Commission is missing a big opportunity here to educate people about induced demand and the impossibility of building our way out of congestion. But they don't seem to understand it themselves - or if they do, they keep quiet about it. Commissioner Jay Bradshaw even said that codifying the requirement to be VMT neutral "will potentially kill all highway projects in certain parts of our state. I don't think that's what we can do as a transportation commission."

In response to similar objections raised earlier in the update process, CalSTA floated the suggestion of making the VMT requirement a "programmatic," rather than "project-based" goal. That is, the Solutions for Congested Corridors Program, when all the projects are accounted for, would be VMT neutral, rather than each individual project. One problem with that, however, is the question of how it would be overseen and enforced, and by whom.

Other concerns raised over the past few months of public discussion have been around geographic equity and rural competitiveness for funding. People asked that funding be kept as flexible as possible and that more effort be made to address the environmental justice impacts of transportation investments.

One of the proposed CAPTI changes would have the SB 1 program guidelines more specifically address those impacts.

These are purposely general proposals right now. The details of how, for example, the guidelines would "address environmental justice impacts" would be subject to further discussion and decision-making at the CTC.

CAPTI also proposed that the TCEP - which focuses on freight corridors - prioritize projects that mitigate new passenger vehicle driving. That's right - not freight miles but passenger travel that might be induced by improving roads for trucks. There was pushback on this too: it could prevent the funding of "important projects aimed at improving freight movement," according to the summarized feedback.

But this topic is one deep, dark, messy rabbit hole. The CAPTI proposal doesn't even address new freight miles traveled, and freight miles are also not accounted for in other state analyses - including environmental impact reports under CEQA - while they have a direct impact on congestion and pollution. Building freight corridors without accounting for increased truck traffic would, at a minimum, likely lead to highway traffic being dominated by trucks - something that is already happening on multiple CA highways now.

Relying on upcoming electrification of trucks won't work by itself, as has been made clear with passenger EVs, which are no panacea. Also, the likely lack of federal support for any electrification of travel modes under the new administration, resistance from freight companies, high costs, and the slow rollout of infrastructure will all hamper the transition to clean freight. And electrifying fleets does nothing to reduce congestion. Yet California is not planning to do anything about the steady rise in freight traffic at all, including in CAPTI, except in the most marginal ways.

There are other proposed actions in the CAPTI update as well. For example, it calls on Caltrans to create a "comprehensive climate adaptation planning and delivery framework and corresponding performance targets." It suggests finding a way to improve VMT analysis and mitigation guidance to better account for lower VMT impacts of many rural projects. And it calls on Caltrans to create an anti-displacement policy, and avoid taking housing, when it builds its projects.

Comments on the draft CAPTI update are due by December 13 to capti (at) calsta.ca.gov. The final CAPTI update is expected to be released in early 2025.

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