New Research: MD Governor Falls Short on Climate Action

December 24, 2019

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(ClimateXChange) Alongside the Chesapeake Climate Action Network, we requested a policy review of Maryland’s Greenhouse Gas Emissions Reduction Act: 2019 GGRA Draft Plan released by the Maryland Department of the Environment (MDE) in October. Our review was conducted by the Center for Climate Strategies (CCS).

The review finds that Maryland Governor Larry Hogan’s draft plan is critically flawed and falls far short of what is needed to address the climate crisis in the state.

The main findings are:

Maryland’s current greenhouse gas emissions reduction targets are weak compared to other states and inadequate for meeting critical international benchmarks for averting the climate crisis.
Due to overly optimistic assumptions and flawed methodology, MDE’s daft plan is unlikely to result in meeting even these weak emissions reduction targets.
The plan is especially flawed when it comes to reducing greenhouse gas emissions in the transportation sector, due to unrealistic assumptions on widespread electric vehicle adoption, dubious claims that highway widening will result in fewer emissions, and a lack of proposed strategies for reducing car travel demand.
MDE does not account for methane leakage in inventories or future scenarios, even as the Hogan Administration is supporting an expansion of fracked-gas infrastructure.
Inconsistent calculations for the emissions inventory between 2014 and 2017 call into question the accuracy of MDE’s data.
The governor’s study failed to include carbon pricing as a policy option, even though the state’s own prior modeling showed it to be highly effective at reducing emissions.

What this report means for us

The administration’s current emissions reduction commitments do not reflect the scale of the climate crisis and its impacts on Maryland. Without the level of ambition required to tackle this crisis, we will also miss out on the opportunity to uplift communities through a broader transition. Importantly, by undercutting ambition, the Governor is missing out on taking opportunities for large-scale and transformative solutions in the state.

Maryland needs to make meaningful progress in solving the intersecting crises of clean air, equity, and climate change. Unfortunately, Governor Hogan is proposing climate solutions that do not come close to tackling the crisis according to the current science. This has become very clear in the Center for Climate Strategies’ policy review of Governor Hogan’s draft climate plan. The review found, among other things, serious deficiencies in the economic assumptions the administration is making about climate change. The result is likely to be a set of policies far too modest to solve the climate crisis. This also means he won’t take full advantage of this opportunity to address the underlying causes of Maryland’s poor air quality or take steps to empower communities that have been historically marginalized and systematically underserved by our public services and infrastructure.

As Maryland begins this coming legislative session, we must make sure to position the impacts on environmental justice and front-line communities at the center of any solution. And as we strive towards a pollution-free environment, we must consider how to reduce the health effects of harmful air pollutants and make this move a just transition. READ MORE

READ THE FULL REPORT

Findings Regarding the Hogan Administration 2019 Draft Plan to Implement the Maryland Greenhouse Gas Reduction Act (Center for Climate Strategies)

Excerpt from Center for Climate Strategies:

2. The 2019 GGRA Draft Plan Makes Improbable Assumptions regarding Electric Vehicle Adoption

In the transportation sector the Draft Plan includes a scenario wherein the electric vehicle fleet encounters “Increased sales after 2025, and aggressive sales after 2030 (530,000 by 2030, 4.5 Million by 2050).”
27
The scenario assumes that Maryland drivers will purchase over 65,000 EVs in 2020 (10 times that of 2018i), an average of 50,000 EVs per year from 2026-2030, and an average of 175,000 EVs per year from 2031-2050.

To put this in context, Maryland’s total purchase of both fully electric and plug-in hybrid vehicles was
approximately 3,250 in 2017 and 6,300 in 2018.
28
According to the Maryland Motor Vehicle Administration, the total new-vehicle sales in the state was approximately 335,000 and total used sales were around twice that number in 2018. The overall vehicle market has not grown; the state has registered close to one million vehicle sales per year steadily from 2002 through 2018 and appears to be
on track to be consistent with that trend in 2019.29 The 2018 EV sales figure represents approximately 2% of new car sales in 2018, or 0.6% of the overall new and used sales combined.

3. The 2019 GGRA Draft Plan Anticipates Emissions Reductions from Highway Expansion, Despite Consensus to the Contrary

The 2019 GGRA Draft Plan, in Section 4.3.5 regarding “Transportation Technologies” presents an enhancement proposal named “Managed Lanes (I-270/I-495 Traffic Relief Plan Implementation).” This proposal describes adding express lanes to the two mentioned interstate highway as well as to the Baltimore-Washington Parkway. The Draft Plan document, in Table 4.3-7, assesses this initiative an emissions reduction value of 0.051 million (51,000) tons of greenhouse gases.30 The Draft Plan also makes a statement, in Figure 4.3-7, to the effect that a vehicle traveling at 20 miles per hour may produce over a third more emissions than the same vehicle traveling at 50 miles per hour, and cites the commonly-used MOVES model available from the US Environmental Protection Agency as its source.

Though capacity expansion projects on highway corridors can achieve some measure of congestion reduction in the short term, the clear and consistent pattern is that expansions result in more travel volume. This effect, referred to as “induced demand,” occurs immediately, and grows stronger over the following several years. A review of several cases around the United States found consistent increases in cars on the road just after highway expansion, with increases growing more pronounced in all cases over the following decade. The effect identified was significant: adding 10% more capacity (in terms of total lane-miles) to a highway resulted in between 4% and 10% more travel volume on that highway in every case. I-270 has experienced this before, when the widening of I-270 in the 1990s resulted in a return to full congestion by 1998, rather than by 2010 as projected.

Considering that I-270, I-495 and B-W Parkway corridors carry 620,000 motorists daily (per the draft study’s own language), this represents a reasonable expectation that even a small increase in capacity would eventually induce thousands – and possibly tens of thousands – of additional trips in the region.

Because that additional demand will re-introduce congestion to the highways in question, the pressure on the state’s greenhouse gas emissions profile would be upward, rather than downward.

4. The 2019 GGRA Draft Plan’s Successful Achievement of 2030 Targets Depends on a Large Reduction in Travel Demand without Credible Strategies in Support

On-road transportation represents about a third of Maryland’s annual emissions, per the 2017 greenhouse gas emissions inventory cited in Chapter 3 of the Draft Plan. This sector is also, per the same source, the component of the state’s emissions that has fallen the least since 2006. While the state’s overall emissions have fallen a reported 30% in that time, transportation emissions have effectively held steady. Despite a mild set of policy options offered in the 2019 Draft Plan, Appendix F states that a significant assumption regarding the Draft Plan’s effectiveness is that light-duty vehicle travel is expected to be reduced by 11% by 2030, accredited to “emerging and innovative strategies for
highway management, smart transit, etc.” There is little confidence that the policy approaches presented would result in such a major drop in vehicle travel.

Table 4.3, starting on page 66 of Appendix F, clarifies a series of significant assumptions that underly this
projection:
1. Ride-hailing service is credited with reducing travel volumes by nearly a billion miles traveled in 2030, the equivalent of removing the equivalent of 10,000 cars from the road that year, despitemany studies showing these services actually add to, not reduce, total on-road travel demand.

2. Better bicycle and pedestrian infrastructure is projected to avoid 293 million miles traveled that year, equivalent to taking 29,000 vehicles off the road. Improving non-motorized travel options is generally considered a wise and cost-effective approach to managing travel demand, and the Draft Plan refers to a number of existing programs that should continue. However, the analysis gives no basis for the large impact assumed, only mentioning a potential study to determine a basis for calculating reductions in car VMT. This language suggests that no VMT reduction has been calculated, and that no methodology to do so has even been established. Yet, a large numeric projection is used in the analysis.

3. Expanded [Travel Demand Management] strategies (dynamic), telecommute, non-work strategies are projected to reduce travel volume by over 1.1 billion miles traveled, or the travel volume of over 100,000 vehicles in 2030. TDM strategies are very valid approaches to VMT reduction, but in this document, they are described only conceptually, without any listed strategy as to design, level of effort, location, or implementation. Assuming major reductions
from them is a hopeful statement rather than a valid basis upon which to project that an actual plan will achieve actual reductions.

4. “Fiscally unconstrained” transit expansion is credited with an expected reduction of 250 million miles driven in 2030, equivalent to removing 25,000 vehicles from the road in 2030. This is concerning because Table 4.6 of Appendix F describes these projects explicitly as “Post-2030”, indicating they likely would not impact travel volumes in 2030 or before as the analysis expects.

Further, the projects in contemplation – expansion of rail transit and development of a new Bus Rapid Transit network – could easily take a decade to implement and are currently only mentioned in state and county long-range transportation plans. These plans offer no assurance of timing or completion of any of these projects.

5. The plan relies on avoiding 200 million vehicle miles traveled through the completion of the Maryland Area Regional Commuter (MARC) Cornerstone Plan by 2030. This plan, however, is not slated for completion until 2045.

132 Given that many elements of the plan that would increase ridership and reduce VMT involve major planning and capital investment (such as building a new West Baltimore Station, replacing the railcar fleet, eliminating at-grade
pedestrian crossings, and major redevelopment projects in collaboration with Amtrak around existing stations), MARC’s current plan calls for most of these to occur between 2025 and 2045.

32 https://evadoption.com/ev-market-share/ev-market-share-state/Policy Review of Maryland 2019 GGRA Draft Plan

Expecting a 25-year plan to be implemented in 10 years is unrealistic, and not a sound basis for projecting emissions reductions.

6. Transit expansion projects in general involve a trade-off, as the 2019 GGRA draft plan itself recognizes. Providing more service is energy-intensive, and (unless the vehicle is running on energy derived from a zero-carbon source) offsets to some extent the emissions reductions achieved. There is no indication that the VMT reduction assumption made in the underlying analysis takes this net effect into account.

In total, over 3 billion miles traveled are projected to be avoided by all listed measures. Of that figure, at least a third must be questioned based on estimates from ride-hailing alone.

The same table presents a significant assumption that autonomous and connected vehicle technologies are projected to achieve the equivalent fuel savings (72 million gallons in 2030 alone) of taking around 140,000 cars off the road that year. Truck fuel efficiency savings of over 5 million gallons that year is also expected. This represents a projection of nearly a million tons of GHGs avoided from a technology that is not yet developed, let alone in implementation at any scale, anywhere in the world.

30 GGRA Draft Plan Document, https://mde.state.md.us/programs/Air/ClimateChange/Pages/2019-GreenhouseGas-Emissions-Reduction-Act-(GGRA)--Draft-Plan.aspx
31 Handy, S. and Boarnet, M. for California Air Resources Board, “Impact of Highway Capacity and Induced Travel
on Passenger Vehicle Use and Greenhouse Gas Emissions.”
Policy Review of Maryland 2019 GGRA Draft Plan