Northeast/Mid-Atlantic Regional Cap-and-Invest Modeling Lacks Consideration of Renewable Fuel Adoption and Infrastructure

December 18, 2019

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by Joanne Ivancic (Advanced Biofuels USA) Modeling by Georgetown Climate Center's Transportation and Climate Initiative of the Northeast and Mid-Atlantic States released Tuesday showed potential for greenhouse gas emissions reduction, pollution reduction, job creation and public health benefits. The anticipated program is designed around auctions of credits by member states for investment in climate conscious transportation improvements. The participating states are: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia along with the District of Columbia.

Promoters of the TCI approach continue to revise proposed the memorandum of understanding released Tuesday and ask for additional comments and suggestions from the general public and interested parties. After states join the eventual MOU, each state will develop their own programs to implement the regional initiative.

Although clearly focused on an "electrify everything" approach, TCI promoters do recognize that liquid fuels will be important for a long time, with one graph showing that the stock of EVs in the region will only reach about 16% by the end of the first decade of the program, 2032.

In response to a question about how the planners anticipate accounting for emissions related to liquid transportation fuels, particularly renewable or biofuels, they said that only the fossil component of motor gasoline and diesel combustion would be counted; not the renewable portion. Thus, they anticipate no low carbon measurements of fuels such as carbon intensity analysis or life cycle analysis such as in the Argonne National Laboratory's GREET modeling.

Similarly, the promoters are working on incorporating into the models a more accurate reflection of the source of the power for electric vehicles (coal, natural gas, renewable natural gas, hydropower, solar, wind, etc.) taking into account the various state programs. They will also be factoring in the additional demand for electricity that achieving the electrification goals will produce.

The webinar presentation for the draft MOU release included an illustrative portfolio of clean transportation investments, purportedly focused on "the most cost-effective emissions reduction strategies." However, the list did not include investment in infrastructure for cleaner renewable fuels such as high blends of high octane ethanol or biodiesel, renewable natural gas or renewable diesel.

These options, although not included in the investment-related modeling, could be an option as member states determine how they design their programs.

It appears that the modeling also does not factor in variables related to the potential adoption of renewable transportation fuels and the effect that would have on reducing the greenhouse gas emissions and other pollution caused by fossil fuel combustion.

Experts in this field should contribute their comments and resources as the TCI developers continue to request input, with a February 28, 2020 deadline for comments on the draft MOU. Additional opportunities will arise as the modeling related to credit auction continues and as states develop their implementation strategies. READ MORE

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:

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