USGBC has submitted a public comment urging the U.S. Department of Transportation and the Federal Highway Administration to keep in place the current greenhouse gas (GHG) measure for federal highways. This message came in response to a proposed rulemaking that would repeal the measure, which requires state transportation departments and metropolitan planning organizations to monitor on-road vehicle emissions and set targets for improvement.
The GHG measure applies to state and metro area transportation agencies that receive federal funding, and is one of a suite of performance measures. The current rule does not impose any specific limit, but rather identifies on-road vehicle emissions as among the metrics appropriate for evaluating overall transportation system performance.
DOT initially suspended the GHG measure, which eight states then challenged in a lawsuit. Notably, each of the states—which included California, Iowa, Maryland, Massachusetts, Minnesota, Oregon, Vermont and Washington—argued that they have the duty to protect their residents from the adverse effects of climate change. California, the lead plaintiff in the lawsuit, cited its own legislatively mandated targets for emissions reductions, as well as the state’s particular vulnerability to the consequences of high GHG emissions.
The built environment, which encompasses transportation systems and commercial, residential and industrial buildings, was responsible for 60 percent of total U.S. GHG emissions in 2015, according to the U.S. EPA. Tracking these emissions is essential to making our cities and states more livable, healthy and green—especially since you can’t manage what you don’t measure.
LEED strongly supports GHG emission reduction through innovative and mindful design and implementation, including LEED credits that offer incentives to accommodate non-motorized modes of transportation and green vehicles, as well as rewarding strategies that provide access to reliable public transit.
USGBC will continue to monitor all transportation performance-measure rulemakings, in order to support ways for society to measure and understand externalities imposed by our built environment.