Methods for State DOTs to Reduce Greenhouse Gas Emissions from the Transportation Sector (2022)

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C-1 A P P E N D I X C Interviews The project team conducted telephone interviews with several States. The States were selected for interviews on the basis of responses to the survey, and included State departments of transportation (DOT) across a range of engagement levels. The state DOTs responding either “yes” or “possibly” to survey question 15 (“Would your agency be interested in participating in additional activities of this research project, including workshops to develop and review greenhouse gas (GHG) resources, and/or implementation support of GHG analysis methods?”) were contacted for an interview. In addition, the project team contacted a small number of other State DOTs known to the team to be active in activities to reduce GHG emissions from the transportation sector. Staff at 16 State DOTs were invited to participate in a phone interview. Of those 16, 2 declined. The 14 States where staff were interviewed were as follows: Arkansas, California, Colorado, District of Columbia, Delaware, Georgia, Hawaii, Massachusetts, Minnesota, North Carolina, Oregon, Rhode Island, Texas, and Washington. In order to allow for sufficient consideration prior to the interview, the team provided a State DOT staff contact with the interview questions prior to scheduled interviews. Interviews ranged in duration from 30 minutes to an hour, depending on the nature of the State’s involvement with GHG reduction activities. The Colorado interview was the only one to take place with several staff participating; others limited to just the survey respondent. A number of interviewees indicated they had discussed the interview questions with other DOT staff prior to the interview. The interview was conducted as a conversation. Depending on the State DOT’s level of engagement in GHG activities and the interviewee’s experience, longevity, and placement within the organization, not all questions were discussed. The interview topics were as follows:  State context—leadership and policy support for GHG consideration (internal and external). – How long has leadership been in place—longer than one Commissioner/Secretary and/or Governor? – How long have statewide policies been in place? – Are adopted policies still being actively followed or are they “dormant”?  GHG policies, goals, metrics—adopted, and under consideration by the DOT. – How adopted?—Legislation? Executive Order? Commissioner/Secretary Directive? Other? – How have they been institutionalized within DOT? Incorporated into departmental workplans? Individual review cycles? – Do you expect institutional responsibilities to change?  GHG analysis tools and resources applied or considered by the agency (inventory, forecasting, strategy evaluation), strengths and limitations. – What tools or methods have you applied or considered applying? (Quantitative or qualitative). – What information sources on GHGs (data, strategies, impacts, analysis methods) have you used? (e.g., Federal Highway Administration (FHWA) reports, National Cooperative Highway Research Program (NCHRP) reports, Strategic Highway Research Program (SHRP) reports, another report such as Moving Cooler or U.S. DOT Report to Congress, Annual Energy Outlook (AEO), State Energy Consumption, Price, and Expenditure Estimates (SEDS), or Environmental Planning Agency (EPA) data, other State agency resources, university research) – Accomplished in house or with consultant help? – How much staff time was required to gather needed data?

C-2 – Have you leveraged tools or methods you’ve used for other purposes (e.g., Motor Vehicle Emission Simulator (MOVES))? – What decisions are the tools being used for? – Do the tools provide the right type of information you need for decision-making? – How confident are you in results? – What information on tools and resources would have been helpful?  Barriers to consideration of GHG emissions (technical/resource, policy, institutional, cultural) by stage—planning, programming, project development, operations. – DOT staff reaction?—Level of buy-in? Any resistance? – Sufficient staff resources/capacity? – Adequacy of information/data/tools? – Which stage of the effort has been easier/harder to implement? Why? – Any steps taken to reduce/consolidate effort with other ongoing work (e.g., coordinate with conformity analyses)? – If your agency has a GHG policy- and/or planning-level assessment, but does not consider GHGs at the programming or project level, why not?  Partnering—with other State agencies (e.g., State Climate Action Plan); with metropolitan planning organizations (MPO)/regional planning organizations (RPO); with local jurisdictions (requests/by whom and for what, what DOT has or has not been able to contribute, data/info needs, working relationships, success examples, barriers to collaboration, etc.). – Who initiated the partnerships and why? – Any new working relationships established? If yes, what agency(ies)? – Roles for DOT within effort (e.g., State CAP)—Lead? Support?  Potential future directions of the agency with respect to GHG. – Planning and programming—transportation system GHG. – Agency operations, e.g., carbon footprinting, sustainability initiatives. – Leading or supporting specific initiatives, such as EVSE planning and deployment, Alternative Fuel Corridor nominations, generation of renewables in ROW.  Data and information needs by stage of process—what advice, tools, and resources would the agency find most helpful from an NCHRP guidebook? From hands-on training or piloting efforts?  How were DOT policies/procedures developed? – One functional unit? Collaborative effort among several functional units? Copy other agencies? – Peer review process?  How is effort led within DOT? – Roles/titles and functional units – How is communication and collaboration across DOT divisions accomplished?  Lessons learned? Advice for other DOTs. The discussions were open, and the responses reflected the respondent’s views on their agency’s role in efforts to reduce GHG emissions. Although the level of engagement for the DOTs varied, some common views emerged. Some valuable insights were gained from the interviews and are detailed below. Summary of Findings External Drivers Perhaps the most significant driver for State DOT involvement in efforts to reduce transportation GHG emissions is an external requirement imposed upon the agency, typically by Governor’s Executive Order (EO) or State legislation. Notably, the State DOTs with the highest levels of GHG engagement are in States with rigorous EOs or legislation requiring stringent GHG reductions.

C-3 The scope and language of the EO or legislation also is important. The external drivers whose language is more active (i.e., will act or implement) rather than passive (i.e., will consider or study) also help determine the State DOT activity level. The active language in the external drivers seems to compel all the relevant State agencies (including the DOT) to work on strategies to reduce GHG emissions from their sector of the economy. Taken together, a combination of not having any specific requirements, public sensitivities, limited available data, and perceived limited influence over GHG may begin to explain why many agencies have chosen not to focus their attention on GHG reduction efforts in favor of more pressing and less politically sensitive initiatives. Illustrations of how complementary agency initiatives such as mobility, safety, and energy savings also can improve GHG performance could be useful in this context. State DOT Jurisdiction The scopes of State DOT’s jurisdictions vary across the country. Some DOTs are primarily highway agencies while others oversee rail, commuter transit, freight, air, and/or motor vehicle registration. DOTs vary as to the modes of transportation over which they have control or influence. Based on conversations with the respondents, it seemed that if a State DOT had jurisdiction over more than the roadway network, the DOT was more involved in multimodal activities to reduce GHG emissions and more willing to tackle the transportation sector’s emissions. Some of the States that controlled only the roadway network seemed to feel there was less the State DOT could do to reduce emissions because emissions were being driven by other factors beyond their control (i.e., they only took care of the infrastructure). Partnerships All State DOTs that are active in GHG reduction efforts have established collaborative partnerships with other agencies and stress the value of the partnerships. Some partnerships were established as a result of having to work together to meet requirements of legislation or EOs. For some State DOTs, work on GHGs serves to strengthen and reinforce existing relationships. The number of partners varies with the State, depending on the requirements of the EO or legislation, but the most common partners were the State environmental agency and the State energy agency. At the regional and local levels, MPOs also are common partners. Many State DOTs suggested that the earlier partnerships are established, the more successful the relationship and work products will be. Transportation Sector versus Internal Operations To varying degrees, many State DOTs have taken steps to reduce GHG emissions from their own internal operations. Some are tracking and reducing energy use from their buildings, such as installing light-emitting diodes (LED) and more efficient heating, ventilation, and air conditioning (HVAC) systems. Many are purchasing cleaner vehicles (including electric vehicles (EV) for their fleets. Some are calculating and seeking ways to reduce GHG emissions from their construction and maintenance operations. Others are installing or experimenting with solar panels. Many have inventoried their internal GHG emissions to varying extents, with some tracking and reporting those emissions. These DOTs seem happy and eager to undergo these efforts. However, many State DOTs, even those at high levels of engagement, have difficulty with the concept of effectively reducing GHG emissions from the transportation sector as a whole. Some indicate they do not have sufficient influence over how and who uses the roadway network. While many can quantify the GHG emissions emanating from the transportation system, there is underlying concern that they will not be able to demonstrate sufficient reductions from the transportation sector to meet GHG reduction targets or goals, leading to negative consequences and publicity for their agencies. They suggest that expectations be realistically set.

C-4 Organizational Setting and Leadership There does not appear to be one clear organizational arrangement within State DOTs for working on GHG emission reductions. Aside from the ideal of having committed, interested, and accessible executives nominally leading this work, there are several organizational settings that work for different States. A common arrangement, especially among State DOTs at high levels of GHG engagement, is to house GHG reduction work under the umbrella of a sustainability initiative. In this arrangement, staff working on GHG reduction from the transportation sector also are working on reducing GHG emissions from internal operations and other sustainability activities. In this arrangement, staff seem to be most knowledgeable about all GHG-related activity within their DOT and State. Some States house GHG reduction work in the planning division and some in the environmental division. Generally, State DOTs that are more focused on project-level GHG activity have the staff lead in the environmental division, while State DOTs focused on GHG planning-level issues have the staff lead in the planning division. In few cases do agencies have staff dedicated full-time to GHG emission reduction, much less staff dedicated full-time to GHG emission reductions from the transportation sector specifically. In most cases, there are multiple staff working on GHG issues, but this activity has been added to their existing responsibilities. Tools and Data There are several available tools to measure and quantify different aspects of GHG emissions. There are tools for transportation system-level planning, emissions from construction activities, emissions by vehicle type and age, emissions from buildings, etc. State DOTs prefer tools that are designed for the intended purpose and as simple to use as possible. However, over time and lacking specific training, DOTs have self-taught and learned to adapt various tools to their needs. Many felt prepared to continue to do the same as needed. Many felt that guidance directing them to the appropriate tool and information on how to use that tool would be helpful. The main challenges DOTs face are data availability and usefulness. The array of data needs for the various tools is daunting. DOTs that have used Energy and Emissions Reduction Policy Analysis Tool (EERPAT) found the data needs to be extensive and difficult to collect. Some DOTs found it challenging to obtain the data required to inventory their emissions if the emission sources (e.g., vehicles used by DOT staff, building in which the DOT is housed) were owned by entities whose data were collected differently. It would be helpful to develop a standard for data collection and/or a conversion method from the form and units of collected data to the form and units of needed data for tool manipulation. Additionally, it would be helpful to indicate the significance and sensitivity of inputs of various tools; this information would help DOTs guide data collection efforts towards the most significant variables. A few State DOTs mentioned the issue of a full life-cycle analysis. DOTs would benefit from a definition of the term, guidance on how to perform the analysis, and guidance on how looking at life-cycle impacts could affect the selection of GHG reduction strategies. Greenhouse Gases and Air Quality Some State DOTs, especially those with less experience and engagement in GHG emissions reduction, consider GHG emissions in the same context as criteria air pollutants. Some believe that because they are not in nonattainment, they have no air quality issues and thus do not need to consider GHGs. Some only report GHG emissions for information purposes when performing project-level air quality analysis for a transportation project. Some believe that because there is no air quality standard for GHGs, a given project would not have a significant air quality impact. For these situations, guidance on scales of air quality analysis and differences in scope, effect, and impact between GHGs and criteria pollutants would be useful.

C-5 Nevertheless, the confluence of air quality and GHG analysis techniques and tools offers an opportunity to better understand and report benefits of various transportation actions. In addition to documenting that a project improves air quality by improving traffic flow, for example, agencies could also document that the project also reduces GHGs. Similarly, actions at a program level that might reduce criteria pollutant emissions, such as installation of Intelligent Transportation Systems (ITS), also would likely reduce GHG emissions. Since both efforts would use the same tool (e.g., MOVES) that already models criteria pollutants, the additional effort to model GHGs would be minimal. It is useful to highlight these synergies. Documents Consumers of reports and guidebooks expect them to be clear and easy to understand. Most State DOTs want report titles to be short and indicative of the work contained in the report. The body of the report should be written in a style that is easy to read and conveys the meaning and finding of the study. Technical and/or complex material is often understood to be necessary, but DOTs noted that it would be helpful to keep that type of material to an appendix or other subordinate document. Sustainability and “Greening” An emerging model of efforts to reduce GHG emissions from the transportation sector is the umbrella of sustainability or “greening” work. Some DOTs include GHG reductions, both internal and from the transportation sector, in their sustainability initiatives. Depending on the specific initiative, metrics, guidance, or procedures could be established to ensure that GHG reduction considerations are included as part of good sustainable practice. This model also may serve those States where discussions on climate change may be challenging. Consultant Use State DOTs interviewed varied in their use of consultants versus in-house staff. Some States use consultants, including academics, frequently, while others primarily rely on in-house staff. Depending on the need or application, those activities that require considerable effort, such as data collection or complex model runs, are usually performed by consultants. The most common model is that in-house staff develop the guidance and procedures while relying on consultants to perform the model runs and/or application of the guidance and procedures. In some cases, in-house staff perform the first model runs or applications and when satisfied on the outcomes and validity of the process, turn over subsequent work to consultants. In cases where the initial run of the model requires a substantial amount of data (e.g., EERPAT), consultants have been asked to help in collecting the needed input data. GHG Reduction versus Adaptation Practically all the State DOTs interviewed recognize and are dealing with the impacts of climate change through various resiliency and/or sustainability efforts. There is a sense of criticality for adaptation, especially for the coastal States. For some State DOTs, the terms “climate change” or “greenhouse gases” brings about discussion about adaptation, rather than emission reduction. This is probably an indication of those States’ involvement with GHG mitigation efforts. At least one State DOT recognized the relationship between transportation GHG emissions and issues with sea-level rise and, therefore, thought it appropriate to try to reduce their State’s transportation emissions. This thinking may be a model for State DOTs seeking to increase their efforts toward GHG emission reduction. It also builds on generally accepted “greening” efforts and environmental “stewardship”—especially when combined with the synergies of actions focused on mobility, air quality, etc.

C-6 Federal versus State Several States cited the variable nature of Federal requirements as a confounding effect for their climate change work. The revocation of project-level National Environmental Policy Act (NEPA) guidance and the proposed revision to fuel economy standards were mentioned specifically. At least one State DOT indicated that since these changes in Federal requirements, they no longer mention GHG reduction in their planning and project documents. Technical versus Executive By the nature of the issue and the potential strategies involved to reduce GHG emissions from the transportation sector, the ongoing work is highly visible internally within the State DOT and with the public using the transportation system. The model that seems to work best within the DOTs is a high-level executive in charge of the overall effort with technical staff in charge of the day-to-day effort. The technical staff could be the point of contact for inquires/requests, both internal and external, and be technically knowledgeable about climate science, tools, and the transportation system. The technical staff also should have access to all relevant program areas of the State DOT. Many of the State DOTs interviewed stressed that those working on the issue should have a personal interest, enthusiasm, and commitment to the subject. They also felt that continuity in staff and interest was important. Some felt that too many “initiatives” within the agency could dilute the effort and cause unnecessary distractions. That said, the State DOTs generally did not find much internal resistance to undertaking GHG reduction work. With clear direction from leadership, most staff understood the need for this work. Conclusions State DOTs have adapted to undertaking GHG reduction efforts, depending upon the mandate and their organization’s role in the effort and control of the transportation system, with varying degrees of success. Many of their efforts have been limited to reducing emissions from their own operations. Most often they have done this with no additional staffing. An emerging model of GHG reduction efforts is the umbrella of sustainability or “greening” work. Many of the State DOTs interviewed stressed the importance of good communications, both internally and with outside groups, and the importance of good planning to undertake the effort. DOTs value partnerships with other State agencies, local or regional agencies, or local and civic groups. The partnerships provide a common sense of purpose, spread the workload, and deflect potential negative reactions to the ongoing work. The confluence of air quality and GHG analysis techniques and tools offers an opportunity to better understand and report benefits of various transportation actions. For agencies that lack strong external direction, illustrations of how common agency initiatives such as mobility, safety and energy savings are related to GHG performance could be of value in delivering on statewide or regional initiatives. Some interviewees preferred webinars or pilot programs to hands-on training as the most helpful outcomes of this project. Whatever the format, training, report documents, and guidebooks are expected to be clear and easy to understand. The State DOTs did not find much internal resistance to undertaking GHG reduction work. With clear direction from the State DOT leadership, most staff understood the need for this work. At this point, to keep the effort ongoing in a unified and comprehensive manner is where the communication and planning discussed previously becomes important. It also helps prioritize their efforts among many potential reduction strategies that could be pursued. A few State DOTs mentioned the issue of a full life-cycle analysis. They would benefit from a definition of the term, guidance on how to perform the analysis, and how the results affect the selection of reduction strategies. Some felt that this analysis might preclude the selection of certain reduction strategies.

C-7 Some State DOTs noted the challenge of multiple conflicting priorities, in which other initiatives could distract, delay, or otherwise hinder GHG reduction efforts. Priority initiatives can change as State and agency leadership changes or other imperatives arise. This can sometimes result in reassignment of staff working on GHG reduction efforts to other efforts.