NCLA Comments to CDOT Hearing on Proposed Greenhouse Pollution Reduction Standards

It is imperative that Coloradoans are clear on the overall costs of the rule and how the policies encompassed in the are structured to reduce their quality of life.”

During a Colorado Department of Transportation virtual hearing (November 10, 2021) on a proposal to reduce greenhouse gas emissions (GHG) related to transportation projects, the Northern Colorado Legislative Alliance — representing Fort Collins, Greeley, and Loveland Chambers of Commerce and Upstate Colorado EDC– offered public remarks in response to CDOT’s proposed rule shifts highway funds from roads to programs intended to reduce GHG.

The following is a statement from Sandra Hagen Solin, Head of the Northern Colorado Legislative Alliance and Fix North I-25 Business Alliance (the latter which is a subcommittee of the Northern Colorado Legislative Alliance):

“It pains me to say that we have significant concerns with the rules as proposed as we have had a very strong relationship with CDOT for years and have been a partner in driving billions of funding from the general fund and financing tools into CDOT coffers in the last five years.  Our concerns align with, and we strongly support, the comments and recommendations made by the North Front Range Metropolitan Planning Organization.

“The Fix North I-25 Business Alliance was formed by the NCLA and the business community in the region to ensure an investment in the capacity expansion of the North I-25 corridor with an express managed lane. Long established CDOT policy dictates the use of an express managed land for the expansion of roadways, an approach broadly agreeable to the northern Colorado region as an operational approach and strategy to reduce congestion and improve air quality.

“Despite the $1B investment made in North I-25 so far by CDOT, no funding has been identified or allocated for Segment 5 of the corridor creating a significant gap in the express lane between Mead and Longmont and thereby ultimately creating significant safety concerns.

“The rules, especially with the modifications made on Oct. 19, and their operative one size fits all approach, threaten the completion of the north I-25 Corridor. North I-25 is but one example of

critical regionally significant corridors across the northern Colorado region and across all of Colorado that require ongoing investment in their congestion relief, capacity improvements and operational strategies and are at risk. The revised rules and the comments conveyed this afternoon in support of the rule make very clear the intent behind the rule is to dramatically reduce Vehicle Miles Travelled (VMT) and roadway investments.

“Under the rule revisions, roadway capacity improvements to address congestion and operational strategies that can include technology improvements that improve the flow of traffic are specifically disallowed despite no technical basis provided in the rule. Capacity improvements and operational strategies should be allowed mitigation measures for regionally significant projects.

“I mentioned at the outset we strongly support the NFRMPOs written and oral comments and their recommendations. We encourage you to pay particular attention to their very thorough critique of the Cost Benefit Analysis (CBA). The CBA goes to great lengths to demonstrate economic benefits of the rule. The overall cost, however, is too low, they found by a factor of four.  Using the methodology in the CBA, the NFRMPO estimates costs of the rule at $18.8B compared to a cost of $4.5B conveyed in the CBA.

“Furthermore, we would suggest the induced demand theory embedded in the rule set and CBA and its intended and consequential reduction in congestion mitigation and capacity improvements fails to fully consider the negative economic impacts upon the disproportionately impacted communities, create an undue burden to these communities, and are in conflict with the intent of HB21-1266, the Environmental Justice Act.

“Lastly, we concur in comments related to the new inclusion of VMT as a factor in the rule.  We will expand upon this in our written comments.

“In conclusion, it is imperative that Coloradoans are clear on the overall costs of the rule and how the policies encompassed in the are structured to reduce their quality of life.”

 

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