Envisioning a Zero-Carbon Transportation System: A New Transportation Toolbox of Strategies from Tony Dutzik and The Frontier Group

In May 2016, Tony Dutzik and the Frontier Group published A New Way Forward, which explored a series of pathways by which American cities might eliminate greenhouse gas emissions from urban light-duty vehicles by mid-century.12 The pathways incorporated unique mixes of new and old ideas, tailored for the needs of specific types of urban areas, showing that every type of city has a viable way forward in the effort to prevent dangerous global warming.

It also described a New Transportation Toolbox of strategies that – especially if combined in ways that maximize synergies among them – can help to create a zero-carbon transportation system. Among those strategies are:

  • Repowering Vehicles: Efficient electric vehicles that can be powered by clean, renewable electricity are entering the marketplace faster than the hybrid cars of a decade ago, and technology continues to improve, reducing costs and increasing travel range. Electric vehicles reduce carbon emissions even when using electricity from today’s grid, and will deliver greater benefits in the years to come as America transitions to electricity provided by clean, renewable sources of energy.13
  • Urbanization and Smart Growth: American cities – especially their downtowns – are experiencing a renaissance, driven by a growing desire for walkable living. A future in which most new development takes place in urban and walkable neighborhoods could reduce transportation greenhouse gas emissions by 9 to 15 percent by mid-century, according to research by the Urban Land Institute.14
  • Shared Mobility: Over the last decade, an explosion of technology-enabled services – from carsharing to bikesharing to Lyft and Uber – has revolutionized transportation in many cities. Some of these “shared mobility” services have been shown to reduce vehicle ownership and driving, while the effects of others are just beginning to be studied.
  • Public Transportation: Transit ridership hit a modern high in 2014, the result of recent transit expansion projects and growing urban population and employment.15 Current public transportation services reduce vehicle travel (and greenhouse gas emissions) by about 10 percent in U.S. cities, according to research conducted for the Transportation Research Board.16
  • Reallocating Space: The vast majority of street space in American cities is devoted to moving or storing cars, pushing people who walk, bike or take transit to the margins. Cities in the United States and around the world are reallocating space formerly devoted to cars to other public purposes, encouraging the use of low-carbon modes of transportation. U.S. cities with good bicycling infrastructure have nearly twice as many bike commuters as the national average.17
  • Smart Pricing: Americans typically pay nothing to drive on most roads and enjoy the lowest gas taxes in the industrialized world. Government subsidies for driving and parking, along with free access to roads and policies that encourage annual pricing for auto insurance and other costs of driving, create economic signals that encourage Americans to drive and put competing low-carbon transportation modes at an economic disadvantage. Cities around the world have shown that smart pricing policies can reduce congestion and encourage the use of low- carbon modes of travel.18
  • Walking and Biking: Americans prefer walking to any other mode of transportation, according to a recent survey, and the number of people traveling by bicycle in many cities has grown dramatically in the last decade.19 The Institute for Transportation and Development Policy estimates that bicycling alone could curb global carbon dioxide emissions from transportation by 11 percent by 2050.20
  • Information Technology: Advances in technology are enabling Americans to plan, schedule and pay for trips via low-carbon modes as easily as traveling by car. Real-time transit information has already been shown to trigger modest increases in transit ridership.21

In addition, autonomous vehicles can be deployed in ways that reduce greenhouse gas emissions – especially if they facilitate the use of shared mobility services, vehicle electrification and smart pricing. Intelligent public policy can help to realize these benefits while preventing alternative scenarios that lead to marked increases in vehicle travel and pollution.

The smart application of tools from this New Transportation Toolbox can drive large-scale reductions in carbon pollution from transportation consistent with those the United States must achieve if it is to meet its goals under the Paris Climate Agreement.

Not every tool in the toolbox will be equally important everywhere. A New Way Forward describes several pathways by which a variety of cities – dense coastal cities, formerly industrial Midwestern cities, growing Western cities, and the sprawling cities of the Sun Belt – can combine the tools in unique ways to reduce pollution, improve the efficiency of the transportation system, and support economic, public health and societal equity goals.

Such a transformation needs support from federal and state policy.

America has less than 35 years – just over a generation – to virtually eliminate greenhouse gas emissions, including from our transportation system. The infrastructure investments and public policy decisions we make today will shape that transition for decades to come.

The old management dictum states that you can’t manage what you don’t measure.  For decades, the United States has failed to measure the climate impacts of key transportation policy and infrastructure investment decisions, or to incorporate climate concerns into transportation decision-making. At the federal level, and in some states, that is now beginning to change. But to manage the transition, the United States will need to set emissions targets, regularly measure progress toward them, create mechanisms for accountability, and evaluate every major transportation decision, in part, by whether it aids in or hinders progress toward a zero-carbon  transportation system.

Moving Ahead for Progress in the 21st Century (MAP-21) Performance Measures: MAP-21, the federal transportation law adopted in 2012, established performance monitoring, reporting and goal-setting requirements for a range of transportation outcomes, from safety to congestion relief. The performance targets required of states in the law are non-binding.

In 2016, the Obama administration requested comment on a proposal to require states to set greenhouse gas performance standards intended to guide transportation plans.26 The proposed targets would put states on the record for specific greenhouse gas reduction commitments, and allow for evaluation of states’ progress in meeting those targets over time.

Clean Air Act: The federal Clean Air Act empowers the federal government to take action to limit emissions of pollutants from motor vehicles that “may reasonably be anticipated to endanger public health or welfare.”27 The federal government has used this authority to set greenhouse gas standards for light- duty vehicles and heavy-duty trucks. (See page 42).

However, the Clean Air Act also provides a lever to compel states to develop transportation plans consistent with achieving or maintaining healthy air quality. States whose air quality falls short of national ambient air quality standards (NAAQS) are required to adopt state implementation plans that specify the steps states will take to reduce pollution to safe levels, or to maintain clean air in the event the standards have already been met.

The act requires that transportation plans in areas that violate (or have previously violated) clean air standards be assessed for their conformity with clean air goals. 28 The conformity process is designed to ensure that federal money is not spent on transportation projects that will worsen air quality problems.29 But, while greenhouse gases (GHGs) are regulated as pollutants under the Clean Air Act, no NAAQS for greenhouse gases have yet been established by the EPA, and no conformity process for greenhouse gases exists.

In short, until recently, the three main federal statutes that might be used to require assessment, disclosure and accountability for greenhouse gas emissions resulting from transportation infrastructure decisions all failed to do so. Pending improvements in the NEPA process – and the potential adoption of GHG performance measures under MAP-21 – create new opportunities to ensure that climate impacts are considered during the planning of transportation projects.

One notable aspect of federal policy in which climate concerns have been given consideration is in the allocation of funds under the U.S. Department of Transportation’s discretionary capital grant programs. Both the transit “New Starts” and “Small Starts” programs and the Transportation Investment

Generating Economic Recovery (TIGER) grant program consider environmental sustainability – including measures related to the climate – in assessing the projects competing for funding.

Few States Set Greenhouse Gas Limits or Require Projects to Be Evaluated for Climate Impacts

A few leading states have taken action to establish binding limits for greenhouse gas emission reductions across the entire economy, and several also require that climate impacts of transportation plans or projects be quantified in planning efforts. Only California, however, has begun to take the kind of bold steps needed to realign transportation policy with the need to address climate change.

States have several opportunities to set policies to measure and limit carbon pollution from transportation:

Enforceable caps on carbon pollution: Seven U.S. states – California, Connecticut, Hawaii, Maryland, Massachusetts, New Jersey and Rhode Island – have established binding, economy-wide targets for reducing greenhouse gas emissions.32 Of those states, only one – California – has established an enforceable cap on carbon pollution from transportation fuels, which is incorporated within the state’s multi-sector carbon cap-and-trade system. Under California’s program, the carbon cap, which also covers the electric power sector and large industrial facilities, is reduced by 3 percent per year between 2015 and 2020.33

In 2016, Massachusetts’ Supreme Judicial Court ruled that the state had failed to adopt regulations sufficient to ensure that the state’s legally mandated emission reduction targets would be met.34 The decision may result in the adoption of specific regulations for transportation emissions or the inclusion of transportation emissions within a carbon cap-and-trade program.

Many other states have non-binding greenhouse gas emission targets designed to guide policy action, but in many cases, the policy steps called for in those plans have not been implemented.35 A 2012 report produced as part of the National Highway Cooperative Research Project (NHCRP) found that only six states and 12 metropolitan planning organizations (MPOs) of those surveyed had greenhouse gas emissions targets in place.36

Evaluation of transportation projects and policies for climate impacts: The effects of transportation investment decisions and policies on greenhouse gas emissions are often an afterthought – when they are considered at all – by state decision-makers.

Several states require that the greenhouse gas implications of transportation plans or projects be quantified and evaluated during the planning process.

New York, Washington, Massachusetts, California and Oregon, at minimum, require that major transportation projects and/or transportation plans include quantification and assessment of greenhouse gas emissions impacts.37

California, as a result of SB 375, passed in 2008, further requires the state’s Air Resources Board to set regional targets for greenhouse gas emission reductions from passenger transportation and requires metropolitan planning organizations to produce “sustainable communities strategies” that incorporate transportation, land use and housing policies sufficient to meet the targets.38

The vast majority of states have not established binding greenhouse gas emission limits for transportation, nor do they provide clear and consistent guidance regarding how and when the greenhouse gas impacts of transportation projects and plans must be measured. Indeed, the 2012 NHCRP survey cited above found that only 10 percent of state DOTs and MPOs surveyed even considered greenhouse gas emissions in agency planning processes.

Climate considerations are also often missing from debates about transportation policy changes. In recent years, many states have increased the speed limits on their Interstate highways, especially in rural areas, a move that can lead to increased fuel consumption and greenhouse gas emissions. A 2013 study conducted by researchers at the Oak Ridge National Laboratory found that vehicle fuel economy drops by 12 percent on average when speeds increase from 50 to 60 miles per hour, a further 14 percent when speed increases to 70 miles per hour, and an additional 15 percent at 80 miles per hour.39 In states like Pennsylvania, however, fuel consumption and emissions were not considered in decisions to raise speed limits.40 When they have been considered, as was the case when the state of Michigan undertook a comprehensive evaluation of increasing speed limits, the effects on fuel consumption and emissions have been found to be significant.41

The federally required addition of greenhouse gas analysis to the NEPA environmental review process, along with the potential adoption of greenhouse gas performance standards, will lead more states to consider the climate implications of transportation projects and plans. But states’ refusal to take these steps to date, following a quarter-century of mounting evidence of the threat posed by global warming, suggests that continued vigilance will be needed to ensure that climate change is given appropriate weight in transportation decision-making.

Funding Disparity

In 2014, non-user funds – much of them coming from income, property and sales taxes – provided $98 billion in funding for highways, compared with only $45 billion for public transportation.53  In other words, U.S. taxpayers provide more than twice the volume of subsidies to roads than they do to transit.

Since 1995, even as the dangers of global warming and the urgency of switching to low-carbon modes of transport have become more apparent, the balance of public subsidies has shifted even more dramatically toward highways and away from public transportation. According to data from the U.S. Department of Transportation, the amount of non-user revenue (or “supporting funds”) for highways increased by 127 percent in inflation-adjusted terms between 1995 and 2012, compared with a 48 percent increase for public transportation.55

Many state environmental and planning laws require that new development or infrastructure be evaluated for its effects on automobile traffic congestion.66 Level-of-service (LOS) standards, which grade roads on an A through F scale based on traffic flow, are commonly used as an indicator of congestion impacts. These metrics often put urban “infill” developments and facilities such as bus or bike lanes at a disadvantage, even if they reduce vehicle travel or greenhouse gas emissions over a broad area. Worse, they often require developers to mitigate traffic impacts by expanding roadway capacity – often making it more difficult for bicyclists or pedestrians to navigate an area safely.

In California, which enshrined level-of-service metrics in its flagship environmental law, the California Environmental Quality Act (CEQA), infill development projects were far more likely to be the target of CEQA lawsuits than projects on newly developed land, while transit projects were the most frequent target of litigation among public infrastructure projects, according to a study  by the law firm of Holland & Knight.67 California has since removed level-of- service from its evaluation of projects under CEQA, while the federal Department of Transportation has clarified that there are no federally imposed LOS requirements for federally funded highways.68 Many state and local governments, however, continue to use these outmoded metrics.

Level-of-service is not the only measure that privileges the high-speed movement of vehicles over low-carbon transportation options or the development of walkable communities. In 2016, the U.S. Department of Transportation proposed national performance measures for congestion that focused on movement of vehicles, not people, a step that could drive states to deemphasize or devalue the needs of transit riders, pedestrians and people on bikes.69

The Reality: Programs to Reduce or Manage Travel Demand Are Poorly Funded

American transportation policy debates often focus on infrastructure – should we add more lanes of highway or more transit lines? But there is often comparatively little attention paid to, or money spent on, strategies that ensure that our existing infrastructure is used efficiently. Such strategies have the potential to significantly reduce greenhouse gas emissions.

Technology solutions – including smartphone apps like Waze (above) – can help to enable more efficient use of existing infrastructure. But public investment in technological solutions to traffic problems tends to lag well behind investments in infrastructure expansion.

These strategies have long been classified under the term “transportation demand management” (TDM). TDM strategies recognize that it can often be quicker, cheaper and more beneficial to address congestion and other transportation problems by reducing or shifting vehicle travel – through incentives to share rides, work from home, take transit or use active travel modes – than by adding new highway capacity.

High-quality, well-resourced TDM programs have shown impressive results in shifting travel habits. Arlington County, Virginia, for example, operates a comprehensive TDM program that partners with local businesses to provide an array of services – from real-time transit information screens in high-visibility locations to marketing campaigns directed toward residents, workers and visitors. As of 2011, the program helped shift more than 40,000 car trips per workday to higher occupancy modes of travel – reducing vehicle-miles traveled, congestion and pollution.70 The program has a goal of reducing the share of trips taken by single-occupancy vehicles by 0.5 percent each year for the next 20 years. Many colleges and universities have created similar programs aimed toward students and staff.71

Technology solutions can also help to smooth traffic flow and manage demand, using electronic signboards, electronic tolling, automated traffic alerts, ramp metering and trip-planning tools that provide travelers with detailed, real-time information on alternatives to private vehicle travel. These “intelligent transportation systems” have demonstrated the potential to deliver at least modest reductions in carbon emissions.72

TDM programs and technological solutions typically take a back seat to infrastructure expansion. While many cities and business districts have “transportation management associations” (TMAs) – private or public-private organizations charged with helping reduce or manage travel demand – these organizations often focus largely on commuting (which accounts for only 16 percent of all trips in the United States), not the overall travel needs of an area’s residents, and usually operate with limited resources.73 A 2014 survey of 51 TMAs found that more than half had annual budgets of between $100,000 and $500,000 per year.74 Similarly, the Government Accountability Office (GAO) reported in 2012 that deployment of intelligent transportation systems had been “spotty” and their adoption by state and local governments had been “slow.”75

Federal funding for transportation demand management – which accounts for two-thirds of all government TDM funding in the U.S. 76 – comes primarily through the Congestion Mitigation and Air Quality (CMAQ) program.77 However, TDM efforts must compete with a myriad of other transportation programs in pursuit of these funds and receive only 4 percent of all funding allocated under the CMAQ program – approximately $40 million in 2014.78 Intelligent transportation services, meanwhile, receive approximately 0.5 percent of federal surface transportation funding, despite cost-benefit ratios for these technologies that are vastly greater than highway expansions.79

State governments generally fail to prioritize TDM strategies, except during highway construction or other transportation system disruptions.80 There are a few exceptions: Washington State, for example, has a long-running commute trip reduction program that provides technical assistance to employers to help them meet state targets for cutting vehicle trips to workplaces. The program is responsible for reducing approximately 33 million vehicle-miles of travel annually.81

The failure of state and federal governments to take full advantage of the potential for transportation demand management leaves a potentially large pool of low-cost carbon pollution reductions untapped. New modes of shared mobility that provide more ways for people to share vehicles and rides, coupled with improvements in information technology, create vast new opportunities for transportation demand management – if the people, resources and will exist to take advantage of them. Elevating the role of TDM as a strategy for addressing transportation problems can help to tap that potential.

Americans will make low-carbon transportation choices when they are easier, more convenient, more comfortable and cheaper than higher-carbon alternatives. At the very least, government policies should not penalize individuals or companies for making low-carbon transportation choices or reward those making high-carbon choices. And market forces – which serve to balance supply and demand throughout the economy – should be employed appropriately to drive rational decisions by individuals, employers and governments.

Today, however, America’s tax system fails to make drivers pay their fair share of the costs that driving imposes on the public – or even the cost of maintaining the roads on which they travel.82 Key provisions of the tax code actually reward Americans for driving in some cases. Meanwhile, innovative modes of travel are often stifled by inequitable treatment under federal, state and local law.

Market forces, which might be employed to drive the adoption of economically efficient strategies to cut carbon pollution, are largely absent from the management of the transportation network. America’s approach to transportation policy has been derided by some observers as “asphalt

socialism,”83 with free travel on most highways and free parking on many streets fueling excessive demand and shortages (in the form of congestion) that some have likened to Soviet bread lines.84

The result is a system that rewards and encourages people to use high-carbon modes of transportation – undercutting the nation’s efforts to reduce global warming pollution.

The Reality: American Drivers Do Not Pay the Full Costs of Driving

The “polluter pays” principle is a cornerstone of environmental law – asserting that it is the responsibility of those who pollute the environment to pay for restoring the damage. The “user pays” principle has long been enshrined (in theory, if not in practice) as a cornerstone of the U.S. system of transportation finance – asserting that those who benefit from the use of transportation infrastructure should be responsible for its costs.

Both principles lead to one conclusion: to assure fairness and to deliver societally optimal results, those who engage in transportation activities that inflict damage on roads, pollute the environment, contribute to congestion, or impose other impacts on society should be held responsible for paying for the damage. Failing to do so, in effect, subsidizes destructive practices and encourages them to continue.

One of the enduring myths of U.S. transportation policy is that drivers pay for the cost of the roads they use through gas taxes. In reality, however, general taxpayers contribute nearly as much to the construction and maintenance of the nation’s road network as do drivers through so-called “user fees.” In 2014, taxes on general taxpayers supplied $98 billion in highway funding, nearly as much as was supplied through fees such as gas taxes on highway users ($106 billion).85

But driving does more than damage roads – it also damages human health, the environment and community quality of life. A 2007 study by researchers with Resources for the Future estimated that these and other “external costs” of driving was equivalent to approximately $2.10 per gallon of fuel consumed.86

Countries around the world have acknowledged the costs that driving imposes on society by setting high levels of taxation for motor fuels. According to a 2014 report by the Federal Highway Administration, the average gas tax rate in the United States was 42 cents a gallon, compared with more than $4 a gallon in Germany and the United Kingdom.87 In these countries, high gasoline taxes are seen as ways to recoup some of the societal costs imposed by driving, not as ways to raise revenues to pay for highway maintenance and construction.88 Undertaking a similar shift in the purpose of fuel taxes in the United States – or augmenting gas taxes with carbon taxes or other similar fees – would ensure that any increases in taxation do not end up supporting highway expansions that lead to further driving and sprawl.

The Reality: Tax Incentives Provide Rewards for Driving

Governments often use the tax code to encourage societally beneficial behaviors or discourage damaging ones. The U.S. Treasury Department has identified more than 160 “tax expenditures” in the federal income tax code – provisions of the tax code designed, among other things, to incentivize basic scientific research, support adoption of clean energy technologies, and encourage home ownership through the home interest mortgage deduction.90

Tax expenditures function much like government spending – both represent the targeting of resources (taxpayer funds or tax money otherwise owed that is not collected) to specific purposes. State and federal governments provide tax expenditures that exclusively benefit motorists, transferring resources from general taxpayers to those engaged in a polluting activity. 

In addition there are State Sales Tax Exemptions for Motor Fuels.  Drivers in each of the 50 states pay taxes on motor fuel, which in most states are dedicated largely or exclusively to maintenance and operation of the road network (see page 29). However, in many states, drivers receive a countervailing tax subsidy, as motor vehicle fuels are exempt from the general sales tax.

The Reality: Data Collection and Availability Fails to Support Innovation

Existing public sources of transportation data are inadequate to understand the rapid changes taking place in transportation and to support innovation that moves the nation toward a zero-carbon transportation system.  Unlike several other industrialized countries that conduct annual or continuous travel surveys, the U.S. National Household Travel Survey – the sole detailed national survey of transportation behaviors – takes place only irregularly. The last edition was conducted in 2008 and released in 2009, at a time when the mobile Internet revolution was in its infancy and key transportation services such as Uber did not exist. (A new edition of the survey is being conducted in 2016.)

At the same time, vast new reservoirs of data on the daily transportation behaviors of Americans – from cell phone records, crowdsourced data sets, social media, fitness trackers such as Strava and Fitbit, and other sources – create the potential to understand transportation as never before, unlocking potential new strategies for supporting sustainability. While a few agencies have begun to take advantage of new sources of data, public agencies are not guaranteed access to many of these sources, and the level of detail of the data raise privacy concerns.

Governments need to assert their prerogative to obtain data needed to plan and operate the transportation system, and provide access to open data that can fuel innovative strategies, solutions and business models for decarbonizing transportation, even as they safeguard privacy.

Key Principles

  1. Climate concerns should inform every transportation policy
  2. Low-carbon transportation solutions should be at the front of the line for public
  3. Public policy should reward people who make low-carbon transportation
  4. Carbon-intensive vehicles and fuels should be phased out
  5. Public policy should support the development of climate-friendly
  6. Public policy should foster low-carbon transportation


1            Richard F. Weingroff, “Federal Aid Road Act of 1916: Building the Foundation,” Public Roads, Summer 1996, archived at web. archive.org/web/20160910094829/http://www.fhwa.dot.gov/publications/publicroads/96summer/p96su2.cfm.

2           The “80 percent or more by 2050” target has long been used as a guideline for necessary reductions from industrial countries like the United States to prevent dangerous global warming. (See, for example, The White House, Fact Sheet: U.S. Reports its 2025 Emissions Target to the UNFCCC, 31 March 2015, accessed at www.whitehouse.gov/the-press-office/2015/03/31/fact- sheet-us-reports-its-2025-emissions-target-unfccc, 26 April 2016.) Deeper and faster reductions in emissions may be needed to achieve the targets of the Paris Climate Agreement.

3            Per capita emissions: Based on data from World Energy Council, Energy Efficiency Indicators, accessed 2 February 2016, archived  at web.archive.org/web/20160201204437/https://www.wec-indicators.enerdata.eu/transport-co2-intensity.

htm; 4 percent: U.S. emissions: U.S. Environmental Protection Agency, Greenhouse Gas Inventory Data Explorer www3.epa. gov/climatechange/ghgemissions/inventoryexplorer/#allsectors/allgas/econsect/all, accessed 27 April 2016; global GHG emissions: David Victor, Dadi Zhou, et al., “Introductory Chapter,” in Climate Change 2014: Mitigation of Climate Change.

Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, 2014, archived at web.archive.org/web/20160201203321/https://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_ chapter1.pdf.

4            Based on data from World Energy Council, Energy Efficiency Indicators, accessed 2 February 2016, archived at web.archive.org/ web/20160201204437/https://www.wec-indicators.enerdata.eu/transport-co2-intensity.html.

5            U.S. Energy Information Administration, Monthly Energy Review September 2016, 27 September 2016.

6            Ibid.

7            Mike Salisbury and Will Toor, Southwest Energy Efficiency Project, Evaluation of Colorado Electric Vehicle Group Purchase Programs, February 2016; Boulder County, Benefits Boulder County, accessed 10 September 2016, archived at web.archive.org/ web/20160910124123/http://www.bouldercounty.org/env/sustainability/pages/ev.aspx/

8           TriMet, Bike Barometer: Portland Tilikum Crossing, accessed at portland-tilikum-crossing.visio-tools.com/, 10 September 2016.

9            U.S. Department of Transportation, Overwhelming Response by Cities Across the Country to U.S. Department of Transportation Smart City Challenge, 8 February 2016, archived at web.archive.org/web/20161007153201/https://www.transportation.gov/ briefing-room/overwhelming-response-cities-across-country-us-department-transportation-smart-city.

10      See, for example: Michael A. Replogle and Lewis M. Fulton, Institute for Transportation and Development Policy, A Global    High Shift Scenario: Impacts and Potential for More Public Transport, Walking and Cycling with Lower Car Use, September 2014, archived at web.archive.org/web/20160201215853/https://www.itdp.org/wp-content/uploads/2014/09/A-Global- High-Shift-Scenario_WEB.pdf; U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Transportation Energy Futures, March 2013, archived at web.archive.org/web/20160201215635/http://www.nrel.gov/docs/fy13osti/56269. pdf; Rocky Mountain Institute, Reinventing Fire: Projected Decline in U.S. Transportation Sector Fuel Use, 2010-2050, accessed 1 February 2016, archived at web.archive.org/web/20160201220034/http://www.rmi.org/RFGraph-Projected_decline_in_US_ transportation_sector_fuel_use; James Williams, et al., Pathways to Deep Decarbonization in the United States, prepared for

Sustainable Development Solutions Network and the Institute for Sustainable Development and International Relations, 2014, archived at web.archive.org/web/20160201220351/http://unsdsn.org/wp-content/uploads/2014/09/US-Deep-Decarbonization- Report.pdf; Gabe Pacyniak, et al., Georgetown Climate Center, Reducing Greenhouse Gas Emissions from Transportation: Opportunities in the Northeast and Mid-Atlantic, November 2015.

11 See, for example: Jeffery B. Greenblatt and Samveg Saxena, “Autonomous Taxis Could Greatly Reduce Greenhouse Gas Emissions of U.S. Light-duty Vehicles,” Nature Climate Change, 5: 860-863, 2015, DOI: 10.1038/nclimate2685; International Transport Forum, Corporate Partnership Board, Shared Mobility: Innovation for Liveable Cities, 2016.

12  Tony Dutzik and Alana Miller, Frontier Group, A New Way Forward: Envisioning a Transportation System without Climate Pollution, May 2016, available at www.frontiergroup.org/reports/fg/new-way-forward.

13 Current: Rachael Nealer, David Reichmuth and Don Anair, Union of Concerned Scientists, Cleaner Cars from Cradle to Grave: How Electric Cars Beat Gasoline Cars on Lifetime Global Warming Emissions, November 2015.

14 Urban Land Institute, Moving Cooler: An Analysis of Transportation Strategies for Reducing Greenhouse Gas Emissions, July 2009.

15   American Public Transportation Association, Record 10.8 Billion Trips Taken on U.S. Public Transportation in 2014 (news release), 9 March 2015.

16 Frank Gallivan et al., Transportation Research Board of the National Academies, Quantifying Transit’s Impact on GHG Emissions and Energy Use – The Land Use Component, 2015.

17   The League of American Bicyclists, Where We Ride: An Analysis of Bicycling in American Cities, October 2014.

18  Ed Pike, International Council on Clean Transportation, Congestion Charging: Challenges and Opportunities, April 2010.

19 National Association of Realtors, Portland State University, Community & Transportation Preferences Survey, 23 July 2015, archived at web.archive.org/web/20160202174726/http://www.realtor.org/sites/default/files/reports/2015/nar-psu-2015-poll- report.

20 Jacob Mason, Lew Fulton and Zane McDonald, Institute for Transportation & Development Policy and University of California, Davis, A Global High Shift Cycling Scenario: The Potential for Dramatically Increasing Bicycle and E-bike Use in Cities Around the World, with Estimated Energy, CO2, and Cost Impacts, 12 November 2015.

21    Candace Brakewood, Sean Barbeau, and Kari Watkins, “An Experiment Evaluating the Impacts of Real-Time Transit Information on Bus Riders in Tampa, Florida,” Transportation Research Part A: Policy and Practice, Vol. 69: 409-422, November 2014; Candace Brakewood, Sean Barbeau, and Kari Watkins, “The Impact of Real-Time Information on Bus Ridership in New York City,” Transportation Research Part C: Emerging Technologies, Vol. 53: 59-65, April 2015.

22  42 U.S.C. § 4332(2)(C)

23    40 U.S.C. § 1508.8

24 Council on Environmental Quality, CEQ Releases Final Guidance on Greenhouse Gases and Climate Change, accessed 11 September 2016, archived at web.archive.org/web/20160912000823/https://www.whitehouse.gov/administration/eop/ceq/ initiatives/nepa/ghg-guidance.

25 See Amy L. Stein, “Climate Change under NEPA: Avoiding Cursory Consideration of Greenhouse Gases,” University of Colorado Law Review, 81:473-544.

26      81 FR 23805

27  42 U.S.C. § 7521(a)(1)

28 U.S. Department of Transportation, Federal Highway Administration, Air Quality: Transportation Conformity, accessed 11 September 2016, archived at web.archive.org/web/20160912002223/http://www.fhwa.dot.gov/environment/air_quality/ conformity/.

29      James E. McCarthy, Congressional Research Service, Transportation Conformity Under the Clean Air Act, 21 May 2015.

30  81 FR 9935; 78 FR 1992.

31    Carbon dioxide emissions: U.S. Energy Information Administration, State Carbon Dioxide Emissions, “Transportation Emissions by State (1980-2013)”, 26 October 2015; population: U.S. Census, “Table 1. Annual Estimates of the Resident Population for the United States, Regions, States, and Puerto Rico: April 1, 2010 to July 1, 2014”, available at www.census.gov/popest/data/state/ totals/2014/.

32 Elizabeth Ridlington and Jeff Inglis, Frontier Group, Travis Madsen, Environment America Research & Policy Center, Path to the Paris Climate Conference: American Progress in Cutting Carbon Pollution Could Pave the Way for Global Action, Summer 2015

33    California Air Resources Board, Overview of ARB Emissions Trading Program, 9 February 2015.

34   Massachusetts Supreme Judicial Court, Isabel Kain & Others vs. Department of Environmental Protection.

35 For a database of state climate action plans, see Center for Climate Strategies, State and Local Climate Blackboard, accessed at www.climatestrategies.us/policy_tracker/state/index, 12 September 2016,

36      Tiffany Batac, Guido Schattanek and Michael D. Meyer, NCHRP 08-36, Task 107, Synthesis of State DOT and MPO Planning and Analysis Strategies to Reduce Greenhouse Gas Emissions, October 2012.

37 Federal Highway Administration, Climate Mitigation: Questions & Answers, updated January 2016, archived at web.archive. org/web/20160912135919/https://www.fhwa.dot.gov/environment/climate_change/mitigation/q_and_a/; Oregon: Oregon Department of Transportation, Oregon Sustainable Transportation Initiative, accessed 12 September 2016, archived at web. archive.org/web/20160912140825/https://www.oregon.gov/ODOT/TD/OSTI/Pages/Scenarios.aspx.

38 California Air Resources Board, Sustainable Communities, accessed 12 September 2016, archived at web.archive.org/ web/20160912141106/https://www.arb.ca.gov/cc/sb375/sb375.htm.

39 John F. Thomas, Brian H. West and Shean P. Huff, “ORNL Researchers Quantify the Effect of Increasing Highway Speed on Vehicle Fuel Economy,” Green Car Congress, 18 January 2013, archived at web.archive.org/web/20161004141246/http://www. greencarcongress.com/2013/01/thomas-20130117.html.

40 Laura Legere, “As Speed Limits Rise on Pa. Highways, Fuel Economy Falls,” Pittsburgh Post-Gazette PowerSource blog, 10 May 2016.

41 Peter Savolainen, et al., Evaluating the Impacts of Speed Limit Policy Alternatives: Final Report, prepared for the Michigan Department of Transportation, 21 July 2014.

42  See Gilles Duranton and Matthew Turner, The Fundamental Law of Road Congestion: Evidence from U.S. Cities, 8 September 2009; Todd Litman, Victoria Transport Policy Institute, Generated Traffic and Induced Travel: Implications for Transport Planning, 11 May 2016; Susan Handy and Marlon G. Boarnet, Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions (policy brief), prepared for California Air Resources Board, 30 September 2014.

43   Clark Williams-Derry, Sightline Institute, Increases in Greenhouse Gas Emissions from Highway Widening Projects, October 2007.

44 Frank Gallivan, et al., Quantifying Transit’s Impact on GHG Emissions and Energy Use – The Land Use Component, Transit Cooperative Research Program Report 176, 2015.

45 Susan Handy and Marlon G. Boarnet, Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions (policy brief), prepared for California Air Resources Board, 30 September 2014.

46 Congressional Budget Office, Public Spending on Transportation and Water Infrastructure, 1956 to 2014, supplemental data, 2 March 2015.

47  Ibid.

48 Expenditures: U.S. Department of Transportation, Federal Highway Administration, Highway Statistics 2014, Table HF-10, March 2016; GDP: U.S. Bureau of Economic Analysis, Current Dollar and “Real” GDP (Excel file), accessed at www.bea.gov/national/xls/ gdplev.xls, 12 September 2016.

49 Smart Growth America and Taxpayers for Common Sense, Repair Priorities 2014: Transportation Spending Priorities to Save Taxpayer Dollars and Improve Roads, March 2014.

50   2 percent: Alliance for Biking and Walking, Bicycling & Walking in the United States: 2016 Benchmarking Report, 2016; 12 percent: U.S. Department of Transportation and Pedestrian and Bicycle Information Center, The National Bicycling and Walking Study: 15-Year Status Report, May 2010.

51   Alliance for Biking and Walking, Bicycling & Walking in the United States: 2016 Benchmarking Report, 2016.

52 See Tony Dutzik and Gideon Weissman, Frontier Group, Phineas Baxandall, U.S. PIRG Education Fund, Who Pays for Roads? How the “Users Pay” Myth Gets in the Way of Solving America’s Transportation Problems, Spring 2015.

53     $98 billion: Sum of revenue used for highways from property taxes and assessments, general fund appropriations and other taxes and fees from U.S. Department of Transportation, Federal Highway Administration, Highway Statistics 2014, Table HF-10, March 2016; $45 billion including all transit revenues except fares and “other directly generated funds” from U.S. Department of Transportation, Federal Transit Administration, National Transit Database for 2014, tables 1 and 7, accessed at www.transit.dot. gov/ntd/ntd-data, 12 September 2016.

54     Ibid.

55 U.S. Department of Transportation, Government Transportation Financial Statistics 2014, August 2014, Table 10B. “Other sources” includes all revenue sources identified as “supporting revenue,” plus, in the case of transit, funding from the Mass Transit Account of the Highway Trust Fund and state gasoline taxes used for transit and designated as “own-source revenues” by U.S. DOT. “User fees” for highways includes own-source revenues deposited in the Highway Account of the Highway

Trust Fund and all state and local own-source revenues. “Fares and own-source revenues” for transit includes all own-source revenues except revenues dedicated to transit from gas taxes and tolls.

56     Ibid.

57   Robert S. Kirk, Congressional Research Service, Federal-Aid Highway Program (FAHP): In-Brief, 14 January 2016.

58 U.S. Department of Transportation, Federal Transit Administration, Annual Report on Funding Recommendations: Fiscal Year 2017 Capital Investment Grant Program, 2016.

59 U.S. Government Accountability Office, Public Transit: Funding for New Starts and Small Starts Projects, October 2004 through June 2012, November 2012.

60 U.S. Government Accountability Office, Flexible Funding Continues to Play a Role in Supporting State and Local Transportation Priorities, 15 November 2012.

61 Gasoline tax dedication: National Conference of State Legislatures and AASHTO Center for Excellence in Project Finance, Transportation Governance and Finance: A 50-State Review of State Legislatures and Departments of Transportation, Figure 5, 2011 May; Sales tax exemption: American Petroleum Institute, July 2016 State Motor Fuel Taxes by State, August 2016, available at:      www.api.org/oil-and-natural-gas/consumer-information/motor-fuel-taxes.

62    Jamie Rall, et al., National Conference of State Legislatures and AASHTO Center for Excellence in Project Finance, Transportation Governance and Finance: A 50-State Review of State Legislatures and Departments of Transportation, May 2011. In some cases, the text of these provisions can and has been interpreted to allow for some expenditure of state funds for public transportation or other purposes.

63 American Association of State Highway and Transportation Officials, Final Report 2016 – FY 2014 Data: Public Transportation: Survey of State Funding, April 2016. Population data: U.S. Census Bureau. State carbon dioxide emissions from transportation:

U.S. Energy Information Administration, State Carbon Dioxide Emissions with Data for 2013, 26 October 2015.

64 State carbon dioxide pollution from transportation: U.S. Energy Information Administration, State Carbon Dioxide Emissions with Data for 2013, 26 October 2015, accessed at www.eia.gov/environment/emissions/state/; international emissions: Organization for Economic Cooperation and Development, OECD.Stat: Greenhouse Gas Emissions, Table A13, Transport, accessed at stats. oecd.org/Index.aspx?DataSetCode=AIR_GHG#, 12 September 2016. Japan, Germany, France and the United Kingdom emitted 619 million metric tons, carbon dioxide-equivalent, of greenhouse gases in 2014. These four nations house more than 330 million people – more than the population of the entire United States.

65 American Association of State Highway and Transportation Officials, Final Report 2016 – FY 2014 Data: Public Transportation: Survey of State Funding, April 2016.

66 Michelle DeRobertis, et al., “Changing the Paradigm of Traffic Impact Studies: How Typical Traffic Studies Inhibit Sustainable Transportation,” ITE Journal, May 2014.

67 Jennifer Hernandez, David Friedman and Stephanie DeHerrera, Holland & Knight, In the Name of the Environment: How Litigation Abuse Under the California Environmental Quality Act Undermines California’s Environmental, Social Equity and Economic Priorities – and Proposed Reforms to Protect the Environment from CEQA Litigation Abuse, August 2015.

68    Angie Schmitt, “The Feds Want to Reform the Cult of Level of Service,” Streetsblog USA, 28 January 2016.

69 Stephen Lee Davis, Transportation for America, Ten Things to Know About U.S. DOT’s New Proposal for Measuring Traffic Congestion, 20 April 2016, archived at web.archive.org/web/20161004142350/http://t4america.org/2016/04/20/nine-things-to- know-about-usdots-new-proposal-for-measuring-traffic-congestion/.

70 Arlington County (Virginia) Commuter Services, Transportation Demand Management Strategic Plan Update: Fiscal Years 2014 to 2031, 2012.

71 For more details on college TDM efforts, see Will Toor and Spenser W. Havlick, Transportation & Sustainable Campus Communities: Issues, Examples, Solutions, Island Press, 2014; Tom Van Heeke and Elise Sullivan, Frontier Group, Phineas Baxandall, U.S. PIRG Education Fund, A New Course: How Innovative University Programs Are Reducing Driving on Campus and Creating New Models for Transportation Policy, February 2014.

72 Matthew J. Barth, Guoyuan Wu and Kanok Boriboonsomsin, “Intelligent Transportation Systems and Greenhouse Gas Reductions,” Current Sustainable/Renewable Energy Reports, 2(3): 90-97, September 2015, doi: 10.1007/s40518-015-0032-y.

73   “16 percent”: American Association of State Highway and Transportation Officials, Commuting in America 2013: Brief 2: The Role of Commuting in Overall Travel, 2013.

74 Philip L. Winters, Center for Urban Transportation Research, 2014 TMA Survey – Final Results, accessed 12 September 2016, archived at web.archive.org/web/20160912155933/http://www.bestworkplaces.org/wp-content/uploads/2015/07/TMA- Survey-2014-Final-Results-4-7-15-compressed.pdf.

75 U.S. Government Accountability Office, Intelligent Transportation Systems: Improved DOT Communication and Collaboration Could Enhance the Use of Technology to Manage Congestion, March 2012.

76 U.S. Department of Transportation, Federal Highway Administration, Integrating Demand Management into the Transportation Planning Process: A Desk Reference, August 2012, Chapter 11.

77 Steven Higashide, TransitCenter, “How Federal Policy Holds Back Local TDM Innovation and How it Can Help,” The Connnection blog, 24 July 2015; U.S. Department of Transportation, Federal Highway Administration, Air Quality: Congestion Mitigation and Air Quality Improvement (CMAQ) Program, accessed 12 September 2016, archived at web.archive.org/web/20160912161307/ http://www.fhwa.dot.gov/environment/air_quality/cmaq/.

78 Based on data from U.S. Department of Transportation, CMAQ Public Access System, accessed at fhwaapps.fhwa.dot.gov/ cmaq_pub/, 27 September 2016. Includes only spending labeled “Transportation Demand Management.” The CMAQ program also supports programs such as ridesharing and transit improvements that are sometimes supported by Transportation Management Associations and other agencies concerned with TDM strategies.

79 Stephen J. Ezell and Robert D. Atkinson, Information Technology & Innovation Foundation, From Concrete to Chips: Bringing the Surface Transportation Reauthorization into the Digital Age, May 2015.

80 National Cooperative Highway Research Program, Research Reports Digest 348: State Department of Transportation Role in the Implementation of Transportation Demand Management Programs, July 2010.

81    Washington State Commute Trip Reduction Board, 2015 Report to the Legislature, 2015.

82    See note 52.

83    Joe Cortright, “House Republicans’ Asphalt Socialism,” The American Conservative, 17 November 2015.

84   Stephen Crim, “Highway Congestion, America’s Soviet Bread Line Problem, Needs a Price,” Mobility Lab, 7 April 2016.

85 U.S. Department of Transportation, Federal Highway Administration, Highway Statistics 2014, Table HF-10, March 2016. Note: highway user fees contributed an additional $27 billion used for non-highway purposes (public transportation or general government purposes), while governments generated an additional $48 billion in proceeds for highways from bond issues and the use of investment proceeds and other unspecified revenues.

86   Ian W. H. Parry, Margaret Walls and Winston Harrington, Resources for the Future, Automobile Externalities and Policies, revised January 2007.

87   U.S. Department of Transportation, Federal Highway Administration, Highway Statistics 2014, Table IN-1, August 2015.

88   Eno Center for Transportation, The Life and Death of the Highway Trust Fund, December 2014.

89  See note 87; American Petroleum Institute, July 2016 State Motor Fuel Taxes by State, August 2016, available at: www.api.org/ oil-and-natural-gas/consumer-information/motor-fuel-taxes.

90  U.S. Congress, Joint Committee on Taxation, Tax Expenditures, Estimates of Federal Tax Expenditures for Fiscal Years 2015- 2019, 7 December 2015.

91   See note 52.

92  TransitCenter and Frontier Group, Subsidizing Congestion: The Multibillion-Dollar Tax Subsidy That’s Making Your Commute Worse, November 2014.

93    Impacts of bikesharing and carsharing on vehicle ownership, use and/or greenhouse gas emissions: Elliot Martin, Susan Shaheen, and Jeffrey Lidicker, Transportation Sustainability Research Center, University of California Berkeley, “Impact of Carsharing on Household Vehicle Holdings: Results from North American Shared-Use Vehicle Survey,” Transportation Research Record, No 2143: pp 150-158, doi: 10.3141/2143-19, 2010; Susan A. Shaheen, et al., Mineta Transportation Institute, Public Bikesharing in North America During a Period of Rapid Expansion: Understanding Business Models, Industry Trends and User Impacts, October 2014; Elliot Fishman et al., “Bike Share’s Impact On Car Use: Evidence From The United States, Great Britain, and Australia,” Transportation Research Part D: Transport and Environment, 31 (2014): 13-20, doi:10.1016/j.trd.2014.05.013, August 2014; Elliott Martin and Susan Shaheen, Transportation Sustainability Research Center, University of California, Berkeley, Impacts of Car2Go on Vehicle Ownership, Modal Shift, Vehicle-Miles Traveled and Greenhouse Gas Emissions: An Analysis of Five North American Cities (working paper), July 2016.

94 National Conference of State Legislatures, Rental Car Taxes, 18 March 2015, accessed at www.ncsl.org/research/fiscal-policy/ rental-car-taxes.aspx.

95 Joseph P. Schwieterman and Heather Spray, Chaddick Institute for Metropolitan Development at DePaul University, When Sharing Is Taxing: Comparing the Tax Burden on Carsharing Services in Major U.S. Cities, 21 July 2016.

96  Internal Revenue Service, Publication 15-B (2016): Employers Guide to Fringe Benefits, 2016.

97 Bikesharing: Internal Revenue Service, Letter from Lynne Camillo to unknown recipients regarding eligibility of bike-sharing expenses for commuter benefits, 26 July 2013, archived at web.archive.org/web/20160912194647/https://www.irs.gov/pub/ irs-wd/13-0032.pdf; for further discussion of treatment of shared mobility in commuter benefits rules, see: Jordan M. Berry and Paul L. Caron, “Tax Regulation, Transportation Innovation and the Sharing Economy,” University of Chicago Law Review, 82:69-84, 2015.

98 Federal Highway Administration, Toll Facilities in the United States, January 2016, archived at hweb.archive.org/ web/20160912194958/https://www.fhwa.dot.gov/policyinformation/tollpage/.

99    Federal Highway Administration, Highway Statistics 2014, Table HM-220, 1 October 2014.

100   Todd Wallack, “Unlimited Permits Strain Boston’s Parking System,” Boston Globe, 20 January 2015.

101  Jason E. Bordoff and Pascal J. Noel, The Hamilton Project at the Brookings Institution, Pay-As-You-Drive Auto Insurance: A Simple Way to Reduce Driving-Related Harms and Increase Equity, July 2008.

102   Oregon Department of Consumer & Business Services, Pay As You Go Auto Insurance: Available in Oregon?, June 2013, archived at web.archive.org/web/20161004145351/https://www.oregon.gov/DCBS/Insurance/gethelp/Documents/guides/4845-30_pay- as-you-go-insurance.pdf.

103   U.S. Environmental Protection Agency, EPA and NHTSA Propose Standards to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond, June 2015; U.S. Environmental Protection Agency, EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, August 2011.

104 U.S. Environmental Protection Agency, EPA and NHTSA Set Standards to Reduce Greenhouse Gases and Improve Fuel Economy for Model Years 2017-2025 Cars and Light Trucks, August 2012.

105  Peter Faguy, U.S. Department of Energy, Overview of the DOE Advanced Battery R&D Program (Powerpoint presentation), 8 June 2015; Bjorn Nykvist and Mans Nilsson, “Rapidly Falling Costs of Battery Packs for Electric Vehicles,” Nature Climate Change, 5: 329-332, 2015, DOI: doi:10.1038/nclimate2564.

106 Jeff Cobb, “Five Pending 200-Mile Range EVs That Won’t Break the Bank,” HybridCars.com, 25 May 2016, archived at web. archive.org/web/20161007154916/http://www.hybridcars.com/five-pending-200-mile-range-evs-that-wont-break-the-bank/.

107 Sales: Inside EVs, Monthly Plug-In Sales Scorecard, accessed 12 September 2016, archived at web.archive.org/ web/20160912200841/http://insideevs.com/monthly-plug-in-sales-scorecard/.

108 370,000 preorders: Noah Joseph, “Tesla Model 3 Pre-Orders Whittled Down to 373,000,” AutoBlog, 19 May 2016, archived at web.archive.org/web/20160912200604/http://www.autoblog.com/2016/05/19/tesla-model-3-pre-orders-lower-report/.

109 Based on comparison of costs of compliance for the EPA GHG standards between 2012 initial model rule and 2016 mid-term assessment. Source: U.S. Environmental Protection Agency, California Air Resources Board and National Highway Traffic Safety Administration, Draft Technical Assessment Report: Midterm Evaluation of Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards for Model Years 2022-2025, July 2016 ES-9.

110 Steve Hanley, “Netherlands on Verge of Banning New Gasoline Cars by 2025,” CleanTechnica, 16 August 2016; Craig Morris, “Norway Will Not Ban Gas & Diesel Car Sales,” CleanTechnica, 9 June 2016.

111   ZEV Program Implementation Task Force, Multi-State ZEV Action Plan, May 2014.

112 The White House, Fact Sheet: Obama Administration Announces Federal and Private Sector Actions to Accelerate Electric Vehicle Adoption in the United States, 21 July 2016, archived at web.archive.org/web/20160912201753/https://www.whitehouse.gov/ the-press-office/2016/07/21/fact-sheet-obama-administration-announces-federal-and-private-sector.

113 Corn ethanol is required to meet a 20 percent life-cycle greenhouse emission reduction to qualify under the Renewable Fuel Standard, but the extent of life-cycle emission reductions depends greatly on the assumptions used to calculate them.

114   U.S. Environmental Protection Agency, Proposed Renewable Fuel Standards for 2017 and the Biomass-Based Diesel Volume for 2018, accessed 12 September 2016, archived at web.archive.org/web/20160912202043/https://www.epa.gov/renewable- fuel-standard-program/proposed-renewable-fuel-standards-2017-and-biomass-based-diesel; U.S. Environmental Protection Agency, Program Overview for Renewable Fuel Standard Program, accessed 12 September 2016, archived at web.archive.org/ web/20160912202153/https://www.epa.gov/renewable-fuel-standard-program/program-overview-renewable-fuel-standard- program.

115 California Air Resources Board, Low Carbon Fuel Standard: Data Dashboard, accessed 12 September 2016, archived at web. archive.org/web/20160912202337/https://www.arb.ca.gov/fuels/lcfs/dashboard/dashboard.htm

116  Northeast and Mid-Atlantic Low-Carbon Fuel Standard Memorandum of Understanding, 30 December 2009.

117 Based on data from U.S. Energy Information Administration, Electricity Data Browser, accessed at www.eia.gov/electricity/data/ browser/, 12 September 2016.

118  See, for example: Alexander MacDonald et al., “Future Cost-Competitive Electricity Systems and Their Impact on U.S. CO Emissions,” Nature Climate Change, DOI: 10.1038/nclimate2921, 25 January 2016; Mark Jacobson et al., “100% Clean and Renewable Wind, Water, and Sunlight (WWS) All-sector Energy Roadmaps for the 50 United States,” Energy & Environmental Science 2015 8:2093, DOI: 10.1039/C5EE01283J, 27 May 2015; Sven Teske et al., Energy [R]evolution: A Sustainable World Energy Outlook 2015, Greenpeace International, Global Wind Energy Council, Solar PowerEurope, September 2015; James H. Williams et al., Energy and Environmental Economics, Pathways to Deep Decarbonization in the United States, 16 November 2015; Cory Budischak, “Cost-minimized Combinations of Wind Power, Solar Power and Electrochemical Storage, Powering the Grid up to 99.9% of the Time,” Journal of Power Sources, 225: 60-74, 1 March 2013; M.M. Hand et al., National Renewable Energy Laboratory, Renewable Electricity Futures Study, December 2012; WWF, The Energy Report – 100% Renewable Energy by 2050, 2011.

119 Galen Barbose, Lawrence Berkeley National Laboratory, U.S. Renewables Portfolio Standards 2016 Annual Progress Report, April 2016.

120    Ibid.

121 U.S. Department of Energy, Renewable Energy Production Tax Credit, accessed 12 September 2016, archived at web.archive.org/ web/20160912203719/http://energy.gov/savings/renewable-electricity-production-tax-credit-ptc.

122 Solar Energy Industries Association, Solar Investment Tax Credit (ITC), accessed 12 September 2016, archived at web.archive. org/web/20160912203822/http://www.seia.org/policy/finance-tax/solar-investment-tax-credit.

123 “32 percent”: U.S. Environmental Protection Agency, Fact Sheet: Overview of the Clean Power Plan, accessed 4 October 2016, archived at web.archive.org/web/20161004145519/https://www.epa.gov/cleanpowerplan/fact-sheet-overview-clean-power- plan.

124 U.S. Energy Information Administration, Today in Energy: Clean Power Plan Accelerates the Growth of Renewable Generation throughout United States, 17 June 2016, archived at web.archive.org/web/20161004145742/https://www.eia.gov/ todayinenergy/detail.php?id=26712.

125  Smart Growth America, Federal Involvement in Real Estate: A Call for Examination, January 2013.

126 Steven Spears, et al., Impacts of Land-Use Mix on Passenger Vehicle Use and Greenhouse Gas Emissions, prepared for California Air Resources Board, 30 September 2014.

127   Regional Plan Association, The Unintended Consequences of Housing Finance, January 2016.

128 Greg LeRoy, “Subsidizing Sprawl,” Reimagine, accessed 12 September 2016, archived at https://web.archive.org/ web/20160912204328/http://www.reimaginerpe.org/node/27.

129   Greg LeRoy and Leigh McIlvane, Good Jobs First, Paid to Sprawl: Subsidized Job Flight from Cleveland and Cincinnati, July 2011.

130  N. J. Slabbert, “What a Giant, Dysfunctional Federal Agency is Doing to America,” Governing, 1 September 2016.

131  The White House, Housing Development Toolkit, September 2016.

132    Ibid.

133  7 Tex. Trans. 541.001 (1)

134  Scott Le Vine, et al., Vehicle Automation, Legal Standards of Care, and Freeway Capacity (working paper), 21 June 2016.

135  National League of Cities, City of the Future: Technology and Mobility, 2015

136  Colin Campbell, “NC Senate Budget Jeopardizes Durham-Chapel Hill Light Rail,” News & Observer, 3 June 2016; Michael Kranish, “A City’s Immovable Roadblock,” Boston Globe, 10 October 2015.

137   Angie Schmitt, “Advocates Prevail Over Road Diet Ban in North Carolina,” Streetsblog USA, 22 September 2015.

138 See, for example: Nok-Noi Ricker, “Planners Claim State Forced them to Approve I-395 Connector Project,” Bangor Daily News, 26 March 2016.

139   Kail Padgitt, Tax Foundation, State and Local-Option General Sales Tax Rates, 19 August 2010.

140 Eric Sundquist, State Smart Transportation Initiative, Virginia Adopts Multimodal, Competitive Project Scoring Process, 22 June 2015.

141  See, for example, Beth Osborne, The Century Foundation, New Principles for Our Transportation Program, 11 May 2016.

142 For example: C40 Cities, ICLEI USA – Local Governments for Sustainability, the National Association of City Transportation Officers, and others.

143 See additional comments in Center for Neighborhood Technology, Natural Resources Defense Council and United States Public Interest Research Group, Treatment of Greenhouse Gases in the Federal Highway Administration Proposed Rule for National Performance Management Measures, Docket No. FHWA-2013-0054, 8 August 2016, accessed at www.nrdc.org.

144   Charge Ahead California, New California Law Speeds Transition to Electric Vehicles, accessed 12 September 2016, archived at https://web.archive.org/web/20160912210529/http://chargeahead.org/2014/09/new-california-law-speeds-transition-to- electric-vehicles/.

145 Kathy Lindquist and Michel Wendt, Washington State Department of Transportation, Least-Cost Planning in Transportation: Synthesis, 12 April 2012.

146   Michael Cabanatuan, “Parkmerced Plans to Subsidize Residents’ Use of Uber, Muni, BART,” SFGate, 18 May 2016.

147 Ed Pike, International Council on Clean Transportation, Congestion Charging: Challenges and Opportunities, April 2010.

148   26 DE Code Section 1014g

149 See Multi-State ZEV Task Force, www.zevstates.us/.

150 Federal Highway Administration, FAST Act: Transportation Infrastructure Finance and Innovation Act, accessed 12 September 2016,  archived  at web.archive.org/web/20160912213014/https://www.fhwa.dot.gov/fastact/factsheets/tifiafs.cfm.

151 U.S. Department of Transportation, U.S. Transportation Secretary Foxx Announces Four Winning Cities of the Every Place Counts Design Challenge (press release), 27 June 2016.

152 Zia Wadud et al., Help or Hindrance? The Travel, Energy and Carbon Impacts of Highly Automated Vehicles, Transportation Research Part A: Policy and Practice, 86:1-18, April 2016, www.sciencedirect.com/science/article/pii/S0965856415002694.

153 See City of Columbus, Ohio, #SmartColumbus: Application, accessed at www.columbus.gov/smartcolumbus/application/, 4 October 2016.

154  Luz Lazo, “Uber, Lyft Partner with Transportation Authority to Offer Paratransit Customers Service in Boston,” Washington Post,

16 September 2016.