The Minnesota Department of Transportation wants your comments on their new Statewide Multimodal Transportation Plan. In general, I found many of the strategies overly ambiguous, at least when compared with the old plan. But they score points for including context-sensitive design and land use-transportation connection references.
Most of my comments deal with the almost total absence of discussion in the document of climate change, transportation system’s contribution to it, or potential solutions. Here are my comments:
- Page 9 – The plan inaccurately states that the Next Generation Energy Act calls for a 25% reduction in GHG emissions by 2025. The Act calls for a 30% reduction by 2025. It also calls for an 80 reduction by 2050. The plan should note this last goal, since by 2032 (the time horizon of this plan) we’ll be well on our way there.
- Given that these goals are adopted state law, I think the plan should spell out transportation’s contribution to the problem (24% in 2005 according to the State’s inventory).
- These contributions and the adopted state law should also be referenced in Chapter 3, which identifies the policy framework that impacts transportation planning.
- Given these impacts and adopted targets, I find chapter 4 almost totally lacking in any reference to MNDOT’s approach to meeting these targets. The words “greenhouse gas emissions” do not even appear in this chapter. Approaches to mitigating emissions from the transportation sector are many, but basically boil down to: 1) reducing VMT, 2) switching to more efficient modes (transit, bicycle) and/or 3) switching fuels (The Minnesota Climate Change Advisory Group’s Final Report includes a robust set of transportation-related recommendations). I understand that this is a high-level policy document, but failing to address this issue at this stage is a very significant oversight in my opinion. In addition, this document actually appears to be a step backwards from the previously adopted Statewide Transportation Plan, which specifically references the emissions reduction goals adopted by the State, pledges that MNDOT will advance these goals, and identifies strategies it will pursue in accordance.
- I appreciate the plan’s focus on “System Security”. However, all the strategies listed here (page 79) address responses to “emergency events”. I recommend another strategy be added to begin assessing potential risks MNDOT’s systems may face in the next 20 years. The Upper Midwest has seen a 31 percent increase in “intense” rainfalls in the last 50 years. A focus on designing our systems differently, rather than reacting to “emergencies” will likely be much more cost-effective in the long run.
- The first strategy on page 72 seems to imply the application of cost-benefit analysis to new projects. While this is a positive step, I think the plan should describe how MNDOT will begin to identify all those “costs” and “benefits” and apply them in a rigorous way.
- The section on “Transportation in Context” starting on page 78 is very welcome, especially reference to the importance of the connection between transportation and land use decisions.
- While the plan references MNDOT’s performance measures, no measures are identified for the multimodal plan as a whole, or for specific strategies identified within it. The previous version of the system plan included performance measures to track progress and I would suggest that MNDOT continue this approach.