Context: Electrification of vehicles alone will not allow the state to meet the transportation greenhouse gas reductions that are needed For example, the 2021 National Capital Region Transportation Planning Board Climate Change Mitigation Study indicated that the Greater Washington region must reduce per capita driving (light duty VMT) 15 20% below the 2030 baseline forecast under the region’s current transportation plan, ensure 50% of cars sold are EVs by 2030, and take additional actions to reduce emissions at least 50% by 2030. VMTper capita and total VMTwere increasing prior to the COVID 19 pandemic in 2020 and have been increasing since 2021. Buses also produce 1/3 less CO2 per passenger mile than cars. But that is based on average bus occupancy. Buses get far more efficient as ridership goes up (see figure 2 in this FederalTransitAdministration report) Also, since Maryland has a mandate in place to convert MarylandTransitAdministration buses to zero emissions models, the advantage over trips in private vehicles will increase Throughout Maryland, public transit and other strategies to reduce VMThave been underfunded while investments in highway capacity that increases VMTcontinue to rise In the 2023 list of regional transportation projects planned over the next four years in the Baltimore area for example, there were zero dollars for transit capacity or commuter rail but $900 million planned
1800 Washington Blvd Baltimore,
August 30, 2022
Re: Comments Regarding Maryland Commission on Climate ChangeAnnual Report Transportation Recommendations
Dear Maryland Commission on Climate Change Mitigation Working Group, We, the undersigned organizations, encourage the Maryland Commission on Climate Change to incorporate the following transportation recommendations in its annual report.These actions will help Maryland close the emissions gap between the current Maryland Greenhouse Gas ReductionAct (GGRA) Plan that yields approximately 48% reductions by 2030 and the new GGRAgoal of 60% reductions from 2006 levels by 2031 The state should prioritize the communities heavily impacted by transportation pollution and historically excluded from transportation decision making and infrastructure resources, including communities of color, low wealth communities, rural communities, and people with disabilities, in the development and implementation of these policies Items marked in * indicate an updated version of a recommendation from the Commission’s reports in 2020 and 2021.
21230
Maryland Commission on Climate Change, Mitigation Working Group MD
Transit & Land Use: Invest in public transit, bike, pedestrian, transportation demand management and other strategies that reduce vehicle miles traveled (VMT) through mode shift (shifting from using passenger cars to other cleaner modes of transportation like public transit)
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for expanding highway capacity Also, operations budgets for transit agencies in Maryland are insufficient to provide service that is frequent and reliable enough to grow ridership. To address this spending imbalance and reduce GHG emissions, we recommend the following:
○ Require a study to evaluate the use and effectiveness of Priority FundingAreas (PFAs) and designatedTransit-Oriented Development (TOD) areas.The study should review whether general plans, zoning, affordable housing funding, and other factors are aligned with PFAs andTOD designations
○ Create a mechanism to enforce counties’general plan’s housing targets and ensure alignment between the general plan’s land use and PFAs
○ Encourage and allow accessory dwelling units and small multifamily housing in areas near transit centers.
4 The Maryland GeneralAssembly should take legislative action to encourage transit-oriented development, especially transit-oriented affordable housing, to reduce VMT. Such legislation could include:
○ Place caps on parking minimums for all multi use buildings near transit, including offices and multi family residential housing
3 Increase transparency of MDOT spending to guide MDOT and local government planning and budgeting. MDOT’s ConsolidatedTransportation Program (CTP) should include a breakdown of what percentage of total spending goes toward transit, walking and biking MDOT’s CTPshould include a breakdown of what percentage of total spending goes toward new capacity projects that increase the flow of vehicles and/or people versus system preservation projects that maintain the transportation assets we already have MDOT’s future budgets should show sources of all income including federal grants.
2. Maryland should set a goal for reducing VMT 20% under 2019 levels by 2030 and undertake modeling to determine the best alternative or combination of alternatives to reduce VMT The state should also put in mechanisms to track and measure overall VMT as well as measure VMTreduction potential for each proposed transportation project.
1. The state should mandate that 50% of Surface Transportation Block Grant and National Highway Performance Program federal funds be used by state agencies and shared with cities and counties for public transit, bike and pedestrian infrastructure, and Transit Oriented Development programs. These are formula grants that Maryland automatically receives from the federal government each year for transportation programs Maryland’s apportionment in FY2022 was $203 million and $418 million for the SurfaceTransportation Block Grant and National Highway Performance Program, respectively. 50% of these federal funds can be transferred to other programs
5. The state should take immediate action to address significant frequency and reliability issues of current transit service to grow ridership:
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○ Repurpose the existing Harry W Nice Bridge for bike and pedestrian lanes.
○ Complete the cost and construction plan of extending MARC service into Western Maryland (this was required under theTransit Safety & InvestmentAct in 2021 but no concrete action has been taken)
The state legislature should strengthen WMATA’s ability to provide rail and bus service, contingent on parallel action in DC and Virginia, by allowing WMATAto increase year-over-year operating expenditures by more than three percent.
○ In order to address the operator shortage, MTA, WMATA, and the Locally OperatedTransit Systems (LOTS) should actively recruit, hire, and train additional transit operators with necessary incentives including signing bonuses, and the state should help provide the funding for the transit agencies to do so
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7 MDOT should make major changes to the Maryland Commuter Choice program* to increase the number of employers participating from 10 employers (in 2021) to at least 500 starting in 2024, including Maryland's top 32 employers that each employ over 2,500 people.The commuter choice program includes a reimbursement of 50% of employers costs (up to $100 per employee) per month for offering employees qualified commuting benefits programs like transit, cash in lieu of parking, telework and more. Maryland should consider a mandate, similar to what Washington D.C. and New Jersey have, that employers of a certain size must offer sustainable commuter benefit options
6. The state should take the following actions to expand transit service, bike and pedestrian access to grow ridership:
○ Collaborate with the federal government to secure an updated plan, re evaluation of the National Environmental PolicyAct process, Record of Decision, and funding needed to complete the Red Line East West light rail project in Baltimore
8. The Governor should revoke plans to expand I-495 and I-270 with private toll lanes, withdraw plans to build a third Bridge across the Chesapeake Bay, and instead work on comprehensive congestion management plans that will reduce VMT
○ Ensure the completion of the Purple Line*
○ Secure funding needed to implement the MARC Cornerstone Implementation Study and Investment Program, I 270 Corridor Forward Plan, Southern Maryland RapidTransit plan, and MARC run through service to Virginia and Delaware
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Increase frequency of service, including weekend and evening service on transit service throughout the state. Fund transit operating budget increases to close operator shortages and support more frequent service as a strategy to grow ridership.
Transportation electrification: Electrify light medium and heavy duty vehicles
○ Ensure funding and completion of the Frederick DouglassTunnel Project that will dramatically reduce bottlenecks and speed up MARC &Amtrak Service on the Northeast Corridor
5. The GeneralAssembly should allocate funding over a multi-year period dedicated to school bus electrification, including charging infrastructure, and prioritizing school districts in environmental justice communities
1. By 2023, Maryland should adopt theAdvanced Clean Truck rule which will require manufacturers to increase the sale of zero emission trucks and school buses through 2035
3 By the end of 2022, Maryland should adopt California’sAdvanced Clean Cars II standards for 100% of new vehicles sold by 2035 to be zero emission.
2. By 2023, Maryland should adopt the Heavy-Duty Omnibus (low NOx) Regulation that would dramatically reduce the pollutant nitrogen oxide by comprehensively overhauling exhaust emission standards, test procedures and other emissions related requirements.
4 Starting in 2025, require the procurement of zero-emission buses for locally operated transit systems (LOTS)*, and either provide grants to help fund this or provide the administrative support for LOTs to secure grants from other sources such as the federal IIJAprograms The same training and worker protections contained in the legislation governing the transition for new MTAbuses should apply to the LOTS
6. The state should create a multi-agency and stakeholder (including utilities and school districts) working group to accelerate deployment of electric school buses by providing technical assistance and support with applications for federal funding.
Therefore, we recommend the following:
Context: As of July 31, 2022 Maryland has only 52,966 registered EVs and is falling far behind the 2025 goal of 300,000 EVs registered. In addition, Maryland has not taken any significant steps to meet its goal of having 30 percent of all medium and heavy duty vehicle sales in Maryland zero emission vehicles by no later than 2030.This goal outlined in theThe Mediumand Heavy Duty ZEV Memorandum of Understanding (MOU) was modeled by the Maryland Department of Environment as a critical tool to meet even 50% reductions by 2030 Maryland utility programs are also approaching their term ends and are vastly inadequate to meet the projected business as usual Light Duty Vehicle adoption rate of 34% rate by 2030, and the Medium and Heavy Duty ZEV MOU
7 The GeneralAssembly should pass a bill ○ Setting certain requirements for newly constructed buildings to be wired for EV charging; ○ Allocating funding adequate to support the rapid increase in EV adoption needed to meet Maryland’s transportation commitments and regulations or otherwise direct the PSC to authorize utility EVSE (electric vehicle supply equipment) programs* to this effect This money should be used to deploy charging stations in a way that recognizes the power levels and physical needs of light medium and heavy duty vehicles, and identify public and private charging locations that will meet the needs of commercial drivers, while also ensuring strong workforce and equity provisions.
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Directing the MD Office of Energy, MDOT, PSC and MDE to coordinate and take all reasonable steps to maximize the ability of MD entities to take advantage of federal funds, such as the National Electric Vehicle Infrastructure Formula Grant and the Clean School Bus program including by providing administrative support for public entities’grant applications.
This list of recommendations is not all encompassing of what we believe needs to be done in the state to mitigate climate pollution from the transportation sector The state should conduct meaningful inclusive public engagement to ensure communities can shape the development of these and additional policies
Climate Justice Wing Mobilize Frederick Montgomery CountrysideAlliance
8 The Public Service Commission (PSC) should require new utility EVSE program proposals to be submitted that are scaled to building/supporting the EVSE needed for Maryland’s electrification regulations. The PSC should also approve prudent proposals for publicly funded public chargers, incentives for off peak/managed charging, pass through requirements for fuel cost savings, and adoption of an open system for payment
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Sincerely, ArchPlan Inc Audubon Mid Atlantic Audubon Naturalist Society Bikemore Cedar Lane Environmental Justice Ministry Central MarylandTransportationAlliance Ceres Chesapeake ClimateAction Network Climate Reality Montgomery County Coalition for Smarter Growth Disability Rights Maryland Downtown ResidentsAdvocacy Network (Baltimore) Elders ClimateAction Maryland Chapter Elizabeth Bunn Glen Echo Heights Mobilization Greenbelt ClimateAction Network (GCAN) Labor Network for Sustainability League of Women Voters of Maryland Locust Point Community Garden
The
comprehensive,
George's County DSA Strong Future Maryland
Choices Union of Concerned Scientists
Universalist Legislative Ministry of Maryland WashingtonArea BicyclistAssociation
Conservation Council Maryland League of Conservation Voters Maryland Legislative Coalition Maryland Nonprofits Maryland PIRG Maryland Sierra Club
Climate Mobilization Montgomery County Chapter (TCM MoCo)
Maryland
MLC
Transit
Unitarian