The State of Washington’s “top-down” legislative mandate in House Bill 2815 (2008), where the legislature set targets only at the state level and did not include direction on the role of the MPOs, created a much different target setting process than in California – where MPOs largely drove the process of establishing a methodology to assign GHG reduction percentages to the regions that would be “ambitious yet achievable.” Instead, the Governor’s Executive Order (EO) 09-05 directs the Washington State Department of Transportation to work with the four largest MPOs/RTPOs to “develop and adopt regional transportation plans that will, when implemented… reduce GHGs and achieve statutory benchmarks to reduce annual per capita VMT.” There are a few key elements in Washington’s target setting process which differ from California’s, with the underlining difference being that Washington State approached answers to the following RTAC considerations primarily through a legislative directive rather than through a collaborative process involving technical experts and practitioners. While the EO may have intended to consider such issues, the lack of clarity on the EO intent and role of the MPOs is resulting in targets not being applied beyond the state level.
GHG vs VMT
In 2008, House Bill 2815 established GHG emissions and VMT reductions – including goals for GHG emissions reduction to 1990 levels by 2020, and an 18 percent VMT per capita reduction below business–as-usual projections for 2020 (forecasted baseline of 75 billion total VMT, excluding heavy duty vehicles); 30 percent by 2035; and 50% by 2050. While California faced challenges in choosing a methodology to assign regional GHG reduction targets for passenger vehicles, Washington’s major challenges revolve around achieving statutory benchmarks for regional GHG and VMT reduction without a technical advisory team with feasibility and methodology input, or significant MPO engagement on regional GHG reduction efforts.
Absolute vs Relative
Washington is similar to California in that it chose – through the legislative process rather than a technical advisory team – a relative (percentage) approach to setting a VMT reduction target which works toward a statewide absolute GHG reduction goal. However, due to the VMT statute, the discussion has revolved around VMT as a target rather than the full range of transportation and land use strategies needed for comprehensive GHG reduction from travel behavior and network management.
The targets outlined in HB 2815 create a challenge for regional governments responsible for a proportional share of the State’s GHG and VMT reductions because there was no collaborative and technical process that led to the quantification of targets – resulting in legal challenges over compliance with a target that was perhaps too ambitious and not achievable in some regions. Further, the greater issue regarding proportional share was the lack of clarity around the role of the regions. A recent ruling in the Puget Sound Regional Council (PSRC) lawsuit support’s the MPOs assertion that because the State of Washington’s statue on GHG reduction is not inclusive of MPOs, proportional shares are irrelevant – despite being the most populous region in Washington.
Benchmarking: Baseline vs Trend
The issue of establishing a per capita VMT target through a legislative rather than a technical/ collaborative approach extends from measurement metrics to benchmarking. Unlike California which established a 2005 baseline with supporting data, Washington’s HB 2815 established a business-as-usual projection of 75 billion total VMT in 2020 from which the 18 percent VMT per capita target would be measured. The VMT forecasting model using by WSDOT has since increased its sensitivity to VMT reduction strategies. Further, the Department recommended in the 2010 report to the Washington State Legislature that the benchmark be changed from a future to a historic baseline.
Washington’s ambitious GHG and VMT targets are facing political and legal challenges as a result of there being no extensive target setting process based on technical and fiscal constraints at the regional level, and no clear direction on the role of the MPOs in GHG reduction. However, State agencies and Washington’s largest MPOs have increased collaboration due to these types of challenges and as a result are creating a collaborative voice in identifying the need for capacity assistance to develop technical capabilities to develop methodologies and tools to determine GHG and VMT target feasibility. Similar to California’s Blueprint Program laying the foundation for SB 375 collaboration, Washington’s Commute Trip Reduction Law and Growth Management Act in the 1990s resulted in state agency partnerships which have carried into the implementation of HB 2815 – which is one successful area where Washington has seen more progress than California’s state agency silos.
Washington found that benchmarking to a business-as-usual trend forecast is inaccurate, because the VMT target was skewed by the economic recession and resulted in an overly ambitious and not feasible target. The State believes using a historical baseline is much better than a future forecast, as factors such as projections in electric vehicle market share complicate a more accurate, practical, and sensible baseline.