Providence Urbanist Network

Peter Alviti, Jr. P.E., Director
Rhode Island Department of Transportation
2 Capitol Hill
Providence, RI 02903

Following are the Providence Urbanist Network's (PUN) comments on the Rhode Island Department of Transportation's draft Carbon Reduction Strategy (CRS). As currently written, this strategy is wholly inadequate to meaningfully reduce emissions, let alone meet the state's Act on Climate targets. It starts with a lack of ambition, essentially ignoring the state's critical 2030 target, and follows this up with a lack of a meaningful plan of action. These failures are accompanied by questionable claims about the efficacy and cost-effectiveness of existing and planned approaches and an absence of evidence to support RIDOT's claims.

In order for this plan to resemble a legitimate strategy to reduce greenhouse gas emissions in the transportation sector and for transportation to play its part in meeting Rhode Island's Act on Climate mandate, several things will need to change.

First, RIDOT needs to increase its ambition. RIDOT has set its current goal for Rhode Island's annual transportation emissions to decline to 2.79 million metric tons of CO2 equivalent (MMTCO2e) by 2030 (CRS Section 1, Figure 1.1). Based on the 3.2 MMTCO2e figure provided for 2021, this would result in reductions of only 410,000 tons by 2030, a paltry 13% reduction over nine years - and one that would entirely be met without further state action.

By law Rhode Island needs to reduce overall emission 45% by 2030. When counting for emissions reductions from 1990-2020 (the last year with full data publicly available), this still means a 32% decrease, economy-wide.

With RIDOT planning for such weak performance from the transportation sector, other sectors will likely not be able to make up the gap in order for the state to reduce annual emissions by the full 2.88 MMTCO2e that is needed by 2030 (from 2020 levels). Even when accounting for the progress that Rhode Island plans for its electricity sector, it is still critical that transportation do its share given how difficult it will be to reduce emissions in the residential and commercial heating sectors and the industrial sector. In the residential and commercial heating sectors, the pace of electrification is fundamentally challenged by the enormous stock of existing buildings with gas and oil heating. In the industrial sector, solutions for industrial decarbonization are not as mature as they are for other sectors.

As such, RIDOT should set a more aggressive goal and aim to reduce annual transportation emissions to 2.2 MMTCO2e by 2030, 1 MMTCO2e and a 31% decrease from 2021 levels. This would require RIDOT to take meaningful action to reduce emissions, unlike what is envisioned in the current draft of the strategy.

Second, RIDOT needs to back up an increased ambition with action. RIDOT's only currently employed method of reducing emissions cited to date (CRS Section 8) is various highway projects to decrease congestion. However, the volume of reductions RIDOT claims through existing and planned congestion reduction projects is simply not to scale with the changes needed. The aggregate 10,520 tons of CO2e per year in reductions attributed to the three highway projects underway (CRS Section 8.3) is 0.1% of the 1 million MMTCO2e of reductions that RIDOT should be aiming for, and only 2.6% of the contribution to its existing, inadequate, target.