Attorney General Peter F. Neronha has submitted a comment letter regarding the recent proposal by the Rhode Island Department of Transportation (RIDOT) intended to reduce the state’s carbon emissions, stating it is misguided in its approach, unambitious in its goals, and ultimately risks wasting millions of dollars of federal funds.
In the comment letter, Attorney General Neronha contends that RIDOT’s proposal did not specify how it would reduce carbon emissions, and instead proposed using a majority of the funds for pre-planned highway maintenance projects, under the moniker of “congestion reduction,” even as it acknowledged these projects “will not substantially ‘move the needle’ when it comes to carbon reduction.”
RIDOT has to submit a Carbon Reduction Strategy in order to qualify for an additional $35.7 million of federal funds for the Ocean State under the U.S. Department of Transportation’s Carbon Reduction Program. The strategy has to specify how the plan would reduce carbon emissions – which the Attorney General contends it fails to do. RIDOT’s strategy is also an opportunity to plan how Rhode Island’s transportation sector will meet important mandates set forth in the 2021 Act on Climate. The transportation sector is responsible for at least 36% of the state’s greenhouse gas emissions.
Additionally, the Attorney General warns that RIDOT’s strategy falls far short of the goals and priorities in the statewide plan developed by the Executive Climate Change Coordinating Council (EC4) in 2022. The EC4, of which RIDOT is a member, is tasked with creating a statewide plan to reduce greenhouse gas emissions, in part to meet the mandates of the state’s Act on Climate.
“As a lifelong Rhode Islander, I know climate change is already impacting our state’s people and natural environment. It is concerning, to say the least, when I see that RIDOT’s plan for critical federal dollars for carbon reductions fails to meet the moment; not only falling short of the goals we must meet, but suggesting a proposal at odds with the existing statewide plan to reduce greenhouse gas emissions,” said Attorney General Neronha. “Rhode Island needs every state agency to use all available federal carbon reduction funds to support coordinated, statewide efforts. The Act on Climate was a bold step towards addressing climate change, and collectively we need to take a hard look at how we are going to meet critical greenhouse gas emission reduction goals.”
The U.S. Department of Transportation’s Carbon Reduction Program has made additional $35.7 million in FY 2022-25 in federal transportation funds available to RIDOT as a result of the Bipartisan Infrastructure Law. The Carbon Reduction Strategy must be certified by USDOT in order to receive these federal funds.
The Attorney General detailed specific examples of the ways RIDOT’s proposed plan fall short of meaningful reductions, including:
- RIDOT did not tie its Carbon Reduction Strategy to EC4’s just-issued 2022 Update.
- The plan did not include ready-made carbon reducing plans like the Transit Master Plan designed to shift transportation to cleaner alternatives.
- The plan proposed a majority of the funds be used for pre-planned highway maintenance projects, justifying this use as “congestion reduction,” while acknowledging these projects “will not substantially ‘move the needle’ when it comes to carbon reduction.”
- RIDOT’s proposal failed to disclose how it would lead to reduction in carbon emissions.
- Inadequate funding of replacement of RIDOT fleet vehicles with electric vehicles;
- Inadequate funding for building EV infrastructure.
- RIDOT’s process did not provide an adequate level of stakeholder engagement, potentially leaving good ideas on the table.
- Funds are dedicated to bicycle infrastructure maintenance, as opposed to new construction of bicycle or pedestrian routes that could help more people replace some car trips.
Leading on Climate Change Action and Protecting our natural environment
The Attorney General’s comment letter follows additional environmental protection and climate-based actions, including the pending climate change lawsuit against 21 major fossil fuel companies; filing suit to stop the discharge of sewage into the Blackstone River; suing manufacturers of toxic “forever chemicals”; securing more than $200 million in value for RI ratepayers and Act on Climate mandates in PPL-Narragansett Electric sale; reaching settlements worth nearly $20 million dollars with major gas companies for MTBE contamination; and successfully challenging in the Rhode Island Supreme Court the unlawful expansion of a marina on Block Island, among others.
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