October 6, 2026
Oregon Transportation Commission
355 Capitol Street NE Salem, Oregon 97301
RE: Statewide Transportation Strategy Monitoring Report
Dear Commissioners:
For the past three years, 350 Salem Oregon has closely monitored the state’s efforts to reduce greenhouse gas emissions from transportation and has provided extensive comments to the Oregon Department of Transportation (ODOT) and the Department of Land Conservation and Development.
We are deeply concerned about the Oregon Transportation Commission’s and ODOT’s ambivalent response to ODOT’s recent revelation that Oregon is projected to achieve only a 10 percent reduction in transportation greenhouse gas emissions by 2050. This falls dramatically short of the 75–80 percent reduction called for in Oregon’s adopted climate goals.
Oregon’s Failure to Meet Its Climate Goals
The projected 10 percent reduction by 2050 is not a minor deviation from Oregon’s intended path. It represents a fundamental failure of the state’s transportation policies, investments, and implementation efforts. After more than a decade of planning and action, Oregon is not on track to meet its emissions or vehicle miles traveled (VMT) reduction targets.
ODOT’s recently updated Oregon Transportation Emissions Website, released on September 15th, provides an incomplete assessment of Oregon’s progress. It does not clearly explain how far the state has fallen behind its emissions and VMT goals, why progress has been so limited, or what actions are necessary to correct the course. It also provides insufficient links to supporting reports, data, and technical analyses.
Federal Policy Changes Do Not Explain the Lack of Progress
ODOT appears to place substantial responsibility for Oregon’s failure to meet its climate goals on recent federal decisions to roll back climate policies and programs. Federal policy changes do make future progress more difficult, but they do not explain Oregon’s lack of meaningful progress during the past decade. For much of that period, Oregon benefited from strong federal support for climate action, yet the state failed to achieve the reductions anticipated in the Statewide Transportation Strategy (STS) and the Land Conservation and Development Commission’s Target Rules.
Two state-level factors are more significant.
First, state agencies have continued to rely on outdated forecasts that substantially overestimated how quickly Oregonians would adopt low-carbon vehicles, fuel-efficient vehicles, and cleaner fuels. Although progress has occurred, it has taken place at approximately 1 percent per year rather than the 4 percent annual rate assumed in the STS and Target Rules. Oregon is therefore several years behind the trajectory established in its adopted plans.
Second, Oregon has made little progress implementing strategies designed to reduce VMT. Metropolitan areas are not planning for most new housing and employment to be located in walkable, mixed-use neighborhoods. The state has not made the investments necessary to significantly increase walking, bicycling, and transit use. Transportation-demand-management programs do not provide meaningful financial incentives for people to drive less, and transportation funding policies do not adequately encourage alternatives to driving.
Attributing the shortfall primarily to federal policy changes diverts attention from these longstanding state-level failures.
ODOT’s Responsibility Under the STS and Executive Order 20-04
ODOT’s responsibility now is not merely to document Oregon’s failure to meet its climate goals. Under the STS and Executive Order 20-04, ODOT must identify and commit to specific actions that will enable the state to meet those goals.
The purpose of regular monitoring reports is to assess how the state is performing relative to its emissions goals. When progress is inadequate, the STS review process is intended to trigger consideration of new or additional actions. The STS states:
“The broad 40-year course of action charted in the STS is agile and can be adapted to an evolving future and unforeseen opportunities. Progress will be monitored over time and the course adjusted accordingly. The STS allows flexibility in what strategies and actions may be pursued and points to those projected to be effective at achieving the intent of the legislation.”
Oregon’s Climate Action Plan, Executive Order 20-04 directs agencies to:
“…exercise any and all authority and discretion vested in them by law to help facilitate Oregon’s achievement of the GHG emissions reduction goals” It further provides that agencies shall, to the full extent allowed by law, integrate climate change and the state’s greenhouse gas reduction goals into their planning, budgets, investments, and policymaking decisions, while prioritizing cost-effective emissions reductions.
Consistent with these directives, ODOT should identify, evaluate, and commit to specific actions capable of producing the emissions and VMT reductions Oregon needs. A monitoring report that simply documents the shortfall—or attributes it primarily to federal policy changes—does not fulfill the purpose of the STS review process or Executive Order 20-04.
As outlined in our comments to the Oregon Climate Action Commission, the Transportation Commission should direct ODOT to propose specific actions to get the STS on track, including:
● Update vehicle-emissions forecasts using actual experience, current
trends, and current federal policies;
● Recalculate Oregon’s VMT-reduction targets to account for the lack of progress and the state’s more ambitious climate goals;
● Require walkable, mixed-use development;
● Prioritize investments that substantially increase walking, bicycling, and transit use;
● Establish transportation-demand-management programs with
meaningful financial incentives;
● Reform transportation funding through measures such as congestion
pricing and pay-as-you-drive insurance; and
● Pause major highway-expansion projects until Oregon demonstrates
measurable progress toward its emissions and VMT goals.
Oregon will not meet its climate commitments through optimistic forecasts, incremental measures, or a passive response to a projected 10 percent reduction in transportation emissions by 2050. ODOT must acknowledge the magnitude of the failure and fulfill its responsibilities under the STS and Executive Order 20-04 by committing to concrete, effective actions that will return Oregon to a path consistent with its adopted climate goals.
Sincerely,
Bob Cortright
Phil Carver
On behalf of 350 Salem Oregon
Attachment: 350 Salem to Oregon Climate Action Commission