DOT Just Checking Federal Box, Not Measuring Effectiveness of Efforts to Reduce Carbon Emissions

SDDOT’s Carbon Reduction Strategy meets all the requirements of 23 U.S.C. 175(d)(2) by identifying projects and strategies to limit emissions. A critical aspect of addressing these requirements is Congress’s direction that the program be appropriate to the population density and context of the State because a program that is appropriate, economically efficient, and practical will best shape its implementation. Following this Congressional recognition will avoid creating economic and lifestyle hardships and restrictions on the freedom of travel. Another critical aspect is that any quantification of emissions by the State is at the State’s discretion. South Dakota chose not to do quantification [emphasis in original; South Dakota Department of Transportation, draft Carbon Reduction Strategy, 2023.06.09, pp. 37–38].

I’d like to think the DOT is taking the comforting and folksy philosophical perspective that not everything that counts can be counted. But it seems more likely that the DOT is looking for ways to meet the bare minimum statutory requirement of composing a carbon reduction plan without committing to taking such a green-smelling plan seriously. We’re not talking about love, beauty, or chocolate chip cookies (don’t count them; just eat and enjoy!); we’re talking about a measurable substance produced by measurable economic activities with measurable environmental impacts. When it comes to public policy, more often than not and most certainly in this case, if we don’t count it, it doesn’t count.