DRCOG reports on 2025 Mitigation Action Plan tied to Colorado transportation GHG rule; staff say measures are voluntary and tracking is challenging

DRCOG Multimodal Transportation Planning Manager Jacob Reagor presented the DRCOG 2025 Mitigation Action Plan annual report March 18, explaining how the mitigation measures fit into statewide greenhouse-gas planning and the Transportation Greenhouse Gas Planning rule that applied to CDOT and the state’s metropolitan planning organizations.

Reagor said the mitigation action plan is the “bottom layer” of a broader compliance effort tied to the Colorado Greenhouse Gas Pollution Reduction Roadmap and the Transportation Commission’s greenhouse-gas rule adopted in December 2021. DRCOG and North Front Range MPO were the first two MPOs to which the rule applied, he said, because their metropolitan planning areas include nonattainment ozone areas requiring regional conformity work.

DRCOG staff modeled investments and changes to the RTP and then used additional policy-based mitigation measures to close remaining reduction gaps for the analysis years 2030, 2040 and 2050. Policy-based mitigation measures DRCOG selected are land-use and policy actions rather than project or service deployments; examples include transit-oriented development incentives, increased residential or job density through rezoning, parking reform, and other locally implemented standards. Reagor emphasized these mitigation measures are voluntary for local governments and are implemented in "strategic and applicable geographies" where they make sense.

Reagor walked the committee through reporting requirements under the rule: quantify and analyze mitigation measures at a regional level, describe implementation status, and report disproportionately impacted community considerations. He said DRCOG has to prepare an annual report, due to the Transportation Commission by April 1, and that this year’s report is under preparation.

Committee members pressed staff on tracking and accountability. Director Adams and multiple members expressed concern about auditability: Rezoning and policy actions are the unit the rule uses (for example, acres rezoned), and DRCOG does not routinely track rezoning actions across 57 member jurisdictions. Reagor said DRCOG’s GIS and modeling work produced conservative geographic screening of where measures might be applicable, but that tracking acres rezoned is administratively difficult and that some measurement approaches in CDOT Policy Directive 16 10 may not map easily to available data.

Members asked whether mitigation measures’ modeled greenhouse-gas reductions are calibrated to observed outcomes. DRCOG staff and committee members said the rule and compliance are model- and forecast-based; local on-the-ground GHG measurement for each mitigation action is not practical. DRCOG will explore support tasks in the upcoming UPWP to help local governments with reporting, data and implementation guidance.

Staff also noted recent state legislation that could affect mitigation measures over time and signaled they are coordinating with CDOT staff, who have their own mitigation action plan and land-use components. No local government is required to implement measures under the DRCOG mitigation action plan; DRCOG staff said the agency’s role is to support, document and report measures that local governments voluntarily adopt.

Committee members recommended continued outreach and additional technical support so jurisdictions can report land-use and parking standard changes if they want to be counted toward the mitigation action plan. DRCOG said it will continue coordination with CDOT and local governments and that the mitigation action plan can be adjusted in future years as implementation data improve.

The committee did not take formal action on the mitigation action plan at the meeting; staff are preparing the annual report and plan to provide implementation support through the UPWP.