Maryland: Comments on Frederick draft Climate and Energy Action Plan

Posted on by Elena Sorokina

August 22, 2025
Rayla Bellis
Climate and Energy Manager
Department of Climate and Energy
Frederick County, MD

Jenny Willoughby
Sustainability Manager
City of Frederick

Re: Comments on Frederick draft Climate and Energy Action Plan

Frederick County and City of Frederick officials and staff:

On behalf of the Coalition for Smarter Growth, I am submitting the following comments on the draft Frederick Climate and Energy Action Plan. Our organization advocates for walkable, bikeable, inclusive, and transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all. We have been working in the region for over 28 years.

We commend Frederick County and the City of Frederick for preparing this plan and setting targets to reduce greenhouse gas emissions by 50% by 2030 (from 2010 baseline) and 100% by 2050.

1. Set necessary VMT reduction and EV adoption performance benchmarks to achieve transportation and overall emissions reductions

  • Reduce per capita light duty VMT by 20% by the 2030’s and further by 2050
  • Set both ambitious and feasible goals for EV adoption by 2030 and 2035 consistent with State of Maryland and regional targets 

Transportation is the county’s biggest source of emissions, almost half (49% total; 45% on-road), so it is critical to set sufficiently strong benchmarks that reflect what is needed to achieve the plan’s overall GHG reduction targets. 

We are glad to see that the plan sets strategies to both speed up adoption of electric vehicles (EVs) and reduce vehicle miles traveled (VMT) – strategies T1 and T2, and the list of action categories under T2.

The plan should set performance benchmarks for these two metrics so decisionmakers and stakeholders can track progress. 

  • The National Capital Region Transportation Planning Board’s (TPB) 2021 Climate Change Mitigation Study found that the region must more urgently move to walkable, transit-oriented communities and implement more robust travel demand management programs in addition to transitioning to electric vehicles. 
  • The study (similar to national studies) found that the region must reduce per capita VMT of passenger cars by about 20% by 2030, with further reductions of around 25-30% in later decades, for the region to achieve the COG GHG targets, which are similar to Frederick County and City’s targets. (This level of VMT reduction is accompanied by a relatively aggressive shift to EVs, 50% of light duty sales by 2030).  
  • The draft Frederick plan assumes a “reduction in vehicle miles traveled of 7% by 2035 and 9% by 2050, which would result from land use changes, travel demand management strategies, transit enhancement, and bike, pedestrian, and micro-mobility improvements” (p. 58) Note that the plan is unclear if this is per capita VMT, total VMT, and/or specifically light duty VMT; and if the percentage reductions are aspirational goals or assumed based on currently programmed projects. In any case, the plan’s future VMT levels appear to be inadequate to achieve its overall GHG targets.
  • The need to reduce per capita VMT by 20% and further, are why numerous states, including the State of Maryland, have set goals to reduce per capita VMT by 20% or more.
  • Fostering a more walkable, bikeable, transit-friendly Frederick County and City – enabling residents and workers to drive less for daily needs – also increases affordability for families and workers, provides health and safety benefits, and results in cleaner air and water that EVs alone cannot provide. We appreciate that the plan reflects this in the descriptions of strategy T2 and the action categories. 

2. Redirect transportation investment away from highway and arterial expansion to safe, convenient walking, biking and transit, and also to making existing transportation resilient to the impacts of climate change

The Climate and Energy Action Plan should acknowledge the role of induced demand, by which highway and arterial widening causes net increases in driving and emissions, while not solving congestion.

Achieving the plan’s strategy to “Harden Transportation infrastructure to withstand future climate impacts” will require significant financial investment. The high cost of planned highway and arterial widening and new interchanges in Frederick County would take resources away from hardening existing infrastructure, while also worsening the County’s transportation emissions. 

3. Focusing new housing and affordable housing near jobs, transit and services is an important climate and equity action and needs follow-on implementation in planning and zoning

CSG applauds the plan’s action category T2.4 “Support population growth with new housing developed in communities that are walkable, bikeable, transit-supportive, and mixed-use.”

To accommodate a growing population while promoting sustainability, this measure will encourage the development of new housing in communities that are walkable, bikeable, transit-supportive, and mixed-use. Prioritizing these types of communities helps reduce car dependency, lower greenhouse gas emissions, and enhance quality of life for Frederick’s community members. It is imperative that transit-friendly design is incorporated into the planning processes in Frederick as development patterns will be instrumental in influencing the number of community-wide VMT. (p. 66)

It is critical that the County and City establish concrete actions and policies in planning, zoning, and housing that implement this. 

4. Add an action category to strategy T2 for Transportation Demand Management (TDM) and operations programs that both reduce emissions and improve mobility 

Transportation demand management programs should be added to complement the plan’s transit, bike and pedestrian action categories. The TPB’s Long-Range Plan Study showed that more robust travel demand management programs would be one of the top mobility strategies for the region – much more effective than highway expansion. The TPB’s Climate Change Mitigation Study and follow-on Implementation Considerations study also showed that travel demand management and pricing programs will be critical to reducing GHG emissions. 

Operational strategies can complement TDM. The I-270 Innovative Congestion Management program is an example of how even modest operations improvements have travel benefits without highway capacity expansion.

Thank you for your consideration and work on this plan.
Sincerely,
Bill Pugh, AICP CTP
Senior Policy Fellow
CC: Mobilize Frederick