March 24, 2026

Hon. Reuben Collins, Board Chair
Hon. Cindy Dyballa, CEEPC Chair
Mr. Clark Mercer, Executive Director
Metropolitan Washington Council of Governments

Re: COG must prepare a strong Mid-Course Review of the region’s 2030 Climate Plan

Board Chair Collins, CEEPC Chair Dyballa and Mr. Mercer:

The Coalition for Smarter Growth greatly appreciates the work of the Metropolitan Washington Council of Governments coordinating regional climate change analysis and policy.

As we get closer to 2030 and a critical milestone year for preventing disastrous climate change, it is critical that COG’s Mid-Course Review of the region’s 2030 Climate and Energy Action Plan (2030 CEAP) provide a clear and accountable progress update for officials and the public. Given the lack of a federal partner in addressing climate change, transparency and accountability on
climate action at the local and regional levels are that much more important.

We ask that the Mid-Course Review draft report be revised to clearly communicate that the region is off course in reducing climate pollution to safe levels and the key action areas to get us back on track.

Specifically, we ask that the draft Mid-Course Review Report be revised to:

1. State clearly up front that the region is not on track to meet its 2030 GHG target and more urgent action is needed. On the key question of whether or not the region is on track to meet its 2030 greenhouse gas commitments, the answer is “No.” This failure needs to be clearly stated up front rather than buried inside the report in technical language. Our busy elected officials need clear, actionable information.

2. Show 2030 targets for the performance indicators – To effectively communicate progress toward a goal, a chart must show the goal target. COG and the 2030 CEAP have 2030 target levels for most of the performance indicators, and these need to be shown on the graphic charts, not just mentioned elsewhere deep in a paragraph. COG has identified needed 2030 target levels for: Grid Connected Renewables, Electric Vehicle ownership, Electric Vehicle charging stations, per capita Vehicle Miles Traveled, Waste Diversion, and Tree Canopy – these all need to be shown on the progress charts.

3. Separate out data centers from commercial buildings. Data centers are not simply commercial buildings, and the tremendous energy needs and emissions need to be shown in the report. COG has already done some of this work and rather than including a footnoted reference to a separate report, the Mid-Course Review needs to clearly show the impact of existing data centers and the enormous pipeline of approvals.

4. Include the recent Visualize 2050 transportation emissions analysis – COG data from the Visualize 2050 plan show the region will miss 2030 and 2050 GHG reduction targets for transportation, one of the most important sectors. Studies by COG’s Transportation Planning Board have shown that per capita resident Vehicle Miles Traveled (VMT) need to decline by 20% by 2030, in addition to a rapid transition to electric vehicles, to meet the COG 2030 CEAP. Yet Visualize 2050 maintains a high level of car dependence, with per capita resident VMT only declining by 5% by 2050. Officials need to know this, because the Visualize plan is largely a collection of local transportation and land use policy decisions under their control.

5. Housing is a critical regional issue – and an action in the climate plan – and needs to be included in the Review. Housing in activity centers and near transit is one of the 2030 CEAP’s actions – and is a core component of COG’s adopted plans and policies (e.g., Region United, 2019 Housing Targets, Region Forward, Visualize 2050) – but it has been excluded from the selected Mid-Course Review performance indicators. Land use is an underreported but key factor driving metropolitan area GHG emissions. Multiple studies show that walkable, mixed-use, compact land use is critical to meeting climate targets.

6. Important context of current trends through 2030 is needed – Recent policies and data from our region show troubling trends and projections. For example:

• Far faster data center growth in the next five years. The pipeline for new data centers is five times Northern Virginia’s current data center volume;
• New fossil fuel powered electric plants (e.g., Dominion is planning six), and further fossil gas distribution infrastructure investment (DC, VA);
• Slower electric vehicle (EV) adoption;
• 500 to 1,200 new lane miles of widened highways and arterials planned;
• Recent Maryland data showing the state will miss its 2031 GHG target, with the transportation sector highlighted for insufficient progress.

7. State the key action steps to meet regional and local GHG reduction targets.

• Smart growth – meeting our housing goals and prioritizing walkable, transit-friendly, inclusive communities, and transportation demand management, instead of funding highway and arterial expansion.
• Data center accountability – holding the industry and state officials accountable for its expensive infrastructure and energy needs as well as pollution.
• Energy efficient building codes – making progress at the state and local levels.
• Following through on state clean energy goals – rather than backtracking to build new fossil fuel power plants and distribution infrastructure.

We note that elected officials and other stakeholders on the COG Climate Energy and Environment Policy Committee have also brought up these points.

We appreciate the work of COG staff in assembling data and analysis to inform our region’s officials on their progress implementing climate actions and achieving GHG reduction targets.
The report draft does a good job highlighting successes and best practices by our local jurisdictions that we applaud. But the report also needs a clear call for more urgent action up
top.

These recommended changes to the report can be done expeditiously using available data; the one exception, the housing targets, could be provided later this spring or summer as an
addendum. The Mid-Course Review report must provide a clear picture of where we are and where our region must make more effort over the rest of the decade.

Thank you for your consideration,

Bill Pugh, AICP CTP
Transportation & Climate Director
Coalition for Smarter Growth