S1E5: Colorado's ETRP

May 20, 2021

Andy Keeton

VP Global Strategy

Between the Lines S1E5: Colorado's Employee Traffic Reduction Program (ETRP)

with Claybourne Clarke


Why will Colorado's Employee Traffic Reduction Program (ETRP) save the planet?

Join us for this week's episode of Between the Lines, as we speak with Claybourne Clarke, Supervisor of the Colorado Department of Public Health & Environment's Climate Unit, about a potential regulation in the Denver Front Range that would have a dramatic impact on commute-based emissions in the region. (*Note: Claybourne Clarke is speaking as a private citizen and not on behalf of CDPHE or the State of Colorado.)

And check out Claybourne's favorite commuting songs on our exclusive commuter playlists on Spotify.

  • Mashin’ on the Motorway - DJ Shadow

  • Long Way Home - Tom Waits

  • Square One - Tom Petty


Episode Transcript:

-(Voiceover) Commutifi presents Between The Lines with Andy Keeton. Each week we explore the challenging issues transportation demand management professionals face on their journey to transition commuters from driving alone to more sustainable, shared, and active commuting habits. Be sure to subscribe to hear next week's episode and check out our exclusive commuter playlists on Spotify. This is Between The Lines with Andy Keeton.

-(Andy Keeton) Hi everyone and welcome on board to Between The Lines. This episode we are talking to Claybourne Clarke. Claybourne is the supervisor of the Colorado Department of Public Health Environment or CDPHE in their climate unit and he's been instrumental in the upcoming employee traffic reduction program in the Denver front range area in Colorado. Before joining CDPHE, he spent over 20 years practicing environmental law including serving as senior assistant attorney general for the state of Colorado representing CDPHE's air division. His work as council for the air division included representing the state in adoption of the 2014 methane rules for oil and gas: The first GHG emissions for oil and gas production in the US and in the adoption of Colorado's low and zero-emission vehicle standards. And prior to that work in Colorado, Clay has worked as an attorney in Washington DC and internationally on climate issues. He served as an invited speaker at the 2006 United Nations climate change conference and is an author of a chapter in the book "Legal Aspects of Carbon Trading" published by the Oxford University Press. Outside of all of this work, he's an avid rock climber or avid rock and mountain climber and has summited several of the world's highest peaks including the daunting mount Everest. And he's also a husband and proud father of two. We can see here Clay. You've got your your vest on a true Coloradan here. Thanks for being on.

-(Claybourne Clarke) Well, thanks for the invitation to be here Andy. I appreciate it. And frankly, yeah it's a little chilly in here.

-(Andy Keeton) No worries. So today we're talking about why the Denver front range employee traffic reduction program is going to help save the planet. I’m really excited to talk with you today about this. There's a lot of words in that employee traffic reduction program or e-trip Denver front range. Can you just tell us a little bit Claybourne about what is this? And just give us a high-level overview.

-(Claybourne Clarke) sure. So the Denver front range is basically the sort of the Denver metro area just south of the city of Denver then on all the way up into fort collins but really the significance for our conversation is that area is also out of attainment for the federal standards for ozone. And so we refer that in Colorado's the ozone non-attainment area and so the consideration of TDM measures such as: an employee traffic reduction program has really been a strategy that's been examined as an ozone strategy but really now has also sort of two-fold if you will has been picked up also as a greenhouse gas reduction strategy and it has really been picked up as I say. As a way for the state, you know both to get on top of local air quality issues around ozone but to contribute to reducing greenhouse gases and address climate change.

-(Andy Keeton) Yeah and this is I think you know listeners particularly in the public sector around the country know all too well about the ozone attainment and non-attainment there's a big issue here in the Denver area, so it's good to see that this as a solution that you all are looking into to help kind of solve those issues. So can you tell me... We talked a little bit about why the e-trip kind of came to be? What is the e-trip itself? What would...Who is impacted by it? What could you expect if you are impacted by it?

-(Claybourne Clarke) Sure. So the program would apply to large employers and large employers as the rule has been developed for consideration would be employers of 100 or more employees at a single location and that would require those employers to come up with a program really to offer incentives and options to their employees other than just driving to work alone. Right? So we're talking everything from promoting public transit, van shuttle, even biking to work through bike lockers and showers at work. So really! Whatever works best for that employer and their employees based on their type of operations and where they're located.

-(Andy Keeton) Sure. Okay, so yeah that's one of the things that's... I think exciting about this is that it provides this... you know puts this regulation in place that makes it so commuters who are working for these larger employers are given the opportunities a wide range going to this whole TDM stack of solutions. There's this whole wide range of things people can do and this is helping to ensure that employees are given those options or those incentives. So that sounds really promising. So what is the process been to create this and moving forward? How does this become an official thing? What can employers in the Denver metro, Denver front range area expect timing-wise or when this might come and how this might come to be?

-(Claybourne Clarke) Sure. Sort of backing up and taking that in order again because this was looked at as initially as an ozone strategy. It's something that's actually been considered for quite some time and really our regional air quality council has really led the way in sort of to doing the initial analysis on this. So really we've picked up at the state on a lot of that work that was started there and what we refer to as the rack but with that body but really the next steps would be as we developed this rule for consideration. We have been doing a number of meetings and stakeholder events and listening sessions both with: across this area with the various chambers and business organizations as well as with the public and some of the larger stakeholders, and listening sessions really to get input on what would make the most sense for implementation of a program like this in Colorado. And so you know based on that we have a draft regulation that we're about ready to propose to the air quality control commission here in Colorado and the way that would work here in Colorado, our state air act authorizes this commission to adopt regulations around air quality and so really where we are in the stages. We would propose this draft rule to the air commission that's about to happen. The first step would be we would request a hearing on this regulation. If the commission decides to do that they would grant this hearing and so that hearing right now would be contemplated or is contemplated to take place in August. So a commission would make a decision on if it would adopt these rules and so then the program would be anticipated really to sort of kick in beginning of 2022. Probably. Really, you know with some. So there would be sort of the initial steps of the employer putting their contact person or naming their contact person that would be sort of in charge of developing the program on their behalf. That could also be an outside entity. They could utilize the transportation association or such as well if they wanted to have some outside input on that but really to sort of then beginning to develop that program in-house and conduct an initial survey of what their employers are doing and you know currently and so we know where they are currently in order to figure out what reductions they can make they're in line with the regulation. So essentially coming into place beginning of 2022 doing that survey probably and having that done mid-2022 and then sort of reporting back annually each year on how the program is working for each of the employers to the state.

-(Andy Keeton) So there's a lot there that you talked about and this is one of the things we like to to get into the weeds here on between the lines and if you're listening here coming from another state or region outside of the Denver front range, we're going to get to in a bit here why this is important for you and how this can help you moving forward or impact you moving forward but if you're in... If you're in the Denver front range particularly, if you're a company or an employer here with 100 plus employees, the key things there that if this were to pass this is going to go through starting 2022 and I like the idea thereof building that baseline understanding sometime in 2022 and then presumably off of that there's some sort of goals that or metrics that employers have to hit moving forward based on that baseline. Is that correct?

-(Claybourne Clarke) That's right and the thought would be that initially a lot of employers are probably already achieving this but really the idea would be that you know to assure a sort of across this area that employers are achieving you know through these programs. Probably at least 25% of their employees coming to work in a way other than through a single-occupancy vehicle and that would sort of be in the near term and then sort of having that trajectory of going down in the coming years over what that you know and increasing that percentage to say 40% out by 2025.

-(Andy Keeton) Got it. Okay, that's good to know and I think generally in line with a lot of the ones we see in other places as well around the country I know. There's some in Seattle and in the LA region, DC. So that this makes sense this is just continuing to build this across the country and I think this particular one coming out in the Denver front range, I think it's going to add a lot to the region's TDM efforts. So what impacts do we think we can see whether it's emissions or moat you know single occupancy vehicle usage change? Do we think there's a big impact that's going to come out of this regulation?

-(Claybourne Clarke) Well, I think so and I think you know based on sort of the initial analysis that's been conducted by the regional air quality council. You know we're looking at really trying to lock in through this process emission reductions in the range of probably just over 750000 tons per year by 2025. So you know that's significant but I think you know when we think about developing these regulations really you know it's that air quality benefit but it really is sort of this sort of nudging employers to take advantages of a lot of those resources that are out there through the transportation management associations if you will and through. All these things and really just you know again what we want to do is structure this in a way that sort of compliance is ultimately sort of the preferred path or the preferred sort of action, right? Where there's a regulatory component that achieves these sort of meaningful reductions in greenhouse gas emissions and in pollutants that contribute to ozone but really that employers and employees see that look. This program really makes sense. Right? It can save employees money. It can save employers money through less overhead through parking, all these different things where if you can just in to put this in place and provide sort of a connection to the resources that are really out there that are being developed to these employers and employees that it becomes hey this is a good idea and this is something that you know really makes sense going forward. It's not just that we're complying because there's this regulatory burden and we've actually already sort of... Even from some of the smaller businesses begin to hear hey maybe we can participate in the platform and so they wouldn't be obligated to be doing this but the idea is that we would have this as I mentioned you a platform that the employers would go on to and the employees could go into as well where they would do the surveys for example that I mentioned to say you know here's where we are but through that would connect you with term key solutions for how you can sort of offer these incentives or these options. And so there's no reason to think that you know other employers wouldn't want to take advantage of that sort of being able to sort of see that and maybe there's way for employees that you know across various employers could find shuttles or carpooling or things that wouldn't necessarily be available just if they were sort of looking at it as a standalone sort of effort but because you've got this web portal that sort of all this is taking place in, it allows for both employers and employees to sort of take advantage of things that they wouldn't otherwise be able to if this program wasn't there.

-(Andy Keeton) That's really cool and I’m glad that you brought that up because I think a lot of people particularly you know employers who be impacted by a program like this. They hear regulation they hear you know there's is there going to be some sort of you know fine for me to not hit this and it's just getting kind of forced to do something I don't want to do but in tandem with this putting together this platform that standardizes this TDM system for anyone in the region is really exciting and it does mean that anyone here any employer can take advantage of these benefits and like you mentioned employees saving time, less turnover because better commutes leads as everyone listening here knows better commutes means less turnover. Obviously, the emission savings is a huge piece here and employers can actually save money on this and I think that's really exciting and the other thing you pointed out is these TMAs the transportation management associations, they're all over the Denver metro area you know Denver up to Fort Collins and south. I mean they're all over and finally you know this is going to help once again prove the value of these TMAs and help get employers connected with them. So I think that's really good and excited as well about the admissions number you threw out there that's a big that's a pretty big savings. So Yeah that's really exciting. So let's move on a little bit to you know anyone here in the Denver front range this is obviously very important to you very relevant to what you're doing but if you're not in the Denver front range this is still interesting hopefully and it's also important to you because this isn't adding another one of these employee traffic reduction trip reduction type programs to a growing list here across the country. Like I said we know there's some in Seattle, there's LA, there's DC, there's more cropping up all over. So what I want to kind of hear from you if other regulatory bodies, other regions, other states are looking at implementing something similar to this, what could they learn from the process that you all have gone through in Colorado to help you know smooth that process moving forward for them?

-(Claybourne Clarke) Sure and again I think you know this is still something that's being considered for development but what I would say is I think you know the way we envision this and what I think might distinguish this from some other sort of e-trip programs in other areas is really is this we intend this to be you know have this you know a regulatory component that achieves meaningful reductions but again at the same time employers and employees will see this as something that really makes sense and something that they see is really like I say that sort of compliance would be sort of the default where this is what makes the most sense anyway. And sort of being able to find that balance and do it that way I think the model that we want to show here in Colorado. And Colorado has a history of really leading when it comes to addressing air quality. I mean we were as I think you mentioned in the intro you know in 2014, we were the first state to adopt regulations around greenhouse gas emissions from oil and gas productions. We were recently the first state to adopt the U.S. climate alliance model framework for the phase-out of hydrofluorocarbons which are obviously a very potent greenhouse gas emissions. So you know I think you know Colorado sees its role as is again sort of being a leader and sort of pioneering these concepts where there is as you say sort of this proof of concept that other states or the jurisdiction can model off.

-(Andy Keeton) Yeah and I think...I mean that's definitely true. I grew up in Colorado. It's a proud point for me as well. Colorado is certainly a leading state in this and I know Commutifi is very excited about this effort particularly here the e-trip effort as a folder-based company as well but for all the TDM professionals out there listening to this I think what is most exciting for you possibly when listening to Claybourne talk here is you know he's... Correct me if I’m wrong here but you're not a TDM specialist expert. You're a climate person TDM is has become such an important thing to help solve some climate issues that it's being brought in to the fray. So it's not coming at it from certainly coming at it from a transportation perspective but it's starting at we have an emissions problem.

-(Claybourne Clarke) Oh! TDM is a really good solution I think that's really exciting.

-(Andy Keeton) So...We have just a few minutes here left. There's a lot to this. If you are listening we'll post you know subscribe to our email list on our website betweenthelines.io and we'll send out resources that are you know publicly available here so you can read more if you are interested in looking into the actual you know wording of this. Like like you said Claybourne this is in process going to the air quality control commission some point here hopefully around august or so. So definitely want to keep up with that. What are you...Final question here! What are you most excited about when you think about a future where the e-trip is in place?

-(Claybourne Clarke) Well, you know as you mentioned you know transportation is just one sector that my group is looking at but I think you know it's going to take strategies across all sectors. Right? Across multiple economies, across generations. I mean we've talked about this and you know in order to really make meaningful change and to address climate change it's going to take those strategies again you know sort of across all these different facets of our economy and I see really e-trip as being you know one of those important strategies. It is just you know one among many and but you know in some ways it's like you know like climbing a mountain or running a marathon. Right? It's you know it's one step at a time and e-trip is just one of those steps but you know each step is what gets you to the top or across the finish line. So I see you know being able to put this in place is just one more of those important steps as we really address climate change and so it's not the most novel and it probably won't get the most reductions but it is just one among many important strategies.

-(Andy Keeton) I like that answer and agree. I mean wholeheartedly. Certainly, this is a whole collection of solutions we need to put in place to solve the climate problem TDM you know. Anyone listening here knows it's important an important part of that puzzle and this employee traffic reduction program is a good step moving the right direction in the Colorado region and you know we hope to see other regions follow suit as well. So I guess just in you know a couple sentences here just summarize. We talked about a lot of things what are kind of the key points around the Colorado, Denver front range, employee traffic reduction program and why are they important? Why would they help save the planet?

-(Claybourne Clark) Sure. Well, so just to recap. So the program would apply to large employers in the ozone nonattainment area in Colorado which basically is the sort of Denver front range area. So employers with over 100 employees at a single location the requirement would be to come up with a program that offers options or incentives to your employers that promotes getting out of a single-occupancy vehicle and coming to work in some other way. That's really the sort of overview of the program and sort of the simplest possible way. Why is it important? Again, it really is about you know these strategies across sectors. Transportation largest source of greenhouse gas emissions in Colorado so everything we can do to reduce emissions in the transportation sector is crucial, Again though we're looking at reductions across the economy in Colorado so transportation is just one piece of this and again you know I don't know that there's anyone strategy that's going to save the planet but as I said you know each one of these is an important step and it's that one step that gets you to the top of the mountain or across the finish line in the marathon and this is an important step. And so that's why I think e-trip is going to save the world because it is one of those important steps that you have to take in order to sort of get to the finish line or to the summit.

-(Andy Keeton) I like it and I like you bringing back in the mountain climbing there you got it Colorado you know get keep Colorado proud. There can't have a podcast but with the talking about Colorado if you don't talk about climbing mountains about running marathons. So labor I think that's great and anyone listening as well you know it's employee traffic reduction program. As you've probably seen as someone living in Denver, traffic's getting bad this hopefully will help save you know reduce some of that as well. So I think that's great Claybourne. Thanks for being on. To our listeners, remember to subscribe to the podcast on Spotify, Apple podcast, Google podcast or wherever you listen to it and feel free to give us a rating as well that really helps and subscribe to our email list on betweenthelines.io We'll send out every week additional resources so you can follow along and learn a bit more about what we're talking about because there's a lot here. And feel free as well to join the conversation with hashtag between the lines on social media. So Claybourne before we leave. We like to end it off with a little fun point here we're we're adding we're putting together this music playlist on Spotify just in case you know people aren't quite to their final destination there's not quite to work they need to fill the rest of time with some music. So we like to fill that up with our guests favorite songs they want to add into here. So tell me what song do you want to add into our playlist.

-(Claybourne Clark) All right. So the first time that always comes to mind when I think of commuting and being in traffic is the DJ shadow mashing on the motorway and so it is...

-(Andy Keeton) I haven't heard it yet. I need to listen to this.

-(Claybourne Clark) So I’m not trying to promote any lawlessness out there on the roads but it is such a funny song. It's definitely worth the listen and there's a funny animated video actually that goes along with it as well. That's definitely worth a watch as well if you're looking for something to make you smile.

-(Andy Keeton) All right. All right. I’ll watch it right when we get off. I’m excited about that. That's fun. All right. Perfect! Well, once again thanks for being on Claybourne and to our listeners. Thanks for listening.

-(Claybourne Clark) Thank you.

-(Voiceover) Thanks for joining us on this week's episode of Between the Lines with Andy Keeton. Be sure to subscribe to hear next week's episode and check out our exclusive commuter playlists on Spotify.

Better commuting starts here.

Better commuting starts here.

Better commuting starts here.