Draft MI Healthy Climate Plan

  • The state has released a draft of the MI Healthy Climate Plan
  • This draft does not call for reduced vehicle miles traveled (VMT) by investing in green travel modes such as walking, biking, and electricified transit
  • Michigan cannot reach carbon neutrality without reducing VMT
  • The public is able to comment via email or the upcoming listening sessions

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) has released a draft of the MI Healthy Climate Plan.

This plan lays out a broad vision for fulfilling the governor’s fall 2020 commitment for Michigan to achieve 100% economy-wide carbon neutrality by mid Century – the global science-based benchmark for reducing greenhouse gas emissions to avoid the most devastating and costly impacts of climate change.

Liesl Eichler Clark, EGLE Director

There are three online public listening sessions scheduled:

  • Wednesday, January 26th, 10am to 12pm
  • Tuesday, February 8th, 6pm to 8pm
  • Monday, February 14th, 6pm to 8pm. Focus on Environmental Justice

You can email comments to

The deadline for submitting comments is February 14th March 14th.

Transportation and Mobility

We were on the workgroup that developed recommendations to reduce greenhouse gas (GHG) emissions for the state’s transportation sector — the largest GHG source. While the workgroup’s automotive stakeholders pushed electric vehicles, we partnered with others on recommendations that reducing vehicle miles traveled (VMT) through investments in biking, walking, and public transit. (Read more)

However, the draft plan fails to include our recommendation on GHG budgeting for road agencies, an idea that Colorado recently turned into reality. This budgeting would not only shift funding to the truly green travel modes (walking, biking, electric transit), it could shape land use patterns that make those modes more viable.

From our recommendation to shift vehicle trips to walking and biking

Michigan’s VMT continues to grow, outpacing our population growth (or decline.) That’s not sustainable and will prevent Michigan from reaching carbon neutrality. The plan needs to do more.

Our Draft Plan Comments

The transportation sector’s predominant focus on electric vehicles (EVs) will not make Michigan “a global leader in addressing climate change” nor is it an equitable strategy. We suggest the following improvements to widen the transportation vision and ensure the final plan meets the goals set forth by the governor.

Explicitly call for decreasing vehicle miles traveled (VMT)

The draft plan did not include the Workgroup recommendation on greenhouse gas (GHG) emissions budgeting for road agencies. We believe this was a solid tool for reducing VMT and a necessity for reaching carbon neutrality. Eliminating this recommendation and not providing any explicit strategy for reducing VMT will result in this plan not reaching neutrality. 

MDOT’s recent 2045 State Long-Range Transportation plan – in which the initial draft made no mention of carbon neutrality or the governor’s directive – also does not acknowledge the necessity of reducing VMT. In fact, the plan associates reduced VMT with a stagnant economy. 

Additionally, neither the MDOT plan nor this draft plan mention local road agencies and their role in VMT. 

Michigan’s expanding road infrastructure has fueled sprawl. This has led to rising VMT and lower dense communities where biking, walking, and public transportation are less viable options. Michigan’s climate plan must explicitly call for reduced VMT because the status quo will only continue to deliver higher carbon emissions.

Make measurable commitments to bike and walk investments

The draft plan provides no details on how to increase biking and walking, nor does it define any goals. It also doesn’t mention safety, a primary reason why more Michigan residents don’t bike or walk. 

We suggest the plan include a commitment to zero pedestrian and bicyclist fatalities and serious injuries through a Safe Systems Approach. We also suggest setting goals for increased travel mode shares for biking, walking, and public transportation. Both suggestions will help prioritize investments and provide measures of success.

Highlight the role of e-bikes and provide purchase incentives

E-bikes are one of the most significant travel modes for reducing carbon emissions, yet we found no mention of them in the draft plan. We believe the following points deserve to be included.

  • E-bikes produce 81% fewer carbon emissions per mile than EVs. This is due to the latter having greater manufacturing emissions as well as more emissions associated with their electricity and road infrastructure requirements.
  • E-bikes use the existing electrical infrastructure and aren’t hampered by the lack of a charging network. This is perhaps one reason why e-bikes are outselling EVs in the U.S.
  • E-bike use improves physical and mental health, which reduces health care costs.
  • E-bikes were a proven success in the City of Detroit’s Essential Workers Micromobility Pilot. The Pilot user survey found that 95% of the respondents were interested in continued use of the e-bikes. 55% wanted to use them year round. It gave Detroiters a dependable, affordable transportation choice for their work commute.

Incentives for e-bikes should also be explicitly mentioned.

Subsidizing EVs only helps those who can afford to operate a vehicle. Approximately 34% of Detroiters don’t own a vehicle. According to the University of Michigan Poverty Solutions Report, The Financial Well-Being of Detroit Residents, auto insurance premiums average $5,414, or 18% of the median income in Detroit. An estimated 60% of Detroit drivers don’t have auto insurance according to the Detroit Police. Consumer Reports says, EVs “ cost more to insure than equivalent gasoline-powered cars.” 

Recent analysis of a similar state EV incentive program found it largely benefitted those in the wealthiest suburbs with over a third of the incentive funding used to purchase luxury vehicles. 

Acknowledge EV emissions increases

The Health and Quality of Life section on page 23 fails to mention the expected increases in some emissions from EVs. While EVs have zero tailpipe emissions, 90% of all road traffic particulate matter (PM) comes from unregulated, non-tailpipe sources, primarily tire wear and the suspension of road dust. One recent study found some EVs emit an estimated 3-8% more PM 2.5 than equivalent conventional vehicles due to increased curb weights and increased tire wear. 

Many Detroit communities already pay a heavy price for transportation-related emissions and that will continue if we only encourage EV adoption.