The Cuomo administration is bounding ahead with ambitious goals to reduce carbon emissions—in the energy sector. Meanwhile in the transportation sector, now the nation’s largest source of carbon emissions, the New York State Department of Transportation has quietly submitted troubling comments on the Obama administration’s rule-making efforts to reduce transportation’s impact on climate change.

Governor Cuomo has had a strong record on reducing GHG emissions, and he doesn’t mince words on the topic:

In the case of climate change, denial is not a survival strategy…Climate change is a reality, and not to address it is gross negligence by government and irresponsible as citizens.

And New York’s new State Energy Plan has very specific and ambitious goals, including a 40 percent reduction in greenhouse gas emissions from 1990 levels, a goal of getting half of the state’s energy from renewable sources, and a 600 trillion BTU increase in statewide energy efficiency.

The Obama administration has proposed a similar strategy for the transportation sector by encouraging states to reign in emissions through system performance measures that analyze and disclose carbon pollution, along with establishing GHG reduction targets.

But NYSDOT’s comments, on what is primarily an accountability rule, diverge from the spirit of Cuomo’s climate efforts. Essentially towing the AASHTO party line, NYSDOT calls for a “longer phased-in approach,” the convening of a group of experts to mull the complexity of it all, and states that many DOTs and MPOs aren’t prepared for the age of using Big Data, as envisioned by this rule. NYSDOT goes so far as to suggest that we delay addressing role of transportation in climate change: “Inclusion of additional measures, such as ones for greenhouse gas (GHG) and multi-modal use of highways should be detailed and vetted through a separate rule making.”

It’s not clear why New York needs more time “to adjust to the many demands of addressing this series of measures” if presumably these calculations are, to some degree, already being recorded and tracked as part of the Regional Greenhouse Gas Initiative. While NYSDOT’s suggestion to pursue a corridor approach to GHG emissions make a lot of sense, the agency’s continued push to set local speed limits denies local attempts to improve the multi-modal approach to our downtowns.

On one hand, NYSDOT’s comments come as a bit of a surprise. New York is a progressive state with a Democratic governor and more transit commuters than any other state. But on the other hand, that Democratic governor hasn’t always been a leader on trying to reduce driving. Sure, he’s paid lots of attention to rail and bus infrastructure in the last few months, but the fact that this transportation department appears squeamish about tackling climate change shouldn’t be such a shocker.

Not all of NYSDOT’s comments missed the mark. Like many in the advocacy community, they recognize that this rule fails to account for the impacts of a multi-modal transportation system on congestion:

Congestion, reliability and environmental sustainability investments routinely require a balancing of travel time objectives with the need for safe access for pedestrians, bicycles, efficient and effective freight and public transportation. These are essential to vibrant local economies. The national goals reflect this need for a balanced approach whereas the proposed performance measures do not.