Work remains to make ambitious goals a reality
By Adrian Shelley
On May 27, the Dallas City Council unanimously passed its Comprehensive Environmental and Climate Action Plan (CECAP) after nearly two years of planning and persistence by advocates, city leaders and members of the community.
Dallas joins the ranks of Austin, San Antonio, and Houston as a Texas city with a climate action plan. We applaud Dallas Mayor Eric Johnson, Dallas City Council, and the staff at the Dallas Office of Environmental Quality for passing the first climate plan adopted in North Texas. Now the proof will be in plan implementation and the results it brings.
Public Citizen took an active role in shaping each plan passed in Texas. After Trump’s election and the shameful withdrawal of the United States from the Paris Climate Agreement, we joined mayors across the country in the belief that local action could still help us meet our global climate goals. It is a priority of Public Citizen in Texas to pass climate plans now in as many cities as possible.
Dallas had a robust debate about the strength and merit of the city’s climate plan proposals. Some advocates created the Dallas People’s Climate Action Plan, which was a comprehensive evaluation of much of the work needed to be done on climate action, resilience, and environmental justice. We urge Dallas to take a second look at some of the People’s Climate Plan initiatives, as there is support across the board for measures including:
- More electric vehicle charging stations. The original draft had 9000 EV charging stations; the final plan reduced that to 1500. We challenge Dallas to go beyond 1500 by 2030 and set more aggressive target.
- Quicker electrification of the city vehicle fleet (goal T1, CECAP p. 55). The city should begin electrifying its fleet immediately—there is no reason to wait until 2030 (see p. 7 of the People’s Plan). There are grants available right now for electrification. Dallas should stop converting vehicles to alternative fuels such as natural gas and convert all vehicles to electric instead.
- The city council should pass a resolution now asking DART and DISD to electrify their fleets. Goal T1 in the Dallas CECAP mentions transitioning DART and DISD by 2040. Again, there is no reason to wait.
- Encourage the creation of community renewables and microgrids (People’s Plan at p. 7.) The Dallas CECAP mentions pursuing renewable energy. We would like the City to start looking for sites suitable for rooftop solar as soon as possible.
We think these steps would put Dallas on a path to even stronger climate action.
Public Citizen supported the Dallas CECAP in its present form because we saw improvements to the plan from a draft released in February to the final version. Public Citizen was one voice advocating for the plan; other supporters included 350.org Dallas, Texas Nature Conservancy, Texas Trees Foundation, Climate Reality, Green Careers Dallas, West Dallas One, Joppa Freedman’s Township Association, North Texas Renewable Energy Group, Dallas Sierra Club, and USGBC.
Below are some specific improvements made to the plan, and one place we noted where it was unfortunately weakened.
A Plan Should Meet its Goals
First, we urged Dallas to develop a plan that would meet its stated goal of net zero carbon emissions by 2050. By its own reckoning, Dallas’ plan falls far short of this goal.
This is a common criticism of Dallas’ plan; and in fact, there are few if any climate plans in existence that do meet their net zero goal. Dallas is particularly vulnerable to this criticism because it released a detailed greenhouse gas emissions inventory and attempted to quantify the emissions reductions from its strategies. Many cities, including Houston, do not have enough detail in their plans to quantify emissions reductions over time. So, while the Dallas plan clearly falls short, it does so with thorough documentation and sound reasoning.
The number crunchers believe that Dallas’ plan was measurably improved from the February draft to the final version. The draft estimated the plan would achieve 18 percent greenhouse gas reductions by 2030 and 65 percent by 2050. The final plan estimates 25 percent reductions by 2030 and 66 percent by 2050. These are modest gains, but at least they are front loaded in the years that will have the greatest climate impact.
Dallas has committed to a three-year cycle of updating its emissions inventory and evaluating the success of its plan against the inventory. We look forward to this review process and urge Dallas to strengthen its plan over time in order to meet its stated goals. We also hope that Dallas follows through on its commitment to equity by forming an advisory committee, and later a commission, that reflects the diversity of the city.
Submetering to Support Energy Conservation
Submetering gives each tenant in a building their own energy metering, allowing them to pay only for the energy they use. This creates an incentive for tenants to reduce energy use and reduce their monthly bill.
Public Citizen encouraged Dallas to include a plan for submetering. The final CECAP included a new strategy, B16, to “encourage building owners to submeter their buildings to support energy conservation.” This program is not mandatory—and in fact the Dallas plan is rightly criticized for lacking any mandatory measures before 2030—but we think its addition is a significant improvement to the plan.
City Lobbying for Renewable Energy
Dallas adopted another of our suggestions as action E10—lobbying for pro-renewable energy policies at the state and federal level. State and federal governments can either help or hinder the transition from fossil fuels top renewables. Several years ago, the state legislature passed HB 40 to bar cities such as Denton from prohibiting hydraulic fracturing. In the 2021 legislative session, Texas could pass new laws to create unequal tax incentives for fossil versus clean energy sources. As part of the CECAP, Dallas has committed to lobbying for pro-clean energy policies at the state and federal levels.
Demand Side Management Education for Businesses
Demand-side management is an energy conservation strategy that encourages energy users to reduce their energy use, especially when demand is high. Dallas added strategy E11 into the final CECAP—educating commercial power customers about demand-side management and its benefits. Energy users can reduce their energy bills. Power providers can limit the use of more dirty energy sources such as coal. Everyone benefits from reduced carbon emissions.
Stronger Goals need more Teeth
Some of the Dallas plan’s more ambitious goals offer little about the strategies needed to achieve them. We appreciate that Dallas has set stronger goals—and we intend to hold the city to them in the years to come. But we are concerned a lack of clarity about how these goals will be met without additional measures. Here are a few examples:
A Stronger Target for Renewable Energy
Dallas has set a goal of 20% enrollment in renewable energy plans for residents and buildings by 2030, with a 50% goal for 2050. This goal was increased from 5% in 2030 in the February draft.
We encouraged Dallas to improve the goal and to establish something more than a voluntary or educational program to meet it. Although Dallas did increase the goal, it has not established any clear program to achieve it. There are some strategies in the plan related to this goal (E3, E5), but they relate mostly to customer outreach and education. Dallas will need to be proactive in order to achieve this new renewable energy goal.
Energy Savings in Existing Buildings
Dallas has added to Goal 1, energy efficient and climate resilient buildings. The original goal set a target only for new construction, which should be net-zero by 2030. The final goal also includes a target for existing buildings: 10 percent of them should reduce their energy by 10 percent by 2030 and 25 percent by 2050.
Again, this is a better goal, but the strategies to support it (B3-B6) haven’t really improved in the final plan. We hope that Dallas will seriously evaluate its strategies and progress over time. After all, the city will have to exceed the goals in this plan if it is to achieve the ultimate goal of net zero by 2050.
Airport Carbon Accreditation for the Dallas Executive Airport
The Airport Carbon Accreditation program requires airports to commit to carbon reductions with the goal of carbon neutrality. The draft CECAP said that Dallas would “consider pursuing” accreditation at the Dallas Executive Airport. We encouraged the city to pursue accreditation and that change was made in the final CECAP (goal B2).
A Weaker Goal for Electric Vehicles
Finally, we note a significant weakening of Goal 3, access to sustainable, affordable, transportation options. The February draft of the plan included a goal of 9,000 electric vehicle charging outlets by 2030. The final CECAP has reduced that goal to 1,500 outlets—just a sixth of the original target.
Dallas won’t meet ambitious goals if it doesn’t set them. Bloomberg estimates that 28% of new passenger vehicle sales will by electric in 2030. If nearly a third of Dallas vehicle buyers choose electric in 2030, they will need charging stations.
A Way Forward
Now that Dallas has a climate plan, the city can work toward aggressive climate action. We are pleased with this first step and mindful of work still to be done. The plan must be implemented with public input so that equitable progress can be made.
The climate planning process brought together climate advocates from across North Texas. There are other cities in the region now considering their own climate plans. At Public Citizen, we look forward to working with more cities across Texas as they commit to climate action.