Oct 14, 2021

Deyanira "Deya" Zavala served as CCLP's Interim Associate Executive Director. Deya is an experienced, collaborative nonprofit leader with experience working in community economic development. Driven by her commitment to equity, she previously served as Executive Director of Mile High Connects, a regional coalition which actively worked to build a thriving, resilient Denver metro region. In her role, she forged partnership between public and private sector partners while facilitating community-driven change. Her areas of expertise additionally include resilience, mobility and resilient cities. Visit Deya's CCLP staff profile here.

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Greenhouse Gas Emissions Rulemaking – Centering Equity in the Process

by | Oct 14, 2021

Subject: Green House Gas Emissions Rulemaking – Recommendations for a more equitable process

The undersigned members of the Denver-based Land Use Work Group (LUWG) led by Mile High Connects, Denver Streets Partnership, and YIMBY Denver applauds CDOT in its stakeholder outreach and thank you for the opportunity to provide input on the draft Rules Governing Statewide Transportation Planning Process and Transportation Planning Regions. The LUWG is a Denver-based group of nonprofit advocacy organizations, nonprofit developers, Business Improvement Districts (BIDs), and residents tracking and amplifying local efforts while advocating for policy change to reflect the nexus of housing and transportation and ensure that investments in the built environment reduce racial disparities, maintain community, build a culture of health, and respond to the climate crisis.

While the draft rule proposes important policies to mitigate transportation pollution, it fails to adequately and directly promote climate-friendly land use, a key near-term strategy listed in the state’s GHG Pollution Reduction Roadmap.

More investment in multimodal transportation is essential to reducing VMT and should be coupled with smart land-use policies to locate housing, jobs, schools, goods, and services near one another. Achieving an 11% VMT reduction target by 2030 requires a comprehensive approach that integrates transportation and smart land use planning.

The following recommendations seek to create a more equitable approach that responds to the needs of the community:

  • Strengthen and Review Travel Demand Modeling: Fundamentally, the success or failure of a project depends on the modeling involved, and yet state DOT models have a track record of being inaccurate. To improve the accuracy of project assumptions, modeling scenarios must be strengthened and periodically reviewed to ensure that modeling results reflect real world data. Additionally, Both CDOT and MPOs should be required to model the impacts of transportation projects to evaluate plans for compliance. CDOT should also maintain its commitment to project-level modeling in addition to program or transportation-plan level modeling. Finally, to prevent conflicts of interest and ensure accuracy, CDOT should require an independent agency to verify and validate results produced by all compliance models.
  • Center People and Climate Justice for Greater Equity: CDOT should seek to strengthen public engagement in the decision-making process, with an emphasis on climate resilience and advancing equity. We believe that, while engagement has been positive, this is an opportunity to test innovative solutions to gather meaningful input. The rule should incorporate the following:
    • Adopt a transportation equity framework identifying equity-related performance measures adopted at the state and national level, and indicators that drive local decision-making. Assessing equity includes quantitative and qualitative analysis, and a decision-making process that is inclusive and representative of communities that are most burdened, leading to a more equitable outcome. Incorporating an equity lens provides a complete picture of the overall impact.
    • Support capacity building, including education about planning processes, to realize meaningful engagement and powerful collaboration among community organizations and CDOT in implementing the rulemaking.
    • Transparency in the equity evaluation process is crucial to emphasize inclusion in numerous ways – at the staff level, decision-making level, and through deliberate community engagement.
  • Lead with Smart Land Use Strategies: DRCOG’s Metro Vision 2050 Scenario Modeling compares different transportation and land use scenarios to identify pathways to achieve their Metro Vision GHG and VMT targets. One scenario would invest $16 billion in transit over 30 years, resulting in a 2% decrease in VMT per capita by 2050. A second scenario combines the same $16 billion transit investment with a land use scenario that focuses two-thirds of all new housing and employment in existing urban centers and along high-frequency transit corridors. The result is a 25% reduction in VMT per capita. CDOT and MPOs are required by Senate Bill 21-260 to “consider the role of land use in the transportation planning process and development strategies to encourage land use decisions that reduce vehicle miles traveled and greenhouse gas emissions.” Reports have shown that daily VMT are about three times higher in suburban areas, than in compact multimodal neighborhoods (VTPI, 2021). Therefore, CDOT should aim to incorporate smart land use policies within transportation funding to reduce car dependence and overall VMT, specifically among suburban locations. Furthermore, CDOT should consider the role of specific land use policies such as ADUs, equitable transit-oriented development, up zoning in dense urban areas, reduced parking requirements, etc. in transportation planning efforts. The rule should incorporate land use metrics in the evaluation of each transportation project by requiring CDOT and MPOs to:
    • Measure the VMT and VMT per capita impacts of individual transportation projects in all planning and programming, including the RTPs and 10 Year Plans, and the TIP and Four-Year Prioritized Plan project selection process.
    • Gather baseline data on transportation-efficient land use for each local government in Colorado.
      • Once baseline data is determined, local governments should be required to report on specific land use metrics in each plan to demonstrate progress toward VMT and GHG reduction targets.
    • Consider local land use and development patterns and the extent to which they contribute to VMT per capita reductions for the proposed transportation project.
    • Prioritize projects that incorporate additional smart growth strategies such as up zoning, mixed-use infill development, and transit-oriented development.
    • Create a bonus for projects that advance equity by incorporating affordable housing and TDM programs that lower the combined housing and transportation costs for low-income households.

We appreciate your commitment and efforts to reduce greenhouse gas emissions from the transportation sector, improve air quality, and provide more travel options throughout Colorado, and your consideration of these recommendations.

Mile High Connects
YIMBY Denver
Denver Streets Partnership
All In Denver
JJK Places

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To maintain health and well-being, people of all ages need access to quality health care that improves outcomes and reduces costs for the community. Health First Colorado, the state's Medicaid program, is public health insurance for low-income Coloradans who qualify. The program is funded jointly by a federal-state partnership and is administered by the Colorado Department of Health Care Policy & Financing.

Benefits of the program include behavioral health, dental services, emergency care, family planning services, hospitalization, laboratory services, maternity care, newborn care, outpatient care, prescription drugs, preventive and wellness services, primary care and rehabilitative services.

In tandem with the Affordable Care Act, Colorado expanded Medicaid eligibility in 2013 - providing hundreds of thousands of adults with incomes less than 133% FPL with health insurance for the first time increasing the health and economic well-being of these Coloradans. Most of the money for newly eligible Medicaid clients has been covered by the federal government, which will gradually decrease its contribution to 90% by 2020.

Other populations eligible for Medicaid include children, who qualify with income up to 142% FPL, pregnant women with household income under 195% FPL, and adults with dependent children with household income under 68% FPL.

Some analyses indicate that Colorado's investment in Medicaid will pay off in the long run by reducing spending on programs for the uninsured.


Hunger, though often invisible, affects everyone. It impacts people's physical, mental and emotional health and can be a culprit of obesity, depression, acute and chronic illnesses and other preventable medical conditions. Hunger also hinders education and productivity, not only stunting a child's overall well-being and academic achievement, but consuming an adult's ability to be a focused, industrious member of society. Even those who have never worried about having enough food experience the ripple effects of hunger, which seeps into our communities and erodes our state's economy.

Community resources like the Supplemental Nutrition Assistance Program (SNAP), formerly known as Food Stamps, exist to ensure that families and individuals can purchase groceries, with the average benefit being about $1.40 per meal, per person.

Funding for SNAP comes from the USDA, but the administrative costs are split between local, state, and federal governments. Yet, the lack of investment in a strong, effective SNAP program impedes Colorado's progress in becoming the healthiest state in the nation and providing a better, brighter future for all. Indeed, Colorado ranks 44th in the nation for access to SNAP and lost out on more than $261 million in grocery sales due to a large access gap in SNAP enrollment.

See the Food Assistance (SNAP) Benefit Calculator to get an estimate of your eligibility for food benefits.


Every child deserves the nutritional resources needed to get a healthy start on life both inside and outside the mother's womb. In particular, good nutrition and health care is critical for establishing a strong foundation that could affect a child's future physical and mental health, academic achievement and economic productivity. Likewise, the inability to access good nutrition and health care endangers the very integrity of that foundation.

The Special Supplemental Nutrition Program for Women, Infants and Children (WIC) provides federal grants to states for supplemental foods, health care referrals, and nutrition information for low-income pregnant, breastfeeding and non-breastfeeding postpartum women and to infants and children up to age five who are found to be at nutritional risk.

Research has shown that WIC has played an important role in improving birth outcomes and containing health care costs, resulting in longer pregnancies, fewer infant deaths, a greater likelihood of receiving prenatal care, improved infant-feeding practices, and immunization rates

Financial Security:
Colorado Works

In building a foundation for self-sufficiency, some Colorado families need some extra tools to ensure they can weather challenging financial circumstances and obtain basic resources to help them and their communities reach their potential.

Colorado Works is Colorado's Temporary Assistance for Needy Families (TANF) program and provides public assistance to families in need. The Colorado Works program is designed to assist participants in becoming self-sufficient by strengthening the economic and social stability of families. The program provides monthly cash assistance and support services to eligible Colorado families.

The program is primarily funded by a federal block grant to the state. Counties also contribute about 20% of the cost.


Child care is a must for working families. Along with ensuring that parents can work or obtain job skills training to improve their families' economic security, studies show that quality child care improves children's academic performance, career development and health outcomes.

Yet despite these proven benefits, low-income families often struggle with the cost of child care. Colorado ranks among the top 10 most expensive states in the country for center-based child care. For families with an infant, full-time enrollment at a child care center cost an average of $15,140 a year-or about three-quarters of the total income of a family of three living at the Federal Poverty Level (FPL).

The Colorado Child Care Assistance Program (CCCAP) provides child care assistance to parents who are working, searching for employment or participating in training, and parents who are enrolled in the Colorado Works Program and need child care services to support their efforts toward self-sufficiency. Most of the money for CCCAP comes from the federal Child Care and Development Fund. Each county can set their own income eligibility limit as long as it is at or above 165% of the federal poverty level and does not exceed 85% of area median income.

Unfortunately, while the need is growing, only an estimated one-quarter of all eligible children in the state are served by CCCAP. Low reimbursement rates have also resulted in fewer providers willing to accept CCCAP subsidies.