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Criterion Details

OM-01 Internal Sustainability Plan

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Focus on sustainability improvements within the agency’s internal operations that affect all three principles of the triple bottom line.

Sustainability Linkage

Triple Bottom Line

Implementation of a sustainability plan or similar document shows organizational commitment to all of the triple bottom line principles by being dedicated to the responsible use of natural resources, providing alternative commuting options, training employees about sustainability, and other related activities.

Background & Scoring Requirements


The purpose of this criterion is to focus on improving the internal sustainability of the agency. Also see the following, related criteria:

  • OM-02: Electrical Energy Efficiency and Use
  • OM-03: Vehicle Fuel Efficiency and Use
  • OM-04: Reuse and Recycle 

Where overlap exists with plans identified in these three related criteria, those plans should be included in the Comprehensive Internal Sustainability Plan (CISP) as an element of the plan or by reference.

For the purposes of this criterion, the following definitions apply:

  • “Internal”– Internal refers to an agency’s administrative and maintenance & operations functions that occur at existing owned or leased facilities and should address the agency’s energy consumption, solid waste production, recycling rate, employee commute, water consumption, stormwater management, and procurement policies. Generally, internal operations refer to those areas over which a transportation agency has complete control. For sustainability planning related to the transportation system that the agency manages, travel demand management programs for agency employees, or professional development education programs, see System Planning and Project Development criteria. 
  • “Sustainability” – The CISP should incorporate all three of the triple bottom line sustainability principles (environmental, social, and economic). A plan does not need to use the term “sustainability” to receive points, so long as the contents of the plan can clearly be demonstrated to relate back to the three sustainability principles.
  • “Plan” – For this criterion, a plan can be a list of actions that tie back to clearly stated objectives. The plan can be in the form of a published document, website, brochure, or other format, so long as the elements under the requirement section can be clearly demonstrated. 
  • “Performance Measurement” – A fully developed internal sustainability plan should contain a performance measurement system that includes goals, performance metrics, quantifiable targets, strategies, and actions designed to help meet the overall plan objectives. 

Scoring Requirements

Requirement OM-01.1

2 points. Executive Commitment

Agency sustainability commitment is endorsed by senior executives. Evidence of this could include an executive order or policy statement, organizational directive, endorsement of the Sustainability Plan, a memo to staff, or other document.

Requirement OM-01.2

4 points. Develop a Comprehensive Internal Sustainability Plan

The agency has a Comprehensive Internal Sustainability Plan that includes goals, performance metrics, quantifiable targets, strategies, and actions designed to help meet the overall plan objectives. Table OM-01.2.A shows examples of each of these components.




A goal is the area that needs to be improved.

A transportation agency wants to reduce its environmental footprint.

A performance metric will be used to  evaluate the progress being made towards  the goal area.

To measure its performance, the agency will track its energy  consumption.

A target uses the selected performance  metric and identifies specific objectives to be  achieved in the future.

The target is to reduce the agency’s annual energy consumption 20%  below current levels 2 years from now. (The baseline is how much  energy the agency currently consumes per year.)

Strategies are categories of actions used to  achieve the target.

The agency will use three main strategies to reach the target: (1)  consume less electricity, (2) consume less gasoline and diesel fuel, and  (3) consume less natural gas.

Actions are specific things that can be done  to implement the strategies.

To implement the strategy of consuming less electricity the agency will:  (1) replace incandescent light bulbs with compact fluorescents, (2)  replace broken office equipment with energy efficient models, and (3)  install occupancy sensors in the lighting system.

Common performance metrics for internal sustainability plans include:

  • Annual electricity, natural gas, gasoline, and diesel fuel consumption (see OM-02 and OM-03)
  • Annual renewable energy consumption (see OM-02)
  • Agency fleet fuel efficiency (see OM-03)
  • Agency fleet annual vehicle miles traveled (see OM-03)
  • Annual tons of solid waste produced (see OM-04)
  • Annual recycling rate (see OM-04)
  • Annual reams of paper consumed (see OM-04)
  • Annual water consumption
  • Stormwater infiltrations rates at agency-owned facilities
  • Percent of procured items that are sustainably produced, contain recycled materials, produced locally, etc.
  • Percent of building inventory meeting green or sustainable building criteria

If an agency is growing in size, one option may be to select performance metrics that are normalized by the number of employees. This way an agency can seek to reduce the amount of materials consumed per employee, rather than the total amount consumed across the agency. However, this approach can result in an overall increase in an agency’s environmental footprint, even though it appears to be meeting its sustainability goals.

Several resources and examples exist to help agencies develop sustainability plans, including:

  1. ICLEI - Local Governments for Sustainability’s Sustainability Planning Toolkit1
  2. ICLEI - Local Governments for Sustainability’s Tools website2 “provides a broad range of concrete and globally accessible tools to help cities transit to more sustainable urban management, covering the areas of urban design, eco-budgeting, urbanization, sustainability management and eco-procurement.”
  3. US DOT’s Our Sustainability Efforts website3

Requirement OM-01.3

1-3 points. Components of a Comprehensive Internal Sustainability Plan

Scoring is based on the following, cumulative requirements:

  • Requirement OM-01.3a

1 point. Coordination

The CISP is integrated with national, state, and/or regional sustainability goals.

  • Requirement OM-01.3b

1 point. Implementation

The CISP includes an implementation section that includes responsible parties, timelines, and potential funding sources.

  • Requirement OM-01.3c

1 point. Monitoring and Tracking

The CISP includes a performance measurement system, a plan for monitoring the plan’s progress, and a schedule for updating the plan as needed.

Requirement OM-01.4

1-2 points. Employee Engagement and Training

Scoring is based on the following, cumulative requirements:

  • Requirement OM-01.4a

1 point. Sustainability Training

Training on sustainability is provided for staff, including an introduction to the Comprehensive Internal Sustainability Plan.

  • Requirement OM-01.4b

1 point. Employee Sustainability Representative or Committee

The agency has an employee or an employee committee that promotes sustainability. Sometimes called a green team, this committee is focused on implementing more sustainable measures throughout the agency.

Requirement OM-01.5

1-2 points. Commuting Options

Scoring is based on the following, cumulative requirements:

  • Requirement OM-01.5a

1 point. Implement Travel Demand Management Options

The agency implements at least two Travel Demand Management options including, but not limited to, compressed work weeks, alternative working hours, carpooling/vanpooling support, virtual meetings, teleworking options, bicycle and pedestrian amenities (e.g., parking, showers, lockers, etc.), and subsidized transit.

  • Requirement OM-01.5b

1 point. Provide Support for Alternative Fuel Vehicles

The agency provides support for alternative fuel vehicles used for commuting. This could include providing electric vehicle plug in stations, providing alternative fuel vanpools, or other options.

Requirement OM-01.6

2 points. Demonstrate Sustainable Outcomes

To earn credit for this scoring requirement, the agency must have a Comprehensive Internal Sustainability Plan as described in scoring requirement OM-01.2. Monitor progress towards goals for at least one year after goal establishment and show measurable advancement towards stated goals. Sustainable outcomes measured in this requirement shall not include those covered in OM-01.4 and OM-01.5.


Above-Referenced Resources

The following resources are referenced in this criterion and consolidated here:

  1. ICLEI - Local Governments for Sustainability, Sustainability Planning Toolkit,
  2. ICLEI - Local Governments for Sustainability, Tools website,
  3. US DOT, Our Sustainability Efforts website,

Case Studies & Criterion Examples

Utah DOT - Saving Money and Improving Operations and Maintenance with INVEST: Using the pilot version of INVEST, UDOT developed specific recommendations for sustainability improvements to its operations and maintenance program. UDOT then performed a new self-evaluation in 2014 using INVEST 1.0 to measure progress and identify room for improvement.

Arizona DOT - Using INVEST to Benefit Planning, Programming, and Maintenance in Arizona: Arizona Department of Transportation (ADOT) has been a front-runner in utilizing and embedding INVEST throughout the full lifecycle of its transportation services, including administration, project planning, design, construction, and systems operations and maintenance. INVEST has also been a keystone in the development of the agency’s Sustainable Transportation Program. This case study focuses on ADOT’s use of the Operations and Maintenance (OM) module.

Western Federal Lands - Using INVEST to Enhance Sustainable Operations and Maintenance at Denali: The Western Federal Lands Highway Division (WFLHD) and the National Park Service (NPS) used INVEST to evaluate the operations and maintenance policies and procedures at Denali National Park and Preserve (DNP), specifically on Denali Park Road. The park achieved the platinum level for the INVEST evaluation, and identified many sustainable operations and maintenance practices that it plans to continue moving forward. WFLHD also identified several INVEST criteria that were not relevant to the park because its context and mission are different from that of a traditional transportation agency.

Scoring Sources

The program is considered to have met this criterion if the requirements above can be reasonably substantiated through the existence of one of the following documentation sources (or equal where not available):

  1. Comprehensive Internal Sustainability Plan, or similar document.
  2. An attachment to the plan that clearly describes how the plan includes measurements of performance.
  3. Plan progress report (likely produced independently of this application) that provides evidence that the agency has been monitoring and tracking its performance towards meeting the plan’s goals. The report should include quantifiable metrics (such as water or energy reduced per employee) that demonstrates the agency’s commitment to tracking its progress.