### 4245 N. Fairfax Avenue NW Tel (703) 841

- 5300 Suite 100 Arlington, VA 22203 www.tnc.org

April 8, 2013

Secretary Ray LaHood Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

Re: DOT

- OST

- 2013

- 0023

- 0001 U.S. Department of Transportation

- Climate Adaptation Plan

Dear Secretary LaHood :

The Nature Conservancy welcomes the opportunity to submit comments in response to the first integrated Department of Transportation Climate Adaptation Plan.

We applaud the Transportation Department for recognizing the impacts that climate change is having and will continue to have on your mission and the commitment made to address those impacts. Planning for climate change impacts

- economic, social and environmental

- will be an iterative process,
but the p lan represent s important first steps toward articu lating risks and vulnerabilities and laying out actions to integrate climate considerations into your Department’s processes and governance. We hope the Transportation Department will now turn its attention to operationalizing the p lan , including analysis of budget impacts in the near, medium and long term.

There are several areas that we urge you and other Federal Agencies to continue to focus on as you
work to finalize and operationalize this year’s Adaptation Plan : 1. It is important to continue to iden tify the knowledge and data gaps to guide future workplans. In particular

, the Conservancy thinks it is critical to emphasize ecosystem

- based management and natural infrastructure as key adaptation solutions. Major weather events, such as Hurricane Sandy

, have already demonstrated that healthy and intact natural systems and landforms make both human and natural communities more resilient to climate change. We urge that use of natural infrastructure be an important element of future adaptation planning.
2. Additionally, more can be done to foster the sharing of adaptation science, tools, data, and expertise among federal agencies and with state, local and tribal governments. Creating robust, multidisciplinary learning networks at many levels of government and of the public should be an explicit federal agency goal.
3. Finally, in the administration of many federal programs, significant administrative, regulatory and legislative barriers will hamper efforts to respond and adapt to climate impacts. We ask your agency to identify such laws, regulations and rules and determine how they can be improved to help advance adaptation strategies.

### 2

Below are specific comments and recommendations for the Transportation Department plan.

The Department of Transportation has made significant commitments to understanding how climate change may impact the agency’s mission and our Nation’s transportation system. The agency has made progress with risk and vulnerabilities assessments in most of its administrations; and is implementing adaptation solutions through policy changes, pilots and sharing best practices. The plan is strongest in the tools priority and each administration has identified a range of actions to build awareness of the impac ts of climate change and develop skills for implementing adaptation solutions.

However, the plan fails to identify ecosystems

- based adaptation or natural infrastructure as adaptation solutions. Additionally, the plan should better address collaboration opportunities with other agencies such as the natural resources agencies, the Army Corps of Engineers, Department of Defense. Finally, while administrations are using tools to share best practices within each administration, it is unclear
how well inform ation is being shared between administrations.

Strengths of the plan :

 The plan does a good job identifying the various impacts that climate variability and change may have on transportation infrastructure, systems and assets. It also takes into account t he long

term nature on transportation projects, and the need to incorporate climate science now, by looking at existing and future infrastructure and summarizing acute, combined and indirect impacts.

 The plan identifies three high

- level priorities for acti on: tools, planning, and asset management. These are important categories: planning allows resiliency to be integrated into long

- term transportation decisions; asset management considers specific impacts from floods, fires, etc.; and tools are important f or changing culture and practices of transportation planners.

 The plan is especially strong in the tools category. DOT, in particular FHWA, seems to be doing a good job implementing systems for integrating climate adaptation planning and design into each administration’s operating procedures. Administrations are each building a number of tools to build adaptation awareness and skills, including: assessments of risk and vulnerability, costs and
trade

- offs analysis of adaptation strategies; and pilot projec ts. These efforts will provide important data for ensuring the success of adaptation solutions. Other tools including workshops, peer exchanges, and webinars; policy guidelines and best practices documents; and stakeholder outreach help capture and share lessons learned. As indicated below, natural infrastructure should be included as a resiliency strategy in these projects and tools.

Aspects of the plan that need improvement :

 A major weakness of the plan is that it neither identifies the impacts to natu ral infrastructure from climate change, nor recognizes natural infrastructure as a resilient infrastructure solution. The plan should encourage administrations to consider natural infrastructure options in their asset management and planning and create to ols to share knowledge for employing natural
infrastructures solutions.

### 3

 While the plan mentions that DOT met with Interior staff and consulted the National Fish, Wildlife, and Plants Climate Change Adaptation Strategy , there is little attention given to

co llaboration outside of the DOT agencies. FHWA has been a leader in developing and implementing the Eco

- Logical approach to early integration of ecological and transportation planning. Eco

- logical is a collaborative approach supported by 8 agencies includ ing the Department of Interior’s Bureau of Land Management and Fish and Wildlife Service, and the Forest Service. The planning priority should include reference to Eco

- Logical and actions for integrating DOT climate change adaptation activities with scien ce and planning initiatives of the other signatory agencies. In particular, this plan should address DOTs interaction with Landscape Conservation Collaboratives and DOI’s Climate Science Centers. Additionally, collaboration with the Army Corps of Enginee rs, Department of Defense, or other agencies that are concerned with infrastructure assets could advance understanding of costs and trade

- offs of adaptation solutions, including natural infrastructure. Additionally, while the administrations are using tool s to share best practices within each administration, it is unclear how well information is being shared between administrations.

 The plan should consider a fourth priority to reduce emissions from transportation systems. While perhaps emissions reduction s may be seen as a mitigation strategy, rather than an adaptation strategy, this plan should at least mention activities the DOT is taking and will take to increase efficiency and reduce emissions during construction, maintenance, and throughout the
transp ortation system.

Thank you again for the opportunity to review this plan. We look forward to working with you and other Federal Agencies as you continue to plan and implement climate change adaptation strategies.

Sincerely,

Sarah Woodhouse Murdock
Dir ector, US Climate Adaptation Policy