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 plan represents important first steps toward articulating 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 plan, 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 identify 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. 
 

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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 

impacts 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 information 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 the longterm 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 action: 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 for 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 projects. 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 natural 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 tools to share knowledge for employing natural 

infrastructures solutions.
 

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 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 

collaboration 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 including 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 science 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 Engineers, 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 tools 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 reductions 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 

transportation 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

Director, US Climate Adaptation Policy