To: 82024932251@fax.law.georgetown.e 04/09/13 08:51AM Page 2 of 3 

# GEOR'C3ETO\NI\J ·r··

Docket Management Facility U.S. Department ofTransportation 1200 New Jersey Avenue, SE. Washington, DC 20590 Sent Via Fax: (202) 493-2251 Re: Docket Number DOT-OST-2013-0023 From: 11Michelle K. FoumBi 11**~-.:!**j:: ... , '.:, :
April 8, 2013

.**;~ ~**  ... i

.To Whom ItMay Concern: t::.> '',;

.. ·

TI1e Georgeto·wn Climate Center appreciates the opportunity to comment on the U.S. Department of Transportation (DOT) Climate Adaptation Plan. We are pleased that DOT recognizes that climate change \vill affect its strategic goals ofsafety, state ofgood repair, and environmental sustainabili

### ty, and its mission ofensuring a safe, efficient, accessible and convenienttranspmiation system. The DOT Plan includes a comprehensive list ofpossible effects ofclimate change on DOT's interests, and indicates that DOT clearly understands the importance ofplanning for climate impacts in the most cost-effective way. DOT's Plan also usefully includes a list ofadaptation resources and reports developed bythe agency-we hope other agencies will follow this example in future adaptation plans. We support DOT's goals to incorporate consideration ofclimate impacts in state and metropolitan transportation planning, asset management, and DOT's commitment to developing tools and best practices for incorporating climate considerations into transp01iation decision-making. In patiicular, we applaud FHWA's leadership in supporting adaptation pilot projects and issuing guidance on the use ofFHW A funds for adaptation. We look fonv-ard to the release ofFTA's pilot projects on the climate change vulnerabilities to transit. vVe also look forward to the release of FHWA guidance on how states and MPOs can incorporate consideration ofclimate change in transportation plans, design analysis for highway projects in coastal areas, and in NEPA at1alyzes. vVe would encourage FHWA to also considerhowto incorporate consideration offuture impacts when approving cost-effective betterments using emergencyrelieffunding and to provide guidance to states and MPOs on howto make the case that adaptation measures qualify as betterments. TI1e DOT Plan could also be improved through the addition ofspecific agency-level plans for communication and integration ofefforts among the modal administrations and to state and metropolitan partners. Each ofthe modes has individual plans and grantrequirements, and many are doing their own pilot studies or case studies. For example, the Federal Transit Administration and Federal Highway Administration are conducting vulnerability assessment pilot studies, while the Federal Motor Carrier Safety Administration and Federal Railroad Administration are modifying

l·lall ol' States 

### I Sllil.rt: ,[z:l 

### i .cl44 Norl.ll.**c'~Jl•itol** Street 

### !**w~s~·riington.** J)C 20001

Ci·co·rgetown ta·w i 600 New Jersey Aver11.1,:>. NW i Washingtmt. DC' :?000 l 21ll:
..66**~** .6566 ;:...

Opt-Out: Not DefinedTo: 82024932251@fax.law.georgetown.e From: ••Michelle K. FoumBi•• 04/09/13 08:52 AM Page 3 of 3

their grant application language to consider impacts ofclimate change. Itwill be importantfor DOT to ensure that the work ofthe individual modes will notbetrapped in silos, the results, and lessons learned from these efforts can be disseminated to the state and local entities that \\rill ultimatelybe charged with making transportation decisions. For ex..U11ple, we encourage FHWA to translatethe lessons learned from adaptation pilots to assist state DOTs and 11PO incorporate climate chance consideration in short- and long-range transpmiation plans. DOT has taken impmiant steps in identifying the tlu·eats toits mission from climate change, and we hope that DOT will utilize the recommendations called for here to establish more specifk commitments inthe future. Sincerely,

Vicki Arroyo, Executive Director, Georgetown Climate Center Visiting Professor, Georgetown University Law Center Jessica Grannis StaffAttorney, Adjunct Professor Harrison Institute for Public Law and Georgetown Climate Center

2 Opt-Out: Not Defined