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 of Transportation 

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 

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April 8, 2013 

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. To Whom It May Concern: t::.> 

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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 of safety, state of good repair, and environmental sustainabili ty, 

and its mission of ensuring a safe, efficient, accessible and convenient transpmiation system. The 

DOT Plan includes a comprehensive list of possible effects of climate change on DOT's interests, 

and indicates that DOT clearly understands the importance of planning for climate impacts in the 

most cost-effective way. DOT's Plan also usefully includes a list of adaptation resources and 

reports developed by the agency-we hope other agencies will follow this example in future 

adaptation plans. 

We support DOT's goals to incorporate consideration of climate 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 of FHW A funds for adaptation. We look fonv-ard to the release of FTA' s pilot 

projects on the climate change vulnerabilities to transit. vVe also look forward to the release of 

FHW A guidance on how states and MPOs can incorporate consideration of climate change in 

transportation plans, design analysis for highway projects in coastal areas, and in NEPA at1alyzes. 

vVe would encourage FHWA to also consider how to incorporate consideration of future impacts 

when approving cost-effective betterments using emergency relief funding and to provide guidance 

to states and MPOs on how to make the case that adaptation measures qualify as betterments. 

TI1e DOT Plan could also be improved through the addition of specific agency-level plans for 

communication and integration of efforts among the modal administrations and to state and 

metropolitan partners. Each of the modes has individual plans and grant requirements, 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 

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To: 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 of climate change. It will be important for DOT 

to ensure that the work of the individual modes will not be trapped in silos, the results, and lessons 

learned from these efforts can be disseminated to the state and local entities that \\rill ultimately be 

charged with making transportation decisions. For ex..U11ple, we encourage FHWA to translate the 

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 to its mission from climate change, and we 

hope that DOT will utilize the recommendations called for here to establish more specifk 

commitments in the future. 

Sincerely, 

Vicki Arroyo, 

Executive Director, Georgetown Climate Center 

Visiting Professor, Georgetown University Law 

Center 

Jessica Grannis 

Staff Attorney, Adjunct Professor 

Harrison Institute for Public Law and Georgetown 

Climate Center 

2 

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