Last week, ASCE submitted public comments on three proposed climate action plans drafted by Federal agencies. Plans drafted by 26 agencies were submitted to the Council on Environmental Quality (CEQ) on October 6, 2021 in accordance with Executive Order 14008, Tackling the Climate Crisis at Home and Abroad.
This Executive Order set out to establish a comprehensive strategy to address climate change, including making climate change a central component of U.S. foreign policy and national security, establishing a government wide approach, and requiring agencies to outline actions it is taking to strengthen resilience, adaptation, and incorporation of climate change science into its facilities, operations, and policies.
ASCE supports efforts to address the effects of climate change, and efforts to strengthen and support climate resilience and adaptation for development of the nation’s infrastructure. In keeping with this, ASCE carefully reviewed the plans submitted to CEQ, with a particular focus on three agencies: the Department of Transportation (DOT), the Department of Energy (DOE), and the Environmental Protection Agency (EPA). After consulting with our members, ASCE submitted comments to CEQ on November 5, 2021. Below is a brief synopsis of the issues addressed in ASCE’s comments.
Department of Transportation
ASCE recognizes the effects of climate change such as extreme storms, droughts, and floods have the potential to seriously impact the infrastructure network operated and maintained by DOT. These impacts could require modified design practices, increased maintenance costs, and measures to address the threat of rising sea levels and damage to critical infrastructure facilities. Specific to DOT, ASCE requested special consideration of building codes and standards, risk management, and climate change research.
According to the plan, DOT is currently identifying and prioritizing adaptation strategies that increase the climate resilience of existing buildings based on identified vulnerabilities. Modern, updated building codes are a reliable way to ensure infrastructure is resilient, and ASCE supports funding for research needed to develop model building codes.
ASCE 7 is one of several of the Society’s documents that offers a basis for designing structures that can reasonably withstand the ever-increasing impacts of climate change. As the DOT works to ensure the resilience of facilities for the upcoming year, we urge the consideration of the most up-to-date codes and standards as an integral part of that effort.
ASCE supports DOT’s recommendation to use a risk management framework to identify and incorporate critical adaptation actions into capital improvement projects and design standards. Asset management strategies can also serve as useful tools to help government agencies prioritize investment decisions and determine repairs. This practice involves managing infrastructure capital assets to minimize the total cost of operating them while maintaining a desired level of service for customers.
ASCE believes education and research efforts regarding resilience at a DOT level would assist in positioning the agency to address climate-related challenges associated with the nation’s critical transportation infrastructure. ASCE supports funding for additional basic and applied research efforts and the development of national standards in support of initiatives that increase the safety and resilience of the nation’s vast infrastructure against natural and man-made disasters.
Department of Energy
Increasingly severe weather events caused by climate change pose significant risks to the nation’s energy infrastructure. In 2021 alone, a severe winter storm in Texas, as well as a category 4 hurricane in Louisiana, left millions without power, and in many cases without access to clean water. This was a result of failure to ensure the energy grids in these states were able to stand up to the effects of stronger storm systems. In its comments, ASCE recommended that DOE place priority on addressing the resilience of electric grids, and again, the implementation of effective building codes and standards.
Among the priority actions laid out in DOE’s Climate Adaptation and Resilience Plan, incorporation of grid hardening and modernization measures is highlighted as a key tool for implementing climate adaptation and mitigation policies. ASCE strongly supports these actions and encouraged DOE in its comments to engage with key stakeholders such as state and local governments, energy providers, and the civil engineering community to ensure grid resilience and modernization remains a priority.
We also strongly recommended more proactive steps to achieve these goals, including the development of a national “storm hardening” plan, identifying risks to energy security in the electric power grid, and promoting reliability and resilience in power generation and transmission.
DOE’s plan also includes the adoption of building codes and standards as an essential implementation method. ASCE strongly supports this approach and highlighted several ASCE produced standards and guidelines specific to energy systems. These include ASCE 74, Guidelines for Electrical Transmission Line Structural Loading; ASCE 113, Substation Structure Design Guide; and ASCE 141, Wood Pole Structures for Electrical Transmission Lines.
Environmental Protection Agency
Climate change poses significant threat to the nation’s infrastructure. Rapidly changing weather patterns and temperatures threaten to limit access to clean water, hinder coastal development, and negatively impact infrastructure designs which are based on storm frequency. Any approach to mitigating the effects of climate change needs to account for these changing conditions, ensure proper design, and work with essential stakeholders.
In its comments on EPA’s Climate Adaptation Action Plan, ASCE encouraged the agency to effectively engage with the civil engineering community, implement proper building codes and standards, and account for future threats and challenges.
Among the priority actions EPA lays out in its action plan is engaging with essential stakeholders its rule making, policies, and enforcement actions. It lists engagement with state and local governments and other stakeholders to strengthen adaptive capacity and increase resilience.
ASCE specifically recommended that EPA ensure it engages effectively with the civil engineering community. The comments note that civil engineers are responsible for the planning, design, construction, operations, and maintenance of physical infrastructure and should be viewed as essential stakeholders in EPA’s processes. Doing so will ensure that policies account for up to date science, community needs, and up to date standards and codes.
As with other agency plans, EPA identifies implementation of resilience and adaptation measures for its facilities and critical infrastructure. ASCE again reiterated in its comments to EPA that the most reliable way to ensure infrastructure resilience is adoption and enforcement of modern building codes and standards. These tools are an essential component of civil engineering, and widespread adoption will help ensure that EPA is able to effectively implement policies that strengthen the resilience and adaptability of the nation’s, as well as its own infrastructure.
ASCE was encouraged by EPA’s recognition of the challenges posed by future threats of increasingly sever weather patterns and the effects that they have on the natural and built environment, including more severe wildfires, decreased water supplies, and physical threats to electric grids and water treatment systems.
ASCE noted that strengthening the best available science and data is critical to infrastructure design, and supports efforts to ensure that the most accurate and up to date information is available to civil engineers for designing infrastructure systems to with stand the challenges posed by ever changing conditions.
ASCE appreciates the efforts of these agencies to put forward these necessary action plans, as well as the opportunity to provide comment to strengthen and support their future development. We will continue to monitor the formulation of these action plans and remain available to assist in the implementation of the actions laid out by federal agencies.
This post was written with contributions from Matthew McGinn and Eleanor Lamb.