Federal Highway Administration Docket

Federal Highway Administration Docket No.: FHWA-2023-0002

May 20, 2024

Submitted via www.regulations.gov
Docket No.: FHWA-2023-0002

Rebecca Lupes
Office of Natural Environment
1200 New Jersey Avenue SE
Washington, DC 20590

RE: Request for Comments on Federal Highway Administration Docket No.: FHWA-2023-0002

Dear Ms. Lupes:

On behalf of our millions of combined members and supporters, the undersigned conservation organizations
write to submit this joint letter of comment on the Federal Highway Administration’s (FHWA) proposed
performance metrics to support the Promoting Resilient Operations for Transformative, Efficient, and Cost-
Saving Transportation (PROTECT) Discretionary Grant Program described within Federal Register Docket
Number FHWA-2023-0002.

The PROTECT Program has the potential to serve as an important tool for climate change resilience and
adaptation. Most importantly, the program’s emphasis on natural infrastructure / nature-based solutions
(NBS) offers cost-effective strategies that demonstrate high-performing alternatives to traditional or gray
infrastructure strategies. These approaches will deliver on the program’s vision for a more resilient
transportation system while also lessening climate change impacts by reducing erosion, preventing
wildfires, enhancing soil health, protecting against drought and flooding, strengthening coastlines,
improving the quality and availability of clean water, and sequestering and storing carbon. We appreciate
the FHWA’s efforts to clearly articulate the applicability and eligibility of natural infrastructure projects in
addition to recommending measures that recognize and capture their effectiveness and impact.

In addition to our general support for the proposed metrics, our organizations recognize that opportunities
remain for further improvement. To address these opportunities, we have compiled the following
recommendations for consideration in the development of a final monitoring and evaluation plan.

Areas Where FHWA Is Seeking Input

• Number and detail of proposed metrics. The FHWA seeks comment on the number and level of detail
of the proposed metrics.

Table 1, Planning Grants:
Metric P2 measures tools utilized or procured for resilience related planning analysis and tracks the
number or type of tools but could be improved by evaluating the use of (1) resources in the form of
“experts” or accredited consultants and (2) best-available or most-current data in their analysis.
Historical or baseline understanding of how systems operate or conditions present themselves is less
applicable in the face of climate change.

Recommended change: “Number, type, and modernity of qualified tools, data, and resources
procured or utilized for resilience...”

The recommended data sources should include the U.S. Global Change Research Program and
the Climate Mapping for Resilience and Adaptation portal.

Table 2, Resilience Grants:
Metric R5 measures reductions in roadway, bridge, and culvert vulnerability to floods, however the
performance metric would be improved by including nature-based solutions in the list of strategies.
Nature-based solutions are known for their ability to reduce flood risk and vulnerability. Inclusion of
these solutions in the strategies will clarify the known applicability to flooding/scour for applicants
and improve the likelihood of their use in future project proposals.

Recommended change: “Number of hydraulic countermeasures, structural measures, road drainage
features, or nature-based solutions installed or enhanced in the project area.”

Metrics R12 & R13 are identified as applicable only to projects incorporating nature-based solutions
(either coastal or all other). The use of nature-based solutions can protect and enhance surface
transportation assets while also improving ecosystem conditions, as described in the stated goal of
protecting natural infrastructure in the establishment of the PROTECT competitive grant program.
However, metrics R12 and R13 fail to capture the full suite of potential benefits of nature-based
projects for infrastructure resilience and critical improvements to ecosystem conditions.

Nature-based solutions can yield numerous alternative risk- and vulnerability-reduction outcomes for
coastal infrastructure aside from the performance measures provided by this proposal (“erosion rate
and shoreline position” or “vegetation coverage”), such as reduced flooding or inundation,
infrastructure stabilization, and reduced slope failures. We recommend additional metrics be
developed to ensure the wide range of infrastructure resilience benefits from nature-based solutions
are fully captured.

The proposed metrics are insufficient to measure the stated program goal of funding projects to protect
natural infrastructure that protects and enhances surface transportation while improving ecosystem
conditions. Metric R13 focuses solely on vegetation coverage change, however, not all nature-based
solutions strategies will yield vegetative cover (e.g., oyster reef breakwaters, coral reefs, dunes). The
FHWA has provided a broad list of potential nature-based solutions that represent a wide array of
habitat types. Many of these deliver the intended resilience impact without a demonstrated change in
vegetation. Additionally, these vegetation-specific metrics may introduce reporting challenges if
further detail on how to measure change isn’t provided. We recommend a more comprehensive metric
be developed to fully capture the impact of nature-based projects on ecosystem enhancements more
broadly.

Recommended change: The measures specific to nature-based solutions should be a broad,
comprehensive menu to select from depending on the additional value or ecosystem services that
the applied NBS strategy is designed to deliver (e.g., wave attenuation, water quality
improvements, heat island reduction, habitat expansion, terrestrial and aquatic connectivity,
recreation or tourism income, carbon storage, fire resilience, etc.).

Recommended change: Given the previous recommendation, it would also be beneficial for all
applicants to further clarify at the onset that projects including NBS are applicable to other metrics
based on the intended performance outcome.

Recommended change: An additional or alternative performance measurement specific to projects
incorporating nature-based solutions would be one that reflects the benefit they provide related to
cost. NBS strategies have been shown to reduce repetitive damages (e.g., levee setbacks) and
decrease cost per year of access preserved (e.g., FHWA-HEP-18-088). A metric that demonstrates
these benefits would further demonstrate the expanded value of natural infrastructure and nature-
based solutions.

• Data availability. The FHWA is seeking comment regarding the extent to which data resources are
readily available to support the proposed metrics.

While definitions and guidance for performance management terms are within the FHWA
Transportation Performance Management (TPM) Guidebook, the current usage and expectations
for certain terms, such as “baseline,” could require more explanation with nature-based solutions
to be applied as seamlessly as traditional strategies. As noted above, not all NBS strategies will
yield vegetation or vegetation changes. For example, when conserving existing landscapes or
habitats that provide flood and erosion risk reduction, the baseline would need to measure the
current flood or erosion conditions, not the current representation of vegetation. If the FHWA
continues with the proposed metric of “vegetation change,” expectations need to be clear to
grantees that baseline performance data is needed prior to implementing and time will need to be
given within the grant period to establish those metrics that likely were not already within the
organization’s tracked and available baseline data. Additionally, to be effective, the FHWA should
provide resources for best available data supporting baseline calculations in NBS projects.

• Decision support. The FHWA intends for the proposed metrics to provide useful and timely data to
inform transportation decision-making. The FHWA seeks comment on how data collected and
published by the Agency may later be utilized by State departments of transportation, metropolitan
planning organizations, cities, Tribes, and other stakeholders to deepen the understanding of
resilience.

The PROTECT program will make our nation’s highway infrastructure more resilient against the
current and future impacts of climate change while further validating the effectiveness and importance
of nature-based solutions in climate resilience, adaptation, and mitigation. Through program
implementation, the FHWA will serve as a leader in NBS application. As natural infrastructure and
nature-based solutions projects are growing in understanding and popularity, it is expected that the
number of proposals received and awarded that reflect those strategies will be a small percentage of
the overall recipients.

Recommendation: With the above in mind, either a separate report should be provided reflecting
those projects using natural infrastructure and nature-based solutions or the collection of a
“representative sample” should include at least 50% of the projects that utilized natural
infrastructure or nature-based solutions. This method in sampling will allow for a more equitable
weight in evaluating outcomes and performance that would reflect effective review of project
effectiveness. Given the focus on natural infrastructure and nature-based solutions in this program,
this emphasis and weighting is needed to provide for a meaningful review of effectiveness and
demonstrate opportunities for further scaling of these strategies.

Recommendation: The FHWA should actively report on and promote the intended performance
measures to be delivered from the selected grantee projects that included nature-based solutions to
advance the understanding of the role natural infrastructure and NBS play in highway infrastructure
resilience. This would improve the number and quality of future applications that include NBS
strategies.

Recommendation: Through program evaluation, monitoring, and promotion, the FHWA should
provide additional resources to support future applicants. While there are a significant number of
resources to support natural infrastructure or nature-based solutions in a coastal environment, there
are limited resources demonstrating or encouraging the use of these strategies in a non-coastal
setting. Guidance documents, webinars, convenings, listening sessions, and conferences are all
resources to program participants.

Recommendation: The program’s impact would be magnified if a more focused effort was placed
on interagency collaboration. While the FHWA and respective applicants have a wealth of
experience in traditional highway infrastructure, other Federal land management agencies (FLMA)
have an abundance of experience in implementing natural infrastructure or nature-based solutions.
Although the discretionary grant program allows for eligible applicants to partner with FLMAs,
additional support is needed from the FHWA to promote these partnerships and collaborative
opportunities to deliver cost-effective projects with expanded co-benefits and ecosystem services.

Through these recommendations, the discretionary program can also improve the use of PROTECT
program formula funding and NBS implementation within the formula program. These
recommendations will also better position the program to demonstrate effectiveness for future
reauthorization.

Overall, the proposed metrics for the PROTECT Discretionary Grant Program are organized to enable
future performance management. If implemented, our recommended changes will help the program more
effectively evaluate the impact and effectiveness of the program’s intended outcomes and deliver better
performance. These changes will also support FHWA’s growth in understanding and implementation of
natural infrastructure and nature-based solutions.

We appreciate your thoughtful commitment to the PROTECT program’s effectiveness and request your
consideration of our recommendations in the final monitoring and evaluation plan.

Sincerely,
American Fly Fishing Trade Association
American Shore & Beach Preservation Association
Coastal States Organization
Fly Fishers International
Land Trust Alliance
National Audubon Society
National Wildlife Federation
North American Falconers Association
Restore America’s Estuaries
The Nature Conservancy
Theodore Roosevelt Conservation Partnership