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July 15, 2011 - ASCE comments - on Draft National Action Plan: Priorities for Managing Freshwater Resouces in a Changing Climate

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COUNCIL ON ENVIRONMENTAL QUALITY
DRAFT NATIONAL ACTION PLAN
PRIORITIES FOR MANAGING FRESHWATER RESOURCES IN A CHANGING CLIMATE
COMMENTS OF THE AMERICAN SOCIETY OF CIVIL ENGINEERS∗
July 15, 2011

The American Society of Civil Engineers (ASCE) appreciates the opportunity to comment on the draft National Action Plan for establishing priorities for managing freshwater resources in a changing climate prepared by the Interagency Climate Change Adaptation Task Force (June 2, 2011).

A.

ASCE supports public and private sector strategies and efforts to achieve significant reductions in greenhouse gas emissions. By the end of this century, if current trends continue, atmospheric greenhouse gas concentrations could be twice what they were at the beginning of the industrial revolution. These increased concentrations are predicted to contribute to climate change, causing significant increases in global average temperatures and changes in precipitation patterns. The expected results will be increases in the severity of storms, floods and droughts, all of which will have substantial effects on our infrastructure, economy and quality of life.

The nation needs to establish a comprehensive, long-term infrastructure development and maintenance plan at federal, state and local levels. This plan must support sustainable development through a substantial reduction of greenhouse gas emissions and timely adaptation to the effects of climate change, while maintaining and enhancing environmental quality.

At the same time, we need clear and reasonable targets and schedules for the reduction of greenhouse gas emissions. We must improve the energy efficiency of, and the reduction of greenhouse gas emissions from, infrastructure systems over their entire life cycles by making cost-effective use of existing technologies. These improvements should cover all sectors, and include both stationary and mobile sources. 

Also key are policies that encourage the use of non-greenhouse gas emitting energygenerating sources such as nuclear, hydropower, wind and solar; that finance research into new technologies and materials to further improve energy efficiency and reduce greenhouse gas emissions; that incorporate additional incentives for the short term development and implementation of high efficiency and low or zero greenhouse gas emitting technologies and cost-effective carbon capture and storage; that stimulate private investment in greenhouse gas reducing technologies by establishing a market value for greenhouse gas emissions over the long term; and that allocate, under existing federal infrastructure programs, of revenue from greenhouse gas emissions credits for infrastructure projects that will reduce greenhouse gas emissions. Examples of such projects include new public transportation systems; projects to reduce major chokepoints
that cause transportation congestion; and improved intercity rail transportation.

Other policies should include credit for early action to reduce greenhouse gas emissions, encourage actions by other countries to reduce their greenhouse gas emissions and explore the utilization of forests and the ocean as carbon sinks or other mitigation technologies.

B.

ASCE supports government policies that encourage anticipation of, and preparation for, possible impacts of climate change on the built environment.

Climate change could pose a potentially serious impact on world-wide water resources, energy production and use, agriculture, forestry, coastal development and resources, flood control and public infrastructure. Examples include:

• Alterations to the hydrologic patterns for multipurpose water resource projects, of particular concern to civil engineers working in the hydroelectric industry, and water supply utilities where reservoir storage capacity may need to be increased.
• Climate extremes such as floods and droughts and other significant variations in hydrologic patterns that may necessitate changes or additions to flood control infrastructure to provide adequate public safety and performance.
• Changes in frequency and strength of tropical storms that will require changes in coastal protection systems.
• Changes in ocean levels that will require adaptation of coastal infrastructure, including ports.
• Changes in permafrost conditions that require retrofitting existing foundations and alterations to foundation design.

Such impacts could require modified agricultural practices and measures to deal with rising sea levels, water supply and quality, threats to critical infrastructure facilities and the potential for the outbreak of disease.

C.

ASCE defines sustainability as a set of economic, environmental and social conditions in which all of society has the capacity and opportunity to maintain and improve its quality of life indefinitely, without degrading the quantity, quality or the availability of natural resources and ecosystems. Moreover, sustainable development is the process of converting natural resources into products and services that are more profitable, productive, and useful, while maintaining or enhancing the quantity, quality, availability and productivity of the remaining natural resource base and the ecological systems on which they depend.

The civil engineering profession recognizes the reality of limited natural resources, the desire for sustainable practices (including life-cycle analysis and sustainable design techniques), and the need for social equity in the consumption of resources. To achieve these objectives, ASCE supports the following implementation strategies:

• Promote broad understanding of economic, environmental, political, social, and technical issues and processes as related to sustainable development.
• Advance the skills, knowledge and information necessary for a sustainable future; including habitats, natural systems, system flows, and the effects of all phases of the life cycle of projects on the ecosystem.
• Advocate economic approaches that recognize natural resources and our environment as capital assets.
• Promote multidisciplinary, whole system, integrated and multi-objective goals in all phases of project planning, design, construction, operations, and decommissioning.
• Promote reduction of vulnerability to natural, accidental, and willful hazards to be part of sustainable development.
• Promote performance based standards and guidelines as bases for voluntary actions and for regulations in sustainable development for new and existing infrastructure.

The ASCE Code of Ethics requires civil engineers to strive to comply with the principles of sustainable development in the performance of their professional duties. ASCE will work on a global scale to promote public recognition and understanding of the needs and opportunities for sustainable development. Environmental, economic, social and technological development must be seen as interdependent and complementary concepts, where economic competitiveness and ecological sustainability are complementary aspects of the common goal of improving the quality of life.

D.

In addition, ASCE supports protection of the built environment through research, planning, design, construction and operation and maintenance initiatives that increase the reliability and resilience of the nation’s physical infrastructure against man-made and natural hazards. Development of consistent, national standards that address interdependencies and establish minimum performance goals is imperative. Furthermore, an all-hazard risk assessment that addresses recovery and return to service should be routinely included in the planning and design processes at the national, state, and local levels. Understanding the impact of the loss of infrastructure, along with the duration and cost of restoring its function, is an important element to adding disaster resilience to the nation’s infrastructure. The opportunity to increase the nation’s disaster resilience must be a top priority.

We believe that a unified set of definitions for the concepts of critical infrastructure, hazards, multihazards, and resilience must be developed.

• Critical infrastructure includes systems, facilities, and assets so vital that their destruction or incapacitation would have a debilitating impact on national security, the economy or public health, safety, and welfare. Critical infrastructure may cross political boundaries and may be built (such as structural, energy, water, transportation, and communication systems), natural (such as surface or ground water resources), or virtual (such as cyber, electronic data, and information systems).
• All-hazards include events and conditions such as infrastructure deterioration, natural disasters, accidents, and malevolent acts that have the potential to cause injury, illness, death, damage or disruption of services.
• Multihazards denote the relevant environmental or manmade conditions that are used for engineering analysis and design. A sound multihazard approach to engineering practice will provide infrastructure resilience to all-hazards risks.
• Resilience refers to the capability to militate against significant all-hazards risks and incidents and to expeditiously recover and reconstitute critical services with minimum damage to public safety and health, the economy, and national security.

E.

ASCE supports the development of emergency plans by water providers to prevent or minimize the disruption of service during emergencies. Plans should be developed in conjunction with neighboring water utilities in order to ensure mutual aid when needed. Since some emergencies are likely to involve the need to coordinate with other services and utilities, the plans should be developed jointly with other public and quasi-public organizations that are likely to be impacted by an emergency.

While the fundamental responsibility for development of such plans rests with the water-providing organization, stakeholders should be involved. Where possible, such plans should include water-sharing between providers, on a regional basis, to reduce individual risk. Federal and state governments should encourage such planning and provide technical assistance to water providers in the development of such plans. Since emergencies often impact other utility providers whose ability to operate may be impaired simultaneously, it is important to coordinate mitigation and response with these providers as well as with local emergency management planners.

Plans should be updated periodically as new threats are identified, system vulnerability changes, or the need for coordination with other organizations becomes apparent. Measures to prevent service disruption should be an essential part of the plan. Plans should assess risks and plan for emergencies in a way that provides equitable distribution of risk and resources throughout the service area. Response plans should be tested periodically to ensure that they are meeting current needs and that personnel are prepared to implement them. Potential problems should be identified and dealt with in advance to achieve equity and continuation of service during an emergency. Such planning will require examination of long-range solutions that involve capital investment or inter-agency agreements, short-term response measures, and issues of risk and vulnerability of sources, treatment plants and transmission systems.

Water providers must be prepared to meet situations in which supply, treatment and power supply capabilities are suddenly threatened. Planning for building supplementary sources of supply, redundant transmission mechanisms, emergency water distribution, or arranging for resource-sharing can involve significant investment and long lead times. Advance planning by water providers will help to mitigate impacts to their systems and disruption to service in the event of such situations.

F.

We encourage the federal government to examine the impacts of possible climate alterations by continuing and expanding a long-term hydrologic data collection program for major watersheds and their associated coastal areas, with funding on a continuing basis sufficient to allow prediction of storm surges, major flood events, and sediment transport as well as to allow effective management of changes to established hydrogeomorphological processes (the interaction of water and soil through river systems).

Hydrologic data, including associated hydraulic data, are vitally important to water resource planning, regional sediment management, and flood-risk management, as well as the design and operation of water projects. Such data are critical for performing risk assessment and economic analysis properly, and for evaluating the impact of water projects on public health, welfare, safety and the environment. Good, consistent historical data are absolutely essential for the modeling necessary to make accurate predictions. Most importantly, because these data must be collected on a regional basis, this is inherently a federal responsibility.

Many U.S. agencies, in particular the National Weather Service and the U.S. Geological Survey, provide the foundation of the basic data collection program for water in the United States. Inadequate and uncoordinated hydrologic data collection, resulting from budget shortages and neglect, has long-term adverse effects on the efficiency and certainty of planning, design, construction, and operation of water and other projects and results in an unnecessary and significant risk to the public safety. The lack of adequate data impacts the ability to model, predict and plan for catastrophic events. These events, such as floods and droughts, have obvious impacts on public health, safety and our nation’s economy.

G.

The American Society of Civil Engineers supports basin-wide water resources management. ASCE encourages government institutions to plan and regulate water on a watershed basis, and supports integrating programs and goals across political boundaries. ASCE believes that effective watershed management is facilitated when the government, the public and the private sector work collaboratively on this issue. Federal legislation defining the goals and standards for watershed managers should permit flexibility and accommodate regional needs.

Legislation authorizing and funding water resource management and planning has typically been written for a specific level of government. It has also focused on individual water resources, rather than the interrelated, hydrologic and environmental system which defines the watershed. As a result, efforts to manage water resources are often limited and single-purpose. Watershed plans should consider the multiple water resources and aquatic habitats comprising the watershed, and should include consideration of water supply, water quality, water conservation, flood protection, land use and protection of fish and wildlife resources. A key component of watershed management is cooperative partnerships between the stakeholders in the watershed.

Many water problems are not amenable to traditional regulatory approaches. Examples include non-point sources, competition for water supplies, dam safety, flood damage reduction, habitat degradation, aquatic sediments and minor sources. With the watershed approach, full use of modern technologies like remote sensing, geographic information systems (GIS), global positioning satellites, the personal computer and the world-wide web can be brought to bear on our remaining water quality and quantity problems.

H.

ASCE recommends that the following actions be incorporated into the Plan's Recommendations and Supporting Actions. The government should:

a. Conduct studies to determine how the impacts of climate change will affect current design standards, assumptions and safety factors for water and water-related infrastructure. Such studies should address changes in the mean, variance and plausible extremes of design variables, plus the expected rate of change in those variables. The emergence of new design variables, e.g., embedded energy, carbon footprint, water footprint, should also be considered. (It can be inferred that climate change will affect all forms of infrastructure, but we are limiting our comments to this plan for Water Resources.)

b. Develop specific project management practices designed to effectively address these new conditions, taking into account the changes in design variables and the emergence of new variables.

c. Review existing federal, state and local policies and regulations for conflicts with the Plan. For example, we understand that certain federal policies prohibit the use of public funds for rebuilding or refurbishing infrastructure in ways that extend its original design capacity.

Some of these recommendations coincide with recommendations and supporting
actions in the plan, e.g., Actions 11, 16, 18 and 20. ASCE believes that it is important to make explicit and more specific the needs of the engineering community so that they may address quickly and effectively the issues and consequences of climate change in new, water-related infrastructure. No doing so would result in continuing to build
long-lived infrastructure components that are unable to accommodate change. Having to expand, reinforce or rebuild infrastructure later found inadequate due to known and anticipated changes is a serious waste of resources and dollars.

I.

ASCE is pleased to provide a few specific recommendations with respect to some fo the topics in the plan.

In Action 15, it should be emphasized that water use efficiency y, particularly for agriculture, is too dependent on local conditions and scale of projects to made a mandatory for water resources projects. As we have seen from the application of national economic standards to local projects, applying national standards and benefits to water use efficiency is likely at times to result in a sound local project being considered infeasible just because it doesn't pass some theoretical test of WUE that is not applicable or practicable in the project area.