Beyond protecting or redesigning assets in-place, agencies can consider relocating (or “realigning”) as another alternative to formal disinvestment. Relocating or realigning roads, or high-risk segments of roads, to less vulnerable locations may offer a longer-term solution than design modifications or protective measures. This approach has been utilized in some coastal states to ensure longer-term safety of roads threatened by erosion, frequent inundation, or washout from storms and to reduce future maintenance needs of roads.
State DOTs in particular may be encouraged to consider options for realignment when dealing with coastal highways that are vulnerable to extreme events. Under Federal Highway Administration regulations, state DOTs are required to conduct periodic evaluations to determine if reasonable alternatives exist to roads, highways, or bridges that have repeatedly required repair and reconstruction activities due to emergency events such as natural disasters.See footnote 1
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The intent is to encourage more cost-effective transportation planning and investment. The results of these evaluations are to be incorporated when state DOTs develop projects and are encouraged to be considered in long-range planning.See footnote 2 While these requirements do not apply at the municipal level, nor do they require analysis of repeated damage from non-emergency events such as high tide flooding, they may help encourage infrastructure agencies to plan proactively and build analyses and justifications for relocating infrastructure in high-risk coastal areas.See footnote 3
In the context of a coastal area considering the need for managed retreat in the future, a road relocation or realignment strategy is likely a temporary solution, albeit an often longer-term solution than design modifications or protective features. Where additional near-term managed retreat tools are being pursued, this strategy may not be necessary or appropriate as use of the road would be expected to dwindle as retreat tools are implemented, leading in the extreme to a scenario where a resilient road does not serve any community. Transportation agencies might consider developing a proactive phased approach to public infrastructure disinvestment as part of a managed retreat strategy, which may include road realignment as a strategy to bridge the gap (as with design modifications and protective features) to permanent disinvestment. However, this strategy comes with significant administrative and financial burdens, and accordingly agencies will likely reserve this option for the most critical or heavily used routes.
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When considering the need for relocating/realigning public infrastructure such as roads and bridges, as compared to alternative strategies (redesign in place, disinvestment), decisionmakers may wish to consider the following practice tips to balance policy tradeoffs:
Endnotes:
1. 23 C.F.R. § 667.1 (implementing § 1315(b) of MAP-21 (P.L. 112-141)). The recent publication Asset Management Approaches to Identifying and Evaluating Assets Damaged Due to Emergency Events documents how state DOTs are identifying these locations “where highway assets have been repeatedly damaged” and identifies “considerations for mitigating the risk of recurring damage in those areas,” with a particular focus on decisionmaking and practices for using the results of these evaluations “to improve achievement of asset management or performance management objectives.” Nat’l Acad. of Sci., Eng’g, & Med., Asset Management Approaches to Identifying and Evaluating Assets Damaged Due to Emergency Events (2020), View Source. | Back to contentBack to content
2. 23 C.F.R. § 667.9. Back to contentBack to content
3. These analyses could similarly provide justification for adaptation or protection in place, or for disinvestment methods like abandonment, depending on the context. Back to contentBack to content
4. P.L. 91-190 (1970). NEPA is a procedural statute, meaning that it does not dictate any particular outcome or decision, but rather requires federal agencies to follow certain procedures that help ensure a full accounting and consideration of environmental and other impacts of proposed “major federal actions significantly affecting the quality of the human environment.” Back to contentBack to content
5. Many repair and reconstruction activities within an existing operational right-of-way fall under NEPA Categorical Exclusions. See Fed. Highway Admin., U.S. Dep’t of Transp., Information: Additional Flexibilities in Categorical Exclusions (Memorandum), May 22, 2017, available at View Source. | Back to contentBack to content
6. State DOTs are indeed required to consider these evaluations in their asset management plans and when developing Federal-aid highway projects. 23 C.F.R. §§ 515.7(c), 667.9(a). Both state DOTs and MPOs are further encouraged to consider these evaluations in developing long-range plans and transportation improvement programs (STIPs and TIPs). 23 C.F.R. § 667.9(a). For more clarifying information on the scope of the periodic evaluations required by 23 C.F.R. Part 667, see Fed. Highway Admin., U.S. Dep’t of Transp., Questions and Answers Regarding Implementation of 23 CFR Part 667: Periodic Evaluation of Facilities Repeatedly Requiring Repair and Reconstruction Due to Emergency Events (Nov. 26, 2018), View Source. | Back to contentBack to content
7. Fed. Highway Admin., U.S. Dep’t of Transp., INFORMATION: Eligibility of Activities To Adapt To Climate Change and Extreme Weather Events Under the Federal-Aid and Federal Lands Highway Program (Sept. 24, 2012), available at View Source. | Back to contentBack to content
8. Fed. Highway Admin., U.S. Dep’t of Transp., Memorandum: INFORMATION: Integration of Resilient Infrastructure in the Emergency Relief Program (Oct. 11, 2019), available at View Source. | Back to contentBack to content
9. Id. Economic justification for a “betterment” requires a demonstration that the anticipated repeated damage over the lifetime of the asset in its current design or location would cost the ER program more money over time than the added upfront costs of rebuilding more resiliently. Back to contentBack to content
10. Fed. Highway Admin., U.S. Dep’t of Transp., Climate Change Adaptation Guide for Transportation Systems Management, Operations, and Maintenance 33, available at View Source. | Back to contentBack to content
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