The federal government last month returned to a crucial bit of business: ensuring it can keep doing its job as the climate changes. Climate change threatens every aspect of U.S. government operations and assets, from a safe and healthy workforce to functional office buildings and vehicle fleets and reliable supply chains. But climate adaptation plans first developed by federal agencies under the Obama administration languished under Trump. The Biden-Harris administration deserves a lot of credit for recognizing the current and growing danger of a more extreme climate, and for moving quickly to issue 26 new agency adaptation plans in response to Executive Order 14008.
NRDC just filed formal comments on the 26 climate adaptation plans, offering multiple recommendations to the White House Council on Environmental Quality (CEQ) and the Office of Management and Budget (OMB) for making the plans even more comprehensive, equitable, and actionable.
In general, the 2021 plans are more specific and focused than the previous generation was. Still, improvements are needed across the board to ensure workers are better protected, disaster prevention is prioritized over response, vulnerable communities get the help they need, and leadership puts these issues front and center. We cannot allow these plans to molder away in agency filing cabinets.
Here are our top recommendations for improving the adaptation plans.
Agencies should devote more attention to protecting their most important asset: their employees.
More than half of the 26 agency plans had minimal or no obvious commitments to protecting their workforce from heat-related illnesses, exposure to wildfire smoke, or other health and safety threats of climate change. We urge agencies and Congress to prioritize adaptation measures to protect federal workers. This includes ensuring agencies have the staffing and skill sets they need to meet the increased demand for basic services in the face of more frequent and severe weather events.
Agencies should more thoroughly address the threat of rising average temperatures and increasingly frequent, severe, and longer heat extremes.
Most of the plans didn’t account for the direct effects of heat on human health, infrastructure, or natural areas—a notable absence given the wakeup call of last summer’s catastrophic heat wave in the Pacific Northwest. Heat requires a different approach than most other climate hazards, in part because every piece of human-made infrastructure and technology and every living thing has an upper temperature limit.
Agencies should incorporate implementation of the reinstated Federal Flood Risk Management Standard (FFRMS) into their plans.
In May 2021, the Biden-Harris administration officially reinstated the Federal Flood Risk Management Standard (FFRMS), which requires that all federally funded projects’ siting and design take into account the growing risk from flooding and sea level rise. Although this reinstatement may have happened too late for some agencies to fully incorporate FFRMS into their adaptation plans, CEQ and OMB should ensure that agencies move rapidly to implementation.
Agencies should incorporate more nature-based solutions in their climate strategies.
Our review suggested that agencies aren’t fully appreciating the role of nature-based solutions in the fight against climate change. Nature-based solutions such as conserving existing natural areas and better managing agricultural lands have the potential to reduce climate-changing pollution and protect communities from heat, flooding, and other climate hazards. All federal agencies should do more to explain how they are embedding green infrastructure and other nature-based solutions into their planning and grant funding programs.
Agencies must devote additional resources and capacity to developing and implementing equitable and just adaptation policies, programs, and practices.
We were encouraged by the stated intent of federal agencies to identify and remedy the inequitable harms of climate change. However, the plans typically lacked specifics on how equity will be incorporated into adaptation measures. Agencies should also more deliberately and robustly address the threat of maladaptation, especially in vulnerable communities. Even well-intended climate adaptation strategies can have a range of negative consequences for populations that already experience the disproportionate harm of climate hazards. This phenomenon, known as “maladaptation,” should be an integral consideration for agencies as they review existing practices, policies, and programs—and design new ones.
The adaptation plans should spark a sustained national conversation about the urgency of climate adaptation, job creation, and the resources still needed to build a resilient, climate-smart United States.
Agencies should take every possible opportunity to make climate adaptation visible for the public and key stakeholders. CEQ and OMB should also produce a targeted summary of the 26 plans to help Congress identify major funding gaps, legislative remedies for barriers to agency actions or maladaptive policies, and other action items.
The catastrophic wildfires, hurricanes, floods, and heatwaves in just the last year—let alone in the seven-plus years since agencies last updated their adaptation plans—illustrate the urgent need for an ambitious approach to climate adaptation. Thanks to the Biden-Harris administration, the federal government is once again working to understand how its own operations, facilities, services, and missions must adjust to the reality of climate change. We look forward to working with CEQ, OMB, and individual agencies to build a safer, healthier nation for people, communities, and nature.
NRDC’s comments to CEQ and OMB are based on in-depth reviews of the 13 agency plans listed below and keyword searches of the other 13.
- Department of Defense (DOD)
- Department of Energy (DOE)
- Department of Homeland Security (DHS)
- Department of Housing and Urban Development (HUD)
- Department of Interior (DOI)
- Department of Transportation (DOT)
- General Services Administration (GSA)
- Health and Human Services (HHS)
- Occupational Safety and Health Administration (OSHA)
- U.S. Agency for International Development (USAID)
- U.S. Army Corps of Engineers (USACE)
- U.S. Department of Agriculture (USDA)
- U.S. Environmental Protection Agency (EPA)