Global heat deaths are projected to increase by 370% if direct action is not taken to limit the effects of climate change. The dire implications of rising global temperatures extend across a spectrum of risks, from health crises exacerbated by heat stress, malnutrition, and disease, to economic disparities that disproportionately affect vulnerable communities in the U.S. and in low- and middle-income countries. In light of these challenges, it is imperative to prioritize a coordinated effort at both national and international levels to enhance resilience to extreme heat. This effort must focus on developing and implementing comprehensive strategies to ensure the vulnerable developing countries facing the worst and disproportionate effects of climate change have the proper capacity for adaptation, as wealthier, developed nations mitigate their contributions to climate change. 

To address these challenges, the U.S. Agency for International Development (USAID) should mobilize finance through environmental impact bonds focused on scaling extreme heat adaptation solutions. USAID should build upon the success of the  SERVIR joint initiative and expand it to include a partnership with NIHHIS to co-develop decision support tools for extreme heat. Additionally, the Bureau for Resilience, Environment, and Food Security (REFS) within the USAID should take the lead in tracking and reporting on climate adaptation funding data. This effort will enhance transparency and ensure that adaptation and mitigation efforts are effectively prioritized. By addressing the urgent need for comprehensive adaptation strategies, we can mitigate the impacts of climate change, increase resilience through adaptation, and protect the most vulnerable communities from the increasing threats posed by extreme heat.

Challenge 

Over the past 13 months, temperatures have hit record highs, with much of the world having just experienced their warmest June on record. Berkeley Earth predicts a 95% chance that 2024 will rank as the warmest year in history. Extreme heat drives interconnected impacts across multiple risk areas including: public health; food insecurity; health care system costs; climate migration and the growing transmission of life-threatening diseases.

Thus, as global temperatures continue to rise, resilience to extreme heat becomes a crucial element of climate change adaptation, necessitating a strategic federal response on both domestic and international scales.

Inequitable Economic and Health Impacts 

Despite contributing least to global greenhouse gas emissions, low- and middle-income countries experience four times higher economic losses from excess heat relative to wealthier counterparts. The countries likely to suffer the most are those with the most humidity, i.e. tropical nations in the Global South. Two-thirds of global exposure to extreme heat occurs in urban areas in the Global South, where there are fewer resources to mitigate and adapt. 

The health impacts associated with increased global extreme heat events are severe, with projections of up to 250,000 additional deaths annually between 2030 and 2050 due to heat stress, alongside malnutrition, malaria, and diarrheal diseases. The direct cost to the health sector could reach $4 billion per year, with 80% of the cost being shouldered by Sub-Saharan Africa. On the whole, low-and middle-income countries (LMICs) in the Global South experience a higher portion of adverse health effects from increasing climate variability despite their minimal contributions to global greenhouse emissions, underscoring a clear global inequity challenge. 

This imbalance points to a crucial need for a focus on extreme heat in climate change adaptation efforts and the overall importance of international solidarity in bolstering adaptation capabilities in developing nations. It is more cost-effective to prepare localities for extreme heat now than to deal with the impacts later. However, most communities do not have comprehensive heat resilience strategies or effective early warning systems due to the lack of resources and the necessary data for risk assessment and management — reflected by the fact that only around 16% of global climate financing needs are being met, with far less still flowing to the Global South. Recent analysis from Climate Policy Initiative, an international climate policy research organization, shows that the global adaptation funding gap is widening, as developing countries are projected to require $212 billion per year for climate adaptation through 2030. The needs will only increase without direct policy action.  

Opportunity: The Role of USAID in Climate Adaptation and Resilience

As the primary federal agency responsible for helping partner countries adapt to and build resilience against climate change, USAID announced multiple commitments at COP28 to advance climate adaptation efforts in developing nations. In December 2023, following COP28, Special Presidential Envoy for Climate John Kerry and USAID Administrator Power announced that 31 companies and partners have responded to the President’s Emergency Plan for Adaptation and Resilience (PREPARE) Call to Action and committed $2.3 billion in additional adaptation finance. Per the State Department’s December 2023 Progress Report on President Biden’s Climate Finance Pledge, this funding level puts agencies on track to reach President Biden’s pledge of working with Congress to raise adaptation finance to $3 billion per year by 2024 as part of PREPARE.

USAID’s Bureau for Resilience, Environment, and Food Security (REFS) leads the implementation of PREPARE. USAID’s entire adaptation portfolio was designed to contribute to PREPARE and align with the Action Plan released in September 2022 by the Biden Administration. USAID has further committed to better integrating adaptation in its Climate Strategy for 2022 to 2030 and established a target to support 500 million people’s adaptation efforts.  

This strategy is complemented by USAID’s efforts to spearhead international action on extreme heat at the federal level, with the launch of its Global Sprint of Action on Extreme Heat in March 2024. This program started with the inaugural Global Heat Summit and ran through June 2024, calling on national and local governments, organizations, companies, universities, and youth leaders to take action to help prepare the world for extreme heat, alongside USAID Missions, IFRC and its 191-member National Societies. The executive branch was also advised to utilize the Guidance on Extreme Heat for Federal Agencies Operating Overseas and United States Government Implementing Partners.

On the whole, the USAID approach to climate change adaptation is aimed at predicting, preparing for, and mitigating the impacts of climate change in partner countries. The two main components of USAID’s approach to adaptation include climate risk management and climate information services. Climate risk management involves a “light-touch, staff-led process” for assessing, addressing, and adaptively managing climate risks in non-emergency development funding. The climate information services translate data, statistical analyses, and quantitative outputs into information and knowledge to support decision-making processes. Some climate information services include early warning systems, which are designed to enable governments’ early and effective action. A primary example of a tool for USAID’s climate information services efforts is the SERVIR program, a joint development initiative in partnership with the National Aeronautics and Space Administration (NASA) to provide satellite meteorology information and science to partner countries. ​​

Additionally, as the flagship finance initiative under PREPARE, the State Department and  USAID, in collaboration with the U.S. Development Finance Corporation (DFC), have opened an Adaptation Finance Window under the Climate Finance for Development Accelerator (CFDA), which aims to de-risk the development and scaling of companies and investment vehicles that mobilize private finance for climate adaptation. 

Plan of Action

Recommendation 1: Mobilize private capital through results-based financing such as environmental impact bonds

Results-based financing (RBF) has long been a key component of USAID’s development aid strategy, offering innovative ways to mobilize finance by linking payments to specific outcomes. In recent years, Environmental Impact Bonds (EIBs) have emerged as a promising addition to the RBF toolkit and would greatly benefit as a mechanism for USAID to mobilize and scale novel climate adaptation. Thus, in alignment with the PREPARE plan, USAID should launch an EIB pilot focused on extreme heat through the Climate Finance for Development Accelerator (CFDA), a $250 million initiative designed to mobilize $2.5 billion in public and private climate investments by 2030.  An EIB piloted through the CFDA can help unlock public and private climate financing that focuses on extreme heat adaptation solutions, which are sorely needed. 

With this EIB pilot, the private sector, governments, and philanthropic investors raise the upfront capital and repayment is contingent on the project’s success in meeting predefined goals. By distributing financial risk among stakeholders in the private sector, government, and philanthropy, EIBs encourage investment in pioneering projects that might struggle to attract traditional funding due to their novel or unproven nature. This approach can effectively mobilize the necessary resources to drive climate adaptation solutions. 

This approach can effectively mobilize the necessary resources to drive climate adaptation solutions.

Environmental Impact Bonds structure

Overview of EIB structure, including cash flow (purple and green arrows) and environmental benefits (black arrows). 

Adapted from Environmental Impact Bonds: a common framework and looking ahead

The USAID EIB pilot should focus on scaling projects that facilitate uptake and adoption of affordable and sustainable cooling systems such as solar-reflective roofing and other passive cooling strategies. In Southeast Asia alone, annual heat-related mortality is projected to increase by 295% by 2030. Lack of access to affordable and sustainable cooling mechanisms in the wake of record-shattering heat waves affects public health, food and supply chain, and local economies. An EIB that aims to fund and scale solar-reflective roofing (cool roofs) has the potential to generate high impact for the local population by lowering indoor temperature, reducing energy use for air conditioning, and mitigating the heat island effect in surrounding areas. Indonesia, which is home to 46.5 million people at high risk from a lack of access to cooling, has seen notable success in deploying cool roofs/solar-reflective roofing through the Million Cool Roof Challenge, an initiative of the Clean Cooling Collaborative. The country is now planning to scale production capacity of cool roofs and set up its first testing facility for solar-reflective materials to ensure quality and performance. Given Indonesia’s capacity and readiness, an EIB to scale cool roofs in Indonesia can be a force multiplier to see this cooling mechanism reach millions and spur new manufacturing and installation jobs for the local economy. 

To mainstream EIBs and other innovative financial instruments, it is essential to pilot and explore more EIB projects. Cool roofs are an ideal candidate for scaling through an EIB due to their proven effectiveness as a climate adaptation solution, their numerous co-benefits, and the relative ease with which their environmental impacts can be measured (such as indoor temperature reductions, energy savings, and heat island index improvements). Establishing an EIB can be complex and time-consuming, but the potential rewards make the effort worthwhile if executed effectively. Though not exhaustive, the following steps are crucial to setting up an environmental impact bond:

Analyze ecosystem readiness

Before launching an environmental impact bond, it’s crucial to conduct an analysis to better understand what capacities already exist among the private and public sectors in a given country to implement something like an EIB. Additionally working with local civil society organizations is important to ensure climate adaptation projects and solutions are centered around the local community. 

Determine the financial arrangement, scope, and risk sharing structure 

Determine the financial structure of the bond, including the bond amount, interest rate, and maturity date. Establish a mechanism to manage the funds raised through the bond issuance.

Co-develop standardized, scientifically verified impact metrics and reporting mechanism 

Develop a robust system for measuring and reporting the environmental impact projects; With key stakeholders and partner countries, define key performance indicators (KPIs) to track and report progress.

USAID has already begun to incubate and pilot innovative financing mechanisms in the global health space through development impact bonds. The Utkrisht Impact Bond, for example, is the world’s first maternal and newborn health impact bond, which aims to reach up to 600,000 pregnant women and newborns in Rajasthan, India. Expanding the use case of this financing mechanism in the climate adaptation sector can further leverage private capital to address critical environmental challenges, drive scalable solutions, and enhance the resilience of vulnerable communities to climate impacts.

Recommendation 2: USAID should expand the SERVIR joint initiative to include a partnership with NIHHIS and co-develop decision support tools such as an intersectional vulnerability map. 

Building on the momentum of Administrator Power’s recent announcement at COP28, USAID should expand the SERVIR joint initiative to include a partnership with NOAA, specifically with NIHHIS, the National Integrated Heat Health Information System. NIHHIS is an integrated information system supporting equitable heat resilience, which is an important area that SERVIR should begin to explore. Expanded partnerships could begin with a pilot to map regional extreme heat vulnerability in select Southeast Asian countries. This kind of tool can aid in informing local decision makers about the risks of extreme heat that have many cascading effects on food systems, health, and infrastructure.

Intersectional vulnerabilities related to extreme heat refer to the compounding impacts of various social, economic, and environmental factors on specific groups or individuals. Understanding these intersecting vulnerabilities is crucial for developing effective strategies to address the disproportionate impacts of extreme heat. Some of these intersections include age, income/socioeconomic status, race/ethnicity, gender, and occupation. USAID should partner with NIHHIS to develop an intersectional vulnerability map that can help improve decision-making related to extreme heat. Exploring the intersectionality of extreme heat vulnerabilities is critical to improving local decision-making and helping tailor interventions and policies to where it is most needed. The intersection between extreme heat and health, for example, is an area that is under-analyzed, and work in this area will contribute to expanding the evidence base. 

The pilot can be modeled after the SERVIR-Mekong program, which produced 21 decision support tools throughout the span of the program from 2014-2022. The SERVIR-Mekong program led to the training of more than 1,500 people, the mobilization of $500,000 of investment in climate resilience activities, and the adoption of policies to improve climate resilience in the region. In developing these tools, engaging and co-producing with the local community will be essential. 

Recommendation 3: USAID REFS and the State Department Office of Foreign Assistance should work together to develop a mechanism to consistently track and report climate funding flow. This also requires USAID and the State Department to develop clear guidelines on the U.S. approach to adaptation tracking and determination of adaptation components.

Enhancing analytical and data collection capabilities is vital for crafting effective and informed responses to the challenges posed by extreme heat. To this end, USAID REFS, along with the State Department Office of Foreign Assistance, should co-develop a mechanism to consistently track and report climate funding flow. Currently, both USAID and the State Department do not consistently report funding data on direct and indirect climate adaptation foreign assistance. As the Department of State is required to report on its climate finance contributions annually for the Organisation for Economic Co-operation and Development (OECD) and biennially for the United Nations Framework Convention on Climate Change (UNFCCC), the two agencies should report on adaptation funding at similarly set, regular interval and make this information accessible to the executive branch and the general public. A robust tracking mechanism can better inform and aid agency officials in prioritizing adaptation assistance and ensuring the US fulfills its commitments and pledges to support global adaptation to climate change.

The State Department Office of Foreign Assistance (State F) is responsible for establishing standard program structures, definitions, and performance indicators, along with collecting and reporting allocation data on State and USAID programs. Within the framework of these definitions and beyond, there is a lack of clear definitions in terms of which foreign assistance projects may qualify as climate projects versus development projects and which qualify as both. Many adaptation projects are better understood on a continuum of adaptation and development activities. As such, this tracking mechanism should be standardized via a taxonomy of definitions for adaptation solutions. 

Therefore, State F should create standardized mechanisms for climate-related foreign assistance programs to differentiate and determine the interlinkages between adaptation and mitigation action from the outset in planning, finance, and implementation — and thereby enhance co-benefits. State F relies on the technical expertise of bureaus, such as REFS, and the technical offices within them, to evaluate whether or not operating units have appropriately attributed funding that supports key issues, including indirect climate adaptation. 

Further, announced at COP26, PREPARE is considered the largest U.S. commitment in history to support adaptation to climate change in developing nations. The Biden Administration has committed to using PREPARE to “respond to partner countries’ priorities, strengthen cooperation with other donors, integrate climate risk considerations into multilateral efforts, and strive to mobilize significant private sector capital for adaptation.”  Co-led by USAID and the U.S. Department of State (State Department), the implementation of PREPARE also involves the Treasury, NOAA, and the U.S. International Development Finance Corporation (DFC). Other U.S. agencies, such as USDA, DOE, HHS, DOI, Department of Homeland Security, EPA, FEMA, U.S. Forest Service, Millennium Challenge Corporation, NASA, and U.S. Trade and Development Agency, will respond to the adaptation priorities identified by countries in National Adaptation Plans (NAPs) and nationally determined contributions (NDCs), among others. 

As USAID’s REFS leads the implementation of the PREPARE and hosts USAID’s Chief Climate Officer, this office should be responsible for ensuring the agency’s efforts to effectively track and consistently report climate funding data. The two REFS Centers that should lead the implementation of these efforts include the Center for Climate-Positive Development, which advises USAID leadership and supports the implementation of USAID’s Climate Strategy, and the Center for Resilience, which supports efforts to help reduce recurrent crises — such as climate change-induced extreme weather events — through the promotion of risk management and resilience in the USAID’s strategies and programming. 
In making standardized processes to prioritize and track the flow of adaptation funds, USAID will be able to more effectively determine its progress towards addressing global climate hazards like extreme heat, while enhancing its ability to deliver innovative finance and private capital mechanisms in alignment with PREPARE. Additionally, standardization will enable both the public and private sectors to understand the possible areas of investment and direct their flows for relevant projects.

Summit comes on heels of record 2024 summer heat; convenes experts on strategies to address this nationwide threat

Washington, D.C. – September 13, 2024 – The Federation of American Scientists (FAS), the non-partisan, nonprofit science think tank dedicated to deploying  evidence-based policies to address national threats, is today participating in the White House Summit on Extreme Heat. 

This Summit, announced by President Biden earlier this summer, will bring together local, state, Tribal, and territorial leaders and practitioners to discuss how to drive further locally-tailored and community-driven actions to address extreme heat. FAS has been a leading voice for action on this topic, and has developed a compendium of 150+ heat-related federal policy recommendations. 

FAS will be represented by Hannah Safford, Associate Director of Climate and Environment, and Grace Wickerson, Health Equity Policy Manager.

“Extreme heat is affecting every corner of our nation, making it more difficult and dangerous for Americans to live, work, and play,” says Wickerson. “Heat-related deaths and illnesses are on the rise, especially among our most vulnerable populations. We must work together to tackle this public health crisis.”

“It’s September, and millions of Americans are still suffering in triple-digit temperatures,” adds Safford. “We applaud the Biden-Harris Administration for drawing attention to the increasing challenges of extreme heat, and for driving on action to build a more heat-resilient nation in 2025 and beyond.”

FAS’s Ongoing Work to Address Extreme Heat

To date FAS has fostered extensive policy innovation related to extreme heat:

• Our Extreme Heat Policy Sprint engaged more than 85 experts and generated heat-related policy recommendations for 34 federal offices and agencies.
  
• This work is comprehensively summarized in our Whole-of-Government Strategy To Address Extreme Heat, and our associated library of heat policy memos. 
  
• FAS has delivered expert briefings on extreme heat to the White House and federal agencies. Our policy solutions have informed Senate appropriations requests, proposed legislation, and Congressional Research Service reports.
  

FAS Workshops Will Harness Momentum From White House Summit

Immediately following the White House Heat Summit, FAS will collaborate with the Arizona State University (ASU) Knowledge Exchange for Resilience to host the Celebration for Resilience 2024 Symposium and Gala on September 19th in Tempe.

On Friday, September 20th, FAS will partner with Arizona State University (ASU) to host workshops in Tempe, AZ, Washington DC, and virtually on Defining the 2025 Heat Policy Agenda. This workshop will harness momentum from the White House Summit on Extreme Heat, providing a forum to discuss actions that the next Administration and new Congress should prioritize to tackle extreme heat. For more information and to participate, contact Grace Wickerson (gwickerson@fas.org).  

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ABOUT FAS

The Federation of American Scientists (FAS) works to advance progress on a broad suite of contemporary issues where science, technology, and innovation policy can deliver dramatic progress, and seeks to ensure that scientific and technical expertise have a seat at the policymaking table. Established in 1945 by scientists in response to the atomic bomb, FAS continues to work on behalf of a safer, more equitable, and more peaceful world. More information at fas.org.

Extreme heat is the deadliest weather phenomenon in the United States — more lethal than hurricanes, floods, and tornadoes combined. And, as extreme temperatures rise, so do American household energy bills. An alarming 16% (20.9 million) of U.S. households are behind on their energy bills and at an increased risk of utility shut-offs. 

Many households rely on electrical power systems like air conditioning (AC) to combat immediate heat effects, increasing energy demand and straining power transmission capabilities, non-reliability, and energy insecurity. Even as increasingly warmer winter months due to climate change reduce the need for heating, this indicates a future with increased energy demand for cooling. In the U.S., projected changes in cooling degree days — the metric to estimate how much cooling is needed to maintain a comfortable indoor air temperature — are expected to drive a 71% increase in household cooling demand by 2050, according to the latest annual energy outlook from the U.S. Energy Information Administration (EIA).

Increasingly excessive heat is, therefore, a financial burden for many people, particularly low-income households. This is especially the case as low-income households tend to live in less energy-efficient homes that are more expensive to cool. The inability to afford household energy needs — that is, energy insecurity — makes it a challenge to stay cool, comfortable, and healthy during periods of extreme heat. Thus, as the impacts of extreme heat and energy insecurity are not distributed evenly, it is increasingly essential for the federal government to consider equity and prioritize disadvantaged populations in its efforts to tackle these intertwined crises.

Extreme Heat Drives Energy Burdens and Utility Insecurities

Energy insecurity refers to an individual or household’s inability to adequately meet basic household energy needs, like cooling and heating. Extreme heat compounds existing energy insecurities by surging the need for AC and other electrical sources of cooling technology. Thus, as the demand for cooling during summer increases energy consumption, many households cannot afford to run their AC, leading to life-threatening living conditions. According to the latest EIA Residential Energy Consumption Survey (RECS), a striking one in five households reported reducing or forgoing necessities like food and medicine to pay an energy bill. Over 10% of households reported keeping their home at an unhealthy or unsafe temperature due to costs.

Additionally, while household access to AC has increased over the years, a significant one in eight U.S. homes on average are still lacking AC, with renters going without at a higher rate than homeowners. The lack of access to cooling may be particularly hazardous for low-income, renter, rural, or elderly households, especially for those with underlying health conditions and those living in heat islands—urban areas where temperatures are higher than surrounding rural and suburban areas.

Another critical issue is that at least three million U.S. utility customers have their power disconnected every year due to payment challenges, yet 31 states have no policy preventing energy shut-offs during excessive heat events. The states that do have policies vary widely in their cut-off points and protection policies. Across the board, low-income people are disproportionately facing disconnections and are often charged a “reconnect fee” or a deposit after a cutoff. 

As of 2021, 29 states had seasonal protections and 23 had temperature-based disconnection protections that prohibit utility companies from disconnecting power. Still, research from the Indiana University Energy Justice Lab shows that these do not fully prohibit disconnections, often putting the onus on customers to demonstrate eligibility for an exemption, such as medical need. Further, while 46 states, along with Washington D.C., give customers the option to set up a payment plan as an alternative to disconnection, high interest rates may be costly, and income-based repayment is rarely an option.

These cut-off policies are all set at the state level, and there is still an ongoing need to identify best practices that save lives. Policymakers can use utility regulations to protect residents from the financial burden of extreme heat events. For example, Phoenix passed a policy that went into effect in 2022 and prevents both residential energy disconnections in summer months (through October 2024) and late fees incurred during this time for residents who owe less than $300. Also, some stakeholders in Massachusetts are considering “networked geothermal energy with microdistricts” — also known as geogrids — to build the physical capability to transfer cool air through a geothermal network. This could allow different energy users to trade hot and cool air,  in order to move cool air from members who can pay for it to those who cannot.

Grid Insecurity

Extreme heat also poses a significant threat to national energy grid infrastructure by increasing the risk of power outages due to increased energy consumption. Nationwide, major power outages have increased tenfold since 1980, largely because of damages from extreme weather and aging grid infrastructure. Regions not accustomed to experiencing extreme heat and lacking the infrastructure to deal with it will now become particularly vulnerable. Disadvantaged neighborhoods in urban heat islands also face heightened risks as they more frequently lack the essential infrastructure needed to adapt to the changing climate. For example, grid infrastructure in California’s urban disadvantaged communities has been shown to be weaker and less ready to support electric appliances. 

Similarly, rural communities face unique challenges in preparing for disasters that could lead to power loss. Geographic isolation, limited resources, and older infrastructure are all factors that make power outages more frequent and long-lasting in rural areas. These factors also affect the frequency of maintenance service and speed of repairs. In addition, rural areas often have less access to emergency services and cooling centers, making power outages during extreme heat events additionally hazardous. Power outages during extreme heat events increase the risks for heat-related illnesses such as fainting, heat exhaustion, and heatstroke. And, for rural homes that rely on well water, losing power can mean losing access to water, since well systems rely on electrical pumps to bring water into the home. 

Further heightening the need for urgency to consider these especially vulnerable populations and regions, research has shown that the time to restore power after an outage is significantly longer for rural communities and in low-income communities of color. Power restoration time reflects which communities are prioritized and, as a result, which communities are neglected. 

Equity Considerations For Different Housing Types

Extreme heat and energy security cannot be addressed without considering equity, as the impacts are not distributed evenly, especially by race, income, and housing type. One example of this intersection: Black renters have faced disproportionate burdens of extreme heat and energy security, as wealth is deeply correlated with race and homeownership in the U.S. In 2021, the EPA reported that Black people are 40% more likely than non-Black people to live in areas with the highest projected increase in mortality rates due to extreme temperatures. Simultaneously, a 2020 analysis by the Brookings Institute found that Black renters had greater energy insecurity than white renters, Black homeowners, and white homeowners. Beyond the cost burden of staying cool, this energy security puts lives at greater risk of heat-related illness and death and hinders economic mobility.

This paradigm reflects historic, discriminatory housing policies like redlining. Such policies segregated neighborhoods, induced lower homeownership rates, and ensured underinvestment in low-income communities of color—all of these factors play a significant part in making Black residents more vulnerable to the effects of extreme heat. Further compounding this, a 2020 study of more than 100 cities across the U.S. found that 94% of formerly redlined areas are hotter than non-redlined areas; in the summer, this difference can be as high as 12.6℉. 

Nationwide, households living in manufactured homes also face disproportionate risks and impacts, with about 25% having incomes at or below the federal poverty level. At the same time, manufactured homes consume 70% more per square foot on energy than site-built homes, while using 35% less energy due to their smaller size. Notably, about 70% of all manufactured homes are located in rural areas, which on average have higher median energy burdens than metropolitan areas. 

Further, ​​older manufactured housing units are often in inadequate condition and do not meet building codes established after 1976. However, research has shown that the vulnerability of households living in manufactured housing units to extreme temperatures is only partially related to whether they have AC systems installed. Other key factors that residents report to drive vulnerability include AC units that do not work efficiently, are located in less-used parts of the house, or are ineffective in maintaining comfortable temperatures. These factors hamper manufactured housing residents’ ability to control their home’s thermal environment — thereby driving thermal insecurity.

Manufactured housing households facing challenges with resource access (such as exclusions from assistance programs and lack of credit access), physical health and mental limitations, care burdens, and documentation status may be at disproportionate risk. These households deal with multiple, intersecting vulnerabilities and often must engage in trade-off behavior to meet their most immediate needs, sacrificing their ability to address unsafe temperatures at home. They often take adapting to the increasingly extreme climate into their own hands, using various ways to cope with thermal insecurity, such as installing dual-pane windows, adding insulation, planting shade trees, using supplemental mobile AC units, and even leaving home to visit local air-conditioned malls.

These overlapping paradigms showcase the intrinsic interconnectedness among climate justice, climate justice, energy justice, and housing justice. Essentially, housing equity cannot be pursued without energy justice and climate justice, as the conditions for realizing each of these concepts entail the conditions for the others.  Realizing these conditions will require substantial investment and funding for climate programs to include heat governance, housing resilience, and poverty alleviation policies. 

Policy Considerations

Energy Burdens and Utility Insecurity

Update the Low Income Home Energy Assistance Program (LIHEAP)

The Low Income Home Energy Assistance Program (LIHEAP) exists to relieve energy burdens, yet was designed primarily for heating assistance. Thus, the LIHEAP formulas advantage states with historically cooler climates. To put this in perspective, some states with the highest heat risk — such as Missouri, Nevada, North Carolina, and Utah —  offer no cooling assistance funds from LIHEAP.  Despite their warm climates, Arizona, Arkansas, Florida, and Hawai’i all limit LIHEAP cooling assistance per household to less than half the available heating assistance benefit. And, since most states use their LIHEAP budgets for heating first, very little remains for cooling assistance — in some cases, cooling assistance is not offered at all. As a result, from 2001 to 2019, only 5% of national energy assistance went to cooling. 

For vulnerable households, the lack of cooling assistance is compounded by a lack of disconnection protections from extreme heat. Thus, with advanced forecasts, LIHEAP should also be deployed both to restore disconnected electric service and to make payments on energy bills, which may surge even higher with the increase in demand response pricing due to more extreme temperatures. The distribution of LIHEAP funds to the most vulnerable households should also be maximized. As most states do not have firm guidelines on which households to distribute LIHEAP funds to and use a modified “first-come, first-served” approach, a small number of questions specific to heat risk could be added to LIHEAP applications and used to generate a household heat vulnerability score.

Further, the LIHEAP program is massively oversubscribed, and can only service a portion of in-need families. To adapt to a hotter nation and world at large, the annual budgets for LIHEAP must increase and the allocation formulas will need to be made more “cooling”-aware and equitable for hot-weather states. The FY25 presidential budget keeps LIHEAP’s funding levels at $4.1 billion, while also proposing expanding eligible activities that will draw on available resources. Analysis from the National Energy Assistance Directors Association found that this funding level could cut off up to 1.5 million families from the program and remove program benefits like cooling. 

Reform the Public Utility Regulatory Policies Act of 1978 (PURPA) 

While PURPA prohibits electric utilities from shutting off home electricity for overdue bills when doing so would be dangerous for someone’s health, it does not have explicit protections for extreme temperatures. The federal government could consider reforms to PURPA that require utilities to have moratoriums on energy shut-offs during extreme heat seasons.

Housing Improvements

Expand Weatherization Assistance Programs

Weatherization aims to make homes more energy efficient and comfortable in various climates through actions, such as attic and wall insulation, air sealing, or adding weather stripping to doors and windows. More than half of cities have a weatherization program. The Department of Energy (DOE) Weatherization Assistance Program (WAP) funding is available for states and other entities to retrofit older homes for improved energy efficiency to power cooling technologies like AC. However, similar to LIHEAP, WAP primarily focuses on support for heating-related repairs rather than cooling. For all residential property types, weatherization audits, through WAP and LIHEAP, can be expanded to consider heat resilience and cooling efficiency of the property and then identify upgrades such as more efficient AC, building envelope improvements, cool roofs, cool walls, shade, and other infrastructure. 

Further, weatherization can be complicated when trying to help the most vulnerable populations. As some of the houses are in such poor condition that they do not qualify for weatherization, there is a need for nationwide access to pre-weatherization assistance programs. These programs address severe conditions in a home that would cause a home to be deferred from the federal WAP because the conditions would make the weatherization measures unsafe or ineffective. Pre-weatherization assistance programs are typically run by the State WAP Office or administered in partnership with another state office.  

Additionally, as the Infrastructure Investment and Jobs Act (IJA) allocated roughly $3.5 billion to WAP, states should utilize this funding to target energy-insecure neighborhoods with high rates of rental properties. Doing so will help states prioritize decreasing energy insecurity and its associated safety risks for some of the most vulnerable households.

Increase Research on Federal Protections for Vulnerable Housing Types

There is a need for a nationwide policy for secure access to cooling. While the Department of Housing and Urban Development (HUD) does not regulate manufactured home parks, it does finance the parks through Section 207 mortgages. HUD  could stipulate park owners must guarantee resident safety. This agency could also update the Manufactured Home Construction and Safety Standards to allow for AC and other cooling regulations in local building codes to apply to manufactured homes, as they do for other forms of housing, as well as require homes perform to a certain level of cooling under high heat conditions. Additionally, to support lower-cost retrofit methods for manufactured homes and other vulnerable housing types, new approaches to financing, permitting, and incentivizing building retrofits should be developed, per the Biden-Harris Administration’s Climate Resilience Game Changers Assessment.  HUD’s Green and Resilient Retrofit Program, which provides climate resilience funding to affordable housing properties, can serve as a model.

Further, as home heat-risk remains under-studied and under-addressed by hazard mitigation planning, and policy processes, there needs to be better measures of home thermal security. Without better data, homes will continue to be overlooked in state and federal climate and adaptation efforts. 

Grid Resilience and Energy Access

Prioritize access to affordable, resilient energy alternatives for energy-insecure individuals

The most long-term investment in reducing energy insecurity and climate vulnerability is ensuring the most energy insecure populations have access to alternative, renewable energy sources, such as wind and solar.  This is a core focus of the DOE Energy Futures Grant (EFG) program, which provides $27 million in financial assistance and technical assistance to local- and state-led partnership efforts for increasing access to affordable clean energy. EFG is a Justice 40 program, and required to ensure 40% of the overall benefits of its federal investments flow to disadvantaged communities. Programs like EFG can serve as a model for federal efforts to reduce energy cost burdens, while simultaneously reducing dependence on nonrenewable energy sources like oil and natural gas. 

Accelerate Energy-Efficient Infrastructure

Efficient AC technologies, such as air source heat pumps, can help make cooling more affordable. Therefore, resilient cooling strategies, like high-energy efficiency cooling systems, demand/response systems, and passive cooling interventions, need federal policy actions to rapidly scale for a warming world. For example, cool roofs, walls, and surfaces can keep buildings cool and less reliant on mechanical cooling, but are often not considered a part of weatherization audits and upgrades. District cooling, such as through networked geothermal, can keep entire neighborhoods cool while relying on little electricity. However, this is still in the demonstration project phase in the U.S. Initiatives like the DOE Affordable Home Energy Shot can bring new resilient cooling technologies into reach for millions of Americans, but only if it is given sufficient financial resources. The Environmental Protection Agency’s Energy Star program can further incentivize low-power and resilient cooling technologies if rebates are designed that take advantage of these technologies.

KEY TAKEAWAYS

• OSHA’s proposed heat safety standard is a critical step towards protecting millions of workers, but its success depends on substantial infrastructure investment.
• Effective implementation requires a multifaceted approach, improving workforce development, employer and industry resources, regulatory capacity, healthcare access and community support.
• Federal government plays a pivotal role through funding, grants, technical assistance, and interagency collaboration to protect workers from the effects of extreme heat.
• Investing in heat safety infrastructure offers multiple benefits: lives saved, injuries prevented, economic protection, and enhanced climate resilience.
• Challenges to implementation include regulatory delays, insufficient funding, financial constraints for small businesses, diverse settings, rural infrastructure limitations, and lack of awareness.
• Overcoming these challenges requires dedicated funding sources, financial incentives, tailored solutions, and comprehensive education campaigns.
• The success of the OSHA standard hinges on prioritizing these infrastructure investments to create a comprehensive, well-resourced system for heat safety.

This article is informed by extensive research and stakeholder engagement conducted by the Federation of American Scientists, including a comprehensive literature review and interviews with experts in the field. Much of this work informed our recent publication which can be found here. 

The Imperative for Infrastructure Investment

As climate change intensifies, the need for robust heat safety measures for outdoor workers has never been more pressing. The Occupational Safety and Health Administration has taken a significant step forward in protecting workers from extreme heat by proposing a new safety standard. The proposed rule aims to protect approximately 36 million workers in indoor and outdoor settings from heat-related illnesses and fatalities. As we move forward, the rule’s success hinges on substantial investments to bridge the gap between policy and practice. It is crucial to examine how the federal government can create the necessary infrastructure to support and maximize the effectiveness of this potentially groundbreaking standard.

The need for these investments is underscored by the significant economic and human costs of heat-related illnesses and fatalities. A study by the Atlantic Council estimates that extreme heat costs the U.S. economy $100 billion annually, with agricultural workers being among the most affected. Proper implementation of safety measures could potentially prevent many of these fatalities and reduce substantial economic losses.

Key Areas for Infrastructure Development to Meet OSHA’s Heat Safety Rules

The outdoor occupational sector, employing tens of millions of workers across diverse landscapes and industries, faces unique challenges in properly implementing heat safety measures. From vast open fields to enclosed processing facilities, the infrastructure needs are as varied as the sector itself. Without targeted investments, the OSHA standard risks becoming an unfunded mandate, unable to fulfill its life-saving potential.

The effective implementation of OSHA’s proposed standard requires a multifaceted approach to infrastructure development. By focusing on these key areas, we can create a robust framework that supports the standard’s goals and protects outdoor workers across diverse settings and conditions. To maximize the impact of the proposed rule, investments must be strategically directed across several key areas. It is important to note that these areas represent a broad overview and are not exhaustive– comprehensive stakeholder engagement is essential to tailor solutions to specific needs across different states, regions, industries, and employers.

Workforce

Developing a resilient and well-prepared workforce is a cornerstone of effective safety measures. Key investments in training, access to facilities, and health monitoring ensure that workers are equipped to handle extreme heat conditions, safeguarding their health and productivity.

1. Training & Education. Developing multilingual, interactive training modules accessible to all workers is crucial. These programs must include ongoing education to ensure workers are continually updated on best practices for heat safety.
2. Access to Infrastructure. Installing hydration stations and shaded rest areas is essential to provide necessary relief from extreme heat. These facilities enable workers to stay hydrated and take breaks, significantly reducing the risk of heat exhaustion and heat stroke.
3. Personal Protective Equipment. Providing cooling vests, lightweight clothing, and sunscreen to protect workers from heat stress is another critical component. PPE must be tailored to the specific needs of workers, offering protection without hindering productivity.
4. Health Insurance. Ensuring workers have access to adequate health insurance is crucial, particularly for those in rural and underserved areas. This includes addressing the unique challenges faced by workers with complex immigration statuses, who may be hesitant to seek medical care or face barriers in obtaining insurance coverage.
5. Awareness. Implementing acclimatization programs and regular health screenings can help monitor workers’ health and identify early signs of heat stress. This includes educating workers about recognizing early signs of heat stress in themselves and colleagues, and understanding the importance of gradual adaptation to hot working conditions. 
6. Migrant Worker Vulnerabilities. Undocumented workers face unique challenges in accessing heat safety protections, such as fear of retaliation for reporting unsafe conditions, which can lead to underreporting of incidents. This vulnerability highlights the need for stronger protections and outreach strategies specifically tailored to this population.

Employer & Industry

Employers and industries play a critical role in implementing heat safety standards. By investing in infrastructure, regulatory compliance, and technological innovations, they can create safer working environments and ensure the sustainability of their operations.

1. Financial Assistance. Offering grants, subsidies, and tax incentives can support employers in implementing necessary safety measures. Financial support can alleviate the burden on small and medium-sized enterprises, ensuring that all employers can invest in heat safety infrastructure.
2. Physical Infrastructure. Employers must invest in the necessary infrastructure, including hydration stations, shaded rest areas, and cooling systems. These investments are essential for creating a safe working environment and ensuring compliance with the proposed standards.
3. Regulatory Compliance Support. Developing clear guidelines and compliance tools can help employers adhere to the new standards. Providing technical assistance and resources for compliance can simplify the process and encourage widespread adoption of safety measures .
4. Technology & Innovation. Utilizing weather monitoring systems, wearable heat sensors, and mobile health applications can enhance worker safety. These technologies enable real-time tracking of heat exposure and facilitate timely interventions, reducing the risk of heat-related illnesses.
5. Rural Infrastructure. Many agricultural operations are in rural areas with limited resources and infrastructure. This includes a lack of nearby healthcare facilities, making it difficult to quickly respond to heat-related illnesses in the workplace. Investments in rural infrastructure and targeted support can address these limitations.

Regulatory Agencies

Regulatory agencies are essential in enforcing heat safety standards. Increased resources, staffing, and technical expertise, along with robust data collection and public outreach, are necessary to support compliance and drive continuous improvement in safety measures.

1. Resources & Staffing. Adequate staffing is essential to enforce the new standards effectively. Increased financial resources would support hiring additional staff, enhance the technological capabilities for monitoring compliance, and ensure that there are adequate resources to investigate and address non-compliance.
2. Training & Expertise. Ensuring regulatory agencies possess the necessary technical and operational expertise through ongoing training for inspectors and regulatory staff to stay updated on the latest heat safety technologies, practices, and research.
3. Data Collection & Analysis. Developing incident reporting systems, syndromic surveillance, and integration of data with a centralized health and safety database can inform policy decisions and improve safety measures.
4. Public Outreach & Education. Implementing awareness campaigns, community engagement initiatives, and distributing educational materials can increase awareness of safety.
5. Research & Development. Funding for research collaborations with academic institutions and pilot programs to test new heat safety technologies and strategies is vital.
6. Whistleblower Protections. To ensure the effectiveness of heat safety measures, it’s crucial that all workers, including undocumented workers, can report dangerous conditions without fear of retaliation. Strengthening and enforcing whistleblower protections is essential to create a culture of safety and compliance.

Healthcare

A robust healthcare infrastructure is vital to support the prevention, early detection, and treatment of heat-related illnesses among outdoor workers. Investments in medical facilities, telemedicine, emergency response systems, and healthcare worker training are crucial to providing timely and effective care. 

1. Access to Healthcare. Strengthening access to healthcare is crucial, especially in rural and underserved areas. This involves expanding medical facilities and ensuring workers have access to qualified healthcare professionals and affordable treatment options tailored to heat-related conditions.
2. Telemedicine Infrastructure. Developing robust telemedicine platforms enables remote consultations for workers in remote areas. This provides timely healthcare interventions without the need for extensive travel.
3. Emergency Response Systems. Bolstering emergency response capabilities ensures that medical aid is swiftly available during critical heat-related incidents. This reduces potential health complications and improves outcomes for affected workers.
4. Healthcare Worker Training. Training healthcare professionals in the specifics of heat-related illnesses prepares them to offer effective treatment and preventative care. This enhances the overall response to heat stress conditions and improves patient outcomes.
5. Data Sharing & Coordination. Creating data-sharing frameworks between healthcare providers, emergency services, and public health agencies ensures a coordinated response to heat-related health issues. This enhances overall healthcare efficacy and enables better tracking and management of heat-related incidents.

Community & Advocacy Groups

Community and advocacy groups play a pivotal role in bridging the gap between policy and practice. By supporting local networks, grassroots education programs, and worker advocacy efforts, these groups can significantly enhance the effectiveness of heat safety initiatives. Their involvement ensures that programs are culturally appropriate, widely understood, and effectively implemented on the ground.

1. Worker Education. Implementing wide-reaching education and advocacy programs helps raise awareness about heat risks. These efforts promote community-wide preventive measures and empower workers to protect themselves.
2. Advocacy. Ensuring direct worker representation in policy discussions and implementation planning is crucial. Their firsthand experiences are invaluable in creating effective, practical safety measures that address real-world challenges.
3. Local Heat Safety Networks. Supporting the creation of community networks ensures the distribution of heat safety resources. These networks enhance preparedness and response to heat risks at the local level.
4. Worker Advocacy Support. Providing resources to advocacy groups enables effective representation of workers‘ safety interests. This ensures that policies are worker-centered and address the actual needs of those most affected by heat hazards.
5. Community Resilience Planning. Collaborating with community groups to develop localized resilience strategies strengthens community preparedness against heat impacts. This approach integrates workplace safety measures with broader community resilience efforts.

The Federal Government’s Role in Facilitating Investments

Successful implementation of OSHA’s heat safety standard requires substantial federal support and coordination. The government must actively facilitate and incentivize necessary investments to create a robust heat safety infrastructure. By leveraging its resources, the federal government can catalyze nationwide improvements. Key actions include:

1. Program Investment. Must significantly invest in funding agencies like OSHA and HHS to enhance their capacity to implement and enforce the safety program. This includes financial resources for hiring additional staff, improving technological capabilities, and offering comprehensive training and support to employers.
2. Providing Financial Incentives. Should provide targeted grants, subsidies, and tax incentives. These financial aids will alleviate the burden on small and medium-sized enterprises, fostering widespread adoption of advanced heat safety measures.).
3. Capacity Building. Must develop and support comprehensive educational programs and training workshops to enhance the capabilities of the workforce. This will ensure that workers are well-informed and equipped to effectively navigate and implement complex safety regulations.
4. Public-Private Partnerships. Must encourage collaboration between the public sector and private enterprises, leveraging private innovation alongside public resources to ensure that safety solutions are comprehensive and widely accessible.
5. Interagency Coordination. This involves pooling resources, expertise, and efforts from diverse federal agencies to support and enforce the heat safety regulations efficiently. Agencies should identify and allocate resources within their scope to contribute to a broad-based support network—ranging from funding and manpower to specific programmatic initiatives, as well as data-sharing and surveillance.
6. Overcoming Bureaucratic Inertia. Delays and resistance within government agencies can impede the timely adoption and enforcement of new regulations. Streamlining processes and clear mandates can help overcome this inertia.

The Benefits of Investing in Heat Safety Infrastructure

Investing in heat safety infrastructure yields numerous benefits, including:

1. Lives Saved, Improved Worker Health & Safety. Investing in proper heat safety infrastructure significantly reduces the incidence of heat-related illnesses, such as heat exhaustion and heat stroke, which can be fatal. This reduction cascades into numerous health and safety benefits:
   • The most immediate and crucial benefit is the preservation of human life and health
   • Enhances workplace safety culture
   • Reduces long-term health complications from chronic heat exposure
   • Enables better management of pre-existing health conditions exacerbated by heat
   • Improves public health outcomes in heat-vulnerable communities
   • Reduces inequality by protecting vulnerable worker populations
   • Example: a study reported a 91% decrease in heat-related illnesses following the implementation of safety measures.
2. Economic Benefits. Heat safety investments stimulate economic growth through multiple channels, creating a positive ripple effect across businesses and communities. Key economic advantages include:
   • Increased workforce productivity and efficiency
   • Reduced absenteeism and turnover rates
   • Stimulation of local economies through infrastructure investments
   • Reduced healthcare costs for both employers and the broader healthcare system
   • Improved job satisfaction and worker morale
   • Enhanced employer reputation and ability to attract/retain talent
   • Example: the same study saw heat-related illness claims drop from 30 per 1,000 workers to zero, eliminating workers’ compensation claims entirely.
3. Climate Resilience.  As global temperatures rise, building infrastructure to withstand extreme heat conditions becomes crucial for overall climate resilience. This proactive approach offers several strategic advantages:
   • Increases adaptability to rising global temperatures
   • Enables integration with broader climate adaptation strategies
   • Reduces energy consumption through efficient cooling methods
   • Enhances business continuity during extreme weather events
   • Reduces risk of legal liabilities and regulatory penalties
   • Enhances organizational preparedness for climate change impacts

Moving Forward

As we face the escalating challenges of climate change, the urgency to protect our workforce cannot be overstated. The proposed OSHA heat safety standard marks a crucial advancement in safeguarding our agricultural workers from the rise of extreme heat conditions. While some may express concerns about the costs and regulatory burden of these investments, it’s crucial to consider the long-term benefits. The initial expenses are outweighed by reduced healthcare costs, increased productivity, and avoided workers’ compensation claims. These measures protect businesses from potential legal liabilities and reputational damage associated with worker heat-related illnesses or fatalities. Moreover, investing in federal infrastructure to support this standard is a strategic imperative that will yield significant returns in public health, economic productivity, and climate resilience.

By thoughtfully allocating resources, the federal government can create a powerful framework for implementing and maximizing the impact of the proposed standard. The health and safety of millions of workers, particularly in high-risk sectors like agriculture, depend on our ability to create a comprehensive, well-resourced system. Every stakeholder from policymakers to industry leaders must now rise to the occasion. It is imperative that we channel collective efforts and resources before another heatwave claims more lives. The consequences of inaction are too severe to ignore.

For specific actions you can take to protect our outdoor workers, please refer to the strategies outlined in Appendix A: Call to Action Guide.

Appendix A. Call to Action Guide

This guide offers strategies for various stakeholders to support and enhance the implementation of OSHA’s heat safety rule.

For Policymakers

• Prioritize Funding. Expedite allocation of funds for heat safety infrastructure development.
• Facilitate Collaboration. Promote interagency cooperation to streamline rule implementation.
• Supportive Legislation. Enact laws that reinforce and expand heat safety protections.
• Oversight. Conduct regular reviews of the rule’s implementation and effectiveness.

For Employers

• Proactive Adoption. Implement heat safety measures ahead of the OSHA rule finalization.
• Infrastructure Investment. Allocate resources for necessary heat safety equipment and facilities.
• Training Programs. Develop comprehensive heat safety education for all employees.
• Best Practices. Engage with industry associations to share effective strategies.

For Workers and Advocacy Groups

• Active Participation. Engage in public comment periods and local heat safety initiatives.
• Collaboration. Work with employers to identify and address workplace heat risks.
• Community Education. Raise awareness about heat safety rights and available resources.
• Reporting. Encourage the use of whistleblower protections to report unsafe conditions.

For Healthcare Providers

• Emergency Preparedness. Enhance readiness for heat-related illnesses, especially in underserved areas.
• Ongoing Training. Participate in regular updates on heat illness prevention and treatment.
• Community Outreach. Partner with employers and local organizations to promote heat safety awareness.
• Data Sharing. Contribute to heat-related illness surveillance efforts to inform policy and practice.

For Researchers and Academic Institutions

• Effectiveness Studies. Evaluate various heat safety measures and emerging technologies.
• Innovation. Develop new solutions for heat stress prevention and management.
• Industry Partnerships. Collaborate with businesses to apply research findings in real-world settings.
• Policy Guidance. Provide evidence-based recommendations to inform future regulations.

On Monday, July 9, nearly 3 million homes and businesses in Texas were suddenly without power in the aftermath of Hurricane Beryl. Today, four days later, over 1 million Texans are entering a fourth day powerless. The acting governor, Dan Patrick, said in a statement that restoring power will be a “multi-day restoration event.” As people wait for this catastrophic grid failure to be remedied, much of southeast Texas, which includes Houston, is enduring dangerous, extreme heat with no air conditioning amid an ongoing heatwave. 

Extreme Heat is the “Top Weather Killer”

As our team at FAS has explained, prolonged exposure to extreme heat increases the risk of developing potentially fatal heat-related illnesses, such as heat stroke, where the human body reaches dangerously high internal temperatures. If a person cannot cool down, especially when the nights bring no relief from the heat, this high core temperature can result in organ failure, cognitive damage, and death. Extreme heat is often termed the “top weather killer,” as it’s responsible for 2,300 official deaths a year and 10,000 attributed via excess deaths analysis.  With at least 10 lives already lost in Texas amidst this catastrophic tragedy, excess heat and power losses are further compounding vulnerabilities, making the situation more dire. 

Policy Changes Can Save Lives

These losses of life and power outages are preventable, and it is the job of the federal government to ensure this. Our team at FAS has previously called for attention to the soaring energy demands and unprecedented heat waves that have placed the U.S. on the brink of widespread grid failure across multiple states, potentially jeopardizing millions of lives. In the face of widespread blackouts, restoring power across America is a complex, intricate process requiring seamless collaboration among various agencies, levels of government, and power providers amid constraints extending beyond just the loss of electricity. There is also a need for transparent protocols for safeguarding critical medical services and frameworks to prioritize regions for power restoration, ensuring equitable treatment for low-income and socially vulnerable communities affected by grid failure events.

As a proactive federal measure, there needs to be a mandate for the implementation of an Executive Order or an interagency Memorandum of Understanding (MOU) mandating the expansion of public health and emergency response planning for widespread grid failure under extreme heat. This urgently needed action would help mitigate the worst impacts of future grid failures under extreme heat, safeguarding lives, the economy, and national security as the U.S. moves toward a more sustainable, stable, and reliable electric grid system.Therefore, given the gravity of these high-risk, increasingly probable scenarios facing the United States, it is imperative for the federal government to take a leadership role in assessing and directing planning and readiness capabilities to respond to this evolving disaster.

Image via NWS/Donald Sparks

Comprehensive recommendations from +85 experts to enable a heat-resilient nation

From August 2023 to March 2024, the Federation of American Scientists (FAS) talked with +85 experts to source 20 high-demand opportunity areas for ready policy innovation and 65 policy ideas. In response, FAS recruited 33 authors to work on +18 policy memos through our Extreme Heat Policy Sprint from January 2024 to April 2024, generating an additional +100 policy recommendations to address extreme heat. Our experts’ full recommendations can be found here. In total, FAS has collected +165 recommendations for 34 offices and/or agencies. Key opportunity areas are described below and link out to a set of featured recommendations. Find the 165 policy ideas developed through expert engagement here.

America is rapidly barreling towards its next hottest summer on record. While we wait for a national strategy, states, counties, and cities around the country have taken up the charge of addressing extreme heat in their communities and are experimenting on the fly. California has announced $200 million to build resilience centers that protect communities from extreme heat and has created an all-of-government action plan to address extreme heat. Arizona, New Jersey, and Maryland are all actively developing extreme heat action plans of their own. Miami-Dade County considered passing some of the strictest workplace heat rules (although the measure ultimately failed). Additionally, New York City and Los Angeles have driven cool roof adoption through funding programs and local ordinances, which can reduce energy demands, improve indoor comfort, and potentially lower local outside air temperatures.  

While state and local governments can make significant advances, national extreme heat resilience requires a “whole of government” federal approach, as it intersects health, energy, housing, homeland and national security, international relations, and many more policy domains. The federal government plays a critical role in scaling up heat resilience interventions through research and development, regulations, standards, guidance, funding sources, and other policy levers. But what are the transformational policy opportunities for action?

Sourcing Opportunities and Ideas for Policy Innovation

During Fall 2023, FAS engaged +85 experts in conversations around federal policies needed to address extreme heat. Our stakeholders included: 22 academic researchers, 33 non-profit organization leaders, 12 city and state government employees, 3 private company leaders, 2 current or former Congressional staffers, 3 National Labs leaders, and 10 current or former federal government employees. Our conversations were guided by the following four questions:

• What work are you currently doing to address extreme heat?
• What do you see as some of the opportunity areas to address extreme heat?
• What are the existing challenges to managing and responding to extreme heat?
• What actions should the federal government take to address extreme heat?

Our conversations with experts sourced 20 high-demand opportunity areas for policy innovation and 65 policy ideas. To go deeper, FAS recruited 33 authors to work on +18 policy memos through our Extreme Heat Policy Sprint, generating an additional +100 policy recommendations to address extreme heat’s impacts and build community resilience. Our policy memos from the Extreme Heat Policy Sprint, published in April 2024, provide a more comprehensive dive into many of the key policy opportunities articulated in this report. Overall, FAS’ work scoping the policy landscape, understanding the needs of key actors, identifying demand signals, and responding to these demands has generated +165 policy recommendations for 34 offices and/or agencies.

Opportunities for Extreme Heat Policy Innovation

The following 20 “opportunity areas” are not exhaustive, yet can serve as inspiration for the building blocks of a future strategic initiative.

Facilitate Government-Wide Coordination

The first opportunity is an overarching call to action: the need for a government-wide extreme heat strategic initiative. This can build upon the National Integrated Health Health Information System’s (NIHHIS) National Heat Strategy, set to release this year. This strategy would define the problems to solve, create targets and galvanizing goals, set and assign priorities for federal agencies, review available resources for financial assistance, assess regulatory and rulemaking authority where applicable, highlight legislative action, and include evaluation metrics and timeline for review, adjustment, and renewal of programs. In creating this strategy, one interviewee recommended there should be a comprehensive review of “heat exposure settings” and federal actors that can safeguard Americans in these settings: homes, workplaces, schools and childcare facilities, transit, senior living facilities, correctional facilities, and outdoor public spaces. Through scoping potential regulations, standards, guidelines, planning processes, research agendas, and financial assistance, the federal government will then be prepared to support its intergovernmental actors and communities.

Infrastructure And The Built Environment

Accelerate Resilient Cooling Technologies, Building Codes, and Urban Infrastructure

On average, Americans spend 90% of their time indoors, making the built environment a critical site for heat exposure mitigation. To keep cool, especially in places of the U.S. not used to extreme heat, buildings are increasingly reliant on mechanical cooling interventions. While a life-saving necessity, air conditioning (AC) consumes significant amounts of electricity, putting high demands on aging grid infrastructure during the hottest days. Excess heat from air conditioners can lead to higher outdoor temperatures and even more AC demand. Finally, ACs are useless interventions if there’s no power, an increasing risk due to growing energy poverty and grid failure. In these scenarios, our current construction is likely to widely “fail” in its ability to cool residents.

Resilient cooling strategies, like high-energy efficiency cooling systems, demand/response systems, and passive cooling interventions, need policy actions to rapidly scale for a warming world. For example, cool roofs, walls, and surfaces can keep buildings cool and less reliant on mechanical cooling, but are often not considered a part of weatherization audits and upgrades. District cooling, such as through networked geothermal, can keep entire neighborhoods cool while relying on little electricity, but is still in the demonstration project phase in the United States. Heat pumps are also still out of reach for many Americans, making it essential to design technologies that work for different housing types (i.e. affordable housing construction). Initiatives like the Department of Energy’s (DOE) Affordable Home Energy Shot can bring these technologies into reach for millions of Americans, but only if it is given sufficient financial resources. DOE’s Office of Clean Energy Demonstrations and State and Community Energy Programs FY25 budget request to strengthen heat resilience in disadvantaged communities through energy solutions could be a step towards realizing innovative heat technologies. Further, the Environmental Protection Agency’s Energy Star program can further incentivize low-power and resilient cooling technologies — if rebates are designed that take advantage of these technologies.

Thermal resilience of buildings must also be considered, for both day-to-day operations and emergency blackout scenarios. DOE can work with stakeholders to create “cool” building standards and metrics with human health and safety in mind, and integrate them into building codes like ASHREI 189.1 and 90 series. These codes are “win-wins” for building designers, creating buildings that consume far less electricity while keeping inhabitants safe from the heat. DOE can assist in conducting more demonstration projects for building strategies that ensure indoor survivability in everyday and extreme conditions. 

Intervention efficacy and applicability are still evolving for extreme heat resilience interventions at the community scale, such as cool pavements, urban greening, shading, ventilation corridors, and development regulations (i.e. solar orientation). Individual interventions and their interactions need more evidence of their costs and benefits, potential tradeoffs and maladaptations. The National Institutes of Standards and Technology works on building and urban planning standards for other natural hazards, such as their National Windstorm Impact Reduction Program (NWIRP) and their Community Resilience program, and could serve as a “technology test-bed” for heat resilience practices and advance our understanding of their effectiveness as well as how to measure and account for benefits and costs. This could be done in partnership with the National Science Foundation, which has been dedicating funding for use-inspired research and technology development for climate resilience.

Finally, the U.S. government is the largest landlord in the nation. As the General Services Administration is rapidly decarbonizing its buildings, it can also be a test site for new technologies, building designs, planning, and resilience metrics development and analysis.

Adapt Transportation to the Heat

Public transportation is a site of high exposure to extreme heat. While the Department of Transportation’s Promoting Resilient Operations for Transformative, Efficient, and Cost-saving Transportation (PROTECT) grants are for “surface transportation resilience,” multiple of our local and regional government interviewees expressed difficulty successfully applying to these grants for “cooling” infrastructure, like water fountains, shade, and air-conditioned bus shelters. DOT should make extreme heat resilience explicit in its eligibility requirements as well as review the benefit-cost analysis (BCA) formula and how it might disadvantage cool infrastructure. 

Asphalt and concrete roadways contribute to the urban heat island effect and hotter weather makes asphalt in particular more vulnerable to cracking. DOT should leverage its research and development (R&D) capabilities to develop and deploy reflective and cool materials as a part of transportation infrastructure improvements. Finally, DOT should also consider the levers available to incentivize cool surfaces and cool materials as a part of transportation construction.

Create More Heat-Resilient Schools for Sustained Learning

Higher temperatures combined with minimal to no air conditioning in older school buildings have led to an increase in the number of “heat days”, or school closures due to dangerous temperatures. Pulling children out of the classroom not only negatively impacts them, but also puts increasing strain on families that rely on schools as childcare. Even when school is in session, many students are attempting to learn in classrooms exceeding 80°F, a temperature threshold where studies have repeatedly shown that students struggle to learn and fall short of true academic performance. This is because heat reduces cognitive function and ability to concentrate – both essential to learning. Learning loss from rising heat will only compound the learning losses from the COVID-19 pandemic. The Environmental Protection Agency predicts that the total lost future income attributable to heat-related learning losses may reach $6.9 billion at 2°C (a threshold we are well on the way to meeting) and $13.4 billion at 4°C. Schools need guidance on how to deal with the heat crisis currently at hand, while being supported as they plan necessary climate adaptations needed for a hotter world. 

At a minimum, schools can be encouraged to formalize plans for school heat preparedness to protect both the health of students and safeguard their learning. No federal heat safety recommendations yet exist and thus will need to be created by the Department of Education (Ed), EPA, FEMA, the National Oceanic and Atmospheric Administration (NOAA), and others. Title I Grants, in alignment with Justice40, could then assist schools in adapting to climate change that includes researched guidance on ways to cool students indoors, outdoors, and through behavioral management. Further, school system leaders need a better system to track how schools are currently experiencing extreme heat and what strategies could be employed to respond to heat exposure (closing schools, informed behavioral interventions to manage heat exposure, green infrastructure to build resilience, etc). Federal involvement is essential for creating this tool. Finally, to address the root causes of excessive classroom heat, schools will need to transform their infrastructure through HVAC investments and improvements, greening, playground material changes and shading. HVAC costs alone are expected to be $40 billion for all U.S. schools that need infrastructure improvements. While Inflation Reduction Act (IRA) tax credits are available for updating HVAC systems, many low-wealth schools will not be able to finance the gap between the credit coverage and the true cost and will need additional financial assistance.

Make Housing and Eviction Policy More Climate-Aware and Resilient

Most of the U.S. lacks minimum cooling requirements for buildings and existence of a cooling device within the property. Adoption of the latest building energy codes, despite their previously described limitations, can still be a cost-saving and life-saving advancement according to research by the DOE. For new properties, the Federal Housing Finance Agency could require that they adhere to the latest energy codes to receive a mortgage from Government Sponsored Enterprises, which is already under consideration by Housing and Urban Development (HUD) and the U.S. Department of Agriculture (USDA) for their mortgage products. For older construction, there could be requirements for adequate cooling to exist in the property at the point of sale. 

For all property types, weatherization audits, through the Weatherization Assistance Program (WAP) and Low-Income Home Energy Assistance Program (LIHEAP), can be expanded to consider heat resilience and cooling efficiency of the property and then identify upgrades such as more efficient HVAC, building envelope improvements, cool roofs, cool walls, shade, and other infrastructure. If cooling the entire property is unfeasible or costly, homeowners could benefit from creating “Climate Safe Rooms”  which are guaranteed to be safe during a heat wave. DOE and HUD could collaborate to demonstrate climate safe rooms in affordable housing, where many residents lack access to consistent cooling.

Some housing types are more risky than others. People living in manufactured homes in Arizona were 6 to 8 times more likely to die indoors due to extreme heat. This is because of poorly functioning or completely defunct cooling systems and/or inability to pay electric bills. Manufactured home park landlords can also set a variety of rules for homeowners, including banning cooling devices like window ACs and shade systems. While states like Arizona have now passed laws making these bans illegal, there is a need for a nationwide policy for secure access to cooling. HUD does not regulate manufactured homes parks, but does finance the parks through Section 207 mortgages and could stipulate park owners must guarantee resident safety. Finally, HUD could also update the Manufactured Home Construction and Safety Standards to allow for HVAC and other cooling regulations in local building codes to apply to manufactured homes, as they do for other forms of housing, as well as require homes perform to a certain level of cooling under high heat conditions. 

Renter’s are another highly vulnerable population. Most states do not require landlords to provide cooling devices to tenants or keep housing below risky temperatures. HUD for example does not require cooling devices in public housing, although regulations exist for heating. HUD could implement similar guarantees of a “right to cool”. Evictions in the summer months are also on the rise, due to rising rents compounded with rising energy costs, putting people out in the deadly heat. Keeping people in housing should be of the utmost importance, yet implementation remains fractured across the nation. Eviction moratoriums at a national level have been challenged by the Supreme Court, which overturned the CDC’s COVID-19 moratorium.

Address Communities’ Needs for Long-Term Infrastructure Funding Support

Heat vulnerability mapping has advanced significantly in the past few years. Federal programs like the NIHHIS’s Urban Heat Island Mapping Campaigns have mapped +60 communities in the United States that have guided city policy. The Census’ new product, Community Resilience Estimates (CRE) for Heat, assesses vulnerability at the level of individuals and households. Finally, researchers and non-profit organizations have been developing tools that can assess risk and also aid in individual or local decision-making, such as the Climate Health and Risk Tool and Heat Factor^Ⓡ. 

Advancements in our understanding of heat’s impacts and potential interventions have not translated to sustained resources to support transformative infrastructure development. As one interviewee put it “communities that have mapped their urban heat islands are still waiting on funding opportunities to build relevant infrastructure projects”. Federal grants for mitigation and resilience may or may not consider heat resilience projects “cost-effective” and aligned with grant-making objectives, leading to rejection. 

FEMA’s Hazard Mitigation Grants (HMGP), made available only after a federally-declared disaster, can only be used for extreme heat in specific circumstances and recommends that cost-effective heat mitigation projects will also “reduce risks of other hazards”. Another example, FEMA’s BRIC grant has rejected cooling centers, HVAC upgrades, and weatherization activities, all strategies with some benefit to preventing morbidity and mortality. Green infrastructure projects, with co-benefits such as flood mitigation, have been more successful, often because the BCA is based on the property-damaging hazard, flooding. Only one FEMA BRIC project has been funded with heat as the main hazard, an urban greening project in Portland, Oregon. This unknown regarding grant success can lead to communities not applying with a heat-focused project, when time could be better spent securing grants for other community priorities. FEMA’s announcement that it will fund net-zero projects, including passive heating and cooling, through its HMGP and BRIC programs and Public Assistance could shift the paradigm, yet communities will likely need more guidance and technical assistance to execute these projects.
To invest in resilience to the growing risk of heat, policymakers will need to create a dedicated and reliable funding resource. Federal stakeholders can look to the states for models. California’s Integrated Climate Adaptation and Resiliency Program’s Extreme Heat and Community Resilience grants are currently slated to allocate $118 million to 20-40 communities for planning and implementation grants over three rounds. To start, FEMA could replicate this program, similar to its specific programs for wildfires, providing $50,000 to $5 million to a wide range of heat resilience projects, and make it eligible for joint funding through BRIC. DOE’s $105 million FY25 budget request for a program for planning, development, and demonstration of community-scale solutions to mitigate extreme heat in low-income communities is a step in the right direction. If funded, the program would benefit from coordinating with FEMA’s BRIC program on high-impact solutions.

Workforce Safety And Development

Set Indoor and Outdoor Temperature Standards and Workplace Protections to Protect Human Health

Our understanding of when heat becomes risky to human health and impacts daily governance is still in development. Our interviewees shared that there is not yet consensus or agreement on the lower threshold for 1) when outdoor and indoor temperatures risks begin and 2) at what level of continued exposure should there be cause for action, such as implementing breaks for workers or deploying rapid emergency cooling to residents. For workplaces, guidelines will come soon: the Occupational Health and Safety Administration (OSHA) is set to release their heat standard for indoor and outdoor workers by the end of 2024, which will advance heat safety for workers across the country. For all other settings (such as residential settings and schools), the jury is still out on a valid threshold and a regulatory mechanism to establish it.

Enforcement of standards is necessary for realizing their full potential. In preparation for a workplace heat standard, interviewees recommended the Department of Labor create an advanced Hazard Alert System for Heat (using an evolved data standard discussed in a later section) in order to better pinpoint regulatory enforcement. Small businesses will also need help to be prepared for compliance with the new standard. DOL and the Small Businesses Administration should consider setting up a navigator program for resourcing energy-efficient, worker-centric cooling strategies, leveraging IRA funds where applicable.

Build the Extreme Heat Resilience Workforce

Extreme heat is not just a challenge to worker health, it’s also a challenge to workforce ability and capacity. As heat becomes a threat to the entire nation, many fields are needing to rapidly adapt to entirely new knowledge bases. For example, much of the health workforce, doctors, nurses, public health workers, receive little to no education on climate change and climate’s health impacts. Programs are beginning to crop up, such as Harvard’s C-Change Program, yet will need support to scale. With the federal government being the nation’s largest single source funder of graduate medical education, there are many levers at their disposal to develop, incentivize, and even require climate and health education. The U.S. Public Health Commissioned Corps is another program that could mobilize a climate-aware health workforce, placing professionals with a deep awareness of climate change’s impact on health in local communities.

The weatherization and decarbonization workforce must also be made aware and ready for heat’s growing impacts and emerging strategies to build building and community-scale resilience. While promising strategies exist for heat mitigation, such as cool walls and roofs, these interventions are largely not considered during weatherization audits and energy efficiency audits. Tax credits that have been created by the IRA/BIL could be used for interventions for passive or low-energy cooling, yet a lack of clarity prevents their uptake and implementation. For example, EPA’s EnergyStar program used to certify roofing products before the program sunsetted in 2022. Stakeholders at DOE and EPA should consider their role in workforce readiness for extreme heat, collaborating with third party entities to build awareness about these promising strategies.

Navigating all of the benefits of the IRA and BIL is challenging for resource-strapped communities and households. Program navigators for weatherization assistance and resilience could be an incredible asset to low-resource communities, and leverage IRA resources for technical assistance as well as the newly created American Climate Corps.

Finally, the federal government workforce is being stretched thin by the sheer number of new mandates in IRA and BIL. To meet the moment, agencies have used flexible hiring mechanisms like the Intergovernmental Personnel Act (IPAs) and for some offices its BIL and IRA connected Direct Hire Authority to make those critical talent decisions and staff their agencies. DOE, for example, has exceeded its goals – hiring over 1000 new employees to date. But not all agencies and offices have access to the Direct Hire Authority –  and it’s set to expire anywhere between 2025 (for IRA) and 2027 (for BIL). Congress should be encouraged to expand this authority, extend it beyond 2025 and 2027 respectively, and remove the limit on the number of staff allowed. Further, agencies should be encouraged to use other flexible hiring mechanisms like IPAs and other termed positions. The federal government should have the talent needed to meet its current mandates and be prepared to solve problems like extreme heat.

Public Health, Preparedness, And Health Security

Build Healthcare System Preparedness

Years of underinvestment in preparedness have impacted U.S. health infrastructure’s surveillance, data collection, and workforce capacity to respond to emerging climate threats like extreme heat. The Administration for Strategic Planning and Response’s Hospital Preparedness Program, which prepares healthcare systems for emergencies, has had its budget reduced by 67% from FY 2002-FY2022, considering inflation. Further, the Center for Disease Control and Prevention (CDC) has seen a 20% budget reduction from FY 2002-2022. The CDC’s Climate Ready States and Cities Initiative can only support nine states, one city, and one county, despite 40 jurisdictions having applied. The Trust for America’s Health (TFAH) found increasing funding from $10 million to $110 million is required to support all states, and improve climate surveillance. The TFAH also found that an additional $75 million is needed to extend the CDC’s National Environmental Public Health Tracking Program, a program that tracks threats and plans interventions, to every state. Finally, the Office of Climate Change and Health Equity, the sole office within Health and Human Services solely dedicated to the intersection of climate and health, has yet to receive direct appropriations to support its work. 

Centers for Medicare and Medicaid (CMS) and the Healthcare Resources and Services Administration (HRSA) provide critical investments to healthcare facilities, operations, care provision, and the medical workforce, yet have no publicly available programs dedicated to building climate resilience in the face of rising temperatures. The Veterans Health Administration (VHA), the largest integrated healthcare system in the U.S., includes responding to heat wave exposure in its agency Climate Action Plan and has made commitments to developing biosurveillance systems that incorporate external data on air quality, temperature, heat index, and weather as well as upgrading medical center infrastructure. This is critical as 62% of VHA medical centers are exposed to extreme heat and the VHA sees a rise in heat-related illness in the Veteran population. Given its sheer size, systems changes like this made by the VHA can drive real change in healthcare practice. 

To build resilience to extreme heat within healthcare systems, our interviews and literature review highlighted that these three actions are most critical: 1) increasing surveillance and tracking of heat-related illness through improvements to medical diagnosis and coding practices and technological systems (i.e. EHRs); 2) leveraging healthcare financing for preventative treatments (i.e. cooling devices), incentives for climate-change preparedness, accurate coding and treatment, and quality care delivery (CQIs), and requirements for accreditation and reimbursements; and 3) fostering capacity-building through grants, technical assistance, planning support and guidance, and emergency preparedness. 

Design Activation Thresholds for Public Health, Medical, and Emergency Responses

Despite the fact that extreme heat events have overwhelmed local capacity and triggered local disaster declarations, heat is not explicitly required in healthcare preparedness efforts authorized under the Pandemics and All Hazards Preparedness Act (PAHPA), insufficiently included or not included at all in local and state hazard mitigation plans required by FEMA, and there has yet to be a federal disaster declaration for heat. This all inhibits the deployment of federal resources to mitigation, planning, and response that states and local jurisdictions rely on for other hazards. Our interviewees recommended that there needs to be better “activation thresholds” for heat i.e. markers that the hazard has reached a level of impact that needs additional capacity and resources. Most thresholds set right now just rely on high-temperatures, not the risk factors that exacerbate the impacts of heat. Data inputs into these locally-relevant thresholds can include wet-bulb globe temperature (which accounts for humidity), heat stress risk, level of acclimatization, nighttime temperatures, building conditions and cooling device uptake, work situations, other compounding health risks like wildfire smoke, and other factors. These activation thresholds should also be designed around the most heat-vulnerable populations, such as children, the elderly, pregnant people, and those with comorbidities. 

Increased transmission of viral pathogens and pathogen spread is also a growing risk of overall hotter average temperatures that needs more attention. Increased pathogen surveillance and correlation with existing climate conditions would greatly enable U.S. pandemic and endemic disease surveillance. Finally, no program to date at the Biomedical Advanced Development and Research Authority has focused on creating climate-aware medical countermeasures and the 2022-2026 strategic plan includes no mention of climate change. 

Reduce Energy Burdens, Utility Insecurity, and Grid Insecurity

As temperatures rise, so do energy bills. Americans are facing an ever-growing burden of energy debt. 16% (20.9 million people) of U.S. households find themselves behind on their energy bills, increasing the risk of utility shut-offs due to non-payment. The Low Income Home Energy Assistance Program (LIHEAP) exists to relieve energy burdens, yet was designed primarily for heating assistance. Thus, the LIHEAP formulas advantage states with historically frigid climates. Further, most states use their LIHEAP budgets for heating first, leaving what remains for cooling assistance (or just don’t offer cooling assistance at all). As a result, nationally from 2001-2019, only 5% of energy assistance went to cooling. Finally, the LIHEAP program is massively oversubscribed, and can only service a portion of needy families. To adapt to a hotter world, LIHEAP’s budgets must increase and allocation formulas will need to be made more “cooling”-aware and equitable for hot-weather states. The FY25 presidential budget keeps LIHEAP’s funding levels at $4.1 billion, while also proposing expanding eligible activities that will draw on available resources. The National Energy Assistance Directors Association recent analysis found that this funding level could cut ~1.5 million families from the program and cut program benefits like cooling.

Another key issue is that 31 states have no policy preventing energy shut-offs during excessive heat events and even the states that have policies vary widely in their cut-off points. These cut-off policies are all set at the state level, and there is still an ongoing need to identify best practices that save lives. While the Public Utility Regulatory Policies Act of 1978 (PURPA) prohibits electric utilities from shutting off home electricity for overdue bills when doing so would be dangerous for someone’s health, it does not have explicit protections for extreme weather (hot/cold). Reforms to PURPA could be considered that require utilities to have moratoriums on energy shut-offs during extreme heat seasons.

Finally, grid resilience will become even more essential in a hotter climate. Power outages and blackouts during extreme heat events are deadly. If a blackout were to occur in Phoenix, Arizona during the summer, nearly 900,000 people would need immediate medical attention. Rising use of AC itself is a risk factor for blackouts due to increases in energy demand. The North American Electric Reliability Corporation (NERC), a regulatory organization that works to reduce risks to power grid infrastructure, issued a dire warning that two-thirds of the U.S.  are facing reliability challenges because of heatwaves. Ensuring grids are ready for the climate to come should be top priority for DOE, the Federal Emergency Management Agency (FEMA), and the Federal Energy Regulatory Commission (FERC). Given the risks to human health, the Centers for Disease Control and Prevention (CDC) should work with public health organizations to prepare for blackouts and grid failure events.

Address Critical Needs of Confined Populations Facing Heat

Confined populations, whether because of their medical status or legal status, are vulnerable to extreme heat indoors. Long-term care facilities are required by law to keep properties within 71-81℉. Yet, long-term care facilities are reporting challenges actually meeting resident’s needs in a disaster, such as a power outage, calling for a need for more coordination with CMS. 

Incarcerated populations on the other hand are not guaranteed any cooling, even as summers become more brutal. This directly leads to an increase in deaths, 45% of U.S. detention facilities saw spikes in deaths on hazardous heat days from 1982 to 2020. Despite this lack of sufficient cooling being “cruel and unusual” punishment, there has been no public activity to date from the Department of Justice to secure cooling infrastructure for federal prisons or work with state prisons to expand cooling infrastructure. The National Institute of Corrections does recommend ASHRAE 55 Thermal Environmental Conditions for Human Occupancy to corrections institutions, though this metric needs to be updated for our evolving understanding of extreme heat’s risks to human health.

Food Security And Multi Hazard Resilience

Anticipate and Prevent Supply Chain Disruptions 

Hotter temperatures are changing the landscape of American and global food production. 70% of global agriculture is expected to be affected by heat stress by 2045. Recent heat waves have already killed crops and livestock en masse, leading to lower yields and even shortages for certain products – like olive oil, potatoes, coffee, rice, and fruits. Rising heat is also poised to reshape local and state economies that rely on their changing climatic capabilities to produce certain crops. Oranges, a $5 billion dollar industry for Florida, are struggling in the heat which stresses the trees and provides fertile ground for pathogens. As a result, Florida is facing its worst citrus yield since the Great Depression. A decrease in winter chill is another growing risk, as many perennial crops have adapted to certain amounts of accumulated winter chill to develop and bloom. Winter-time heat is shaking up plants’ biological clocks, decreasing quality and yield. Overall, extreme heat is impacting American household bottom lines in the short-term and long-term through heat-exacerbated earning losses and spiking food prices. 

Ensuring ongoing access to critical commodity and specialty agricultural products in a future of higher temperatures is a national security priority. Resilience of products to extreme heat could be included as a future requirement in the Federal Supplier Climate Risks and Resilience Rule that governs Federal Acquisition Regulations. Further, FAS’ work scoping the federal landscape has shown there are few federal research and development programs, financial assistance opportunities, and incentives for heat resilience, and our interviewees concurred with that assessment. The U.S. Department of Agriculture (USDA) can prepare farmers for future climate risks and hotter temperatures, ensuring consistent food production and reducing the losses and needed economic pay-outs from the USDA through crop insurance and disaster assistance. The USDA can accelerate advances in biotechnology and genetic engineering to improve heat resilience of agricultural products while also encouraging practices like shade, effective water management, and soil regeneration that build system-wide resilience. As Congress continues to consider reauthorizations and appropriations for the Farm Bill, they should consider fully funding the Agriculture Advanced Research and Development Authority to advance resilient agriculture R&D while also increasing funding to the USDA Climate Hubs to support roll-out of heat resilient practices.

Connect Drought Resilience and Heat Resilience Strategies

Hotter winters have literal downstream consequences. Warming is shrinking the snowpack that feeds rivers, leading to further groundwater reliance, straining aquifers to the brink of complete collapse. Warmer temperatures also leads to more surface water evaporating, thus leaving less to seep through the ground to replenish overstressed aquifers. Rising temperatures also mean that plants need more water, as they evapotranspirate at greater rates to keep their internal temperatures in-check. All of these factors compound the growing risk of drought facing American communities. Drought, now made worse by high heat conditions, accounts for a significant portion of annual agricultural losses. 80% of 2023 emergency disaster designations declared by the United States Department of Agriculture (USDA) were for drought and/or excessive heat. Secure access to water is an escalating catastrophe, and to address it requires a national strategy that accounts for future hotter temperatures and how they will put strain on water accounts necessary to sustain agricultural production and human habitation.

Heat and dry weather/drought also combine to make prime conditions for megawildfires. The smoke then generated by these fires compounds the health impacts of extreme heat, with research showing that concurrent effects of heat and smoke drive up the number of hospitalizations and deaths. More funding from Congress is needed to improve wildfire forecasting and threat intelligence in the era of compounding hazards.

Planning And Response

Reform the Benefit-Costs Analysis

Benefit cost analysis (BCA) is a critical tool for guiding infrastructure investments, and yet is not set up to account for the benefits of heat mitigation investments. When the focus of the BCA is mitigating property damage and loss of life, it will discount impact’s that go beyond those damages such as economic losses, learning losses, wage losses, and healthcare costs. Research will likely be needed to generate the pre-calculated benefits of heat mitigation infrastructure, such as avoiding heat illness, death, and wage losses and preventing widespread power failures (a growing risk). Further, strategies that enhance an equitable response, articulated in the recent update to the Office of Management and Budget’s Circular A-4, need to be quantified. This could include response efforts that protect the most vulnerable populations to extreme heat, such as checking in on heat sensitive households identified by the CRE for Heat. Developing these metrics will take time, and should be done in partnership with agencies like the DOE, EPA, and CDC. Finally, FEMA’s BCA is often based on a single hazard, the one with the highest BCA ratio, making it more challenging to work on multi-hazard resilience. FEMA should develop BCA methods that allow for accounting of an infrastructure investment for community resilience to many hazards (like resilience hubs).

Create the “Plan” for How the Federal Emergency Management Agency and Others Should Respond to an Extreme Heat Disaster

Extreme heat’s extended duration, from a few days to several months, poses a significant challenge to existing disaster policy’s focus on acute events that damage property. An acute focus on infrastructure damages by FEMA has been an insurmountable barrier to all past attempts to declare extreme heat as a disaster and receive federal disaster assistance. Because in theory, FEMA can reimburse state and local governments for any disaster response effort that exceeds local resources, including heat waves. Our interviewees acknowledged that federal recognition that heat waves are disasters will only come with extending the definition of what a disaster is.

New governance models will need to be created for climate and health hazards like extreme heat, focusing on an adaptation forward, people-centered disaster response approach given the outsized impact of heat hazards on human health and economic productivity. Such a shift will challenge the federal government’s existing authorities authorized under national disaster law, the Stafford Act, which at this current moment does not consider “human damages” beyond loss of life. Thus, we do not see how existing infrastructure fails to provide critical function during these heat hazard events, such as secure learning, secure workplaces, secure municipal operations, secure healthcare delivery, and resultantly strains or exceeds local resources to respond. By quantifying more of these damages, there will then be an existing incentive to design responses that address current impacts and plan for and mitigate future impacts. 

Finally, there are highly-risky heat disasters that we need to be executing planning scenarios for, specifically an extended power outage in a city under high-heat conditions. A power outage during the summer in Phoenix would send 800,000 people to the emergency room, which would very likely overwhelm local resources and those of all surrounding jurisdictions. There is a need for a power outage during an extended heat wave to be an included planning scenario for emergency management exercises lead by state and local governments. FEMA should produce a comprehensive list of everything a city needs to be prepared for a catastrophic power outage.

Spur Insurance and Financing Innovation

While insurance is the countries’ largest industry, few insurance products and services exist in the U.S. to cover the losses from extreme heat. The U.S. Department of the Treasury recently acknowledged this lack of comprehensive insurance for extreme heat’s impacts in its comprehensive report on how climate change worsens household finances. Heat insurance for individuals could manifest in a variety of ways: security from utility cost spikes during extreme weather events, real-estate assessment and scoring for future heat-risk, “worker safety” coverage to protect wages during extremely hot days where it might be unsafe to work, protections for household items/resources lost due an extended blackout or power outage, and full coverage for healthcare expenses caused by or exacerbated by heat waves. California is currently leading the country on thinking through the role of the insurance industry in mitigating extreme heat’s impacts, and should be a model to watch by federal stakeholders to see what can be scaled and replicated across the nation.

Further, it is important that investments made today are resilient for the climate conditions of tomorrow. The Office of Management and Budget’s November 2023 memo on climate-smart infrastructure, currently being implemented, provides technical guidance on how federal financial assistance programs can and should be invested in climate resilience. A yet unexplored financial lever for climate resilience identified in our interviews is federally-backed municipal bonds. Climate change is undermining this once stable investment, as cities and local governments struggle to pay back interest due to the rising costs of addressing hazards. The municipal bond market could price climate risk when deciding on interest payments, and give beneficial rates to jurisdictions that have done a full analysis of their risks and made steps towards resilience.

Finally, there is a need to update assessments of heat risk that are used to make insurance and financial decisions. Recent research by the DOE has found that the FEMA NRI property damage data appear to be deficient and underestimate damages when compared to published values for recent U.S. extreme temperature events. To start, FEMA should consider including metrics in its NRI that characterize the building stock (i.e. by adherence to certain building codes) and its thermal comfort levels (even with cooling devices) as well as thermal resilience.

Incorporate Future Climate Projections into Planning at All Levels

Recent research has shown that cities and counties are barreling toward temperature thresholds at which it would be dangerous to operate municipal services, affecting the operations of daily life. Yet little of this future risk is accounted for in the various planning activities (for public health, emergency preparedness, grid security, transportation, urban design, etc) done by local and state governments. Our interviewees expressed that because many plans are based on historical and current risk data, there is little anticipation of the future impacts of hotter temperatures when making current planning choices. 

One example stood out around nature-based solutions (NBS): while NBS has received over a billion dollars in federal funding and is argued as an approach to mitigate extreme heat’s impacts – planners are not always considering whether the trees planted today will survive effectively in 20-30 years of warming. Reporting has shown that Southern Nevada is at risk of losing many of its shade trees due to inadequate species selection, as the trees that once thrived in this climate exceed their zones of heat tolerance. 

Changes are being made to some federally-required planning processes to require assessment of future risk. FEMA’s National Mitigation Planning Program now requires state and local governments to plan for future risks caused by climate change, land use, and population change to receive emergency disaster funds and mitigation funding. While extreme heat is a noteworthy future risk, it is not explicitly required in the new guidelines. As of April 2023, only half of U.S. states had a section dedicated to extreme heat in their Hazard Mitigation Plans.

Climate.gov, operated by NOAA, was a recommended starting place for a library of future climate files that can be brought into planning processes and resilience analysis. Technical assistance and decision-making tools that support planners in making predictive analyses based on future extreme temperature conditions can help inform the effective design of resilient transportation systems, infrastructure investments, public health activities, and grids, and ensure accurate estimations of investment cost effectiveness over the measure lifetime.

Data And Indices

Set Standards for Data Collection and Analysis

While official CDC-reported deaths from heat, approximately 1670 in 2022, exceed those from any other natural hazard, experts widely agree this number is an undercount. True mortality is likely at a rate of 10,000 deaths a year from extreme heat under current climate conditions. Many factors compound this systematic undercount: hospitals often do not consider extreme heat in their hazard preparedness plans, there’s a lack of awareness around ICD-10 coding for heat illness, death attribution exacerbated/caused by heat is often attributed to other causes. Retraining the healthcare workforce and modernizing death counting for climate change will take time, our interviewees acknowledged. Thus, decision makers need better data and surveillance systems now to address this growing public health crisis. Excess deaths analysis could provide a proxy data point for the true number of heat deaths, and has already been employed by California to assess the impact of past heat waves. The CDC has utilized excess death methods in tracking the COVID-19 pandemic, and could apply this analysis to “climate killers” like extreme heat to inform healthcare system planning ahead of Summer 2024 (such as forecasting tools like HeatRisk). It will be critical to set a standard methodology in order to compare heat’s impacts in different communities across the United States. True mortality is also essential to enhancing the benefit-cost analysis for heat mitigation and resilience.

Our conversations also highlighted the data gaps that exist around counting worker injuries and deaths due to extreme heat. For work-related heat-health impacts, injuries or deaths are often only counted if there’s a hospital admission that is a required report, heat-exacerbated injuries (i.e. falls) aren’t often counted as heat-related, and harms off the job (i.e. long-term kidney impacts) go unnoticed. Studies estimate that California alone saw 20,000 heat injuries a year, while The U.S. Department of Labor (DOL) reports only 3400 injuries a year nationally. DOL could track how overall workplace injuries correlate with temperature to develop a methodology that would yield much more accurate numbers around true heat impacts.

Finally, anticipating the full risks of heat due to factors like existing infrastructure, social vulnerability, and levels of community resilience, remains a work in progress. For example, FEMA’s National Risk Index (which informs environmental justice tools like the Climate and Economic Justice Screening Tool and the Community Disaster Resilience Zones program) has notable limitations due to its reliance on previous weather data and narrow focus on mortality reduction, leading to underestimates of damages when compared to published values for recent U.S. extreme temperature events. There is a big opportunity to develop a standard data set for extreme heat risks and vulnerabilities in current and future anticipated climate conditions. This data set can then produce high-quality and relevant tools for community decision making (like FEMA’s Flood Maps) and inform federal screening tools and funding decisions. 

Create Regulatory Oversight Infrastructure for Extreme Heat

There are only a few regulatory levers currently in place or in the regulatory pipeline to protect Americans from the growing heat and build more heat resilient communities. These include the temperature standards for senior living facilities set by CMS and OSHA’s upcoming heat standard. There are many more common settings: homes, schools and childcare facilities, transit, correctional facilities, and outdoor public spaces where regulations are needed. There will also need to be expanded enforcement of the regulations, including better monitoring of temperatures outdoors and indoors. HUD, EPA, and NOAA should work to identify expansion opportunities to indoor and outdoor air temperature monitoring, seeking additional funding from Congress where needed

Future regulations for mitigating extreme heat exposure can be conceptualized in the following three ways: technology standards, the required presence of a cooling and/or thermal-regulating technology, behavioral guidelines and expectations, required actions to avert overexposure, and performance standards, requirements that heat exposure cannot cross a certain threshold. These potential regulations will need to be conceptualized, reviewed, and implemented by several federal agencies, as authority for different aspects of heat exposure is fragmented across the federal government. Some examples of regulatory levers identified through our interviews (and introduced in previous sections) include:

• HUD could have standards for building performance that includes thermal comfort and safety, for its properties, backed-mortgages, and public housing it supports, as well as requirements for reducing building waste heat. 
• DOE could expand its performance assessment and certification of energy efficiency products to those that also enhance thermal comfort and resilience.
• FEMA could require individuals, local governments, and state governments to do mitigation planning for extreme heat, and make resources then available to build community-scale thermal resilience. 
• DOT could implement requirements for infrastructure projects to not increase urban areas UHI effects. 
• EPA could further its analysis of the compounding effects of hot air and air pollution, and consider hotter air temperatures (such as those in UHIs) a risk to guaranteeing clean air.
• The Administration for Strategic Planning and Response (ASPR) could require hospital planning for surges in heat illness during heat waves to receive Hospital Preparedness Program funding. 

Conclusion

Extreme heat, both acute and chronic, is a growing threat to American livelihoods, affecting household incomes, students’ learning, worker safety, food security, and health and wellbeing. While the policy landscape for addressing heat is nascent, this report offers recommendations for near and long term solutions that policymakers can consider. Complimentary to FAS’ Extreme Heat Policy Sprint, we hope this report can be a toolkit for potential realistic actions.

Twenty-two organizations and 29 individuals from across 12 states sent a letter calling on the U.S. Department of Education to take urgent action to protect students from the dangers of extreme heat on school campuses

WASHINGTON — With meteorologists predicting a potentially record-breaking hot summer ahead, a coalition of 22 organizations from across 12 states is urgently calling on the Department of Education to use its national platform and coordinating capabilities to help schools prepare for and respond to extreme heat. In a coalition letter sent today, spearheaded by the Federation of American Scientists and UndauntedK12, the groups recommend streamlining funding, enhancing research and data, and integrating heat resilience throughout education policies.

“The heat we’re experiencing today will only get worse. Our nation’s classrooms and campuses were not built to withstand this heat, and students are paying the price when we do not invest in adequate protections. Addressing extreme heat is essential to the Department of Education’s mission of equitable access to healthy, safe, sustainable, 21st century learning environments” says Grace Wickerson, Health Equity Policy Manager at the Federation of American Scientists, who recently authored a policy memo on addressing heat in schools.

Many schools across the country – especially in communities of color – have aging infrastructure that is unfit for the heat. This infrastructure gap exposes millions of students to temperatures where it’s impossible to learn and unhealthy even to exist. Despite the rapidly growing threat of extreme heat fueled by climate change, no national guidance, research and data programs, or dedicated funding source exists to support U.S. schools in adapting to the heat.

“Many of our nation’s school campuses were designed for a different era – they are simply not equipped to keep children safe and learning with the increasing number of 90 and 100 degree days we are now experiencing due to climate change. Our coalition letter outlines common sense steps the Department of Education can take right now to move the needle on this issue, which is particularly pressing in schools serving communities of color. All students deserve access to healthy and climate-resilient classrooms,” said Jonathan Klein, co-founder and CEO of UndauntedK12.

The coalition’s recommendations include:

1. Publish guidance on school heat readiness, heat planning best practices, model programs and artifacts, and strategies to build resilience (such as nature-based solutions) in partnership with the Environmental Protection Agency, Federal Emergency Management Agency, the National Oceanic and Atmospheric Administration, NIHHIS, and subject-area expert partners.
   
2. Join the Extreme Heat Interagency Working Group led by the National Integrated Heat Health Information System (NIHHIS).
   
3. Use ED’s platform to encourage states to direct funding resources for schools to implement targeted heat mitigation and increase awareness of existing funds (i.e. from the Inflation Reduction Act and Bipartisan Infrastructure Law) that can be leveraged for heat resilience. Further Ed and the IRS should work together to understand the financing gap between tax credits coverage and true cost for HVAC upgrades in America’s schools.
   
4. Direct research and development funding through the National Center for Educational Statistics and Institute for Education Sciences toward establishing regionally-relevant indoor temperature standards for schools to guide decision making based on rigorous assessments of impacts on children’s health and learning.
   
5. Adapt existing federal mapping tools, like the NCES’ American Community Survey Education Tabulation Maps and NIHHIS’ Extreme Heat Vulnerability Mapping Tool, to provide school district-relevant information on heat and other climate hazards. As an example, NCES just did a School Pulse Panel on school infrastructure and could in future iterations collect data on HVAC coverage and capacity to complete upgrades.
   
6. Evaluate existing priorities and regulatory authority to identify ways that ED can incorporate heat readiness into programs and gaps that would require new statutory authority.

The Federation of American Scientists and UndauntedK12 and our partner organizations welcome the opportunity to meet with the Department of Education to discuss these recommendations and to provide support in developing much needed guidance as we enter another season of unprecedented heat. 

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About UndauntedK12

UndauntedK12 is a nonprofit organization with a mission to support America’s K-12 public schools to make an equitable transition to zero carbon emissions while preparing youth to build a sustainable future in a rapidly changing climate.

About Federation of American Scientists

FAS envisions a world where cutting-edge science, technology, ideas and talent are deployed to solve the biggest challenges of our time. We embed science, technology, innovation, and experience into government and public discourse in order to build a healthy, safe, prosperous and equitable society. 

KEY TAKEAWAYS

• Urgent Heat Risks: Climate change is leading to more frequent and intense heat waves, increasing the urgency for comprehensive heat safety regulations for agricultural workers.
• Vulnerable Migrant Workers: Migrant workers face heightened risks due to low wages, inadequate healthcare, and precarious working conditions. Fear of retaliation and deportation often prevents them from reporting violations.
• Economic Impact: Lack of heat safety measures endangers workers & results in significant economic costs, including lost productivity. Employers who fail to implement heat safety measures face high costs to their businesses, while investing in worker safety can yield substantial economic benefits.
• Regulatory Progress & Challenges: OSHA is developing federal heat safety regulations, with states like California and Oregon setting effective precedents. As efforts advance, the focus must shift to ensure equitable protection, particularly vulnerable groups like migrant laborers. Inclusive engagement and tailored implementation strategies are crucial to bridge gaps and create effective protections.
• Community & Stakeholder Engagement: True progress in regulation requires the active involvement of all stakeholders, including workers, employers, advocacy groups and industry leaders. Transitioning to more inclusive & direct engagement methods are essential for comprehensive worker protection.

KEY FACTS

• Farmworkers are 20x more likely to die from heat than other workers
• Heat exposure is responsible for as many as 2,000 worker fatalities in the U.S. each year
• Up to 170,000 workers in the U.S. are injured in heat stress related accidents annually. There is a 1% increase in workplace injuries for every increase of 1° Celsius
• The failure of employers to implement simple heat safety measures costs the U.S. economy nearly $100 billion every year

In 2008, Maria Isabel Vasquez Jimenez, a 17-year-old pregnant farmworker, tragically died from heatstroke while working in the vineyards of California. Despite laboring for more than nine hours in the sweltering heat, Maria was denied access to shade and adequate water breaks. Management never called 911 and instructed her fiancé to lie about the events. To this day, her death underscores the dire need for robust protections for those who endure extreme conditions to feed our nation.

This heartbreaking incident is not isolated. With the United States shattering over a thousand temperature records last year, the crisis of heat-related illnesses in the agricultural sector is intensifying. Rising global temperatures are making heat waves more frequent and severe, posing a significant threat to farmworkers who are essential to our food supply. While progress is being made towards comprehensive heat safety regulations, we must now focus on ensuring these protections are equitably implemented to safeguard all farmworkers from the intensifying threats of climate change, especially vulnerable groups like migrants. As individual stories shed light on the real-life tragedies of neglecting climate resilience, broader climate trends reveal a significant rise in these risks, affecting agricultural workers nationwide.

Climate change & agriculture

Rising Temperatures

Climate change poses significant challenges to global agricultural systems, threatening food security, livelihoods, and the overall sustainability of farming practices. Among the various climate-related hazards, rising temperatures stand out as a primary concern for agricultural productivity and worker health and safety. The Environmental Protection Agency (EPA) reports that the average temperature in the United States has increased by 1.8°F over the past century, with the most significant increases occurring in the last few decades. According to the Intergovernmental Panel on Climate Change, global average temperatures have been steadily increasing due to the accumulation of greenhouse gasses in the atmosphere, primarily from human activities such as burning fossil fuels and deforestation. This warming trend is expected to continue, critically impacting agricultural operations worldwide. The Union of Concerned Scientists predicts that by mid-century, the average number of days with a heat index above 100°F in the United States will more than double, severely impacting agricultural productivity and worker health. As the climate continues to change, the direct threats to those who supply our food become increasingly severe, particularly for farmworkers exposed to the elements.

Threats to Farmworkers

In agriculture, rising temperatures worsen challenges like water scarcity, soil degradation, and pest infestations, and introduce new risks like heat stress for farmworkers. As temperatures rise, heatwaves become more frequent, intense, and prolonged, posing serious threats to the health and well-being of agricultural workers who perform physically demanding tasks outdoors. Heat stress can lead to heat-related illnesses such as heat exhaustion and heatstroke, which can be life-threatening if not properly managed. Prolonged exposure to high temperatures can impair cognitive function, reduce productivity, and increase the risk of accidents and injuries in the workplace. According to the Public Citizen, from 2000 to 2010, as many as 2,000 workers  died each year from heat-related causes in the United States, while farmworkers are 20 times more likely to die from heat-related illnesses than other workers.

Given the critical role of agricultural workers in food production and supply chains, protecting their health and safety in the face of escalating heat risks is critical. Comprehensive heat safety standards and regulations are essential to mitigate the adverse impacts of climate change on farmworkers and ensure the sustainability and resilience of agricultural operations. By implementing comprehensive heat safety measures such as heat acclimatization guidelines, shade access, and regular rest breaks, agricultural employers can minimize the risk of heat-related illnesses and injuries. Effective heat standard implementation requires collaboration among policymakers, industry stakeholders, and worker advocacy groups to address climate change challenges and protect agricultural workers. Beyond the direct effects of heat, farmworkers also face compounded environmental hazards that further jeopardize their health and safety.

Compounded Hazards

While the focus of this discussion is on heat safety regulations, it’s important to recognize that these regulations intersect with broader environmental and health challenges faced by agricultural workers. High temperatures often coincide with wildfire seasons, leading to increased exposure to wildfire smoke. This overlap amplifies health risks like respiratory and cardiovascular diseases, disproportionately affecting workers with vulnerable conditions. Effective protection against these compounded hazards requires coordination among policymakers and industry leaders. Comprehensive standards and holistic safety measures are crucial to mitigate the risks associated with heat and to address the broader spectrum of environmental pollutants. While environmental hazards are a significant concern, the specific vulnerabilities of migrant workers introduce additional layers of risk and complexity.

Challenges faced by migrant workers

Recognizing these challenges is only the first step; next, we must assess how current protections measure up and where they fall short in safeguarding these vulnerable populations.

Understanding the Vulnerabilities

Migrant agricultural workers face socioeconomic, legal, and environmental challenges that increase their vulnerability to heat hazards. Economically, many migrant workers endure low wages and lack access to adequate healthcare, which complicates their ability to cope with and recover from heat-related illnesses. A study by the National Center for Farmworker Health found that 85% of migrant workers earn less than the federal poverty level, making it difficult for them to access necessary medical care. Legally, the fragile status of many migrant workers, including those on temporary visas or without documentation, exacerbates their vulnerability. These workers often hesitate to report violations or seek help due to fear of retaliation, job loss, or deportation.

Harsh Working Conditions

Additionally, migrant workers frequently labor in conditions that provide minimal protection against the elements. Excessive heat exposure is compounded by inadequate access to water, shade, and breaks, making outdoor work particularly dangerous during heatwaves. Furthermore, many migrant workers return after work to substandard housing that lacks essential cooling or ventilation, preventing effective recovery from daily heat exposure and exacerbating dehydration and heat-related health risks. According to the National Center for Farmworker Health, about 40% of migrant farmworkers in the United States live in homes without air conditioning.

Barriers to Protection

The barriers to effective heat protection for migrant workers are extensive and complex, which may prevent them from accessing crucial protections and resources, including:

Language Diversity. The migrant worker community is incredibly diverse, encompassing individuals from various cultural and linguistic backgrounds. In the U.S. agricultural sector, over 50% of workers report limited English proficiency. This diversity may present a significant challenge to understand their rights and the safety measures available to them. Even when regulations and protections are in place, the communication of these policies often fails to reach non-English speaking workers effectively, leading to misunderstandings that can prevent them from advocating for their safety and well-being. The National Agricultural Workers Survey reports that 77% of farmworkers in the United States are foreign-born, with 68% primarily speaking Spanish, highlighting the language barriers that complicate effective communication of safety regulations.

Vulnerable Visas & Immigration Status. Visa statuses and undocumented immigration also play a critical role in the vulnerability of migrant workers. Workers holding temporary visas, such as H-2A visas, often face precarious employment conditions because these visas tie them to specific employers, limiting their ability to assert their rights without fear of retaliation. Undocumented workers are particularly susceptible to exploitation and abuse by employers who may use their immigration status as leverage. Fear of deportation and legal repercussions further discourages reporting workplace incidents, perpetuating a cycle of exploitation and vulnerability.

Undocumented workers are particularly susceptible to exploitation and abuse by employers who may use their immigration status as leverage

via Tim Mossholder

Farmworker Housing. Farmworker housing often lacks proper cooling or ventilation, increasing heat exposure risks during off-work hours. Many agricultural workers live in substandard housing characterized by overcrowding, poor insulation, and inadequate access to air conditioning or ventilation systems. Poor living conditions worsen heat-related illnesses, particularly during extreme weather. Limited access to cooling amenities after long hours of outdoor labor exacerbates heat stress and heightens the health risks associated with heat exposure.

Recognizing these challenges is only the first step; next, we must assess how current protections measure up and where they fall short in safeguarding these vulnerable populations.

Review of existing protections

Federal Efforts

Currently, there is no overarching federal mandate specifically addressing heat exposure, leaving significant gaps in worker protection, especially for vulnerable populations like migrant workers. However, the federal government has taken several critical steps to address heat safety in the interim. OSHA has moved beyond relying solely on the General Duty Clause, launching a National Emphasis Program that prioritizes inspections on high-heat days and increases outreach in vulnerable industries. The Biden administration’s Heat Hazard Alert in July 2023 further emphasized employers’ responsibilities, while the initiation of a federal heat standard through OSHA’s rulemaking process signals a commitment to sweeping, nationwide protections.

These efforts reflect progress but it’s crucial that these federal efforts evolve to address the unique challenges faced by workers, ensuring that no one is left behind in the implementation of heat safety measures. The true test of these regulations will be their ability to safeguard those most at risk, bridging gaps in protection and creating a more resilient workforce in the face of rising temperatures.

State-Level Protections

At the state level, the scenario is mixed, with states like California, Washington, and Oregon having implemented their own heat safety regulations, which provide a model for other states and potentially for federal standards. Oregon’s regulations, for instance, require employers to provide drinking water, access to shade, and adequate rest periods during high heat conditions. These measures are designed not just to respond to the immediate needs of workers but also to educate them on the risks of heat exposure and the importance of self-care in high temperatures. When Oregon implemented stricter heat safety standards, it saw a significant reduction in heat-related illnesses reported among agricultural workers. By requiring more frequent breaks, adequate hydration, and access to shade, Oregon’s regulations demonstrate how well-designed policies can decrease the incidence of heat stress and related medical emergencies. California has also taken a comprehensive approach with its Heat Illness Prevention Program, which extends protections to both outdoor and indoor workers, reflecting the broad scope of heat hazards. This program is noted for its requirements, including training programs that educate workers on preventing heat illness, emergency response strategies, and the necessity of acclimatization.

Legislative Challenges & Need for Unified Approach

Conversely, legislative actions in states like Florida and Texas represent a significant challenge to advancements in occupational heat safety. For example, Florida’s HB 433, recently signed into law, expressly prohibits local governments from enacting regulations that would mandate workplace protections against heat exposure. This legislation stalls progress and endangers workers by blocking local standards tailored to the state’s specific needs.

The contradiction between states pushing for more stringent protections and those opposing regulatory measures illustrates a fragmented approach that could undermine worker safety nationwide. Without a federal standard, the protection a worker receives is largely dependent on state policies, which may not adequately address the specific risks associated with heat exposure in increasingly hot climates. This patchwork of regulations underscores the importance of a unified federal standard that could provide consistent and enforceable protections across all states, ensuring that no worker, regardless of geographical location, is left vulnerable to the dangers of heat exposure.

With an understanding of the gaps in current heat safety regulations, the next crucial step is fostering effective stakeholder engagement to drive meaningful changes.

Engaging Stakeholders: Beyond Public Comment

While progress has been made in recognizing the need for heat safety regulations, we must now focus on ensuring equitable representation in the policy-making process. Traditional engagement methods have often fallen short in capturing the voices of those most impacted by these policies, particularly vulnerable groups like migrant agricultural workers. Regulatory agencies must rethink their strategies to include more direct and inclusive approaches, empowering workers to contribute meaningfully to policies that directly affect their safety and well-being.

Challenges in Traditional Engagement

The traditional approaches to stakeholder engagement, particularly in regulatory settings, often rely heavily on formal mechanisms like public comment periods. While these methods are structured to gather feedback, they frequently fall short of engaging those most impacted by the policies—namely, the workers themselves. Many workers, especially in labor-intensive sectors like agriculture, may not have the time, resources, or knowledge to participate in these processes. Relying on online submissions or weekday meetings during work hours can exclude many workers whose insights are crucial for shaping effective regulations. A survey conducted by the Migrant Clinicians Network found that fewer than 10% of migrant workers had participated in any form of public comment or feedback process related to workplace safety.

The complexities of these workers’ lives—ranging from language barriers to fear of retaliation—mean that conventional engagement strategies may not effectively reach or address their concerns. This gap highlights a critical need for regulatory bodies to rethink and expand their engagement strategies to include more direct and inclusive methods.

As we push for broader and more inclusive engagement, we must also consider systemic improvements that can solidify these efforts into lasting safety standards.

Looking Forward: Systemic Improvements & Community Collaboration

Protecting migrant workers from extreme heat requires systemic improvements and a coordinated approach to address gaps in current regulations and foster collaborative efforts among stakeholders. By combining the strengths of government agencies, employers, and community advocates, we can develop robust solutions of heat safety which protect the well-being of vulnerable workers while supporting the productivity and resilience of the agricultural industry.

Systemic Changes Needed

To effectively protect migrant workers from the dangers of extreme heat, systematic changes are required. On the regulatory side, this includes boosting the human resources and funding available to agencies like OSHA to ensure they can effectively implement and enforce new heat safety standards. Building robust infrastructure for enforcement and consultation is crucial, as is ensuring these bodies can handle the demands of new regulatory programs. From the employer and industry perspective, federal support is essential. Incentives such as tax breaks or reimbursement programs similar to those provided under the Families First Coronavirus Response Act during the COVID-19 pandemic could motivate employers to adhere more strictly to safety standards, knowing they can recoup some costs associated with implementing safety measures like paid sick leave.

Fostering a Safe Reporting Culture

Creating a workplace that encourages safe and open communication is vital. Employers must be encouraged to establish non-retaliatory policies and to offer regular training sessions that educate workers about their rights and the importance of reporting safety violations. Reporting mechanisms should protect employee anonymity to reduce fear of retaliation. These practices can improve safety, while also enhancing worker retention and morale, contributing to a healthier workplace culture.

Role of Community & Grassroots Advocacy

Grassroots organizations and community advocates play a pivotal role in shaping and enforcing heat safety regulations. These groups often have direct insights into the needs and challenges of workers on the ground and can help tailor educational and enforcement strategies to the community context. Collaborations with these organizations can facilitate the delivery of multilingual training and legal assistance, ensuring that workers are well-informed about their rights and the safety measures in place to protect them. Additionally, these partnerships can help to monitor compliance and gather grassroots feedback on the efficacy of the regulatory measures. A notable example is the partnership between California Rural Legal Assistance and local farming communities to develop heat stress prevention training tailored to the languages and cultures of the workers. This program has improved knowledge and awareness of heat stress risks among workers, and has also empowered them to take proactive steps in managing their health during extreme conditions. Evaluations of this initiative show a marked improvement in both the adoption of safety practices and worker satisfaction, highlighting the importance of community-driven approaches in policy implementation.

To support these systemic changes, strategic investments are essential, not only to enhance regulatory capacity but to ensure the long-term health and productivity of the agricultural workforce.

The Power of Investment

Investing in heat safety offers strategic, far-reaching benefits for both workers and employers alike. By funding regulatory frameworks and workplace safety programs, organizations can effectively mitigate the impact of heat-related illnesses and injuries. Such investments can enhance regulatory agencies’ capacity to enforce standards while creating safer, more productive work environments that benefit businesses and employees. An investment approach to heat safety strengthens economic sustainability, worker well-being, and industry compliance.

By funding regulatory frameworks and workplace safety programs, organizations can effectively mitigate the impact of heat-related illnesses and injuries.

via Tim Mossholder

Envisioning Enhanced Regulatory Capacity

In the pursuit of more effective heat safety regulations, one critical aspect overlooked is the role of increased investment in regulatory agencies like OSHA. An addition of resources into these bodies is not merely a bureaucratic expansion but a potential lifesaver. Research consistently demonstrates that increased funding for regulatory enforcement can significantly enhance compliance and improve safety outcomes. This investment empowers agencies to provide greater education and outreach, conduct more inspections, and enforce compliance more effectively, which are essential for protecting workers from heat-related hazards. Enhancing the capacity of organizations like OSHA to enforce heat safety standards saves lives, while supporting economic efficiency and sustainability in labor-intensive industries. These investments ensure that safety regulations evolve from paper to practice, significantly impacting the lives of those they are designed to protect.

Economic Benefit

Economic analyses further support the notion that investing in worker safety is not just a cost but a strategic benefit. Studies show that every dollar spent on improving workplace safety yields substantial returns in reducing the costs of workplace injuries and deaths. For instance, implementing stringent heat safety measures not only reduces the incidence of heat-related illnesses but also cuts down on associated costs such as medical expenses, workers’ compensation, and lost workdays. This is particularly relevant in sectors like agriculture, where the physical nature of the work increases vulnerability to heat stress. The economic benefit for employers extends beyond direct cost savings. Maintaining a safe work environment enhances a company’s reputation, aids in employee retention, and increases productivity. Workers are more likely to stay with an employer they trust to prioritize their health and safety, which is crucial in industries facing labor shortages. A culture that encourages reporting and promptly addresses safety concerns can significantly reduce the risk of severe injuries and fatalities, further lowering potential liabilities and insurance costs.

Employer Benefit

A compelling example of the benefits of proactive safety measures is the Gold Star Grower Program in North Carolina. This program recognizes agricultural employers who provide housing that  meets and exceeds the requirements of the Migrant Housing Act of North Carolina. This recognition serves as a badge of honor, indicating to potential employees that these employers value worker well-being. Reports suggest that workers actively seek out employers with this certification, preferring to work in environments where their health and safety are a priority. A preference like this can drive more growers to participate in safety programs, fostering a broader culture of safety and compliance within the industry.

Call for Collaborative Action

As the climate crisis continues, so does the threat of heat exposure to agricultural workers, posing grave risks to their health and to the core of our food supply systems. The necessity for comprehensive heat safety measures is now both urgent and undeniable. 

Governments at every level, employers across industries, community groups, and the workers themselves must unite to create resilient, practical strategies that prioritize safety and health. The cost of inaction is stark, exceeding $100 billion annually— not only affecting the economy but leading to the irreplaceable loss of life and well-being. 

We are at a critical juncture which demands a unified, strong response to heat hazards. By adopting systemic improvements and fostering a culture of collaboration and proactive communication, we have the opportunity to safeguard those most vulnerable to the impacts of climate threats.  

As we progress towards implementing rigorous heat safety regulations, our focus must now shift to ensuring these protections reach all workers equitably. Let’s mobilize, from grassroots movements to national policy reforms, to create inclusive implementation strategies that protect our most vulnerable workers, particularly migrants, and secure our collective future.

For resources on how you can support these critical efforts, please refer to the guides provided in Appendix A and B, which offer strategies for advocacy, community engagement, and policy development. Together, our collective efforts can protect our most vulnerable and build a resilient path forward in the face of climate change.

APPENDIX A: RESOURCE GUIDE

Further information and support on heat-related safety and worker rights

Resources for Migrant Workers

• National Center for Farmworker Health (NCFH) – Provides health information and advocacy resources for farmworkers. Website: ncfh.org
• Farmworker Justice – Legal support and resources focusing on improving living and working conditions for migrant farmworkers. Website: farmworkerjustice.org
• Heat Stress Prevention Training Materials – Educational resources provided by the Occupational Safety and Health Administration (OSHA). Website: OSHA Heat Stress
• Legal Aid Justice Center – Provides legal aid for low-income individuals, including migrant workers, focusing on civil rights and employment issues. Website: justice4all.org
• Migrant Clinicians Network (MCN) – Offers tools and training for clinicians serving migrant communities. Website: migrantclinician.org

Resources for Employers

• OSHA’s Heat Illness Prevention Campaign – Resources to help employers prevent heat illness in outdoor workers. Website: OSHA Campaign
• AgSafe – Organization offering training, consulting, and resources aimed at ensuring the safety and health of agricultural workers. Website: agsafe.org
• Gold Star Grower Program – North Carolina Department of Labor’s recognition program for employers who exceed migrant housing regulations. Website: NC Dept. of Labor
• Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace – While specific to COVID-19, this guide from OSHA includes valuable information on maintaining a healthy workplace that can apply to heat safety.

Resources for Policymakers

• National Institute for Occupational Safety and Health (NIOSH) – Research and guidelines on occupational safety, including heat-related risks. Website: CDC – NIOSH
• U.S. Environmental Protection Agency (EPA) – Worker Protection Standard – Regulations designed to protect farm workers from pesticide exposures but can be extended to other environmental risks. Website: EPA Worker Protection
• Congressional Research Service Reports – Provides detailed reports and analysis useful for policymakers on various topics, including agricultural worker safety and climate impacts. Website: CRS Reports
• Rural Health Information Hub – Offers resources to improve healthcare and access to healthcare services in rural communities, which can include migrant farmworkers. Website: Rural Health Info

APPENDIX B: ACTION GUIDE

Support Legislative Changes

• Join Advocacy Campaigns: Engage with organizations like the United Farm Workers (UFW) and Farmworker Justice, which are actively lobbying for stronger heat protection laws. Sign up for their newsletters and participate in their advocacy campaigns.
  • United Farm Workers – Farmworker Justice
• Contact Your Representatives: Urge your local, state, and federal representatives to support comprehensive heat safety standards and improved working conditions for agricultural workers. Personalized letters, emails, and phone calls can make an impact.
• Petition for Change: Sign and share petitions calling for better heat safety regulations and protections for migrant workers. Platforms like Change.org often host relevant petitions that need public support.
  • Change.org

Participate in Advocacy Efforts

• Volunteer Your Time: Volunteer with grassroots organizations and advocacy groups that are working directly with farmworkers. Your involvement can help amplify their efforts and bring about meaningful change.
• Educate and Raise Awareness: Use social media platforms to spread awareness about the issue. Share articles, statistics, and personal stories to educate your network and encourage others to take action.
• Support Community Initiatives: Donate to or partner with local nonprofits that provide resources and support to farmworkers. Organizations like the National Center for Farmworker Health and Migrant Clinicians Network rely on community support to continue their vital work.
  • National Center for Farmworker Health – Migrant Clinicians Network

Engage in Policy Development

• Attend Public Hearings and Forums: Participate in public hearings and forums hosted by regulatory bodies like OSHA. Your voice and presence can influence policy decisions and ensure that the needs of agricultural workers are addressed.
  • Occupational Safety & Health Administration
• Collaborate with Employers: If you are an employer or part of an agricultural business, collaborate with worker advocacy groups to implement and promote heat safety measures. Encourage a culture of safety and open communication within your organization.

Last year was the hottest year in recorded human history. In summer 2023 alone, up to 275 million Americans were placed under some type of heat advisory. Experts at NOAA project a one-in-three chance that 2024 will be even warmer than 2023 — with a 99% chance that 2024 will rank among the top five warmest years. With “danger season” 2024, the time when extreme heat and numerous other climate-related hazards in the United States tend to occur — beginning after April 29th, there is a vital need to build resilience to the impending heat waves. 

To begin to respond to this urgent need at the federal level, FAS engaged +85 federal policy experts and recruited 33 authors to work on +18 policy memos through our Extreme Heat Policy Sprint, generating +150 policy recommendations to address extreme heat’s impacts and build community resilience. Our contributors’ recommendations represent the building blocks of a whole-of-government strategy on extreme heat, spanning six domains: 

1. Infrastructure and the built environment
2. Workforce safety and development
3. Public health, medical preparedness, and health security
4. Food security and multi-hazard resilience
5. Planning and response
6. Data and indices

Collectively, FAS has identified 34 offices and/or agencies that can act on extreme heat. However, as noted in our previous publication, extreme heat receives minimal targeted federal support and funding for planning, mitigation, and recovery despite being the number one weather-related killer of Americans. The national response to extreme heat is still being developed and requires increased, coordinated action across the White House, Congress, and federal agencies. Improved coordination and effective planning requires a clear understanding of the landscape of the existing federal efforts. For this reason, the Federation of American Scientists has put together an Extreme Heat Federal Policy and Funding tracker to monitor the progress of federal actions on extreme heat, enhance accountability, and to allow stakeholders to stay informed on the evolving state of U.S. climate-change resilience response as it evolves. This tracker is organized around our six key domains of federal opportunity.

In the absence of a national strategy, states, counties, and cities around the country have had to take on the responsibility of experimenting and attempting to address extreme heat in their communities with limited available resources. While many state and local governments are working diligently to make significant advances, national extreme heat resilience requires a whole-of-government federal approach, as it directly impacts public health, energy, housing, national security, international relations, and many more policy domains. The federal government plays a critical role in scaling heat resilience interventions through funding, guidance, research and development, regulations, and other policy levers.

Executive branch agencies need a government-wide coordination strategy to prioritize and address extreme heat nationwide. This strategy requires comprehensive reviews of available resources for financial assistance, assessments of regulatory and rulemaking authority, and an emphasis on legislative action — in order to define the problems to solve, assign priorities for agencies, and develop evaluation metrics for review, adjustment, and renewal of programs The FAS Federal Extreme Heat Policy and Funding tracker serves as a key starting point towards these necessary actions.

The Federation of American Scientists Solicited Input from 85+ Experts to Address Impacts on the Workforce, Built Environment, Disaster Preparedness, Planning and Resilience, and Food Security

Washington, DC – April 29, 2024 – March 2024 was the 10th consecutive month to break temperature records, according to the National Oceanic and Atmospheric Administration (NOAA). Given the temperatures for the first three months of the year, it’s virtually certain 2024 will be one of the world’s top five warmest years on record globally, NOAA reports, and each year thereafter is likely to be even hotter. In the absence of a national strategy to address the compounding impacts of extreme heat, states, counties, and cities around the country have had to take on the responsibility of experimenting and attempting to address this reality in their communities with limited available resources. While state and local governments can make significant advances, national extreme heat resilience requires a “whole of government” federal approach. 

To meet this need, the Federation of American Scientists (FAS) spent the fall and winter working with more than 85 scientific experts to develop a comprehensive set of policy proposals, found here and listed below, to address extreme heat and its many detrimental effects. The resulting policy memos aim to be force multipliers to existing federal efforts to address heat and enhance resilience to climate change.

“The mild Spring temperatures we’re experiencing in Washington, D.C. right now are still above normal and trending up. That’s cause for concern, especially when it comes to human health impacts,” says Erica Goldman, FAS Director of Science Policy Entrepreneurship, who — along with Grace Wickerson, FAS Health Equity Policy Manager and Autumn Burton, FAS Senior Associate of Climate, Health, and Environment — worked with experts across the country to develop the policy proposals.

“The effects of extreme heat disproportionately burden people who work outdoors, and those of limited financial means living in poorly insulated housing or without air conditioning. Outdoor workers, children and elderly people are at elevated risk of severe outcomes, including death. The effects of extreme heat are devastating to those experiencing homelessness,” says Grace Wickerson.

They continue: “Even if we put aside the harm heat places on our physical bodies, there is no denying extreme heat has consequential knock-on effects in many areas of our society. These include worker productivity, livable cities, and food security, to name just a few. No one is immune from the effects.”

These proposals are timely. Just two weeks ago Governor Ron DeSantis (R-FL) signed into law HB 433, which prevents local governments from requiring heat protection for the estimated 2 million people in the state who work outdoors. Right now, as extreme heat events are becoming increasingly frequent and intense, we need effective, intentional policies to protect vulnerable populations that are disproportionately impacted: outdoor laborers, low-income, BIPOC, seniors, veterans, children, the unhoused, and those with compromised health status, among others.

Extreme Heat Policy Innovation Summit 

These policy memos were presented at the FAS and Arizona State University’s Knowledge Exchange for Resilience’s (ASU KER) Extreme Heat Policy Innovation Summit on April 9th and April 10th. Over two days, 200+ stakeholders came together for the first time to discuss policy innovation to build heat resilience at all levels of government: local, state, tribal, territorial, and federal. FAS and ASU KER will continue to support this community of practice, in order to collectively work towards a whole-of-government strategy on extreme heat preparedness, response, mitigation, and resilience. As we enter the next hottest summer on record, we need transformative ideas as well as sustained collaborations that ensure full implementation.

Here are the FAS policy proposals to address extreme heat.

Infrastructure and the Built Environment 

It is vital that the federal government integrate climate resilience into all federal funding grants and investments.

A Comprehensive Strategy to Address Extreme Heat in Schools 

Rebecca Morgenstern-Brenner, Amie Patchen, Alistair Hayden, Nathaniel Hupert,  Grace Wickerson | link

Adapting the Nation to Future Temperatures through Heat Resilient Procurement 

Kurt Shickman | link

Enhanced Household Air Conditioning Access Data For More Targeted Federal Support Against Extreme Heat

Larissa Larsen | link

Shifting Federal Investments To Address Extreme Heat Through Green And Resilient Infrastructure

Bill Updike, Jacob Miller, Rhea Rao, Dan Metzger | Link

Workforce Safety and Development

With no mandated federal heat stress standard, there is no federal mechanism to ensure the adoption of appropriate heat stress prevention strategies and emergency procedures to protect vulnerable workers.

Protecting Workers From Extreme Heat Through An Energy-Efficient Workplace Cooling Transformation

June Spector | link

Adopting Evidence-Based Heat Stress Management Strategies In The Workplace To Enhance Climate Equity

Margaret Morrissey-Basler, Douglas J. Casa | link

Public Health, Medical Preparedness, and Health Security

The undercounting of deaths related to extreme heat and other people-centered disasters — like extreme cold and smoke waves — hinders the political and public drive to address the problem.

Tracking And Preventing The Health Impacts Of Extreme Heat 

Alistair Hayden, Rebecca Morgenstern Brenner, Amie Patchen, Nathaniel Hupert, Vivian Lam | link

Optimizing $4 Billion Of Low-Income Home Energy Assistance Program Funding To Protect The Most Vulnerable Households From Extreme Heat

Justin Schott | link

Enhancing Public Health Preparedness For Climate Change-Related Health Impacts

Kari Nadeau, Nile Nair | link

A Call For Immediate Public Health And Emergency Response Planning For Widespread Grid Failure Under Extreme Heat

Grace Wickerson, Autumn Burton, A. “Skip” Laitner | link

Addressing The National Challenges Of Extreme Heat By Modernizing Preparedness Approaches 

Nathaniel Matthews-Trigg | link

Food Security and Multi-Hazard Resilience

To balance water shortage, federal, state and local governments must invest in recharging aquifers and reservoirs while also reducing losses due to flooding.

U.S. Water Policy For A Warming Planet

Lori Adornato | link

Planning and Response

Extreme heat is an all-of-society problem that requires an all-of-government response.  

Combating Extreme Heat With A National Moonshot

Louis Blumberg | link

A National Framework For Sustainable Urban Forestry To Combat Extreme Heat
Arnab Ghosh | link

Leveraging Federal Post-Disaster Recovery Reform For Extreme Heat Adaptation And Innovation

Johanna Lawton | link

Defining Disaster: Incorporating Heat Waves And Smoke Waves Into Disaster Policy

Alistair Hayden, Sarah Bassett, Grace Wickerson, Rebecca Morgenstern Brenner, Amie Patchen, Nathaniel Hupert | link 

Preparing and Responding to Local Extreme Heat through Effective Local, State, and Federal Action Planning

Vivek Shandas, Grace Wickerson, Autumn Burton | link 

Data and Indices 

A cross-agency extreme-heat monitoring network can support the development of equitable heat mitigation and disaster preparedness efforts in major cities throughout the country.

Improve Extreme Heat Monitoring By Launching Cross-Agency Temperature Network

Bianca Corpuz | link

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ABOUT FAS

The Federation of American Scientists (FAS) works to advance progress on a broad suite of contemporary issues where science, technology, and innovation policy can deliver dramatic progress, and seeks to ensure that scientific and technical expertise have a seat at the policymaking table. Established in 1945 by scientists in response to the atomic bomb, FAS continues to work on behalf

Heat risks are borne out of a combination of contextual factors (e.g., physical geography, planning efforts, political priorities, etc.) and the creation of vulnerability through exposure to the heat hazard (e.g., exposure, sensitivity, adaptive capacity, etc.). These heat-specific, contextual risks provide insight for formulating tailored strategies and technical guidance for devising heat-mitigation interventions that align with regional needs and climatic conditions.

Thus, heat action planning systematically and scientifically organizes short-, medium-, and long-term heat interventions within a spectrum of context-specific, socially, and fiscally responsive options. Integrating existing planning tools and risk assessment frameworks, similar to the broader-scale natural hazard mitigation planning process, offers a timely and effective approach to developing regionally tailored heat action plans. 

For heat action planning to succeed nationwide, multiple agencies and offices within the federal government need to 1) support state, local, tribal, and territorial (SLTT) governments with timely information and tools that identify specific guidelines, thresholds, objectives, and financial support for advancing interventions for extreme heat adaptation and 2) include extreme heat within their planning processes. Since all state and local public agencies are already involved in a wide variety of planning processes—many of which are requirements to receive federal investments—the focus on heat offers opportunities to integrate several currently disparate efforts into a comprehensive activity aimed at safeguarding the public’s health and infrastructure.

Challenge and Opportunity

Few U.S. municipal governments are actively engaged in a systematic process that prepares local communities for extreme heat. For example, as of 2023, only seven U.S. states had a section dedicated to extreme heat in their Hazard Mitigation Plans (HMPs), as required by the Federal Emergency Management Agency (FEMA). Even when included within HMPs, the medium and long-term planning implications are consistently lacking. Planning for extreme heat’s current and future risk is not a requirement of many federally-mandated planning processes for SLTTs, limiting nationwide uptake. 

Despite decades of scientific assessments on risks to human health and infrastructure, there currently needs to be more precedent for developing comprehensive plans that address heat, nor the integration of risks with effective interventions. Many state, local, tribal, and territorial governments (SLTTs) are not planning for extreme heat and its future risk to populations. The appointment of Chief Heat Officers and other regional coordination efforts are currently limited, and the primary mechanism for heat response relies on emergency management. This short-term solution needs to be revised to prepare a region for ongoing and acute temperature increases. SLTTs and the federal government are just starting to invest billions of dollars in material services and non-material interventions, including tree plantings, air conditioning and heat pumps, white paints, cooling centers, new staff roles (i.e., Chief Heat Officers), and communication programs. 

Planning for Future Risks of Extreme Heat 

Further, as the federal government is just starting to assess its portfolio of assets and programs for heat resilience, it will need to consider future risks of extreme heat beyond immediate health and infrastructure risks to establish a fiscal agenda for risk mitigation. For one, extreme heat events are a catalyst for other destructive disasters, like wildfires and drought. Higher temperatures increase evapotranspiration rates, drying out grasses and trees and turning fallen branches into firewood. Compounding this are the shrinking snowpacks in western states, which make forests more flammable by reducing the water available for vegetation. All of these factors caused by excess heat — along with a history of unsustainable forest management practices and land use decisions — are contributing to more destructive wildfires. From 2017 to 2024, these wildfires came with an estimated $97+ billion in costs. 

Additionally, more surface evaporation (1) increases SLTT reliance on limited groundwater sources and (2) leads to less groundwater seepage and aquifer replenishment. Warmer temperatures also mean plants and animals need more water, further driving up consumption of this limited resource. All of these factors compound the growing risk of drought facing American communities. In 2023, over 80% of the United States Department of Agriculture’s (USDA) emergency disaster designations were for drought or excessive heat, and the costliest 2023 disaster was a combined drought/heat wave at $14.5 billion. The interactions and compounding risk of natural hazards are often unaccounted for in HMPs and other plans that consider hazard events in isolation. 

Federal Support for Risk Mapping and Planning

Existing federal initiatives to assist SLTTs in planning for extreme heat have focused on documenting extreme heat’s disparate impacts in cities and regions but do not strategically progress heat action planning. For example, the National Integrated Heat Health Information System (NIHHIS) is an interagency entity operated by the National Oceanic and Atmospheric Administration (NOAA) that manages www.heat.gov, and provides several opportunities for SLTTs to socialize and familiarize heat-related interventions. Since 2017, NOAA, in collaboration with NIHHIS, has supported the Heat Watch Campaigns, wherein SLTTs and community groups use temperature sensors to collect hyperlocal heat measurements. These sensors measure and collect temperatures every second, and the resulting maps describe differences in intra-regional heat, known popularly as “urban heat islands” (UHIs), which often vary by upwards of 20°F. These Heat Watch campaigns communicate heat as a local challenge and engage residents in socializing the potential impacts, while also advancing several initiatives and policies that aim to reduce the harmful effects of extreme temperatures. While almost all Heat Watch participating organizations have taken some immediate and often one-off actions, these campaigns have not advanced heat action planning through a systematic process. SLTTs have faced barriers to identifying promising adaptation strategies and resourcing necessary infrastructure improvements without dedicated, reliable follow-on investments. And, because most campaigns are conducted in urban areas, the Heat Watch campaigns currently do not capture the rural and ecosystem effects of heat. More systemic actions that integrate chronological and science-based applications of interventions that include the public, along with scientific assessments and contextual factors, are necessary for SLTTs to adapt.

Moreover, the federal government, which employs +3 million people, procures +$700 billion in goods and services annually, and delivers +$700 billion in financial assistance to states, locals, and private entities, must plan more effectively for extreme heat’s impacts on basic operations, services, infrastructure, and program delivery. As an example, the U.S. Department of Defense (DoD) has completed several assessments on heat (and continues to), and other agencies need to follow suit to ensure infrastructure and programs are resilient to future temperatures. The heat risks posed to basic operations can further strain vulnerable supply chains and put employees who are on the frontline of enabling and operating these Federal programs at risk of illness and death.

Plan of Action

The heat action planning process requires five steps that help identify areas and populations that face disproportionate exposure to regionally-specific hottest temperatures and move towards interventions for mitigating extreme heat for SLTTs and the federal government:

Recommendation 1. Define “extreme heat” risk by local geography.

Extreme heat in Phoenix, AZ differs from extreme heat in Portland, OR; a week of 90°F in the Pacific Northwest can cause as many heat-related illnesses as a 110°F day in the South East.  A regional approach to characterizing the relevant risks is an essential first step. Developing heat hazard maps that describe the potential implications of extreme ambient temperatures on the public’s health, infrastructure, and critical services is essential to prepare SLTTs and the federal government. Existing “heat vulnerability indexes and maps” support the articulation of heat hazards, though they remain primarily passive interfaces that do not directly contribute to broader planning or policy processes. In addition, response to hazards requires local understanding and communication of existing risk, which is done by the National Weather Service (NWS) and FEMA through the Integrated Public Alert & Warning System. 

To define current and future “extreme heat” risk by local geography: 

1. FEMA, NOAA, USDA, Centers for Disease Control and Prevention (CDC), and the National Aeronautics and Space Administration (NASA) can collaborate on assessments of regionally-specific risk in the present and future, codifying cooling assets (potentially through ground-based assessments of summertime air temperatures, atmospheric dynamics, land use and land cover assessments), expected population acclimatization and existing health risks, and assessments of future climate conditions, such as ClimRR. Finally, USDA could assess agricultural growing zones for heat risk and better predict impacts on food and nutrition services supply chains.
2. HUD, EPA, and NOAA can work to identify localized exposure to extreme heat by expanding opportunities for monitoring indoor and outdoor air temperature in and around potentially vulnerable land uses (e.g., multifamily residential, older single-family residential, manufactured homes, and trailer parks), seeking additional funding from Congress where needed to develop and place these sensors.
3. FEMA can include metrics in its National Risk Index that characterize the building stock (i.e., by adherence to certain building codes), expected thermal comfort levels (even with cooling devices) under current and future climate conditions, and thermal resilience during power brownouts and blackouts. Additional focus on heat inequities will also help to advance approaches that center the public’s long-term health and safety.

Recommendation 2. Establish standards and codes for extreme heat resilience and risk mitigation.

Several federal agencies are directly involved in the development of standards (National Institute of Standards and Technology (NIST), Housing and Urban Development (HUD), Department of Energy (DOE), Department of Transportation (DOT), Environmental Protection Agency (EPA), FEMA, Department of Education (Ed)); however, we have no current designation for heat risk, certification of promising solutions, and identification of best practices for heat action planning. Once standards and guidelines exist, funding can accelerate the application of suitable technologies, analysis, and local engagement for developing heat action plans for SLTTs and federal government operations. Further, it is critical that adaptation solutions do not come at the risk of climate mitigation, for example, relying solely on air conditioning to keep people cool, which then leads to increased greenhouse gas emissions. Other strategies like urban forestry, building codes, and reflective materials in suitable locations will also need to be directly applied. 

To establish standards and codes for extreme heat resilience and risk mitigation: 

1. NIST, EPA, and U.S. Forest Service (USFS) can create “technology test beds” for heat resilience best practices, effectiveness evaluation, and associated benefits-costs analysis. 
2. DOE can work with stakeholders to create “cool” building standards and metrics with human health and safety in mind, and integrate them into building codes like ASHREI 189.1 and 90 series that can then be adopted by SLTTs. Where possible, DOE should explore evaluations of co-benefits of heat resilience with decarbonization and energy efficiency and work with state energy offices to implement these evaluations. Finally, DOE can also consider grid impacts during increasing periods of demand and conduct predictive analyses needed to prevent overload and prepare SLTT energy suppliers.
3. FEMA can integrate extreme heat considerations and thermal resilience within its National Strategy to Improve Building Codes.
4. HUD can update the Manufactured Home Construction and Safety Standards to require homes to perform a certain level of cooling under high heat conditions.
5. HUD and Ed can consider what safe thresholds for occupancy look like for residential settings and schools and provide guidance to SLTTs.
6. The Office of Management and Budget (OMB) and USFS can consider future risks to nature-based solutions (i.e., extreme heat) within different climate regions as a part of government-wide efforts to scale nature-based solutions.
7. DOT can consider requirements for infrastructure projects in SLTTs to mitigate UHI effects.

Recommendation 3. Operationalize interventions and coordinate amongst agencies that require SLTT planning processes.

While knowledge about heat exposure requires further assessment, integrating thresholds and programming to reduce preventable exposure to heat is necessary within planning processes, financial assistance delivery, and program and regulatory implementation. For example, an important next step will be establishing a heat tolerance threshold for occupations with higher heat exposure to ensure workers do not exceed core body temperatures. Currently, several wearable sensor technologies offer a direct means for firms to monitor the health of their outdoor workers. Such information can help develop material and non-material interventions that reduce the likelihood of heat stress and risk and ensure compliance with federal mandates and regulations. As another example, EPA, Health and Human Services (HHS), HUD, FEMA, Internal Revenue Service (IRS), and others can use new standards to implement federal funds or tax incentives. 

To better operationalize interventions and coordinate amongst agencies that require SLTT planning processes,

1. FEMA can incentivize Hazard Mitigation Planning for SLTTs that accounts for and emphasizes extreme heat risk as well as compounding disaster risk as a part of its National Mitigation Planning Program.
2. The Executive Office of the President (EOP) can consider its role in coordinating nationwide climate-risk planning, through auditing plans required by CDC, Administration for Strategic Planning and Response (ASPR), Federal Energy Regulatory Commission (FERC), Department of Transportation (DOT), FEMA, and other agencies for their readiness for future climate conditions (i.e. extreme heat). Where heat risk is not currently required in a federally-mandated plan, federal agencies should consider incentives to drive the adoption and uptake of heat action planning by SLTTs. 
3. OMB can identify potential regulatory pathways to build extreme heat resilience within SLTTs and federal government operations, considering technology standards, behavioral guidelines and expectations, and performance standards.
   1. Technology standards: Required presence of a cooling and/or thermal-regulating technology
   2. Behavioral guidelines and expectations: Required actions to avert overexposure
   3. Performance standards: Requirements that heat exposure cannot cross a certain threshold.

Recommendation 4. Support fiscal planning and funding prioritization.

Local jurisdictions must plan for many hazards and risks, and because heat funding is scarce and hard to get, it falls to the bottom of the list of priorities. Establishing a clear and accessible set of resources to understand the resources available to support heat adaptation and resilience can help to advance effective solutions. Further, SLTTs will get more funding to prevent past hazards, versus prepare for future ones like extreme heat. Current funding through FEMA and DOE is helping to shore up heat risk assessments and interventions in select locations, yet they remain inadequate for the scale of the challenge facing SLTTs. By prioritizing future climate risk in fiscal planning and funding, extreme heat resilience will become a larger priority because it can integrate into several programmatic and policy priorities, such as transportation, housing, and emergency response. The insurance and healthcare industries, operated by the Centers for Medicare and Medicaid (CMS) and Veterans Health Administration (VHA) can also play a larger role in shepherding heat resilience forward, by advancing beneficiaries that are adapting to extreme heat, and reducing emergency room visits due to heat illness.  

To support fiscal planning and funding prioritization,

1. OMB can work with federal agencies to perform a budget review of actual allocations to extreme heat activities, including financial assistance to SLTTs, as well as extreme heat’s existing risks to federal assets, critical infrastructure, programs, and workforce. OMB can collaborate with the General Services Administration (GSA) on federal workforce and contractor workforce safety protections and VHA, Department of Justice (DOJ), U.S. Army Corps of Engineers (USACE), DOT, Cybersecurity and Infrastructure Security Agency (CISA), DOE, and other relevant agencies on operations of critical infrastructure during current and future heat events.
2. OMB, in collaboration with EPA, FEMA, DOE, and NIST, can produce a report that identifies gaps in funding to advance heat mitigation and preparedness efforts.
3. HUD, FEMA, EPA, and others can recommend recipients of federal financial assistance adhere to building and energy codes that ensure thermal comfort and resilience.
4. Treasury can investigate potential insurance options for covering the losses from extreme heat, including security from utility cost spikes, real-estate assessment and scoring for future heat risk, “worker wage” coverage for days where it is unsafe to work, protections for household resources lost during an extended blackout or power outage, and coverage for healthcare expenses caused by or exacerbated by heat waves that CMS could incentivize.
5. The Securities and Exchange Commission (SEC) can price climate risk when deciding on interest payments for municipal bonds for SLTTs and give beneficial rates to SLTTs that have done a full analysis of their risks and made steps towards resilience.

Recommendation 5. Build evaluative capacity of extreme heat resilience interventions.

There is a need for designated bodies that evaluate and monitor the effectiveness of specific heat mitigation interventions to make systematic improvements. Universities, research non-profits, and many private organizations have deep expertise in evaluating and assessing heat-relevant programs and projects. Such programs will need to be developed through universities and through private-public partnerships that support SLTTs in ensuring that specific actions are effective and transferable. 

To build out the evaluative capacity of extreme heat resilience interventions,

1. GSA can demonstrate low-power, passive and resilient cooling strategies in its buildings as a part of “Net Zero” initiatives and document promising strategies by climate region. DOE can also conduct more demonstration projects to build strategies that ensure indoor survivability in everyday and extreme conditions.
2. EPA and NOAA can administer research and evaluation grants to assess, identify, and promote heat mitigation actions that are effective in reducing heat risks across diverse geographies as well as design effective heat action planning strategies for SLTTs. This could look like further expansion and institutionalization of the NIHHIS Centers of Excellence program.

Conclusion

In all scientific estimates, 2024 will be the next hottest year on human record, and each year thereafter is likely to be even hotter. Under even existing climate conditions, thousands of Americans are already unnecessarily dying every year, and critical infrastructures like grids are being pushed to their limits. With temperature trends point to ever-hotter summers, effective and strategic heat adaptation planning within SLTTs and across the federal government is a national security priority. Through the broad uptake and implementation of the Heat Action Planning framework by key agencies and offices (EOP, OMB, Treasury, SEC, NOAA, USDA, CDC, NASA, HUD, DHS, FEMA, NIST, EPA, USFS, DOE, DOJ, DOT, ASPR, GSA, USACE, VHA, SEC, and others), the federal government will enable a more heat-prepared nation.

This idea of merit originated from our Extreme Heat Ideas Challenge. Scientific and technical experts across disciplines worked with FAS to develop potential solutions in various realms: infrastructure and the built environment, workforce safety and development, public health, food security and resilience, emergency planning and response, and data indices. Review ideas to combat extreme heat here.

In 2000, Fortune magazine observed, “Water promises to be to the 21st century what oil was to the 20th century: the precious commodity that determines the wealth of nations.” Like petroleum, freshwater resources vary across the globe. Unlike petroleum, no living creature survives long without it. Recent global episodes of extreme heat intensify water shortages caused by extended drought and overpumping. Creating actionable solutions to the challenges of a warming planet requires cooperation across all water consumers.

The Biden-Harris administration should work with stakeholders to (1) develop a comprehensive U.S. water policy to preserve equitable access to clean water in the face of a changing climate, extreme heat, and aridification; (2) identify and invest in agricultural improvements to address extreme heat-related challenges via U.S. Department of Agriculture (USDA) and Farm Bill funding; and (3) invest in water replenishment infrastructure and activities to maintain critical surface and subsurface reservoirs. America’s legacy water rules, developed under completely different demographic and environmental conditions than today, no longer meet the nation’s current and emerging needs. A well-conceived holistic policy will optimize water supply for agriculture, tribes, cities, recreation, and ecosystem health even as the planet warms.

Challenge and Opportunity

In 2023, the National Oceanic and Atmospheric Administration (NOAA) recorded the hottest global average temperature since records began 173 years prior. In the same year, the U.S. experienced a record 28 billion-dollar disasters. The earth system responds to increasing heat in a variety of ways, most of them involving swings in weather and water cycles. Warming air holds more moisture, increasing the possibility of severe storm events. Extreme heat also depletes soil moisture and increases evapotranspiration. Finally, warmer average temperatures across the U.S. induce northward shifts in plant hardiness zones, reshaping state economies in the process.

As a result, agriculture currently experiences billions of dollars in losses each year (Fig. 1). Drought, made worse by high heat conditions, accounts for a significant amount of the losses. In 2023, 80% of emergency disaster designations declared by USDA were for drought or excessive heat.

Agriculture consumes up to 80% of the freshwater used annually. Farmers rely on surface water and groundwater during dry conditions, as climate change systematically strains water resources. Rising heat can increase overall demand for water for irrigating crops, exacerbating water shortages. Plants need more water; evapotranspiration rates increase to keep internal temperatures in check. Warming is also shrinking the snowpack that feeds rivers, driving a “snow loss cliff” that will impact future supply. Compounding all of this, Americans have overused depleted reservoirs across the country, leading to a system in crisis.

America’s freshwater resources fall under a tangle of state, local, and watershed agreements cobbled together over the past 100 years. In general, rules fall into two main categories: riparian rights and prior appropriation. In the water-replete eastern U.S., states favor riparian rights. Under this doctrine, property owners generally maintain local use of the water running through the property or in the aquifer below it, except in the case of malicious overuse. Most riparian states currently fall under the Absolute Dominion (or the English) Rule, the Correlative Rights Doctrine, or the Reasonable Use Rule, and many use term-limited permitting to regulate water rights (Table 1). In the arid western region, states prefer the Doctrine of Prior Appropriation. Under this scheme, termed “first in time, first in right,” property owners with older claims have priority over all newer claimants. Unlike riparian rights, prior appropriation claims may be separated from the land and sold or leased elsewhere. Part of the rationale for this is that prior appropriation claims refer to shares of water that must be transported to the land via canals or pipes, rather than water that exists natively on the property, as found in the riparian case. Some states use a mix of the two approaches, and some maintain separate groundwater and surface water rules (Fig. 2).

Original “use it or lose it” rules required claimants to take their entire water allotment as a hedge against speculation by absentee owners. While persistent drought and overuse reduced water availability over time, “use it or lose it” rules continue to penalize reduction in usage rates, making efficiency counterproductive. For example, Colorado’s “use it or lose it”’ rule remains on the books, despite repeated efforts to revise it. In a sign of progress, in 2021, Arizona passed a bipartisan law to change their “use it or lose it” rule to guarantee continued water rights if users choose to conserve water.

Water scarcity extends well beyond the arid western states. In the Midwest, higher temperatures and drought exacerbate overpumping that continues to deplete the vast Ogallala Reservoir that underlies the Great Plains (Fig. 3). Driven in part by rising temperatures, the effective 100th meridian that separates the arid West from the humid East appears to have shifted east by about 140 miles since 1980, indicating creeping aridification across the Midwest. The drought-impacted Mississippi River level dropped for the past two consecutive years, impeding river transport and causing saltwater intrusion into Louisiana groundwater, contaminating formerly potable water in many wells.

Figure 3. Changes to the water level of the Ogallala Aquifer that underlies most of the Great Plains states show depletion in most regions

via Climate.gov

Recognition of water’s increased importance, especially in a future of more extreme heat and its cascading impacts, drives new markets for the trade of physical water. The impetus for some markets arises from the variance in water availability and cost between different industries and communities. Ideally, benefits accrue to both sellers and buyers by offering a valuable revenue stream for meeting a resource need. Markets differ between groundwater and surface water. For groundwater markets, agreements allow one user to trade some portion of allocated pumping rights to another local user, although impacts to neighbors and ecosystems that share the aquifer must be considered. Successful groundwater trades rely on accurate assessments of subsurface water levels over time. For surface water trades, a portion of the prior appropriation water can be sold or leased to another user regardless of proximity, or banked for future use. Legislation passed in 2022 enables Colorado River Indian Tribes to lease or trade newly settled water rights, or to bank them for future use in surface or subsurface reservoirs without facing a “use it or lose it” penalty.

There are less obvious water considerations. Import from and export to foreign nations of heavily irrigated crops or water-intensive commodities equates to virtual water trade. The most common virtual water export involves foreign sale of American farmer-grown crops. Other means include sales or leases of domestic land to foreign entities that grow water-intensive crops on U.S. soil, often on arid land, for export. Virtual water trades occur within the U.S. as well, through exchange of goods and services.

Developing a framework for cooperation across end users, complementary to previous frameworks recommended for the Ogallala Aquifer, creates a mechanism to address urgent water issues. Establishing the federal government’s role to convene and collaborate with stakeholders helps all parties participate within a common structure toward solving a mutual problem. To promote sustained productivity and water resources in the face of extreme heat and aridification, a holistic federal water policy should focus on:

• Simplifying and streamlining water rights 
• Creating a framework for water trades
• Increasing water use efficiency
• Developing data-driven predictive tools
• Initiating and supporting new agricultural approaches 
• Developing strategic water recharge

The Biden-Harris administration should develop a plan that creates incentives for all stakeholders to participate in water management policy development in the face of rising heat and climate change. Specifically, discussions must consider real reservoir volumes (surface and subsurface), current and future temperatures, annual rain and snow measurements, evapotranspiration calculations, and estimates of current and future water needs and trades across all end users. History supports federal assistance in thorny resource management areas. One close analog, that of fisheries management, shows the power of compromise to conserve future resources despite fierce competition. 

Plan of Action

Recommendation 1. The White House Council on Environmental Quality should convene a working group of experts from across federal and state agencies to develop a National Water Policy to future-proof water resources for a hotter nation.

Progress toward increased scientific understanding of the large-scale hydrologic cycle offers new opportunities for managing resources in the face of change. Management efforts started at local scales and expanded to regional scales. Country-wide management requires a more holistic view. The U.S. water budget is moving to a more unstable regime. Climate change and extreme heat add complexity by shifting weather and water cycles in real-time. Improving the system balance requires convening stakeholders and experts to formulate a high-level policy framework that:

• Creates mechanisms for cooperation across all stakeholders
• Coordinates with stakeholders to restructure water rights at the basin scale, including high-demand industries like agriculture
• Accounts for changes in total, and basin- and aquifer-scale, water volumes at the necessary spatial and temporal resolution as a basis for decision-making, including estimations of future water capacity
• Develops a mechanism to assess and manage, when necessary, physical and virtual water trades, considering climate risk to supply and demand
• Identifies opportunities for investment based on observations and best-in-class models
• Includes a framework for adaptive policy modification as climate changes, heat’s impacts are better understood, and new water trends occur
• Monitors and evaluates emerging markets to “buy” water to “bank” it for sale at a higher price during drought years and/or high heat events
• Identifies one lead government agency to coordinate water policy, nominally the Department of the Interior (DOI)
• Coordinates with Congress to identify a lead committee in each chamber to oversee water policy

As such, the White House Council on Environmental Quality should convene a working group of experts from across federal and state agencies to create a comprehensive National Water Policy. Relevant government agencies include the DOI; the U.S. Geological Survey (USGS); the Bureau of Indian Affairs; the U.S. Army Corps of Engineers (USACE); Federal Emergency Management Agency (FEMA); Department of Commerce; NOAA; and the USDA. The envisioned National Water Policy complements the U.S. Government Global Water Strategy.

Figure 4. Map of principal aquifers of the U.S.

via USGS

Data products to support the creation of a robust National Water Policy already exist (Fig. 4). USGS, FEMA, the National Weather Service, USDA’s Natural Resources Conservation Service, and NOAA’s National Climate Data Center, Office of Water Prediction, and National Water Center all contribute data critical to development of both high-level and regional-scale assessments and data layers crucial for short- and mid-term planning. Creating term reassessments as more data accrue and models improve supports effective decision-making as climate change and extreme heat continue to alter the hydrologic cycle. An overall water policy must remain dynamic due to changing trends and new data.

National, regional, and local aspects of the water budget and related models and visualizations help federal and state decision makers develop a strategic plan for modernizing water rights for both river water, basins, and groundwater and to identify risks to supplies (e.g., decreasing snowpack due to higher heat) and opportunities for recharge. Stakeholders and water managers with shared knowledge of well-documented data are best positioned to determine minimum reservoir volumes in the primary storage basins, including aquifers, in alignment with the objectives of the National Strategy to Develop Statistics for Environmental and Economic Decisions. By creating a strategy that uses actual average values to maintain reservoir volumes, some of the potential shocks created by drought years and high heat could be cushioned, and related financial losses could be avoided or mitigated. Ultimately, stakeholders and managers must share a common understanding of the water budget when seeking to resolve water rights disputes, to review and revise water rights, and to inform trades.

Basin and local data promote development of a strategic framework for water trades. As trades and markets continue to grow, states and municipalities must account for water rights, both the lease and sale of rights, to buffer large fluctuations in water prices and availability. Emerging markets to “buy” water to “bank” it for sale at a higher price during drought years and/or high heat events should also be monitored and evaluated by relevant agencies like Commerce. States’ and investors’ maintenance of transparency around market activities, including investor purchases of land with water rights, promotes fair trade and ensures stakeholder confidence in the process. 

Finally, to communicate clearly with the public, funds should be provided through the DOI budget to NOAA and USGS data scientists to create decision-support tools that build on the work already underway through mature databases (e.g., at drought.gov and water.weather.gov). New water visualization tools to show the nowcast and forecast of the national water status would help the public understand policy decisions, akin to depictions used by weather forecasters. Variables should include heat index, humidity, expected evapotranspiration, precipitation, surface volumes, and groundwater levels, along with information on water use restrictions and recharge mechanisms at the local level. Making this product media-friendly aids public education and bolsters policy adoption and acceptance.

Recommendation 2. USDA should invest in infrastructure, research, and development.

Agriculture, as the largest water consumer, faces scarcity in the coming years even as populations continue to grow. Increasing demands on a dwindling resource and growing need for more water lead to conflict and acrimony. To ease tensions and maintain the goods and services needed to fuel the U.S. economy in the future, investment in both immediately practicable future-proofed, heat-resilient water solutions and over-the-horizon research and development must commence. To prepare, USDA will need to:

• Continue to fund the installation of liners or pipes for irrigation and conveyance canals, in alignment with efforts under the Bipartisan Infrastructure Law (BIL). Farmers historically irrigated their fields by flooding them via outdated earthen canals. Extensive evaporation and ground seepage losses delay water delivery to fields and creates unintended ecological side effects.
• Promote the installation of water-efficient irrigation methods on farms that previously used field flooding or other inefficient practices. Policy may include co-funding improvements, buying back “conserved water” and offering low-interest loans. The combination of improved canals with efficient irrigation technologies maintains agricultural production while reducing water loss.
• Test the efficacy of installing solar panels over or adjacent to open lined aqueducts or conveyance canals to both produce energy by taking advantage of evaporative cooling of the panel undersides and reduce some heat-driven evaporation of water from the canal by blocking sunlight. The dual benefit especially increases in the face of extreme heat where panels ordinarily become much less efficient as temperatures rise. An additional advantage includes running electrical infrastructure out to farms where farmers could use energy or connect their own panels if they wished to sell energy back to the grid.
• Add agrivoltaics (or other emerging energy/agricultural land use options) to the Agricultural Conservation Easement Program (ACEP). Research indicates that co-benefits include locally increased moisture for plants protected by panels while evapotranspiration cools the panels. This adaptation creates a reliable source of local energy while keeping agricultural land productive.
• Support transition to USDA-recommended varieties of climate-resilient Western native grasses for forage and soil stabilization of marginal land. Converting some highly irrigated farmland to desert livestock forage maintains agricultural land while reducing water usage, in line with the goals of the ACEP program.
• Support market development for desert agricultural crops adapted to the native conditions under the new Regional Agricultural Promotion Program (RAPP). Include food science and animal feed research to increase adoption. Examples include cactus opuntia fruit for natural sweetening, cactus paddles for food and fodder, drought-tolerant grasses and grains, mesquite grass forage, and mesquite bush seed pod flour. These developments build on careful research and accounts of Indigenous people and early settler practices and diets.
• Support development and deployment of technology that remotely detects water-stressed, heat-stressed plants to enable smart irrigation and cooling under USDA’s Agriculture and Food Research Initiative (AFRI).
• Develop crops with greater resilience to extreme heat, intermittent flooding, and intermittent drought via funding through Agriculture Advanced Research and Development Authority (AgARDA) and AFRI. Examples include genetically modifying or hybridizing plants for:
  • greater heat-tolerance and resilience to heat-stress, 
  • adaptation to inundation-related oxygen deficiency, and
  • resilience to increased heat driving evapotranspiration during droughts.

To support these efforts and broader climate resilience needs of farmers, Congress can:

• Reauthorize and fully fund the AgARDA at the requested $50 million annual budget to begin its mission. AgARDA was originally established under the 2018 Farm Bill (Section 7132 of the Agricultural Improvement Act of 2018(Public Law 115-334)). The agency received $1 million in each of the years 2022 and 2023, for a total of 0.8% of the total amount authorized. Addressing the challenges facing this century’s agriculture requires high-risk, high-reward thinking. No mechanism within the USDA sponsors such programs. Historically, the $250 million total recommended budget represented less than 0.06% of the total value ($428 billion) of the 2018 Farm Bill over its five-year span.

Recommendation 3. Federal, state, and local governments must invest in replenishing water reserves.

To balance water shortage, federal, state and local governments must invest in recharging aquifers and reservoirs while also reducing losses due to flooding. Opportunities for flood basin recharge arise during wet years, especially accounting for the shift from longer, frequent, lighter rainstorms to shorter, less frequent durations of very heavy rainfall. Federal agencies currently have opportunities to leverage Inflation Reduction Act (IRA) and BIL money for replenishment, including the following:

• FEMA, DOI and USDA can encourage grantees to use, and USACE can implement, proven nature-based, physical barriers to slow down surface flow in the event of heavy precipitation and flooding. Restoring river oxbows with associated wetlands, creating tree falls and wetland horizontal levees, reintroducing beavers, and employing other nature-based solutions can improve recharge and reduce downstream flood damage by slowing release of water. These measures should be instigated with a view to improving the hydrologic cycle of streams in the drainage basin, especially those that have been heavily engineered in the past. Co-benefits of these greening interventions include reducing surface temperature, thereby benefiting humans, livestock, and crops.

Congress can further support these actions by:

• Implementing annual-enrollment, permanent floodplain easements in the 2023 US Farm Bill. As outlined in the American Rivers report, the Emergency Watershed Protection (EWP) program “received 2,210 applications, but less than 10 percent of total applications and 16 percent of flood prone acres have been enrolled.” At present, the EWP program solely provides funds following a disaster rather than as a long-term strategic investment. Adopting floodplain easements as policy would maintain soil fertility, offer flood protection for downstream properties, and help to recharge aquifers for subsequent use and safeguard against future extreme heat and drought.
• Creating mechanisms whereby farmers who flood their fields during wet years accrue credits toward water allocations in dry years. Where appropriate, farms should be funded to develop appropriately located swales and catchments to collect rainwater and irrigation runoff.
• Funding expansion of the USACE Managed Aquifer Recharge (MAR) program authorized under the 2016 Water Resources Development Act. Projects have commenced in 17 states so far. In this approach, USACE pumps surface water into aquifers for:
  • Drought resilience 
  • Flood mitigation 
  • Aquatic ecosystem restoration and constructed wetlands 
  • Reducing saltwater intrusion 
  • Multi-use urban environmental restoration projects
• Funding the purchase of properties repeatedly affected by flooding to convert them into natural flood buffer areas and to support aquifer recharge zones in line with FEMA’s Public Assistance Program. Expanding this program beyond disaster response would remove vulnerable structures proactively, based on historic flood records and documented flood risk (Fig. 5). The purchase approach is distinct from the easement program that allows farmers to retain ownership of the property.

Figure 5. Map of insured flood claims

via Washington Post, with credit to Federal Emergency Management Agency, Natural Resources Defense Council

Conclusion

Water policy varies regionally, by basin, and by state. Because aquifers cross regions and water supplies vary over interstate and international boundaries, the federal government is the best arbiter for managing a dynamic, precious resource. By treating the hydrologic cycle as a dynamic system, data-driven water policy benefits all stakeholders and serves as a basis for future federal investment.

This idea of merit originated from our Extreme Heat Ideas Challenge. Scientific and technical experts across disciplines worked with FAS to develop potential solutions in various realms: infrastructure and the built environment, workforce safety and development, public health, food security and resilience, emergency planning and response, and data indices. Review ideas to combat extreme heat here.