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

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, 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.


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.

Frequently Asked Questions
What will be the results of Heat Action Planning Framework and how will they make a difference?
The Heat Action Planning Framework considers the current and future risks of extreme heat to SLTTs and the federal government in order to identify promising adaptation strategies for protecting people, property, and the economy. Plans allow for the most fiscally responsible implementation of financial resources, programs, and staff time. Like any planning process, the ability to implement is essential. While a plan by itself may not immediately make a community heat resilient, pursuing funding to implement the plan and ensuring sustainable actions will. The federal government plays a vital role in building the capacity for SLTTS to follow through on their plans.
What are examples of federal heat risk mitigation?

Potential examples of federal heat risk mitigation include:

  1. General Services Administration (GSA) protecting the federal workforce and federal contractors from extreme heat conditions;

  2. Department of Energy (DOE) and Department of Education (Ed) ensuring heat resilient school and education infrastructure so that children, teachers, and staff are able to engage in continuous learning during the hottest periods of the year;

  3. Veterans Health Administration (VHA) and Department of Justice (DOJ) guaranteeing veterans and incarcerated people in their care (or in the care of dependent organizations) are not dying of heat illness;

  4. USDA assessing potential risk to its food, nutrition, and forestry services due to heat-exacerbated supply chain shortages;

  5. Department of Transportation (DOT), Cybersecurity and Infrastructure Security Agency (CISA), U.S. Army Corps of Engineers (USACE), Department of Homeland Security (DHS), and DOE ensuring critical infrastructure (roads, railways, power grids, data centers, utilities, etc) are designed and ready for increasingly extreme temperatures.

U.S. Water Policy for a Warming Planet

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.

Figure 1

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).

Figure 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

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:

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:

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 and 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:

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

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:

Congress can further support these actions by:

Figure 5. Map of insured flood claims

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


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.

Frequently Asked Questions
Why should the Department of the Interior coordinate the stakeholder engagement rather than the states?

DOI already manages surface waters in some basins through the Bureau of Reclamation and through the decision in Arizona vs. California. DOI also coordinates water infrastructure investments across multiple states via BIL funding. Furthermore, DOI agencies actively engage in collecting and sharing water resource data across the U.S. Because DOI maintains a holistic view of the hydrologic cycle and currently engages with stakeholders across the country on water concerns, it is best positioned to lead the discussions.

How does DOI know who the stakeholders should be for each region?

DOI, through the USGS, mapped out most of the largest U.S. aquifers (Fig. 4) and drainage basins. The main stakeholders for each reservoir emerge through those maps. 

How can farmers protect their livelihoods in light of all of the competing water interests?

The best way to maintain agricultural production is to invest in increasingly efficient water farming practices and infrastructure. For example, installing canal liners, pipes, and smart watering equipment reduces water loss during conveyance and application. Funds have been allocated under the BIL and IRA for water infrastructure upgrades. Some government and state agencies offer grants in support of increased water efficiency. Working with seed companies to select drought- and/or flood-tolerant variants offers another approach. Farmers should also encourage funding agencies to ramp up groundwater replenishment activities and to accelerate development of new supporting technologies that will help maintain production.

How can farmers add agrivoltaics or other kinds of renewable energy to their property?

Funds or tax credits are available to help defray some of the costs of installing renewable energy on rural land. Various agencies also offer targeted funding opportunities to test agrivoltaics; these opportunities tend to entail collaboration with university partners.

Why is there so much controversy around the Colorado River water allotments?

Over a century ago, the prior appropriation doctrine attracted homesteaders to the arid Colorado River basin by offering set water entitlements. Several early miscalculations contributed to the basin’s current water crisis. First, the average annual flow of the Colorado River used to calculate entitlements was overestimated. Second, entitlements grew to exceed the overestimated annual flow, compounding the deficit. Third, water entitlement plans failed to set aside specific shares for federally recognized tribes as well as the vast populations that responded to the call to move west. Finally, “use it or lose it” rules that govern prior appropriation entitlements created roadblocks to progress in water use efficiency.

Are there any existing water markets?

A water futures market already exists in California.

A lot of the homeowners impacted by repeated flooding are disadvantaged. How can the government help these homeowners without disenfranchising them when converting these properties to buffer zones?

Program leaders would need to work cooperatively with impacted families to find agreeable home sites away from flood zones, especially in close-knit communities where residents have established ties with neighbors and businesses. If desired and when practicable, existing homes could be transported to drier ground. Working with all of the stakeholders in the community to chart a path forward remains the best and most equitable policy.

Defining Disaster: Incorporating Heat Waves and Smoke Waves into Disaster Policy

Extreme heat – and similar people-centered disasters like heavy wildfire smoke – kills thousands of Americans annually, more than any other weather disaster. However, U.S. disaster policy is more equipped for events that damage infrastructure than those that mainly cause deaths. Policy actions can save lives and money by better integrating people-centered disasters.

Challenge and Opportunity

At the federal level, emergency management is coordinated through the Federal Emergency Management Agency (FEMA), with many other agencies as partners, including Centers for Disease Control (CDC), Department of Housing and Urban Development (HUD), and Small Business Administration (SBA). Central to the FEMA process is the requirement under the Stafford Act that the President declare a major disaster, which has never happened for extreme heat. This seems to be caused by a lack of tools to determine when a heat wave event escalates into a heat wave disaster, as well as a lack of a clear vision of federal responsibilities around a heat wave disaster.

Gap 1. When is a heat event a heat disaster?

A core tenet of emergency management is that events escalate into disasters when the impacts exceed available resources. Impact measurement is increasingly quantitative across FEMA programs, including quantitative metrics used in awarding Fire Management Assistance Grant (FMAG), Public Assistance (PA), and Individual Assistance (IA) and in the Benefit Cost Analysis (BCA) for hazard mitigation grants.

However, existing calculations are unable to incorporate the health impacts that are a main impact of heat waves. When health impacts are included in a calculation, it is only in limited cases; for example, the BCA allows mental healthcare savings, but only for residential mitigation projects that reduce post-disaster displacement.

Gap 2. What is the federal government’s role in a heat disaster?

Separate from the declaration of a major disaster is the federal government’s role during that disaster. Existing programs within FEMA and its partner agencies are designed for historic disasters rather than those of the modern and future eras. For example, the National Risk Index (NRI), used to understand the national distribution of risks and vulnerability, bases its risk assessment on events between 1996 and 2019. As part of considering future disasters, disaster policy should consider intensified extreme events and compound hazards (e.g., wildfire during a heat wave) that are more likely in the future. 

A key part of including extreme heat and other people-centered disasters will be to shift toward future-oriented resilience and adaptation. FEMA has already been making this shift, including a reorganization to highlight resilience. The below plan of action will further help FEMA with its mission to help people before, during, and after disasters.

Plan of Action

To address these gaps and better incorporate extreme heat and people-centered disasters into U.S. emergency management, Congress and federal agencies should take several interrelated actions.

Recommendation 1. Defining disaster

To clarify that extreme heat and other people-centered disasters can be disasters, Congress should:

(1) Add heat, wildfire smoke, and compound events (e.g., wildfire during a heat wave) to the list of disasters in Section 102(2) of the Stafford Act. Though the list is intended to be illustrative rather than exhaustive, as demonstrated by the declaration of COVID-19 as a disaster despite not being on the list, explicit inclusion of these other disasters on the list clarifies that intent. This action is widely supported and example legislation includes the Extreme Heat Emergency Act of 2023

(2) FEMA should standardize procedures for determining when disparate events are actually a single compound event. For example, many individual tornadoes in Kentucky in 2021 were determined to be the results of a single weather pattern, so the event was declared as a disaster, but wildfires that started due to a single heat dome in 2022 were determined to be individual events and therefore unable to receive a disaster declaration. Compound hazards are expected to be more common in the future, so it is critical to work toward standardized definitions.

(3) Add a new definition of “damage” to Section 102 of the Stafford Act that includes human impacts such as death, illness, economic impacts, and loss of critical function (i.e., delivery of healthcare, school operations, etc.). Including this definition in the statute facilitates the inclusion of these categories of impact.

To quantify the impacts of heat waves, thereby facilitating disaster decisions, FEMA should adopt strategies already used by the federal government. In particular, FEMA should:

(4) Work with HHS to expand the capabilities of the National Syndromic Surveillance Program (NSSP) to evaluate in real time various societal impacts like the medical-care usage and work or school days lost. Recent studies indicate that lost work productivity is a major impact of extreme heat that is currently unaccounted—a gap of potentially billions of dollars. The NSSP Community of Practice can help expand tools across multiple jurisdictions too. Expanding syndromic surveillance expands our ability to measure the impacts of heat, building on the tools available through the CDC Heat and Health Tracker.

(5) Work with CDC to expand their use of excess-death and flu-burden methods, which can provide official estimates of the health impacts of extreme heat. These methods are already in use for heat, but should be regularly applied at the federal level, and would complement the data available from health records via NSSP because it calculates missing data.

(6) Work with EPA to expand BenMAP software to include official estimates of health impacts attributable to extreme heat. The current software provides official estimates of health impacts attributable to air pollution and is used widely in policy. Research is needed to develop health-impact functions for extreme heat, which could be solicited in a research call such as through NIH’s Climate and Health initiative, conducted by CDC epidemiologists, added to the Learning Agenda for FEMA or a partner agency, or tasked to a national lab. Additional software development is also needed to cover real-time and forecast impacts in addition to the historic impacts it currently covers. The proposed tool complements Recommendations #4-5 because it includes forecast data.

(7) Quantify heat illness and death impacts. Real-time data is available in the CDC Heat and Health Tracker. These impacts can be converted to dollars for comparison to property damage using the Value of a Statistical Life (VSL), which FEMA already does in the NRI ($11.6 million per death and $1.16 million per injury in 2022). VSL should be expanded across FEMA programs, in particular the decision for major disaster declarations. VSL could be immediately applied to current data from NSSP, to expanded NSSP and excess-death data (Recommendations #4-5), and is already incorporated into BenMAP so would be available in the expanded BenMAP (Recommendation #6).

(8) Quantify the impact of extreme heat on critical infrastructure, including agriculture. Improved quantification methods could be achieved by expanding the valuation methods for infrastructure damage already in the NRI and could be integrated with the National Integrated Heat Health Information System (NIHHIS). The damage and degradation of infrastructure is often underestimated and should be accurately quantified. For example,

Together, these proposed data tools would provide FEMA with a comprehensive understanding of the impacts of extreme heat on human health in the past, present, and near future, putting heat on the same playing field as other disasters. 

Real-time impacts are particularly important for FEMA to investigate requests for a major disaster declaration. Forecast impacts are important for the ability to preposition resources, as currently done for hurricanes. The goal for forecasting should be 72 hours. To achieve this goal from current models (e.g., air quality forecasts are generally just one day in advance):

(9) Congress should fund additional sensors for extreme weather disasters, to be installed by the appropriate agencies. More detailed ideas can be found in other FAS memos for extreme heat and wildfire smoke and in recommendation 44 of the recent Wildland Fire Commission report.

(10) Congress should invest in research on integrated wildfire-meteorological models through research centers of excellence funded by national agencies or national labs. Federal agencies can also post specific questions as part of their learning agendas. Models should specifically record the contribution of wildfire smoke from each landscape parcel to overall air pollution in order to document the contribution of impacts. This recommendation aligns with the Fire Environment Center proposed in the Wildland Fire Commission report.

Table 1. Division of proposed improvements by time period addressed and implementation readiness
HistoricReal timeForecast
Integrate existing capabilities with FEMAExcess death methods (#5)Use VSL (#7)
Expand program abilitiesExpand infrastructure calculations, NSSP, BenMAP, and sensors (#4–9)Expand BenMAP (#6) and improve smoke forecasts (#10)
Cross-cutting definitionsStafford Act amendments (#1, 3) and compound events (#2)

Recommendation 2. Determining federal response to heat disasters

To incorporate extreme heat and people-centered disasters across emergency management, FEMA and its peer agencies can expand existing programs into new versions that incorporate such disasters. We split these programs here by the phase of emergency management.


(11) Using Flood Maps as a model, FEMA should create maps for extreme heat and other people-centered disasters. Like flood maps, these new maps should highlight the infrastructure at risk of failure or the loss of access to critical infrastructure (e.g., FEMA Community Lifelines) during a disaster. Failure here is defined as the inability of infrastructure to provide its critical function(s); infrastructure that ceases to be usable for its purpose when an extreme weather event occurs (i.e., bitumen softening on airport tarmacs, train line buckling, or schools canceled because classrooms were too hot or too smokey). This includes impacts to evacuation routes and critical infrastructure that would severely impact the functioning of society. Creating such a map requires a major interagency effort integrating detailed information on buildings, heat forecasts, energy grid capacity, and local heat island maps, which likely requires major interagency collaboration. NIHHIS has most of the interagency collaborators needed for such effort, but should also include the Department of Education. Such an effort likely will need direct funding from Congress in order to have the level of effort needed.

(12) FEMA and its partners should publish catastrophic location-specific scenarios to align preparedness planning. Examples include the ARkStorm for atmospheric rivers, HayWired for earthquake, and Cascadia Rising for tsunami. Such scenarios are useful because they help raise public awareness and increase and align practitioner preparedness. A key part of a heat scenario should be infrastructure failure and its cascading impacts; for example, grid failure and the resulting impact on healthcare is expected to have devastating effects.

(13) FEMA should incorporate future projections of disasters into the NRI. The NRI currently only uses historic data on losses (typically 1996 to 2019). An example framework is the $100 million Prepare California program, which combined historic and projected risks in allocating preparedness funds. An example of the type of data needed for extreme heat includes the changes in extreme events that are part of the New York State Climate Impacts Assessment.

(14) FEMA should expand its Community Lifelines to incorporate extreme heat and cascading impacts for critical infrastructure as a result of extreme heat, which must remain operable during and after a disaster to avoid significant loss of human life and property. 

(15) The strategic national stockpile (SNS) should be expanded to focus on tools that are most useful in extreme weather disasters. A key consideration will be fluids, including intravenous (IV) fluids, which the current medical-focused SNS excludes due to weight. In fact, the SNS relies on the presence of IV fluids at the impacted location, so if there is a shortage due to extreme heat, additional medicines might not be deliverable. To include fluids, a new model will be necessary because of the logistics of great weight.

(16) OSHA should develop occupational safety guidelines to protect workers and students from hazardous exposures, expanding on its outdoor and indoor heat-related hazards directive. Establishing these thresholds, such as max indoor air temperatures similar to California’s Occupational Safety and Health Standards Board, can help define the threshold of when a weather event escalates into a disaster. No federal regulations exist for air quality, so California’s example could be used as a template. The need already exists: an average of 2,700 heat-related injuries and 38 heat-related fatalities were reported annually to OSHA between 2011 and 2019.

(17) FEMA and its partners should expand support for community-led multi-hazard resilience hubs, including learning from those focused on extreme heat. FEMA already has its Hubs for Equitable Resilience and Engagement, and EPA has major funding available to support resilience hubs. This equitable model of disaster resilience that centers on the needs of the specific community should be supported.


(18) FEMA should introduce smaller disaster-assistance grants for extreme weather disasters: HMAG, CMAG, and SMAG (Heat, Cold, and Smoke Management Assistance Grants, respectively). They should be modeled on FMAG grants, which are rapidly awarded when firefighting costs exceed available resources but do not necessarily escalate to the level of a major disaster declaration. For extreme weather disasters, the model would be similar, but the eligible activities might focus on climate-controlled shelters, outreach teams to reach especially vulnerable populations, or a surge in medical personnel and equipment. Just like firefighting equipment and staff needed to fight wildfires, this equipment and staff are needed to reduce the impacts of the disaster. FMAG is supported by the Disaster Relief Fund, so if the H/C/SMAG programs also tap that, it will require additional appropriations. Shelters are already supported by the Public Assistance (PA) program, but PA requires a major disaster declaration, so the introduction of lower-threshold funds would increase access.

(19) HHS could activate Disaster Medical Assistance Teams to mitigate any surge in medical needs. These teams are intended to provide a surge in medical support during a disaster and are deployed in other disasters. See our other memos on this topic.

(20) FEMA could deploy Incident Management Assistance Teams and supporting gear for additional logistics. They can also deploy backup energy resources such as generators to prevent energy failure at critical infrastructure.

Recovery and Mitigation

(21) Programs addressing gray or green infrastructure should consider the impact upgrades will have on heat mitigation. For example, EPA and DOE programs funding upgrades to school gray infrastructure should explicitly consider whether proposed upgrades will meet the heat mitigation needs based on climate projections. Projects funding schoolyard redesign should explicitly consider heat when planning blacktop, playground, and greenspace placement to avoid accidentally creating hot spots where children play. CAL FIRE’s grant to provide $47 million for schools to convert asphalt to green space is a state-level example.

(22) Expand the eligible actions of FEMA’s Hazard Mitigation Assistance (HMA) to include installation/upgrade of heating, ventilation, and cooling (HVAC) systems and a more expansive program to support nature-based solutions (NBS) like green space installation. Existing guidance allows HVAC mitigation for other hazards and incentivizes NBS for other hazards.

(23) Increase alignment across federal programs, identifying programs where goals align. For example, FEMA just announced that solar panels would be eligible for the 75% federal cost share as part of mitigation programs; other climate and weatherization improvements should also be eligible under HMA funds.

(24) FEMA should modify its Benefit Cost Analysis (BCA) process to fairly evaluate mitigation of health and life-safety hazards, to better account for mitigation of multiple hazards, and to address equity considerations introduced in Office of Management and Budget’s recent BCA proposal. Some research is likely needed (e.g., the cost-effectiveness of various nature-based solutions like green space is not yet well-defined enough to use in a BCA); this research could be performed by national labs, put into FEMA’s Learning Agenda, or tasked to a partner agency like DOE.

(25) Expand the definition of medical devices to include items that protect against extreme weather. For example, the Center for Medicare and Medicaid Services could define air-conditioning units and innovative personal cooling devices as eligible for prescription under Medicare/Medicaid.

To support the above recommendations, Congress should:

(26) Ensure FEMA is sufficiently and consistently funded to conduct resilience and adaptation activities. Congress augments the Disaster Relief Fund in response to disasters, but they report that the fund will be billions of dollars in deficit by September 2024. It has furthermore been reported that FEMA has delayed payments due to uncertainty of funding through Congressional budget negotiations. In order to support the above programs, it is essential that Congress fund FEMA at a level needed to act. To support FEMA’s shift to a focus on resilience, the increase in funding should be through annual appropriations rather than the Disaster Relief Fund, which is augmented on an ad hoc basis.

(27) Convene a congressional commission like the recent Wildland Fire Commission to analyze the federal capabilities around extreme weather disasters and/or extreme heat. This commission would help source additional ideas and identify political pathways toward creating these solutions, and is merited by the magnitude of the disaster.


People across the U.S. are being increasingly exposed to extreme heat and other people-centered disasters. The suggested policies and programs are needed to upgrade national emergency management for the modern and future era, thereby saving lives and reducing disaster costs to the public.

Frequently Asked Questions
Are the impacts of extreme heat and other people-centered disasters significant enough to be considered disasters?

We estimate a minimum of 1,670 deaths and $157.8 billion of annual heat impacts. These deaths and dollar amounts exceed almost every recorded disaster in U.S. history. Only COVID-19, 9/11, and Hurricanes Maria and Katrina have more deaths, and only Hurricanes Katrina and Harvey have caused more dollar damage. It should be noted that most of the estimates reported are several years out of date and exclude major heat waves of 2021 and 2022. For example, individual heat waves produced sizable numbers of deaths, including 395 deaths in a 2022 California heat wave and 600 deaths in the 2021 Pacific Northwest heatwave.

How could the Stafford Act be amended to include heat waves?

It is insufficient to just add heat to the list of disasters enumerated in the Stafford Act because it omits (1) the important recognition of compound events that often are associated with extreme heat, (2) other people-centered disasters like smoke waves, and (3) the ability to measure these disasters. We, therefore, recommend some version of the following text:

Section 102(2) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5122(2)) is amended by striking “or drought” and inserting “drought, heat, smoke, or any other weather pattern causing a combination of the above”.

Section 102 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5122(2)) is amended by inserting

(13) DAMAGE—“Damage” means–

  • (A) Loss of life or health impacts requiring medical care

  • (B) Loss of property or impacts on property reducing its ability to function

  • (C) Diminished usable lifespan for infrastructure

  • (D) Economic damage, which includes the value of a statistical life, burden on the healthcare system due to injury, burden on the economy placed by lost days of work or school, agricultural losses, or any other economic damage that is directly measurable or calculated.

  • (E) Infrastructure failure of any duration, including temporary, that could lead to any of the above

Tracking and Preventing the Health Impacts of Extreme Heat

The response to the 9/11 terrorist attacks included building from scratch a bioterrorism-monitoring system that remains a model for public health systems worldwide. Today we face a similarly galvanizing moment: weather-related hazards cause multiple times the 9/11 death toll each year, with extreme heat often termed the “top weather killer,” at 1,670 official deaths a year and 10,000 attributed via excess deaths analysis. Extreme cold and dense wildfire smoke each cause comparable numbers of deaths. By rapidly upgrading and expanding the health-tracking systems of the Centers for Disease Control (CDC), Veterans Health Administration (VHA), and Centers for Medicare and Medicaid (CMS) to improve real-time surveillance of health impacts of climate change, the U.S. can similarly meet the current moment to promote climate-conscientious care that save lives.

Challenge and Opportunity

The official death toll of extreme heat since 1979 stands at over 11,000, but the methods used to develop this count are known to underestimate the true impacts of heat waves. 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 and adds difficulty to declaring heat waves as disasters despite the massive loss of life. Similarly, the lack of integration of critical environmental data like “wet bulb” temperature alongside these health impacts in electronic data systems hinders the provision of medical care.

National Accounting

The national reaction to the 9/11 terrorist attacks provides a roadmap forward: improved data and tracking is fundamental to a nation’s evidence-based threat response. Operated by federal, state, and local public health professionals who comprise the CDC’s National Syndromic Surveillance Program (NSSP), surveillance systems were developed across the nation to meet new challenges in disease detection and situational awareness. Since 2020, the CDC’s Data Modernization Initiative (DMI) has provided a framework for this transformation, with the stated goal of improving the nation’s ability to predict, understand, and share data on new health threats in real time. While the DMI has focused on the pioneering role of new technologies for health protection, this effort also offers a once-in-a-generation opportunity for the public health and medical surveillance establishment to increase their capacity to address pressing future threats to the nation’s welfare, including the evolving climate crisis. Increasingly, extreme weather is responsible for both near-term disasters (more frequent and intense heat waves, dense smoke waves, and cold waves) and the long-term exacerbation of prevalent health conditions (such as heart, lung, and neurological disease). Its increasingly severe  impacts demand a detailed and funded roadmap to attain the DMI’s goals of “real-time, scalable emergency response” capability. 

Patient Care

Syndromic surveillance systems track the impacts of events at a population level, but other resources are needed to directly help individual patients during a disaster. Electronic health records (EHRs) allow medical providers to track relevant information that could help diagnose arising health conditions. Some medical systems have begun tracking nonmedical information to assist in diagnosis, such as the social determinants of health (e.g., housing and food availability) that are linked to improving patient outcomes. However, the environmental conditions a patient has experienced are not typically linked to health records. Improving the links between environmental conditions and EHRs will help patients—for example, by determining if a new asthma diagnosis is related to recent smoke waves—and also support syndromic surveillance.

A similar effect occurs with death records. Death records are typically logged at the patient level with free-form text that is mostly up to a medical professional who is often under time pressure. Text for each death record is later coded to fit into specific cause codes as it is aggregated into population-level datasets such as the National Vital Statistics System. Information about the environmental conditions that contributed to the death can be lost at any step along the process, resulting in the undercount of climate-related mortality. Improved tracking at the individual level will improve accounting at the national level.

Plan of Action

In order to track the health impacts from extreme weather events and thereby enhance the provision of medical care during such events, both disaster and health data must be improved.

Recommendation 1. National accounting for health impacts of the climate crisis

The National Syndromic Surveillance Program provides a world-class starting point for better tracking of climate health impacts, both in terms of technology and a dedicated and knowledgeable workforce.  The following plan will permit the evolution of this underlying infrastructure to provide health systems and policy makers with real-time and forecast impacts.

To modernize real-time monitoring of health impacts:

To improve forecasting capabilities of health impacts:

To improve the ability to track health impacts:

Recommendation 2. Improving Patient Care

To integrate environmental conditions into EHRs nationwide:

To support patients during extreme heat:


Deaths from extreme conditions, already high, are forecast to increase in the coming years and decades and potentially define a new modern era. It is vital to prepare our health system for these threats, including accurate accounting of their toll, and better prepare healthcare providers and the public for the conditions they will face.

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.

Frequently Asked Questions
How would including environmental data on EHRs help patients?

While some emergency care providers might be aware of the extreme weather events unfolding outside and therefore be prepared to treat related illness, the situation can change during lengthy shifts, leaving them less well prepared. This disparity between patient exposure and provider expectations can be even greater in rural areas, where patients might travel significant distances and across diverse terrain such that their exposure differs from conditions at the medical facility.

Time is also a factor. For longer-term impacts like asthma complications that could be related to smoke waves, a medical provider might be unaware that a patient experienced heavy smoke and be less able to diagnose the resulting respiratory issues

Leveraging Federal Post-Disaster Recovery Reform for Extreme Heat Adaptation and Innovation

Extreme heat is the leading weather-related cause of death in the U.S., yet it has never been the cause of a federal disaster declaration. This is because heat events are not explicitly recognized as a cause for disaster declarations under the Stafford Act, which defines federal disaster response activities. This renders those impacted by extreme heat ineligible for the substantial federal funding provided to communities that receive the official disaster declaration. A congressional amendment to the Stafford Act, and related post-disaster guidance, explicitly identifying extreme heat as an eligible disaster, would create significant opportunities for planning, funding, and implementing long-term heat adaptation while prioritizing the most physically and socially vulnerable communities.

While an extreme heat occurrence or heat wave may cause loss of life or labor, most disasters only receive federal declarations if they have excessive economic damage, property damage, and devastation beyond the capacity of a state government, which is less common in a heat event. Thus, amending the Stafford Act would assist the communities placed at an acute disadvantage in recovering and mitigating future heat events in comparison to those impacted by other extreme weather events. Likewise, it would increase U.S. capacity to address the growing challenges from increasingly frequent and extensive extreme heat events. 

An extreme heat disaster declaration, followed by an appropriation from Congress, can unlock federal adaptation funding through the Department of Housing and Urban Development (HUD) Community Development Block Grants for Disaster Recovery (CDBG-DR) and Mitigation (CDBG-MIT), as well as the Federal Emergency Management Agency (FEMA) Hazard Mitigation Grant Program (HMGP). Leveraging these programs for heat adaptation, coupled with an expansion of existing proactive resilience programs such as FEMA’s Building Resilient Infrastructure and Communities, would catalyze heat adaptation planning and innovation across the country.

Challenge and Opportunity

Between 2011 and 2021, 90% of U.S. counties experienced a major disaster due to an extreme weather event. Over that period, not a single disaster declaration was made in response to an extreme heat event; yet, communities suffered from the impacts of extreme heat. Two of the states with the lowest number of disaster occurrences, Nevada and Arizona, had the highest number of deaths from heat-related illnesses between 2018 and 2021, highlighting a major flaw in the federal disaster assistance programs’ ability to protect all communities bearing the impacts of climate change. Over those four years, heat has been among the causes of death for 571 people in Nevada and 1,298 people in Arizona. That’s 4.54 and 4.46 deaths per 100,000 residents, respectively – compared to the U.S. average of 0.35 per 100,000 residents over the same period. Additionally, deaths caused by extreme heat are likely undercounted, as there are no comprehensive or consistent mechanisms for healthcare providers to track or report heat-related deaths. 

In addition to being linked to growing mortality rates, extreme heat magnifies health, social, and economic disparities. According to the Centers for Disease Control (CDC), vulnerable populations — including older adults, infants and children, those with chronic conditions, lower-income individuals, athletes, outdoor workers, and pregnant people — are disproportionately affected by increased heat. Additionally, within cities, areas with less green space, often predominated by BIPOC or low-income communities, are likely to experience greater exposure to extreme heat, with higher rates of adverse outcomes. Increased and prolonged heat events also have economic impacts. Under baseline climate conditions, the United States could lose an average of approximately $100 billion annually from heat-induced lost labor productivity, which could double to nearly $200 billion by 2030 and reach $500 billion by 2050. This includes loss of agriculture due to lower labor productivity and lower crop yields. 

With 2023 breaking the record as the hottest year in recorded history, the United States must urgently reform its disaster assistance policies to incorporate extreme heat through an amendment to the Stafford Act and related post-disaster guidance. Currently, the majority of adaptation funding in the United States is tied to post-disaster recovery programs, meaning communities often do not have access to resources to plan ahead unless they have already suffered. Incorporating extreme heat would open new doors for heat mitigation and adaptation for affected communities through FEMA’s HMGP, as well as HUD’s CDBG-DR and CDBG-MIT. 

Plan of Action

Congress, FEMA, HUD, and the White House all have a role to play to optimize post-disaster funding and policies to address the growing challenges from excessively high temperature days and extended heat patterns.

Congress: Amendment to the Robert T. Stafford Act to Explicitly Identify Heat Events

A congressional amendment to the Stafford Act would ensure a heat event is considered an eligible event for a major disaster declaration, removing any doubt around its eligibility in perpetuity. Section 102 part (2) of the Stafford Act should be amended to: 

Any natural catastrophe (including any hurricane, tornado, storm, high water, wind-driven water, tidal wave, tsunami, earthquake, volcanic eruption, landslide, mudslide, snowstorm, drought, extreme heat or cold temperature, or extended heat or cold wave), or, regardless of cause, any fire, flood, or explosion, in any part of the United States, which in the determination of the President causes damage of sufficient severity and magnitude to warrant major disaster assistance under this Act to supplement the efforts and available resources of States, local governments, and disaster relief organizations in alleviating the damage, loss, hardship, or suffering caused thereby.

FEMA: Build Heat Adaptation Capacity through Heat Disaster Response and Planning

The HMGP is a critical resource for communities that have received a presidential disaster declaration to reduce future risk to lives and property from climate hazards. An amendment to the Stafford Act to address heat eligibility would enable state and tribal governments to request HMGP funding to support extreme heat response activities, such as cooling centers, air conditioners, utility vouchers, surge capacity support for hospitals, and direct interventions for vulnerable populations. Likewise, governments could request funding under HMGP for infrastructure upgrades, including increased tree canopy, green infrastructure, cool pavement, reflective roofs, retrofitting buildings with improved HVAC systems and materials that reflect solar energy to keep indoor temperatures cooler, and power grid enhancements. 

Within the HMGP, increased set-asides should be given to planning-related activities to build capacity among communities across America. Doubling funding for planning-related activities from 7% to 14% of the recipient’s HMGP funding would create greater opportunities for state, tribal, territorial, and local governments to conduct activities to strengthen their extreme heat preparedness and response, through eligible activities such as:

  1. Enhancing the current FEMA-approved mitigation plan by incorporating underserved and highly vulnerable populations in the planning process, risk assessment, and mitigation strategy, namely seniors, the unhoused, agriculture workers, and children.
  2. Integrating extreme heat adaptation information/targets from the hazard mitigation strategy into other pre- and post-disaster recovery plans, comprehensive planning, capital improvements, economic development, resource management, or other long-term community planning.
  3. Building capability through delivery of technical assistance and training, particularly through green infrastructure and cooling infrastructure workforce development, as well as community education on heat adaptation strategies to prevent physical and financial losses from future heat events. 
  4. Evaluating the adoption/implementation of codes and ordinances that reduce risk to extreme heat with a focus on improvements to building codes to improve heat resilience. 

Leveraging FEMA’s HMGP will bolster communities’ heat disaster response while shifting investments toward long-term disaster mitigation planning. Coupling FEMA’s HMGP funding for extreme heat planning with an expansion of FEMA’s Building Resilient Infrastructure and Communities (BRIC) would further enable communities to get ahead of the next disaster, before people suffer. FEMA made a total of $2.26 billion available through BRIC in 2022, and $1 billion in 2023. Meanwhile, the United States experienced 18 separate weather and climate disasters costing at least $1 billion in 2022 and 28 separate events in 2023. To meet the rising demands for proactive planning, FEMA must increase funding allocations for BRIC and prioritize projects that address multiple hazards. 

White House: Launch a Heat Adaptation Design Challenge under the America COMPETES Act 

Under the authority of the America COMPETES Act, the White House should launch a time-bound interdisciplinary planning and design challenge that brings together lived and professional expertise from local, national, and international participants to catalyze community-level long-term climate adaptation and land-use changes for communities in the United States. This model builds on the precedent set by the Rebuild by Design Hurricane Sandy Design Competition and the National Disaster Resilience Competition

In 2013, in response to the devastation wrought by Hurricane Sandy, President Obama’s Hurricane Sandy Recovery Task Force and HUD set a new precedent for disaster recovery by launching the Hurricane Sandy Rebuild by Design Competition. The competition, authorized under the America COMPETES Act, set aside almost $1 billion of CDBG-DR funds to launch a nine-month-long interdisciplinary planning and design challenge in the Sandy-impacted region. The competition resulted in seven winning designs, which now have over $4.3 billion invested in them. The Rebuild by Design competition raised the bar for government collaboration with communities in the development of adaptation solutions, demonstrated that innovative ideas attract more dollars, and cast the region center stage of global climate adaptation solutions, attracting local, regional, and international talent. The model was subsequently used in the National Disaster Resilience Competition and the Bay Area Resilient by Design Challenge. These processes have paved the way for reimagining communities to withstand and thrive among growing climate shocks and stressors, while raising the bar for education and collaboration with impacted communities.

To date, a design challenge process has not been used to the same scale to directly address extreme heat adaptation with the support of federal funding. An interdisciplinary design challenge poses a unique opportunity to mobilize planning and design across multiple aspects that contribute to heat mitigation and adaptation, including building and road materials, energy use and storage, land use, architecture, landscape architecture, and engineering while centering the voices of impacted communities. The process could incubate innovative designs like blue-green infrastructure, social infrastructure, and community planning, as well as innovative policies such as tenant protections, energy regulations, and working standards, thereby centering people over property in disaster recovery and propelling the United States to the forefront of the global discourse on adaptation.

A national challenge would create opportunities to incubate (1) exemplary models of comprehensive heat adaptation planning, (2) sector-specific models that agencies could use to guide new and existing grant programs, and (3) heat-adaptive technologies. 

  1. Few exemplary models of comprehensive extreme heat adaptation exist in the United States. Only a few governments – namely, Miami-Dade County, the city of Los Angeles, the city of Phoenix,  the state of Arizona, and the state of Maryland – have taken great strides to mitigate the loss of life and economic output from extreme heat events by appointing chief heat officers. As a result, when tasked with taking action to mitigate extreme heat, localities are drawing from a limited toolbox of solutions, often air conditioners and cooling centers. A design competition could spur new ideas for transforming a locality’s physical spaces, including housing, transportation, right of way, parks, and public amenities to reduce risk during extreme heat, address other climate hazards, and provide needed social benefits to communities. 
  2. Federal agencies play a key role in deploying funding to improve infrastructure across the United States. A national design challenge with a focus on heat adaptation could catalyze innovative sector-specific solutions that agencies could model in new and existing grant programs. For example, a design challenge that focuses on rethinking public right of way infrastructure to mitigate extreme heat would result in an array of outputs (research, designs, and projects) from which agencies could base new grant criteria. Similarly, this model could be used to specifically incubate ideas for housing, energy, transportation, and agriculture. 
  3. The America COMPETES Act improves the competitiveness of the United States through investments in research and technology. A national research and design competition, focused on generating new technologies for communities, households, and individuals to adapt to heat, could seed a new industry in the United States. As rising global temperatures increasingly impact communities around the world, these technologies could thrust the United States to the forefront of global heat adaptation solutions and create domestic jobs and exports. Moreover, these interventions could reduce suffering and save countless American lives.

HUD: Heat Adaptation Planning through CDBG-DR and CDBG-MIT Funds

HUD’s CDBG-DR and CDBG-MIT funds are critical to helping communities recover from an extreme climate event in a way that better prepares them for future events; however, they are not being fully utilized to address extreme heat. These funds are only available to communities that have received a major disaster declaration. The Rebuild by Design Hurricane Sandy Design Competition and the National Disaster Resilience Competition were made feasible through allocations of CDBG-DR funds by HUD to explicitly plan ahead for future impacts from climate change, as opposed to replacing what had previously existed. An amendment to the Stafford Act to create eligibility for heat disasters would allow for an extreme heat design challenge to be supported through an appropriation of HUD CDBG-DR or CDBG-MIT funds in response to a major disaster declaration. A federally funded design challenge would also attract local and international expertise, as well as local governments, as participants would know upfront that there is implementation funding. Furthermore, the funding criteria for all disaster declarations should require that applicants assess heat vulnerability using FEMA’s Risk Rating Index or localized data to prioritize multi-hazard solutions and ensure that all disaster recovery efforts are also incentivized to address heat mitigation. 

To further optimize HUD’s funding for disaster recovery and long-term planning, Congress must permanently authorize CDBG-DR. Currently, HUD allocations for CDBG-DR are slow to reach communities. Permanent authorization would remove delays and create greater predictability and certainty for communities to address the loss of life brought on by heat waves. 


In order to address the growing challenges from extreme heat, the U.S. must dramatically shift investments from reactive disaster recovery to proactive disaster risk reduction. In the interim, making this shift will require striking down the barriers to accessing post-disaster funding for communities that need support to respond to and prepare for extreme heat by amending the Stafford Act. A national design competition, funded through post-disaster assistance, could be the mechanism to catalyze this paradigm shift by seeding innovative and exemplary heat adaptation solutions that could be modeled throughout the country. Leadership from Congress, the White House, FEMA, and HUD would ensure communities are able to respond to the impacts of today, and spur innovation and preparation for the impacts of tomorrow.

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.

A National Framework for Sustainable Urban Forestry to Combat Extreme Heat

Extreme heat events are increasing in frequency and intensity every year, leading to devastating human costs such as hospitalization and death. In urban environments, where over 80% of Americans live, these effects are exacerbated by the urban heat island effect. In alignment with the White House’s nature-based solutions efforts to address the effects of climate change, the role of greening has been touted as a life-saving means to protect urban residents from extreme heat, mitigate stormwater, and reduce air pollution. Nonetheless, the benefits of urban forestry have not yet been realized due to unsustainable funding at municipal levels for maintenance and stewardship, limited coordination across branches of government, inequitable distribution of trees, and a lack of analyses that define the economic value of urban forestry. A coordinated, equity-focused, and economically validated federal plan to guide the development and maintenance of urban forestry will allow the full utilization of this critical resource. Achieving this goal requires action at all levels of government; sustainable funding to grow, develop, research, and sustain urban forests; and ongoing leadership from the scientific and forestry communities.

The incoming administration should undertake a multi-agency effort to further develop the science and quantify the benefits of urban forests today and into the future. This will equip urban foresters and their municipal partners with the necessary decision support tools to plant, grow, and maintain urban forests in cities across the United States. Doing this will ensure current forestry investments created by the Inflation Reduction Act (IRA) and Bipartisan Infrastructure Law (BIL) continue to reap maximum benefits into the future. By using environmental economic principles in national accounts and leveraging the Office of Management and Budget’s (OMB) new Ecosystems Services Guidance to capture the true value of urban forests and their ecosystem services to the U.S., the federal government will provide the economic basis for further strategic planning of urban forestry. Additionally, applying the principles of environmental justice ensures decisions will support efforts to overcome the histories of redlining that prevented the expansion of urban forests into disadvantaged neighborhoods. Undertaking these efforts can lead to the realization of the potential benefits of urban forests, estimated conservatively to be over $17 billion annually

Challenge and Opportunity

Every year, extreme heat events are increasingly threatening to human health. Recent summers have seen rises in heat-related hospitalizations. In 2023, heat-related hospitalizations increased by 51% compared to 2018. However, federal, state, and local governments are limited in their approaches to addressing extreme heat’s effect on human health and well-being. Public health approaches to tackling this growing problem include the development of coordinated messaging between public health, health systems, and community members to warn of impending extreme events, cooling centers, and the distribution of air conditioner units. Unfortunately, these prevention strategies are often reactive and unsustainable in the long term. They rely on forecasting of extreme heat events to initiate alerts or to establish cooling centers and increase demand for air conditioning, which drives up energy costs and greenhouse gas emissions.

An alternate, longer-term, and more effective strategy is to use trees as a form of natural infrastructure, particularly where the urban heat island effect takes place (i.e., the sustained increased temperatures during the day and night due to heat retention from the built environment). Trees can reduce air temperatures by up to 10ºF, and surface temperatures up to 25ºF. Urban forestry impacts over 80% of Americans, where the urban heat island effect is most pronounced. Although not accounted for in today’s macroeconomic evaluations of gross domestic product, the U.S. Department of Agriculture (USDA) Forest Service estimates that urban forestry currently provides over $17 billion in ecosystem service benefits annually through improvements in air quality, stormwater management, improved physical and mental health, and increased property values. Moreover, urban forestry is cost-effective: for every $1 spent on urban tree management, benefits are estimated to be valued at $1.37 to $3.09. Urban forests, when strategically planted or naturally regenerated and maintained, also have the potential to be a long-term, sustainable, nature-based solution to the rising threat of extreme heat on human health.

The USDA US Forest Service is rapidly expanding tree inventories across the nation, informed by the Ten-Year Urban Forestry Action Plan created by the National Urban and Community Forestry Advisory Council (NUCFAC). Funds for urban forestry have recently been appropriated through the IRA and BIL, which allocated over $1 billion over the next five years to urban forestry. Strategically channeling these funds through federal oversight and technical assistance to address the rising threat of extreme heat will provide the best opportunity to maximize the use of these funds and demonstrate the outcomes of sustaining federal investment at that scale. 

Therefore, to reduce extreme heat in urban areas where most Americans live, a comprehensive urban forestry strategy is essential. This strategy should provide ongoing support within and across cities, and link the science of tree selection, climate-resilient seed propagation, planting, and maintenance with efforts to overcome disparities in urban greening infrastructure. Further, there is an ongoing need to develop the urban forestry workforce and capacity necessary to sustain these investments and ensure their benefits come to fruition. Finally, ongoing research and analysis is needed (anticipated at $50 million annually by NUCFAC) to inform urban and community forestry policy and increase the effectiveness and benefits of greening interventions.

Plan of Action

Creating a strategic plan for urban forestry management to combat extreme heat requires equity-centered coordination across various federal agencies, given the clear disparities in urban greening infrastructure within and across U.S. cities. The strategy must also further the development of research to maximize ecosystem services, incorporating the costs of urban forests over extended periods. 

Thus, the federal plan of action must be guided by the following principles:

  1. Placing environmental justice and equitable urban greening practices at the forefront of a strategic plan.
  2. Employing natural capital cost assessments — a key endeavor of the Biden Administration to include environmental-economic appraisal of nature-based solutions — in the development of the potential of public-private partnerships (e.g., US Forest Service Public-Private Partnership Strategy).
  3. Specifying cross-agency collaboration to directly quantify the benefits from a diverse range of perspectives. For example, direct healthcare benefits from urban forestry require long-term and causal research on the quantity, distribution, and duration to account for such benefits from an environmental-economic perspective.

Coordinate the Executive Branch. A federal interagency task force consisting of urban forestry experts, healthcare authorities, economic stewards, and heat science specialists should lead the effort to create a national urban forestry strategic plan. This taskforce should be co-led by OMB and the Council on Environmental Quality (CEQ) and should include the following agencies: the USDA Forest Service, Department of the Interior (DOI), Centers for Disease Control and Prevention (CDC), National Institutes of Health (NIH), Department of Commerce Bureau of Economic Analysis, Housing and Urban Development (HUD), Department of Transportation (DOT), the National Oceanic and Atmospheric Agency (NOAA), and other agencies as relevant. The following courses of action should be taken:

Strengthen the Evidence Base. Empirical data to inform natural capital assessments and the beneficial and detrimental effects on heat mitigation and stormwater mitigation will be required to better analyze and build policies. Areas in need of development include: human health benefits and healthcare return on investment; climate and resilience, especially around forest vulnerabilities; and environmental justice, including lowering the burden of ongoing maintenance on communities. Through the NIH, CDC, National Science Foundation (NSF), Department of Energy (DOE), Environmental Protection Agency (EPA), USDA, NOAA, and National Aeronautics and Space Administration (NASA), funding should be allocated to:


Extreme heat events are rising in intensity, frequency, and severity, particularly within cities. Existing measures to protect residents against the scourge of these events are limited while they need to be equity-focused, sustainable, and address the rising threat of climate change now and into the long term. The influx of investment in urban forestry from the IRA and BIL has provided the necessary foundation for the benefits of urban forestry as a source of nature-based solutions to combat extreme heat.

A federal strategic plan for urban forestry management to combat extreme heat is necessary to fully capture the benefits of this investment. By employing natural capital assessments, directing cross-agency collaboration, and building the necessary scientific evidence, urban forestry can serve as key infrastructure to create climate resilient communities across the United States.

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.

Frequently Asked Questions
How does this proposal fit into the existing national urban forestry frameworks?

This proposal builds on the existing national Ten-Year Urban Forestry Action Plan as outlined by the National Urban and Community Forestry Advisory Council. Specifically, this proposal seeks to utilize the specific cooling effects of trees as a key ecosystem service to offset the already known risks of heat in urbanized locations.

Why not just use existing national urban forestry bodies such as the US Forest Service Urban and Community Forestry Program (UCF) and National Urban and Community Forestry Advisory Council (NUCFAC) to undertake this work?

UCF and NUCFAC are well-equipped to understand and implement the nuances of planting, maintaining, and stewarding urban forests. However, the specific health benefits of trees, the calculation of the economic benefits through natural capital assessments, and their ongoing maintenance through municipal bodies and communities require expertise and reach from a greater range of agencies. NUCFAC in particular is an advisory committee, authorized under the Federal Advisory Committee Act, and receives only a small annual budget.

For example, the impact of urban trees on the risks of heat-related mortality, hospitalization, or emergency room presentation is currently unclear. Such questions require input from health authorities combined with expertise from climatologists who can predict the effect of trees today and in the future as young trees grow, mature, and provide the greatest protection against heat through canopy coverage and evapotranspiration.

Why should this body be federally administered?

Federal administration is necessary because substantial parts of urban forests are managed on public lands, including natural areas (e.g., parks) and street trees that grow alongside thoroughfares.

Furthermore, diversity of urban forest management is necessary. The nativity and biodiversity of urban forests in the U.S. is important for preventing the spread of disease and invasive species. Managing urban forests across the different parts of the United States requires federal oversight to ensure that financial, tree planting (e.g., sapling nurseries), and tree maintenance (e.g., early tree age stewardship) resources are directed to areas of the greatest need where the effects of extreme heat are particularly threatening.

Do non-forestry agencies, such as NIH and HHS, have justifications or authorizations to research urban tree canopy impact?
Currently, the NIH and NSF lack authorization and dedicated funds to focus on urban forestry and its association with health-related benefits. These linkages between the built, natural environment and human health have been limited in terms of NIH funding—despite the need and potential benefit across over 50% of the American population who reside in urban centers.

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

The federal government needs to maximize existing funds to mitigate heat stress and ensure the equitable distribution of these resources to the most vulnerable households. Agencies could increase Low Income Home Energy Assistance Program (LIHEAP) funding allocations through incentives or by mandating a floor of benefits from these programs be distributed to a well-defined set of vulnerable households. This approach is similar to Justice40, the Biden administration’s signature environmental justice initiative that requires federal agencies to ensure a minimum allocation of 40% of program benefits are received by disadvantaged communities.

Challenge and Opportunity 

In addition LIHEAP, which is administered by the Department of Health and Human Services (HHS), Justice40 covered programs with high potential to mitigate heat stress include: 

LIHEAP and these five priority programs have combined allocations of about $30 billion in 2024 alone. Allocating even 10% of this collective budget to the most vulnerable communities and households could significantly reduce heat mortality and morbidity.

Since its inception in 1974, LIHEAP has provided more than $100 billion in direct bill payment assistance, more than double the allocation of seven other low-income energy programs combined. LIHEAP provides a formula block grant to all states and territories and more than 150 tribes. The FY24 LIHEAP allocation is $3.6 billion; state allocations vary depending on overall and low-income population and climate.

LIHEAP is disbursed by the HHS Administration for Children and Families (ACF) to state-level HHS counterparts. These in turn distribute funding to subgrantees, including local HHS offices, national NGOs, and community-based organizations. Furthermore, there is often coordination between state and local LIHEAP administrators and utilities, which provide additional low-income energy efficiency, solar and storage programs, and rate discounts. 
HHS understands the impetus for LIHEAP to reduce heat stress. For instance, in 2021, HHS published a “Heat Stress Flexibilities and Resources” memo, which outlined the disproportionate impacts of future heat conditions on communities of color and recommended using a portion of the state allocation for cooling assistance, providing or loaning air conditioners, targeting vulnerable households, and a range of public educational activities. In 2016, the agency designated a national Extreme Heat Week on how LIHEAP can be a part of the solution.

LIHEAP Formula Funding Favors Heating Assistance

However, LIHEAP funds have not been sufficiently used for cooling assistance. Nationally, from 2001 to 2019, just 5% of all LIHEAP funds were used for cooling assistance, with heating receiving ten times more funding than cooling. Even among states in the Southeast, just 14% of the budget was for cooling assistance. In 2019, only 21 states opted to provide cooling assistance, compared to the 49 that allocated funding to weatherization and 26 that used LIHEAP for energy education and supplemental energy efficiency programs. 

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.

Prior efforts to encourage the use of LIHEAP for cooling have not resulted in a sufficient shift of this landmark funding source. LIHEAP was originally developed to provide home heating assistance at a time when winters were more severe and summers less searing. State LIHEAP administrators used the vast majority of their budgets during the heating season; many viewed cooling assistance as a luxury. This is despite the extreme heat events of recent summers, including temperatures topping 115ºF in the Pacific Northwest in 2019 and 31 days in a row of highs above 110ºF in Phoenix in 2023. 

With many households still struggling to pay their winter bills, LIHEAP administrators may be reluctant to shift allocations from heating assistance that already cannot serve even 50% of eligible households. States that do not set aside dedicated cooling assistance funds frequently run out of LIHEAP, which they receive in October, well before summer. Even if crisis funds could theoretically be used to support families in crisis during heat waves, these funds are exhausted by high crisis demand in winter.

The majority of LIHEAP allocations are based on a formula rooted in a state’s low-income population, energy costs, and the severity of a state’s winter climate (its heating degree days). Residential energy costs may account for the number of cooling degree days, but they do not account for variation in electricity prices and have no consideration of population sensitivity (e.g., age) or adaptive capacity measures that are included in many Heat Vulnerability Indices (HVIs).

LIHEAP’s website on extreme heat points to the 2021 “heat dome” in the Pacific Northwest, which saw daily hospitalizations 69 times higher than the same week in 2020. In Washington state alone, 441 people died. The event, previously thought to be a 1 in 1,000-year occurrence, could occur every 5 to 10 years with just 2℃ of global warming (2023 was 1.35℃ warmer than the preindustrial average). 

With advanced forecasts, LIHEAP could be deployed both to restore disconnected electric service and to make payments on extreme energy bills, which may surge even higher with the increase in demand response pricing. In Michigan, for example, DTE Energy offers a dynamic peak pricing rate that has critical peak periods at $1.03 per kWh, eight times higher than its off-peak rate. Maximum demand for electricity for continuous cooling coupled with time-of-use rate structures is a recipe for exorbitant bills that low-income customers will not be able to afford.

The risk to vulnerable households from the absence of cooling assistance is compounded by a lack of disconnection protections from extreme heat. Forty-one states offer protections for cooling, compared to just 20 that prevent utilities from disconnecting households during extreme heat. Heat protections often only kick in when a specific temperature is reached (e.g., 95°F) or even when a particular alert is issued by the National Weather Service, leaving households uncertain about their status.

In the bi-weekly Pulse Survey of the U.S. Census (June 28 to July 10, 2023, the most recent period of extreme heat nationally), 58.5% of national respondents reported keeping their home at an uncomfortable or unsafe temperature at least some months in the last year, with 18.7% reporting these indoor temperatures almost every month. Households that spend more of their income on energy bills allow indoor temperatures to rise up to 7.5°F more than higher-income households before using air-conditioning, thus dramatically increasing their risk of heat stress.

Plan of Action

Recommendation 1. Maximize LIHEAP funding for cooling assistance

Congressional mandate – Congress could require states to use a specific percentage of their LIHEAP allocations for cooling. This percentage could be derived from FEMA’s National Risk Index (NRI), which accounts for exposure to extreme heat, the vulnerability of the population, and adaptive capacity, such as civic resources to provide emergency response. Heat Factor by First Street and Community Resilience Estimates for Heat by U.S. Census offer more granular estimates of heat vulnerability.

Incentives – LIHEAP regularly receives supplemental federal allocations (e.g. CARES Act); HHS could use these as a pool of matching funds to encourage states to leverage non-federal dollars for cooling assistance. States also have an important role to play in leveraging both public and utility funds to match and expand the impact of LIHEAP.

Emergency funds – HHS should release Emergency Contingency Funds to address extreme heat. In the 1990s and 2000s, these funds were regularly used, sometimes in excess of $700 million per year to direct cooling assistance to extreme heat events; these funds could also be used to provide cooling measures like fans, air conditioners, and insulation. These funds have been authorized but not allocated by Congress and not disbursed since 2011.

Report back to state LIHEAP administrators – Peer comparisons can be a powerful source of information and motivation. A study from the 1990s “targeting index” for the share of LIHEAP delivered to the elderly revealed stark differences between Arizona, where the elderly were underrepresented, and Texas, where they were represented above their proportion of the population. An annual dashboard of how a state compares to its close peers (e.g., to other states in its EPA region) in cooling allocations is a low-effort step that could result in significant shifts in state plans and community outreach. 

Expand outreach and education to state LIHEAP administrators and subgrantees – Memos from 2016 and 2021 were insufficient to encourage many state and local budget shifts. Communications should emphasize the significantly greater risk of fatalities from extreme heat than extreme cold. One study simulated indoor temperatures in Phoenix during the 2006 heat wave and showed that by day two, temperatures in single-story homes would peak at 115ºF (46ºC). Another study projected that a five-day heat wave on the order of the record July 2023 temperatures that corresponds with a blackout would result in a fatality rate of ~1% in Phoenix, or about 1,500 deaths.

Recommendation 2. Maximize LIHEAP distribution to the most vulnerable households

While LIHEAP providers do collect significant household data through their intake forms, 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 (raw or percentile). A list of 10 potential sensitivity factors to assess is included in the Frequently Asked Questions.

In partnership with extreme heat experts, US Digital Service could support the development of an algorithm to assess the likelihood of each household experiencing acute heat stress and the optimal uses of LIHEAP funding to mitigate these threats, at the household level and portfolio-wide.

Existing data from the Community Resilience Estimates for Heat (CRE) by the U.S. Census shows that more than two-thirds of extreme heat vulnerability is concentrated in just 1.5% of U.S. census tracts across 10 states. Even a small amount of LIHEAP cooling assistance, if effectively targeted, could dramatically reduce the risk of heat stroke and death.

States with highest concentration of vulnerable census tracts to extreme heat.
RankStateNo. of census tracts where 50% population has 3+ heat vulnerability factors% of all vulnerable tracts in the U.S.

Recommendation 3. Congressional Amendments to the LIHEAP Statute

Congress has revisited the LIHEAP formula in the past and should consider revising the formulas to elevate the role of cooling assistance and disconnection prevention during extreme heat. Rep. Watson Coleman (D-NJ) proposed this in the Stay Cool Act introduced in 2022. As the climate has changed dramatically since LIHEAP’s inception and will continue to in coming decades, Congress could peg an updated formula to an HVI as a national standard to ensure shifts in climate and population would be automatically updated in the annual LIHEAP formula. It could also update household data collection requirements under LIHEAP Statute Section 2605(c)(1)(G).


The number of heat-related deaths continues to rise in the U.S. In the long term, a multipronged strategy that increases funding for energy efficiency improvements, distributed generation and storage, and bill assistance is needed. But in the near term, it is critically important to work with existing resources and maximize the value of LIHEAP to mitigate the pressures of extreme heat. 

Despite some positive spikes, annual LIHEAP allocations have not kept pace with accelerating demand. The number of households eligible for LIHEAP has grown four times faster than available funding; the number of eligible households served has declined from 36% to 16%. As utility bills outpace inflation, per-household LIHEAP allocations have increased without a corresponding increase in the overall allocation.

States have broad discretion on how to use LIHEAP. Overcoming the inertia of budgets dominated by heating assistance is likely to require significant advocacy, both top-down from the federal government and bottom-up from grassroots community organizations that share concerns about vulnerability to extreme heat. 

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.

Frequently Asked Questions
Where can I find more information about LIHEAP state plans?

States have a process that requires releasing a draft LIHEAP plan each fiscal year for public review and comment. All state LIHEAP managers can be found here; state and territory plans and policy manuals can be accessed here.

If states shift funds from heating assistance to cooling assistance, won’t that leave a gap in winter assistance funding?
The demand for energy assistance far exceeds annual LIHEAP funding. LIHEAP can be used strategically to plug gaps and avert crises, which are increasingly occurring during the summer, when extreme heat poses a significantly greater risk of death than extreme cold. Looking at the energy safety net comprehensively, it is clear that much more funding is needed, and more funds are needed for substantial home energy retrofits so that homes stay cooler, require less energy, and can withstand periods without electricity from outages, climate events, or disconnections. State agencies must everything in their power to maximize the size of the safety net and continue to focus on structural housing improvements that ensure lasting safety and affordability for the most vulnerable. In the interim, the risk of extreme heat is too great not to act, even at the expense of reducing heating assistance in the short term.
How would an algorithm to prioritize assistance to the most vulnerable households be designed?
An automated program could report on the heat stress of all LIHEAP applicants before and after receiving assistance; progress would be measured by the reduction in households experiencing heat stress. For instance, the algorithm might determine heat risk for households at the 95th percentile and above could be mitigated by applying Assurance 16 funds (up to 10% of total LIHEAP allocation) for the installation of air-source heat pumps in homes that lack air-conditioning. As LIHEAP currently uses reduction in energy burdens and disconnections in its performance reporting, reductions in heat risk would complement these performance objectives.
How would household heat scores be treated?

The process to develop household heat risk assessments and performance reporting could entail:

1) Design a method for assigning household scores for heat risk. Scores might consider risk of mortality, risk of heat sickness requiring medical attention/hospitalization, and risk of chronic impacts (e.g., declines in cognition and sleep quality) from consistent, low to moderate exposure to excessive heat.

Current data: LIHEAP reporting by each state’s lead agency currently includes some data that can be used to analyze prioritization of funds to mitigate extreme heat risks:

  • Cooling assistance (dollars; number of households served)

  • Weatherization (funded through LIHEAP)

  • Assistance distributed to households with a vulnerable person (under age 5, over age 60, or a person with a disability)

  • Demographic variables (e.g. race and ethnicity)

  • Housing variables, namely occupancy status and for renters, whether utility bills are included in rent

  • Disconnections 

Proposed data collection:

  • Keeping house at an unsafe temperature Medical conditions associated with heat stress (e.g., diabetes)

  • Prior experience of heat stress

  • Additional age distinctions (children under 2, adults over 70, over 80, over 90)

  • Presence and adequacy of cooling systems Housing age and type (e.g., masonry, duplex)

  • Electricity cost Solar exposure (provided by Google’s Project Sunroof)

  • Urban heat island effect

  • Employment

  • Personal behaviors 

2) Design a process so that existing program resources are distributed among the most vulnerable households, as determined by their individual heat risk scores. LIHEAP administrators might decide to spend 25% of cooling assistance funds among the most vulnerable 10% of LIHEAP applicants, for instance.

Are there existing measures of sensitivity that state administrators could immediately adopt to prioritize the most vulnerable households?

Yes, the Community Resilience Estimates for Heat (CRE) uses American Community Survey Data to determine the number of vulnerability factors a household possesses, down to census tract resolution. The tool sorts census tracts based on the number of households with zero vulnerabilities, 1–2 vulnerabilities, and 3 or more vulnerabilities. Of 73,060 census tracts, just 1,616 (2.2%) have a majority of households with more than three heat vulnerabilities. The Community Resilience Estimates (CRE) for Heat offers 10 binary risk factors.

Enhancing Public Health Preparedness for Climate Change-Related Health Impacts

The escalating frequency and intensity of extreme heat events, exacerbated by climate change, pose a significant and growing threat to public health. This problem is further compounded by the lack of standardized education and preparedness measures within the healthcare system, creating a critical gap in addressing the health impacts of extreme heat. The Department of Health and Human Services (HHS), especially the Centers for Medicare & Medicaid Services (CMS), the Health Resources and Services Administration (HRSA), and the Office of Climate Change and Health Equity (OCCHE) can enhance public health preparedness for the health impacts of climate change. By leveraging funding mechanisms, incentives, and requirements, HHS can strengthen health system preparedness, improve health provider knowledge, and optimize emergency response capabilities. 

By focusing on interagency collaboration and medical education enhancement, strategic measures within HHS, the healthcare system can strengthen its resilience against the health impacts of extreme heat events. This will not only improve coding accuracy, but also enhance healthcare provider knowledge, streamline emergency response efforts, and ultimately mitigate the health disparities arising from climate change-induced extreme heat events. Key recommendations include: establishing dedicated grant programs and incentivizing climate-competent healthcare providers; integrating climate-resilience metrics into quality measurement programs; leveraging the Health Information Technology for Economic and Clinical Health (HITECH) Act to enhance ICD-10 coding education; and collaborating with other federal agencies such as the Department of Veterans Affairs (VA), the Federal Emergency Management Agency (FEMA), and the Department of Defense (DoD) to ensure a coordinated response. The implementation of these recommendations will not only address the evolving health impacts of climate change but also promote a more resilient and prepared healthcare system for the future.


The escalating frequency and intensity of extreme heat events, exacerbated by climate change, pose a significant and growing threat to public health. The scientific consensus, as documented by reports from the Intergovernmental Panel on Climate Change (IPCC) and the National Climate Assessment, reveals that vulnerable populations, such as children, pregnant people, the elderly, and marginalized communities including people of color and Indigenous populations, experience disproportionately higher rates of heat-related illnesses and mortality. The Lancet Countdown’s 2023 U.S. Brief underscores the escalating threat of fossil fuel pollution and climate change to health, highlighting an 88% increase in heat-related mortality among older adults and calling for urgent, equitable climate action to mitigate this public health crisis.

Inadequacies in Current Healthcare System Response

Reports from healthcare institutions and public health agencies highlight how current coding practices contribute to the under-recognition of heat-related health impacts in vulnerable populations, exacerbating existing health disparities. The current inadequacies in ICD-10 coding for extreme heat-related health cases hinder effective healthcare delivery, compromise data accuracy, and impede the development of targeted response strategies. Challenges in coding accuracy are evident in existing studies and reports, emphasizing the difficulties healthcare providers face in accurately documenting extreme heat-related health cases. An analysis of emergency room visits during heat waves further indicates a gap in recognition and coding, pointing to the need for improved medical education and coding practices. Audits of healthcare coding practices reveal inconsistencies and inaccuracies that stem from a lack of standardized medical education and preparedness measures, ultimately leading to underreporting and misclassification of extreme heat cases. Comparative analyses of health data from regions with robust coding practices and those without highlight the disparities in data accuracy, emphasizing the urgent need for standardized coding protocols.

There is a crucial opportunity to enhance public health preparedness by addressing the challenges associated with accurate ICD-10 coding in extreme heat-related health cases. Reports from government agencies and economic research institutions underscore the economic toll of extreme heat events on healthcare systems, including increased healthcare costs, emergency room visits, and lost productivity due to heat-related illnesses. Data from social vulnerability indices and community-level assessments emphasize the disproportionate impact of extreme heat on socially vulnerable populations, highlighting the urgent need for targeted policies to address health disparities.


As Medicare is the largest federal source of Graduate Medical Education (GME) funding (Figure 1), the Department of Health and Human Services’ (HHS) Centers for Medicare & Medicaid Services (CMS) and the National Center for Health Statistics (NCHS) play a critical role in developing coding guidelines. Thus, it is essential for HHS, CMS, and other pertinent coordinating agencies to be involved in the process for developing climate change-informed graduate medical curricula.

By focusing on medical education enhancement, strategic measures within HHS, and fostering interagency collaboration, the healthcare system can strengthen its resilience against the health impacts of extreme heat events. Improving coding accuracy, enhancing healthcare provider knowledge, streamlining emergency response efforts, and mitigating health disparities related to extreme heat events will ultimately strengthen the healthcare system and foster more effective, inclusive, and equitable climate and health policies. Improving the knowledge and training of healthcare providers empowers them to respond more effectively to extreme heat-related health cases. This immediate response capability contributes to the overarching goal of reducing morbidity and mortality rates associated with extreme heat events and creates a public health system that is more resilient and prepared for emerging challenges. 

The inclusion of ICD-10 coding education into graduate medical education funded by CMS aligns with the precedent set by the Pandemic and All Hazards Preparedness Act (PAHPA), emphasizing the importance of preparedness and response to public health emergencies. Similarly, drawing inspiration from the Health Information Technology for Economic and Clinical Health Act (HITECH Act), which promotes the adoption of electronic health records (EHR) systems, presents an opportunity to modernize medical education and ensure the seamless integration of climate-related health considerations. This collaborative and forward-thinking approach recognizes the interconnectedness of health and climate, offering a model that can be applied to various health challenges. Integrating mandates from PAHPA and the HITECH Act serves as a policy precedent, guiding the healthcare system toward a more adaptive and proactive stance in addressing climate change impacts on health.

Conversely, the consequences of inaction on the health impacts of extreme heat extend beyond immediate health concerns. They permeate through the fabric of society, widening health disparities, compromising the accuracy of health data, and undermining emergency response preparedness. Addressing these challenges requires a proactive and comprehensive approach to ensure the well-being of communities, especially those most vulnerable to the effects of extreme heat.

Plan of Action

The following recommendations aim to facilitate public health preparedness for extreme heat events through enhancements in medical education, strategic measures within the Department of Health and Human Services (HHS), and fostering interagency collaboration.

Recommendation 1a. Integrate extreme heat training into the GME curriculum. 

Integrating modules on extreme heat-related health impacts and accurate ICD-10 coding into medical education curricula is essential for preparing future healthcare professionals to address the challenges posed by climate change. This initiative will ensure that medical students receive comprehensive training on identifying, treating, and documenting extreme heat-related health cases. Sec. 304. Core Education and Training of the PAHPA provides policy precedent to develop foundational health and medical response curricula and training materials by modifying relevant existing programs to enhance responses to public health emergencies. Given the prominence of Medicare in funding medical residency training, policies that alter Medicare GME can affect the future physician supply and can be used to address identified healthcare workforce priorities related to extreme heat (Figure 2).

Figure 2: A model for comprehensive climate and medical education (adapted from Jowell et al. 2023)

Recommendation 1b. Collaborate with Veterans Health Administration Training Programs. 

Partnering with the Department of Veterans Affairs (VA) to extend climate-related health coding education to Veterans Health Administration (VHA) training programs will enhance the preparedness of healthcare professionals within the VHA system to manage and document extreme heat-related health cases among veteran populations.

Implementation plan
Agency/Department InvolvementAction StepsEvaluation
HHS; CMS, NCHS, Health Resources and Services Administration (HRSA), Office of Climate Change and Health Equity (OCCHE): Coordinates efforts to integrate extreme heat training into medical education.Needs Assessment: OCCHE within HHS collaborates with VA to assess climate-related health coding education needs within VHA and GME training programs.Curriculum Integration: Assess the extent to which modules on extreme heat-related health impacts and ICD-10 coding are integrated into medical school curricula.
VA: Implements climate-related health coding education initiatives within VHA.Curriculum Development: OCCHE, CMS, NCHS, HRSA collaborate with medical accrediting bodies and subject matter experts to develop modules on extreme heat health impacts and ICD-10 coding for inclusion in medical education curricula.Student Performance: Evaluate medical students’ performance on assessments related to extreme heat-related health impacts and coding practices.
VHA: Participates in training programs and integrates education into its curriculum.Accreditation Standards Integration: Accrediting bodies revise accreditation standards to include requirements for teaching extreme heat-related health topics and coding practices. Work with CMS to update Conditions of Participation to include climate mitigation and resilience. Training Participation: Monitor the number of healthcare professionals, including those in the VHA, participating in climate-related health coding education and assess their level of engagement.
The Joint Commission (TJC); Healthcare Facilities Accreditation Program (HFAP): Accrediting bodies responsible for setting standards for climate competent healthcare facility accreditation.Faculty Training: HHS supports faculty training programs to ensure educators have the necessary knowledge and skills to teach extreme heat topics effectively. VHA incorporates climate-related health coding education into existing training programs for healthcare professionals, including physicians, nurses, and other staff.Faculty Feedback:
Solicit feedback on the effectiveness of training and support provided for delivering the new curriculum.
Environmental Protection Agency (EPA), National Oceanic and Atmospheric Administration (NOAA), Department of Homeland Security (FEMA), Assistant Secretary for Preparedness and Response (ASPR): Provide subject matter expertise on extreme heat and support curriculum development.Funding: Titles VII and VIII of the Public Health Service Act (PHSA) provide funding for programs to improve the healthcare workforce and support public health initiatives.Impact on Patient Care: Assess the impact of enhanced climate-related health coding education on patient care outcomes within participating hospitals and within the VHA system.
Title VII: Health Professions Education Programs can be used to support medical education programs focused on climate-related health impacts, including curriculum development, faculty training, and student scholarships or stipends.
Title VIII: Nursing Workforce Development Programs can support the integration of climate-related health content into nursing education programs, including undergraduate, graduate, and continuing education initiatives.
Evaluation and Feedback: Continuous evaluation of curriculum integration and feedback mechanisms are established to assess the effectiveness of training and make improvements as needed. Research funding provided through PHSA Titles VII and VIII can support studies evaluating the effectiveness of educational interventions on climate-related health knowledge and practice behaviors among healthcare providers.

Recommendation 2. Collaborate with the Agency for Healthcare Research and Quality (AHRQ) 

Establishing a collaborative research initiative with the Agency for Healthcare Research and Quality (AHRQ) will facilitate the in-depth exploration of accurate ICD-10 coding for extreme heat-related health cases. This should be accomplished through the following measures:

Establish joint task forces. CMS, NCHS, and AHRQ should establish joint research initiatives focused on improving ICD-10 coding accuracy for extreme heat-related health cases. This collaboration will involve identifying key research areas, allocating resources, and coordinating research activities. Personnel from each agency, including subject matter experts and researchers from the EPA, NOAA, and FEMA, will work together to conduct studies, analyze data, and publish findings. By conducting systematic reviews, developing standardized coding algorithms, and disseminating findings through AHRQ’s established communication channels, this initiative will improve coding practices and enhance healthcare system preparedness for extreme heat events.

Develop standardized coding algorithms. AHRQ, in collaboration with CMS and NCHS, will lead efforts to develop standardized coding algorithms for extreme heat-related health outcomes. This involves reviewing existing coding practices, identifying gaps and inconsistencies, and developing standardized algorithms to ensure consistent and accurate coding across healthcare settings. AHRQ researchers and coding experts will work closely with personnel from CMS and NCHS to draft, validate, and disseminate these algorithms.

Integrate into Continuous Quality Improvement (CQI) programs. Establish collaborative partnerships between the VA and other federal healthcare agencies, including CMS, HRSA, and DoD, to integrate education on ICD-10 coding for extreme heat-related health outcomes into CQI programs. Regularly assess the effectiveness of training initiatives and adjust based on feedback from healthcare providers. For example, CMS currently requires physicians to screen for the social determinants of health and could include level of climate and/or heat risk within that screening assessment.

Allocate resources. Each agency will allocate financial resources, staff time, and technical expertise to support collaborative activities. Budget allocations will be based on the scope and scale of specific initiatives, with funds earmarked for research, training, data sharing, and evaluation efforts. Additionally, research funding provided through PHSA Titles VII and VIII can support studies evaluating the effectiveness of educational interventions on climate-related health knowledge and practice behaviors among healthcare providers.

Recommendation 3. Leverage the HITECH Act and EHR.

Agency/Department InvolvementAction StepsEvaluation
HHS: Coordinates efforts to integrate climate-related health coding education into HITECH Act programs.Integrate ICD-10 Coding Training in EHR Adoption Programs: HHS, NCHS and CMS coordinate with ONC to include specific modules or training components related to ICD-10 coding for extreme heat-related health outcomes within the educational programs facilitated under HITECH Act incentives. This ensures that healthcare professionals adopting EHR systems receive comprehensive training on coding practices relevant to climate-related health challenges.Integration Success: HHS regularly evaluates the extent to which ICD-10 coding education and climate-related health data collection are integrated into CMS-funded GME programs and EHR systems.
CMS: Implements incentives and requirements for EHR integration and coding education.Customize EHR Templates: ONC provides guidance to EHR vendors and developers to create customized templates or modules within EHR systems that facilitate accurate documentation of extreme heat-related health cases.Coding Accuracy: Assess the accuracy of ICD-10 coding for extreme heat-related health outcomes in electronic health records and reporting systems.
Office of the National Coordinator for Health Information Technology (ONC): Provides technical assistance and guidance on EHR integration.Incorporation into Meaningful Use Criteria: CMS and ONS to oversee the integration of the accurate coding of climate-related health outcomes into the Meaningful Use/Promoting Interoperability Programs criteria outlined by the HITECH Act.Provider Feedback: Solicit feedback from healthcare providers on the effectiveness of training modules and EHR integration efforts.
Establish Reporting Requirements: Use the HITECH Act to establish reporting requirements for climate-related health data, encouraging the inclusion of ICD-10 codes for extreme heat-related health outcomes in electronic reporting systems supported by EHRs.
Incentives for Climate-Ready EHR Implementation:
Expanding incentives within the HITECH Act to healthcare providers integrating climate-related health coding into HER systems could enhance healthcare management. The 2009 program allocated $27 billion to promote EHR adoption. Aligning incentives with climate-related coding fosters a more comprehensive approach. This incentivizes EHR and climate-related ICD-10 coding practices, advancing the capacity to address climate-related health challenges.

Recommendation 4. Establish climate-resilient health system grants to incentivize state-level climate preparedness initiatives

HHS and OCCHE should create competitive grants for states that demonstrate proactive climate change adaptation efforts in healthcare. These agencies can encourage states to integrate climate considerations into their health plans by providing additional funding to states that prioritize climate resilience.

Within CMS, the Center for Medicare and Medicaid Innovation (CMMI) could help create and administer these grants related to climate preparedness initiatives. Given its focus on innovation and testing new approaches, CMMI could design grant programs aimed at incentivizing state-level climate resilience efforts in healthcare. Given its focus on addressing health disparities and promoting preventive care, the Bureau of Primary Health Care (BPHC) within HRSA could oversee grants aimed at integrating climate considerations into primary care settings and enhancing resilience among vulnerable populations.


These recommendations provide a comprehensive framework for HHS — particularly CMS, HRSA, and OCCHE— to bolster public health preparedness for the health impacts of extreme heat events. By leveraging funding mechanisms, incentives, and requirements, HHS can enhance health system preparedness, improve health provider knowledge, and optimize emergency response capabilities. These strategic measures encompass a range of actions, including establishing dedicated grant programs, incentivizing climate-competent healthcare providers, integrating climate-resilience metrics into quality measurement programs, and leveraging the HITECH Act to enhance ICD-10 coding education. Collaboration with other federal agencies further strengthens the coordinated response to the growing challenges posed by climate change-induced extreme heat events. By implementing these policy recommendations, HHS can effectively address the evolving landscape of climate change impacts on health and promote a more resilient and prepared healthcare system for the future.

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.

Frequently Asked Questions
What are the expected outcomes of these recommended policy actions?

  1. Improved Accuracy in ICD-10 Coding: Healthcare providers consistently apply accurate ICD-10 coding for extreme heat-related health cases.

  2. Enhanced Healthcare Provider Knowledge: Healthcare professionals possess comprehensive knowledge on extreme heat-related health impacts, improving patient care and response strategies.

  3. Strengthened Public Health Response: A coordinated effort results in a more effective and equitable public health response to extreme heat events, reducing health disparities.

  4. Improved Public Health Resilience:

    1. Short-Term Outcome: Healthcare providers, armed with enhanced knowledge and training, respond more effectively to extreme heat-related health cases.

    2. Long-Term Outcome: Reduced morbidity and mortality rates associated with extreme heat events lead to a more resilient and prepared public health system.

  5. Enhanced Data Accuracy and Surveillance:

    1. Short-Term Outcome: Improved accuracy in ICD-10 coding facilitates more precise tracking and surveillance of extreme heat-related health outcomes.

    2. Long-Term Outcome: Comprehensive and accurate data contribute to better-informed public health policies, targeted interventions, and long-term trend analysis.

  6. Reduced Health Disparities:

    1. Short-Term Outcome: Incentives and education programs ensure that healthcare providers prioritize accurate coding, reducing disparities in the diagnosis and treatment of extreme heat-related illnesses.

    2. Long-Term Outcome: Health outcomes become more equitable across diverse populations, mitigating the disproportionate impact of extreme heat on vulnerable communities.

  7. Increased Public Awareness and Education:

    1. Short-Term Outcome: Public health campaigns and educational initiatives raise awareness about the health risks associated with extreme heat events.

    2. Long-Term Outcome: Informed communities adopt preventive measures, reducing the overall burden on healthcare systems and fostering a culture of proactive health management.

  8. Streamlined Emergency Response and Preparedness:

    1. Short-Term Outcome: Integrating extreme heat preparedness into emergency response plans results in more efficient and coordinated efforts during heatwaves.

    2. Long-Term Outcome: Improved community resilience, reduced strain on emergency services, and better protection for vulnerable populations during extreme heat events.

  9. Increased Collaboration Across Agencies:

    1. Short-Term Outcome: Collaborative efforts between OCCHE, CMS, HRSA, AHRQ, FEMA, DoD, and the Department of the Interior result in streamlined information sharing and joint initiatives.

    2. Long-Term Outcome: Enhanced cross-agency collaboration establishes a model for addressing complex public health challenges, fostering a more integrated and responsive government approach.

  10. Empowered Healthcare Workforce:

    1. Short-Term Outcome: Incentives for accurate coding and targeted education empower healthcare professionals to address the unique challenges posed by extreme heat.

    2. Long-Term Outcome: A more resilient and adaptive healthcare workforce is equipped to handle emerging health threats, contributing to overall workforce well-being and satisfaction.

  11. Informed Policy Decision-Making:

    1. Short-Term Outcome: Policymakers utilize accurate data and insights to make informed decisions related to extreme heat adaptation and mitigation strategies.

    2. Long-Term Outcome: The integration of health data into broader climate and policy discussions leads to more effective, evidence-based policies at local, regional, and national levels.

A Call for Immediate Public Health and Emergency Response Planning for Widespread Grid Failure Under Extreme Heat

Soaring energy demands and unprecedented heatwaves have placed the U.S. on the brink of a severe threat with the potential to impact millions of lives: widespread grid failure across multiple states. While the North American Electric Reliability Corporation (NERC), tasked with overseeing grid reliability under the Federal Energy Regulatory Commission (FERC), has issued warnings about the heightened risk of grid failures, the prospect of widespread summer blackouts looms large amid the nation’s unpreparedness for such scenarios.

As a proactive 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.

When the lights go out, 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. In a blackout, access to critical services like telecommunications, transportation, and medical assistance is also compromised, which only intensifies and compounds the urgency for coordinated response efforts. To avert blackouts, operators frequently implement planned and unplanned rolling blackouts, a process for load shedding that eases strain on the grid. However, these actions may lack transparent protocols and criteria for safeguarding critical medical services. Equally crucial and missing are frameworks to prioritize regions for power restoration, ensuring equitable treatment for low-income and socially vulnerable communities affected by grid failure events.

Thus, 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.


Grids are facing unprecedented strain due to record-high temperatures, which reduce their energy transmission efficiency and spike demand for air conditioning during the summer. On top of this, new industries are pushing grids to their limits. The Washington Post and insights from the utility industry cite the exponential growth of artificial intelligence and data centers for cloud computing and crypto mining as drivers of a nearly twofold increase in electricity consumption over the past decade. 

Projections from NERC paint a dire picture: between 2024 and 2028, an alarming 300 million people across the United States could face power outages. This underscores the pressing need for robust emergency response and public health planning.

The impact of power loss is especially profound for vulnerable populations, including those reliant on electricity-dependent medical equipment and life-saving medications that require refrigeration. Extreme heat significantly increases public health risks by exacerbating mental health, behavioral disorders, and chronic illnesses such as heart and respiratory conditions, and increasing the likelihood of preterm births and developmental issues in infants and children. Excessive temperatures also impose burdens on older adults.

Since 2015, national power outages have surged by over 150% owing to demand and extreme weather amplified by climate change. Increasing temperatures can cause transformers to overheat and explode, sometimes sparking fires and cascading outages. Other types of severe weather events, such as lightning strikes, high winds, and flying debris, further escalate the risk of utility infrastructure damage.

In 2020, 22 extreme weather events – from cyclones to hurricanes, heat, and drought – cost the U.S. a combined $95 billion. The following year, disasters like the Texas winter storm and the Pacific Northwest heatwave vividly illustrated the severe consequences of extreme weather on grid stability. To put this into perspective, 

These events led to rolling blackouts, thousands of heat-related emergency room visits, numerous deaths, and substantial economic losses. This remains an actively ongoing paradigm, with the National Oceanic and Atmospheric Administration’s (NOAA) 2023 Billion-dollar disaster report confirming 28 weather and climate disasters in a single year, surpassing the previous record of 22 in 2020, with a price tag of at least $92.9 billion.

Historical disasters, such as Hurricane Maria in 2017 and the Northeastern blackout in 2003, are stark reminders of the devastating impact of prolonged power outages. The aftermath of such events includes loss of life, disruptions to healthcare access, and extensive economic damages. 

A stark 2023 study reported that “If a multi-day blackout in Phoenix coincided with a heat wave, nearly half the population would require emergency department care for heat stroke or other heat-related illnesses.” Under such conditions, the researchers estimate that 12,800 people in Phoenix would die.

During these events, restoring power and providing mass care falls on various entities. Utility and power operators are tasked with repairing grid infrastructure, while the Federal Emergency Management Agency (FEMA) coordinates interagency actions through its National Response Framework and Emergency Support Functions (ESFs).

For example, ESF #6 handles mass care missions like sheltering and feeding, while ESF #8 coordinates public health efforts, overseen by the Department of Health and Human Services (HHS). FEMA’s Power Outage Incident Annex (POIA) enables utility operators to request support through ESF #12.While there is some testing of system responses to blackouts, few states have conducted exercises at scale, which is crucial, given the immense complexity of restarting grid infrastructure and coordinating mass care operations simultaneously.


The Department of Energy’s (DOE) Liberty Eclipse Program exemplifies a successful public-private partnership aimed at bolstering energy sector preparedness against cyberattacks on the grid. Similarly, FEMA conducts numerous Incident Command Systems (ICS) training annually, emphasizing collaboration across governments, nongovernmental organizations (NGOs), and the private sector.

By leveraging interagency mechanisms like MOUs, FEMA, DOE, and HHS can integrate and expand exercises addressing heat-induced grid failure into existing training frameworks. Such collaborative efforts would ensure a comprehensive approach to preparedness. Additionally, funds typically earmarked for state and local agency training could cover their participation costs in these exercises, optimizing resource utilization and ensuring widespread preparedness across all government levels.

There are also several federal policy efforts currently aligned with this proposal’s objectives, demonstrating a concerted effort to address related challenges through legislation, executive branch actions, programs, and precedents. Notable legislative initiatives, such as Rep. Ruben Gallego’s proposal to amend the Stafford Act, underscore a growing recognition of the unique threats posed by extreme heat events and the need for proactive federal measures.

Simultaneously, regulatory initiatives, such as those by FERC, signal a proactive stance in enhancing energy infrastructure resilience against extreme weather events. Building on an established precedent, FERC could direct NERC to create extreme heat reliability standards for power sector operators, akin to those established for extreme cold weather in 2024 (E-1 | RD24-1-000), further ensuring the reliable operation of the Bulk Electric System (BES).A pivotal resource informing our proposal is the 2018 report by the President’s National Infrastructure Advisory Council (NIAC), which emphasizes the significance of addressing catastrophic grid failure and underscores ongoing efforts dedicated to this pressing issue. Tasked with assessing the nation’s preparedness for “catastrophic power outages beyond modern experience,” the report offers invaluable insights and recommendations, particularly relevant to the following recommendation.

Plan of Action

To enhance national resilience, save tens of thousands of lives, and prevent significant economic losses, the National Security Council (NSC) should coordinate collaboration between implicated agencies (DOE, HHS, and FEMA) on grid resilience under extreme heat conditions and work to establish an interagency MOU to fortify the nation’s resilience against extreme heat events, with a specific focus on disaster planning for grid failure. This proposal will have minimal direct impact on the federal budget as it will use existing frameworks within agencies such as FEMA, the DOE, and HHS. These agencies already allocate resources towards preparedness training and testing, as evidenced by their annual budgets. 

Recommendation 1. NSC should initiate a collaboration between DOE, HHS, and FEMA.

The NSC should direct DOE to assess grid resilience under extreme heat and coordinate and prepare for widespread grid failure events in collaboration with FEMA and HHS. This collaboration would involve multi-state, multi-jurisdictional entities, tribal governments, and utilities in scaling planning and preparedness.

Under this coordinated action, federal agencies, with input from partners in the NSC should undertake the following steps:

The DOE Office of Cybersecurity, Energy Security, and Emergency Response (CESER), in collaboration with FERC and NERC, should develop comprehensive extreme heat guidelines for utilities and energy providers. These guidelines should include protocols for monitoring grid performance, implementing proactive maintenance measures, communicating concerns and emerging issues, and establishing transparent and equitable processes for load shedding during extreme heat events. Equitable and transparent load shedding is critical as energy consumption rises, driven in part by new industries like clean tech manufacturing and data centers.

FEMA should:

HHS should strengthen functions under ESF#8 to deliver public health services during extreme heat-induced grid failure events, with enhanced coordination between the Centers for Disease Control and Prevention (CDC) and the Assistant Secretary for Preparedness and Response (ASPR).

Recommendation 2. Establish an interagency MOU

An interagency MOU should streamline coordination and collaboration on extreme heat disaster planning and preparedness for grid failure. Further, these agreements should prepare agencies to facilitate cross-sector collaboration with states and local governments through the establishment of a national task force. 

This MOU should outline the following actions:


This proposal emphasizes planning for blackouts and response readiness when the lights go out across wide swaths of America during extreme heat. Addressing this critical gap in federal disaster response planning would secure the safety of millions of citizens and prevent billions of dollars in potential economic losses. 

An Executive Action or interagency MOU would facilitate coordinated planning and preparedness, leveraging existing frameworks and engaging stakeholders beyond traditional boundaries to effectively manage potential catastrophic, multi-state grid failures during heat waves. Specific steps to advance this initiative include ensuring no ongoing similar exercises, scheduling meetings with pertinent agency leaders, revisiting policy recommendations based on agency feedback, and drafting language to incorporate into interagency MOUs.

Using existing authorities and funding, implementing these recommendations would safeguard lives, protect the economy, and bolster national security, particularly as the U.S. moves toward a more sustainable, stable, and reliable electric grid system.

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.

Frequently Asked Questions
How do these recommendations align with existing policy priorities?

This proposal is fully aligned with the Biden Administration’s executive actions on climate change, specifically, Executive Orders 14008 and 13990, which have led to significant initiatives aimed at addressing climate-related challenges and promoting environmental justice. These actions resulted in the establishment of key entities such as the Office of Climate Change and Health Equity at the Department of Health and Human Services (HHS), as well as in the development of the HHS’ national Climate and Health Outlook and the CDC’s Heat and Health Tracker, and heat planning and preparedness guides. Furthermore, the launch of and the interagency National Integrated Heat Health Information System (NIHHIS), are significant steps in providing accessible and science-based information to the public and decision-makers to support equitable heat resilience. serves as a centralized platform offering comprehensive resources, including NIHHIS programs, events, news articles, heat and health program funding opportunities, and information tailored to at-risk communities. This initiative underscores President Biden’s dedication to tackling the health risks associated with extreme heat and is a priority of his National Climate Task Force and its Interagency Working Group on Extreme Heat. This proposal complements these efforts and aligns closely with the administration’s broader climate and health equity agenda. By leveraging existing frameworks and collaborating across agencies, it is possible to further advance the administration’s objectives while effectively addressing the urgent challenges posed by climate change.

How much will this proposal cost?
There is little foreseeable direct impact on the federal budget. Leveraging established frameworks within agencies like FEMA, DOE, and HHS presents a pragmatic approach. These agencies already allocate resources for preparedness training and testing, as evidenced by their annual budgets.
Why should the federal government be the entity to act rather than the private sector or state/local government?
Disaster planning and public health emergency preparedness frameworks and resources are crafted and overseen by the federal government to support the needs of state, tribal, and local governments. In the event of a catastrophic grid failure spanning numerous jurisdictions, FEMA’s National Response Framework would be activated. This proposal contends that enhancing response preparedness for a widespread blackout amid extreme heat can be achieved through existing federal frameworks and enhanced interagency cooperation. Consequently, there is a critical imperative for the federal government to take the lead in evaluating planning and readiness capacities to address this evolving disaster scenario.
Who is likely to push back on this proposal?
The federal agencies outlined in this proposal already bear significant responsibilities for public safety. Therefore, some may perceive this proposal as stretching their capacities or adding further bureaucracy to an already complex response framework. However, these recommendations aim to streamline crucial planning efforts ahead of operationalizing measures in the event of a disaster. This streamlined approach promises greater efficiency in response efforts, ultimately leading to more successful outcomes in preserving lives, economies, and security.
What is the first step to getting this proposal off the ground?
The first step is to assess what level of planning and exercising has taken place or is being planned for wide-scale grid failure events under extreme heat. By understanding the current state of readiness, efforts can be tailored to address any deficiencies and enhance overall preparedness for such critical scenarios.

This policy memo was written by the Federation of American Scientists in collaboration with the Pima County Department of Health (Dr. Theresa Cullen, Dr. Julie Robinson, Kat Davis), which provided research and information support to the authors. The Pima County Department of Health seeks to advance health equity and environmental justice for the citizens of Arizona and beyond.

Protecting Workers from Extreme Heat through an Energy-efficient Workplace Cooling Transformation

Extreme heat is a growing threat to the health and productivity of U.S. workers and businesses. There is a high-impact opportunity to pioneer innovations in energy-efficient worker-centric cooling to protect workers from the growing heat while reducing the costs to businesses to install protections. With the impending Occupational Safety and Health Administration (OSHA) standard, the federal government should ensure that businesses have the necessary support to establish and maintain the infrastructure needed for existing and upcoming worker heat protection requirements while realizing economic, disaster resilience, and climate co-benefits. To achieve this goal, an Executive Order should form a multiagency working group that coordinates federal government and nongovernment partners to define a new building design approach that integrates both worker health and energy-efficiency considerations. The working group should establish roles and a process for coordinating and identifying leaders and funding approaches to advance a policy roadmap to accelerate, scale up, and evaluate equitable deployment and maintenance of energy-efficient worker-centric cooling. This plan presents a unique and timely opportunity to build upon existing national clean energy, climate, and infrastructure commitments and goals to ensure a healthier, more productive, resilient, and sustainable workforce.

Challenge and Opportunity

U.S. workers and businesses face a growing threat of illness, death, and reduced work productivity from extreme heat exposure. There were 436 work-related heat deaths recorded in the U.S. from 2011 to 2021. Workplace heat exposure is linked to heat illnesses, traumatic injuries, and reduced work productivity among otherwise healthy workers, costing the nation an estimated $100 billion each year in lost economic activity. Workers exposed to high heat include those in outdoor occupations in agriculture and construction and those working in hot manufacturing, transportation and warehousing, and food services environments. Spikes in worker heat illness have occurred during recent extreme heat events, such as the “heat dome” event of 2021, which are more likely to occur with climate change. Disproportionately exposed workers and small businesses often do not have the resources or capacity to implement, improve, or maintain existing workplace cooling infrastructure, thus increasing heat exposure inequities.

An energy-efficient workplace cooling transformation is needed to ensure businesses have the support required to comply with existing state heat rules and upcoming federal workplace heat prevention requirements. Several states—California, Colorado, Oregon, Minnesota, and Washington—have already adopted occupational indoor and/or outdoor heat exposure rules to protect workers from heat stress. OSHA is in the process of developing a national workplace heat standard. In addition to requirements for worker rest breaks, training, and hydration, OSHA is considering requirements for employers to implement protections when the measured heat index is 80°F or higher, including engineering controls such as air-conditioned cool-down areas. 

Using energy-efficient active or passive cooling systems and building designs in workplaces has numerous benefits. Cooling the environment is one of the most effective methods for reducing the risk of heat illness. Energy-efficient cooling reduces electricity consumption and greenhouse gas emissions compared to conventional systems. Energy-efficient buildings cost less to operate, allowing greater productivity at lower cost and reduced fossil fuel use and community air pollution. Energy-efficient cooling also decreases the amount of electricity on the grid at one time, reducing the chances of blackouts during extreme weather events. 

We must develop a new approach to building standards – energy-efficient, worker-centric cooling – that integrates both worker health and energy-efficiency considerations. Existing building-centric approaches that blanket-cool entire buildings to the same fixed temperature are energy inefficient and can lead to overcooling of unoccupied areas and increased costs. The urgent need for energy-efficient worker-centric cooling standards is highlighted, for example, by the 300–900 million ft2 per quarter rate of U.S. warehouse space under construction, and a growing warehouse workforce, in recent years.

There is a gap in standards that address both civilian worker health and energy-efficient cooling simultaneously. The U.S. Green Building Council (USGBC) has incorporated a worker-centric approach in its Leadership in Energy and Environmental Design (LEED) certification program. This approach includes pilot credits for Prevention through Design (PtD), which aims to minimize risks to workers by integrating safety measures into building design and redesign. One such example is ensuring roof features, such as vegetated roofs and solar panel installations, are arranged to minimize hazards like falls for maintenance personnel. However, there are no specific PtD standards or LEED credits for energy-efficient cooling approaches that address worker heat hazards. For example, there are no specific standards that incorporate the proximity of indoor cool-down areas to hot work areas, targeted cooling of certain work areas, or mobile outdoor cooling stations that leverage solar and electrochemical technology.

Although there are several potential mechanisms of support for energy-efficient cooling infrastructure for commercial buildings and small businesses, there is no program to assist employers and small businesses in integrating these technologies into worker-centric cooling infrastructure designs. Under the Inflation Reduction Act of 2022 (IRA), tax deductions are available through Internal Revenue Code (IRC) 179D for building owners to install or retrofit equipment aimed at improving energy efficiency, including HVAC systems such as heat pumps and building envelope improvements to “heat-proof” or weatherize structures. However, tax credits may be difficult to access and may not provide a sufficient degree of immediate support for small business owners struggling with inflation costs. While the Biden-Harris Administration has also launched a $14 billion National Clean Investment Fund that will provide Environmental Protection Agency (EPA) grants to small businesses for deploying clean technology projects, there are no earmarked funds for workplace solutions focused on energy-efficient cooling or resilience to extreme heat events that integrate worker health considerations. Current U.S. Small Business Administration efforts focus primarily on supporting small businesses with disaster recovery rather than resilience.

Effective cross-agency coordination is needed to accomplish an energy-efficient cooling transformation in U.S. workplaces, support small businesses, and contribute to the Healthy People 2030 goal of reducing workplace deaths. Coordination among existing agencies and external partners to address gaps in energy-efficient cooling technology, worker-centric designs, and heat-specific PtD building approaches will support a healthier, more productive, and sustainable U.S. workforce.

Plan of Action

Transforming workplace infrastructure to support a healthy, productive, and sustainable U.S. workforce against extreme heat requires coordination across multiple federal agencies. This plan offers the first steps in developing a structure for coordination, defining the approach, developing a roadmap for future actions, and ultimately catalyzing and piloting innovations and implementing and evaluating solutions.

This plan is guided by the following principles:

Following an executive order from the President, the Office of Management and Budget should convene a multiagency working group to develop a plan for coordination and to outline a roadmap toward an energy-efficient workplace cooling transformation for a healthy, productive, and sustainable workforce. The working group should:

Recommendation 1. Be chaired by an agency that has experience in convening multisectoral collaborations and advocating for equitable health outcomes, such as the Department of Health and Human Services (HHS) Office of Climate Change and Health Equity. The inclusion of representatives from the following agencies and offices should be considered:

Recommendation 2. Define roles and develop a plan to enhance coordination with public and private partners in developing and evaluating evidence-based worker-centric cooling infrastructure technologies and building designs. Partners should include those that develop or promote voluntary standards and guidelines for:

Recommendation 3. Establish a consensus definition of energy-efficient worker-centric cooling using a combination of established metrics, including:

Recommendation 4. Outline existing pathways to support an energy-efficient workplace cooling transformation, including: 

Recommendation 5. Articulate follow-on initiatives and identify leaders and potential funding approaches to advance the roadmap of policies to accelerate, scale up, and evaluate equitable deployment, maintenance, and evaluation of worker-centric energy-efficient cooling infrastructure. Policies considerations include:

Funding for agencies to work together to develop and implement approaches to track progress toward an energy-efficient workplace cooling transformation by combining data sources.


Given the growing threat to U.S. workers and businesses posed by illness, death, and reduced work productivity from increasing heat exposure, it is imperative to catalyze an energy-efficient workplace cooling transformation. There is currently a unique and timely opportunity to build upon national clean energy, climate, and infrastructure commitments and goals to address gaps in energy-efficient worker-centric cooling technology and PtD building standards. The proposed plan will incorporate high-level support, provide infrastructure for coordination among government agencies and nongovernmental partners, define the approach, and lay the groundwork for stimulating innovations in promising worker-centric cooling technologies and designs. This plan will produce a roadmap for an energy-efficient workplace cooling transformation that will support businesses in establishing the infrastructure needed for existing and upcoming workplace heat prevention requirements. The approach will build upon existing occupational health equity initiatives to reduce the risk of heat health effects for workers disproportionately affected by heat and small businesses. This initiative will ensure a healthier, more productive, and sustainable workforce with minimal cost and a substantial potential return on 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.

Frequently Asked Questions
Why not just wait until a federal occupational heat rule is adopted to pursue an energy-efficient workplace cooling transformation? Why is technology part of the solution?

Under federal OSHA standards for employers, workplaces are currently only required to address workplace heat if it is causing or likely to cause death or serious harm to employees. This OSHA “General Duty Clause” requirement is insufficient, as workers experience negative effects from workplace heat exposure — ranging from heat illness to death. OSHA is in the process of developing a workplace heat standard that considers engineering controls, such as workplace cooling, along with other requirements related to worker breaks, training, and hydration. Workplace cooling is a proposed federal rule element and is already relevant for U.S. states with indoor workplace heat regulations. Energy-efficient workplace cooling infrastructure transitions do not happen overnight. Investment now is important for states with existing heat rules and to prepare for the future state and/or federal heat rules.

Why not just focus on energy-efficient cooling of homes?

Home cooling only partially addresses extreme heat health risks because many working-age adults spend half of their waking hours during the workweek at work. Further, increased energy-efficiency in the industrial sector, which currently accounts for 30% of U.S. greenhouse emissions, can reduce pollution in surrounding communities and blackout risk during extreme weather events.

Why not just direct business owners to existing incentives and grants?

Existing incentives and grants (e.g., IRA tax deductions for building owner energy-efficient installation or retrofitting, such as IRA 13303; IRC 179D; National Clean Investment Fund grants through EPA to small businesses deploying clean technology projects; and SBA Office of Disaster Recovery and Resilience loans) do not explicitly incorporate worker-centric designs that achieve climate, energy-efficiency, and worker health goals simultaneously. Further, tax deductions and grant programs provide short- and medium-term financial support for energy-efficient workplace cooling transitions. Without a roadmap to address explicit coordination, simplification in processes, and accessibility of incentives, small business owners may be unable to take advantage of these incentives.

What types of data sources could be considered for tracking progress toward an energy-efficient workplace cooling transformation?

Examples of data sources that could be considered are:

What would the workplace cooling transformation cost?
Costs for the formative steps of the transformation described in this brief would use existing agency resources and would not require additional congressional appropriations. As the working group develops the roadmap of future policies, the group can make recommendations for additional resources as part of agency annual budget cycles or congressional appropriations.

A Comprehensive Strategy to Address Extreme Heat in Schools

Requiring children to attend school when classroom temperatures are high is unsafe and reduces learning; yet closing schools for extreme heat has wide-ranging consequences for learning, safety, food access, and social determinants of health. Children are vulnerable to heat, and schooling is compulsory in the U.S. Families rely on schools for food, childcare, and safety. In order to protect the health and well-being of the nation’s children, the federal government must facilitate efforts to collect the data required to drive extreme heat mitigation and adaptive capacity, invest in more resilient infrastructure, provide guidance on preparedness and response, and establish enforceable temperature thresholds. To do this, federal agencies can take action through three paths of mitigation: data collection and collaboration, set policy, and investments. 

Challenge and Opportunity

Schools are on the forefront of heat-related disasters, and the impact extends beyond the hot days. Extreme heat threatens students’ health and academic achievement and causes rippling effects across the social determinants of health in terms of food access, caregiver employment, and future employment/income for students. Coordinated preparation is necessary to protect the health and well-being of children during extreme heat events.

School Infrastructure Failure

Many schools do not have adequate infrastructure to remain cool during extreme heat events. At the start of the 2023–2024 academic year, schools in multiple locations were already experiencing failure due to extreme heat and were closing or struggling to hold classes in sweltering classrooms. The Center for Climate Integrity identified a 39% increase from 1970 to 2025 in the number of school districts that will have more than 32 school days over 80°F (their temperature cutoff for needing air-conditioning to function). The Government Accountability Office found in 2020 that 41% of public school districts urgently need upgrades to HVAC systems in at least half of their buildings, totaling 36,000 buildings nationally. The National Center for Education Statistics’ (NCES) most recent survey of the Condition of America’s Public School Facilities (2012–2013 school year) found 30% of school buildings did not have adequate air-conditioning. The numbers correlate with the population of disadvantaged students: 34% of schools where at least 75% of students are eligible for free or reduced lunch, and only 25% of schools where less than 35% of students are eligible for free/reduced lunch. NCES’s School Pulse Panel, implemented to document schools’ response to COVID-19, is expanding to include other topics relevant to federal, state, and local decision-makers. The survey includes heat-adjacent questions on indoor air quality, air filtration, and HVAC upgrades, but does not currently document schools’ ability to respond to extreme heat. Schools that are not able to maintain cool temperatures during extreme heat events directly affect child health and safety, and have an upstream impact on health.

Impact on Child Health and Safety

When temperatures rise on school days, local districts must decide whether to remain open or close. Both decisions can affect children’s health and safety. If schools remain open, students may be exposed to uncomfortable and unsustainable high temperatures in rooms with inadequate ventilation. Teachers in New York State reported extreme temperatures up to 94℉ inside the classroom and children passing out during September 2023 heatwaves. Spending time in the schoolyard may only compound the problem. Unshaded playgrounds and asphalt quickly heat up and may be hotter than surrounding areas, with surface temperatures that can cause burns. Similar to neighborhood tree cover, shade on school playgrounds is correlated with income (more income, more shade), leading to a higher risk of heat exposure for low-income and historically marginalized students. Children are vulnerable to heat and may have trouble cooling down when their body temperatures rise. Returning to hot classrooms will not provide them with an opportunity to cool down.

If schools close, children who are unable to access school food may go hungry. Procedures exist to ensure the continuation of school food service during unanticipated school closures, but it is not clear how food service would function if the building is overheated during extreme heat events. In New York City, an assessment of public cooling centers identified that nearly half were in senior centers and not open to children. If schools do not have sufficient heat mitigation and are closed for heat, children from low-income households, who are at higher risk for food insecurity and less likely to have air conditioning at home, may be left hot and hungry.

While some state and local education departments have developed plans for responding to extreme heat on school days, the guidance, topics, and level of detail varies across states. Further, while the National Integrated Heat Health Information System (NIHHIS) and the Centers for Disease Control and Prevention (CDC) have identified children as an at-risk group during heat events, they do not offer specific information on how schools can prepare and respond. A comprehensive playbook that provides guidance on the many challenges schools may encounter during extreme heat, and how to keep children safe, would enhance schools’ ability to function. 

Impact on Learning and Social Determinants of Health

The cumulative impact on learning, income, and equity is large. When schools remain open, heat reduces student learning (a 1% reduction in learning for each 1℉ increase across the year). When schools close, children lose learning time. The nation experienced the rippling effects of school closures during the COVID-19 pandemic, when extended closures impacted the achievement gap, projected future earnings, and caregiver employment, particularly for women. Even five days of closure for snow days in a school year has been seen to reduce learning. The projected increase in the number of districts that experience more than 32 school days a year over 80 suggests the impact of heat on learning could be substantial, whether it is from school closure or from learning in overheated classrooms. 

The impact on learning disproportionately affects students in low-income districts, often correlated with race due to historic redlining, as these districts have fewer funds available for school improvement projects and are more likely to have school buildings that lack sufficient cooling mechanisms. These disproportionate impacts foster increasing academic and economic inequity between students in low- and high-income school districts.

Existing Response: Infrastructure

The federal government is aware of the infrastructure challenges and is funding green and gray infrastructure improvements through several programs. The Renew America’s Schools grants focus on funding infrastructure upgrades for K-12 schools. In the initial round of applications, need far exceeded available funds, with 236 Local Education Authorities submitting eligible requests totaling $1.62 billion. In response to the overwhelming need, the Department of Energy (DOE) more than doubled planned funding and awarded $178 million in grants. Through the American Rescue Plan, the Environmental Protection Agency (EPA) is providing technical assistance to help communities develop plans to develop cooling centers in schools. Through the Inflation Reduction Act, EPA is helping schools develop and implement Indoor Air Quality management plans, which include maintenance of acceptable temperatures, with an anticipated $32 million in grant funding over five years. Multiple public and private programs have supported projects to increase green space and tree cover on school grounds, including grants from the U.S. Department of Agriculture (USDA) Forest Service and California Department of Forestry and Fire Protection (CAL FIRE).

These programs are substantial, but also substantially less than the demonstrated need. Embedding heat considerations into future school infrastructure projects and integrating explicit consideration of heat into existing projects would enable all of the activities supported through these grants to mitigate the impact of extreme heat concurrently. A coordinated effort could increase the impact of these funds. 

Existing Response: Temperature Standards

Though many states, school districts, or health departments maintain and enforce standards for minimum required temperatures in occupied buildings, relatively few have similar standards for maximum acceptable temperatures. The Occupational Safety and Health Administration (OSHA) recommends indoor temperatures stay between 68℉ and 76℉ and is currently developing a national standard for protecting workers during extreme heat. Occupational standards for maximum indoor temperature exist in Oregon (80), Minnesota (77 to 86), and California (80 outdoors; indoors pending). As public schools are institutions where adults work and children, an at-risk group, are required to be present, a national standard on acceptable indoor temperatures should be developed to protect children’s health and learning. 

Plan of Action

Managing extreme heat in American public school systems requires urgent action. While education is primarily under the authority of the state governments, the mission of the federal government is to ensure educational excellence and equal access. Federal agencies can facilitate data collection and collaboration, set standards to maintain safety, provide guidelines for local education authorities to follow, and coordinate different actions at state level and act as a source of expertise for capacity building for state and local actors. Similar to the actions outlined in a recent memo on developing heat-resilient schools in California, the federal government should take preemptive action across the nation.

Collect Data and Collaborate. Federal agencies need to collaborate and collect data to better understand and drive mitigation efforts to prepare for extreme heat for schools. 

  1. The U.S. Department of Education (ED) should join NIHHIS as a partnering agency to collaborate on heat preparation and mitigation strategies specifically for schools. 
  2. The NCES should update a national inventory of school infrastructure to identify schools that will need upgrades or investments in infrastructure to mitigate heat based on climate prediction. 
  3. ED should collaborate with EPA and/or National Oceanic and Atmospheric Administration (NOAA) to collect data about heat at indoor and outdoor school facilities so as to provide better guidance to schools and direct heat mitigation efforts (e.g., increasing shade or tree cover on playgrounds). Mechanisms for this could be through creating an optional reporting function of EPA’s School IAQ Assessment tool (see recommendation below), adding heat-related questions to NCES’s School Pulse Panel, or through NOAA heat-island mapping campaigns.
    • EPA should update its School IAQ Assessment and App to include heat-related information. This could include a checklist or questions related to extreme heat, including both before heat events (HVAC status, shade cover on school building and playground, plans for hot days, options for water/cooling for overheated students, and indicators of heat stress), and heat assessments on days at high temperatures (indoor temperature in classrooms, hallways, cafeteria, gym, and outdoor temperatures on playgrounds [air and surfaces], blacktop, and shaded areas). 
    • NCES should add heat-related questions to the School Pulse Panel survey to aid heat-mitigation efforts in the same way the survey was used for COVID-19 mitigation. There are existing questions related to indoor air quality, ventilation, and the state of HVAC systems. Similar questions should be added to collect data on indoor and outdoor temperatures in locations where students spend school time (classrooms, lunch room, playground) during hot months, use of building-wide or local air conditioning or fans to maintain temperature, and availability of cooling spaces if the whole building does not have air-conditioning.
  4. ED should collaborate with state and local education authorities to collect data on school closures and absences during heat events to identify places where heat affects students’ ability to participate due to extreme heat and the reasons that students are absent during extreme heat events. Data on absences should be used to proactively target places where heat is having a larger impact on access to education. 

Set Policy. In order to prepare for future extreme heat events, federal agencies can take the following actions to set policy to expand the adaptive capacity of schools to protect U.S. educational employees and students:

  1. Similar to required minimum indoor temperatures, OSHA should establish a standard that sets the maximum classroom indoor temperatures at which cooling action must be taken or classrooms must be closed. OSHA is already considering a heat standard for outdoor workers; OSHA can set standards for school employees that would also protect students learning in those conditions. 
  2. The Federal Emergency Management Agency (FEMA) should define school infrastructure as failing on school days above 80℉ outdoor temperature in schools without air conditioning or indoor temperature above 80℉ in classrooms. FEMA can then apply mitigation measures if the school is determined to have infrastructure failure, including providing funding for infrastructure upgrades.
  3. FEMA and other agencies that assess and predict hazard risk should explicitly consider schools’ capability to remain open and keep children safe during extreme heat events as part of their assessments. 
  4. ED and the Department of Health and Human Services (HHS) should develop guidelines to protect students’ health, well-being, and learning during extreme heat events and include them in the Emergency Planning section of guidance. This could include an updated and easily accessed, searchable, and centralized library of federal and state resources specifically tailored to heat stress in schools such as California’s EnvironScreen and US Climate Resilience Toolkit. This can expand the capacity of local and state actors and provide ongoing access to updates support. This also sets the stage for state governments to share resources and collaborate.
  5. NIHHIS should add resources for schools in a “For Schools” drop-down section of the Planning and Preparing page on
  6. USDA should develop a federal process to serve food in alternative locations when school buildings are overheated during extreme heat events, similar to New York State’s summer waiver allowing food service in alternate locations during heat events.

Invest in Schools. In order to prepare for and plan for future extreme heat events, EPA, the Consumer Product Safety Commission (CPSC), USDA, and the Department of Energy (DOE) can take the following actions to launch mitigation measures to improve the resilience of schools and alleviate the impact of heat on student and employee health:

  1. Existing projects focused on school upgrades should integrate consideration of heat mitigation into their programs.
    • The Renew America’s Schools Grants and EPA’s Indoor Air Quality project should ensure that infrastructure upgrades they support for K-12 schools will also meet the needs of increasing temperatures. These projects already contribute substantial funding to projects that could affect heat mitigation. Explicitly planning for and investing in heat mitigation as part of those upgrades could reduce the need for additional upgrades to address heat.
    • The CPSC should update their Public Playground Safety Handbook to include a more comprehensive overview of designing thermally comfortable playgrounds. The National Program for Playground Safety developed a good example of this for the Standards Council of Canada with specific details about designing thermally safe playgrounds. Programs supporting schoolyard redesign projects should follow these guidelines.
  2. Substantial funding needs to be allocated to invest in infrastructure, cooling technologies, retrofits, landscape, and other adaptive strategies to prepare for extreme heat. There needs to be investments in researching how much funding is needed and how to allocate that funding equitably. Data collection proposed above will help determine the scale of the need.


Extreme heat is an urgent problem for schools. Opportunities exist across the federal government to protect our nation’s future by protecting our children. Federal agencies can best support state and local schools through three paths of mitigation: collect data and collaborate, set policy, and invest in schools. 

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.

Frequently Asked Questions
Are there any state-level temperature standards in the works for schools?

Several examples of potential legislation exist at the state level in Mississippi (classrooms must be air-conditioned for schools to be accredited), Connecticut (schools with air conditioners must maintain temperatures below 78ºF), Washington (schools must be “reasonably free of… excessive heat”), and Hawaii (classrooms must be a “temperature acceptable for student learning”) and a bill is being considered in New York (cooling action must be taken at 82ºF; classrooms can’t be occupied above 88ºF).

Adapting the Nation to Future Temperatures through Heat-Resilient Procurement

Extreme chronic and acute heat exposes millions of American lives to dangerous health risks and threatens our infrastructure. Yet there are many physical solutions available to mitigate the risk of heat to people and systems in our built environments. Despite clear evidence that heat exposure is a substantial challenge to human health, economic vitality, and the goals of the Justice40 initiative, very little has been done to galvanize viable markets for materials and technologies that can improve heat resilience. 

In order to spur demand and send a strong signal for beneficial private sector innovation and scale, the federal government can lead by example to drive the market for products and services that build heat resilience. The General Services Administration (GSA) should require new and existing public structures (e.g. buildings and parking lots), products, supplies, and service procurement to meet minimum requirements for heat adaptation. These requirements could be adapted from existing green codes (e.g., ASHRAE 189.1 and IEA’s Annex 80) that recognize some of the non-energy benefits of heat-resilient materials and products, recognized supply chain vulnerabilities due to extreme heat (e.g. specialty crops, commodity crops, livestock, pharmaceutical precursors, etc.), and best practices for workplace protections (e.g. Fair Food Program).

Challenge and Opportunity

The federal government’s market-making potential is substantial – purchasing more than $630 billion in goods and services in FY2021 alone. The GSA owns and leases over 363 million square feet of space in 8,397 buildings in more than 2,200 communities nationwide. Updating procurement requirements and solicitations to promote passive cooling and heat resilience is relatively straightforward since GSA already maintains a database for green and sustainable building materials, systems, and services that could be amended, rather than creating a new parallel standard. Further, procurement standard changes are within the purview of a relatively small number of policy actors, compared to policies that incentivize voluntary uptake or require broad enforcement to be effective. 

Even small increases in market demand, driven by policy, can significantly reduce first costs, product availability, and innovation. For example, requirements for solar reflective shingles on residential homes in Los Angeles City and County (a market of roughly 10 million people) reduced costs for high-end shingle products by two-thirds and saw the introduction of mid- and low-cost product lines throughout the country. Similarly, joint innovation around a commitment to incorporating cool pavements into Los Angeles and Phoenix road maintenance and preservation programs has driven global product innovation, improved durability and aesthetics, and more efficient application processes that benefit communities nationwide. GSA action on procurement would send a much stronger market signal to many more communities. 

Heat-resilient procurement will also benefit rapidly developing federal policy to promote reduced heat risk. In January 2024, the Federal Emergency Management Agency announced that it would fund investments in net-zero energy reconstruction in areas under a federal disaster declaration. The provisions, which explicitly highlight investments in passive cooling, apply to Public Assistance, the agency’s largest grant program; the Hazard Mitigation Grant Program; and the Building Resilient Infrastructure and Communities grant program. Heat-resilient interventions can be a net benefit to net-zero priorities, keeping buildings cooler as temperatures rise without driving up energy consumption. Further, heat-resilience procurement standards aligns with the Office of Management and Budget’s climate-smart infrastructure investments memorandum (M-24-03), which calls for incorporation of current and future climate change risk in infrastructure investments and maximizing sustainability over the system’s service life.

The regulatory groundwork and technical language required for these recommendations are already in place. Several state and model codes already have requirements that could easily be adopted or referenced by a procurement standard. For example, California’s Title 24 includes requirements for cool roofs, green roofs, and other heat-adaptive interventions for a variety of climate zones. Similarly, ASHRAE Standard 189.1, the International Energy Conservation Code, ASHRAE Standard 90.1, and the LEED voluntary program include prescriptive urban heat island mitigation or passive cooling requirements for U.S. climate zones. 

In November 2022, the Biden-Harris Administration proposed the Federal Supplier Climate Risks and Resilience Rule, which would require federal contractors receiving more than $7.5 million in annual contracts to publicly disclose their greenhouse gas emissions and climate-related financial risks and set science-based emissions reduction targets. Requiring heat resilience would further push markets toward adaptation.

Executive Order 14057 on catalyzing American clean energy industries and jobs through federal sustainability and the accompanying Federal Sustainability Plan would, in part, create a mandate and mechanism to update federal policies for sustainability, climate action, and resilience. The order includes “buy clean” provisions for low-carbon materials, with a goal of net-zero procurement by 2050, and a Net-Zero Emissions Procurement Federal Working Group and Buy Clean Task Force that is required to report semiannually on progress toward clean procurement. As heat-resilience interventions like cool surfaces can drive down energy consumption, they are aligned with net-zero priorities.

Plan of Action

A number of existing policy pathways and fora could be leveraged to develop, standardize, and include heat-resilience standards in procurement. To start, the GSA could amend its Facilities Standards for the Public Building Service (P100) for public facilities and infrastructure projects to incorporate heat resilience by adopting ASHRAE 189.1 and resilient cooling practices articulated in the International Energy Agency’s Annex 80. Supportive engagement with the Net-Zero Emissions Procurement Federal Working Group would leverage internal reporting requirements to advance heat adaptation. Further, the Environmental Protection Agency (EPA) could incorporate ASHRAE 189.1 performance requirements for highly solar-reflective and vegetated materials into Energy Star, allowing those products to be included in Green Procurement Compilation

To ensure heat-resilient supplies and services, the Federal Acquisition Register (FAR) could be updated to include disclosures on how those products and services improve or reduce resilience to heat. Relevant disclosures include, but are not limited to, extreme heat’s risk to: service provision, such as unsafe working conditions; 2) supply chains and key commodity provisions; and 3) infrastructure operations, such as adequate cooling of data center facilities. The FAR already recognizes the risk of climate change in its proposed implementation of section 5(b)(i) of Executive Order 14030, Climate-Related Financial Risk, to require major federal suppliers to publicly disclose greenhouse gas emissions and climate-related financial risk and to set science-based reduction targets. GSA could also increase the use of life-cycle cost assessments over the lowest first-cost procurement to recognize the broader economic and societal benefits gained from investments in sustainable and resilient products and services. 

Interagency efforts, stewarded by the Interagency Working Group on Extreme Heat, could accelerate standards for heat-resilient building codes as well as product and services procurement. For example, the National Institute of Standards and Technology (NIST) works on other climate-related building standards through the National Windstorm Impact Reduction Program (NWIRP) and the National Construction Safety Team (NCST) Act, which authorizes NIST to investigate extreme weather events on buildings and inform the improvement of codes for the built environment. Further, the U.S. Department of Housing and Urban Development (HUD) establishes construction and safety standards, and the Department of Energy (DOE) proposes energy-efficiency standards for manufactured homes, which account for approximately 10% of single-family houses constructed in the U.S. annually and could include heat-resilient technologies. The U.S. Department of Agriculture’s federal public food procurement system (including the National School Lunch Program, Emergency Food Assistance Program, and Commodity Supplemental Food Program) could take better stock of extreme heat’s risks to the federal government’s ability to affordably procure essential food products. Finally, in alignment with the Occupational Health and Safety Administration’s National Emphasis Program on Extreme Heat, agencies that contract with high-risk industries (e.g. agriculture, construction, manufacturing, firefighters, etc.) should ask for the latest data on workplace injuries and deaths during heat season (April to October) before awarding contracts and rate contractors on heat safety upon contract completion.

Federally supported construction standards and procurement requirements can also be applied at any level of government: national, state, tribal, local, or even school districts and incentivized through federal financing of these subnational efforts. 

Non-Federal Stakeholders

This effort would greatly benefit from robust engagement with organizations outside of the public sector. National laboratories such as Lawrence Berkeley National Lab, Oak Ridge National Lab, National Renewable Energy Lab, and Pacific Northwest National Lab have deep technical experience to identify heat-resilient technologies. Organizations such as the Cool Roof Rating Council (which rates roofing and wall material surface properties) and the National Fenestration Rating Council are entry points to technical support from its industry members. Code experts such as the New Buildings Institute and Regulatory Assistance Project could identify and modify existing code language to match the needs of federal procurement. The American Public Health Association, Smart Surfaces Coalition, Institute for Policy Integrity, and others can support a broader social cost benefit to determine what performance levels to require in procurement standards.

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.

Frequently Asked Questions
How would the implementation of this proposal impact the federal budget?

Cool surfaces are not a monolithic product category. They encompass a huge variety of roofing, wall, and building attachment products spanning commercial, residential, multi-family, institutional, and industrial use cases. In nearly all of those contexts, there is an available, economically viable first-cost option that would promote heat resilience rather than exacerbate heat exposure.

Heat-resilient or passive-cooling procurement standards may generate net positive impacts on the budget. Looking at life-cycle costs and benefits, studies have found that $1 invested in passive cooling measures returns between $1.50 and $15.20.

Beyond the federal budget, mandatory heat-resilience policies also yield substantial social and market benefits. When procurement and codes require heat resilience at a municipal level (as they have in Los Angeles, for example), the budget impact has been negligible but has resulted in dramatically lower first costs for heat-resilient options like advanced cool roof shingles. Similarly, adding questions about heat resilience to the required responses for service procurement is not an undue or onerous burden on potential federal contractors. Heat costs American workers and businesses over $100 billion per year in lost productivity and wages. Investments in the built environment may substantially reduce that existing burden, yielding more equitable outcomes in line with Justice40 (the wage impact is felt most acutely by outdoor, agricultural, and warehouse workers) and potentially more tax revenue.