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

Extreme Heat is the “Top Weather Killer”

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

Policy Changes Can Save Lives

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

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

Image via NWS/Donald Sparks

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

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

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

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

Sourcing Opportunities and Ideas for Policy Innovation

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

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

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

Opportunities for Extreme Heat Policy Innovation

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

Facilitate Government-Wide Coordination

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

Infrastructure And The Built Environment

Accelerate Resilient Cooling Technologies, Building Codes, and Urban Infrastructure

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

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

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

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

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

Adapt Transportation to the Heat

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

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

Create More Heat-Resilient Schools for Sustained Learning

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

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

Make Housing and Eviction Policy More Climate-Aware and Resilient

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

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

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

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

Address Communities’ Needs for Long-Term Infrastructure Funding Support

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

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

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

Workforce Safety And Development

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

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

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

Build the Extreme Heat Resilience Workforce

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

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

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

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

Public Health, Preparedness, And Health Security

Build Healthcare System Preparedness

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

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

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

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

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

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

Reduce Energy Burdens, Utility Insecurity, and Grid Insecurity

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

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

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

Address Critical Needs of Confined Populations Facing Heat

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

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

Food Security And Multi Hazard Resilience

Anticipate and Prevent Supply Chain Disruptions 

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

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

Connect Drought Resilience and Heat Resilience Strategies

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

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

Planning And Response

Reform the Benefit-Costs Analysis

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

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

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

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

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

Spur Insurance and Financing Innovation

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

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

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

Incorporate Future Climate Projections into Planning at All Levels

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

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

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

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

Data And Indices

Set Standards for Data Collection and Analysis

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

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

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

Create Regulatory Oversight Infrastructure for Extreme Heat

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

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

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

Conclusion

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

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

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

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

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

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

The coalition’s recommendations include:

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

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

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About UndauntedK12

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

About Federation of American Scientists

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

KEY TAKEAWAYS

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

KEY FACTS

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

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

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

Climate change & agriculture

Rising Temperatures

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

Threats to Farmworkers

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

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

Compounded Hazards

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

Challenges faced by migrant workers

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

Understanding the Vulnerabilities

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

Harsh Working Conditions

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

Barriers to Protection

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

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

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

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

via Tim Mossholder

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

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

Review of existing protections

Federal Efforts

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

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

State-Level Protections

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

Legislative Challenges & Need for Unified Approach

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

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

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

Engaging Stakeholders: Beyond Public Comment

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

Challenges in Traditional Engagement

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

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

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

Looking Forward: Systemic Improvements & Community Collaboration

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

Systemic Changes Needed

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

Fostering a Safe Reporting Culture

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

Role of Community & Grassroots Advocacy

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

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

The Power of Investment

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

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

via Tim Mossholder

Envisioning Enhanced Regulatory Capacity

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

Economic Benefit

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

Employer Benefit

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

Call for Collaborative Action

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

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

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

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

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

APPENDIX A: RESOURCE GUIDE

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

Resources for Migrant Workers

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

Resources for Employers

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

Resources for Policymakers

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

APPENDIX B: ACTION GUIDE

Support Legislative Changes

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

Participate in Advocacy Efforts

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

Engage in Policy Development

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Extreme Heat Policy Innovation Summit 

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

Here are the FAS policy proposals to address extreme heat.

Infrastructure and the Built Environment 

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

A Comprehensive Strategy to Address Extreme Heat in Schools 

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

Adapting the Nation to Future Temperatures through Heat Resilient Procurement 

Kurt Shickman | link

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

Larissa Larsen | link

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

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

Workforce Safety and Development

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

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

June Spector | link

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

Margaret Morrissey-Basler, Douglas J. Casa | link

Public Health, Medical Preparedness, and Health Security

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

Tracking And Preventing The Health Impacts Of Extreme Heat 

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

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

Justin Schott | link

Enhancing Public Health Preparedness For Climate Change-Related Health Impacts

Kari Nadeau, Nile Nair | link

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

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

Addressing The National Challenges Of Extreme Heat By Modernizing Preparedness Approaches 

Nathaniel Matthews-Trigg | link

Food Security and Multi-Hazard Resilience

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

U.S. Water Policy For A Warming Planet

Lori Adornato | link

Planning and Response

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

Combating Extreme Heat With A National Moonshot

Louis Blumberg | link

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

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

Johanna Lawton | link

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

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

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

Vivek Shandas, Grace Wickerson, Autumn Burton | link 

Data and Indices 

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

Improve Extreme Heat Monitoring By Launching Cross-Agency Temperature Network

Bianca Corpuz | link

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ABOUT FAS

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

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

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

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

Challenge and Opportunity

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

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

Planning for Future Risks of Extreme Heat 

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

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

Federal Support for Risk Mapping and Planning

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

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

Plan of Action

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation 4. Support fiscal planning and funding prioritization.

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

To support fiscal planning and funding prioritization,

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

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

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

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

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

Conclusion

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

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

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

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

Challenge and Opportunity

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

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

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

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

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

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

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

via Climate.gov

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

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

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

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

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

Plan of Action

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

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

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

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

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

via USGS

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

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

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

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

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

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

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

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

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

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

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

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

Congress can further support these actions by:

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

Figure 5. Map of insured flood claims

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

Conclusion

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

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

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,

• (a) The Federal Highway Administration (FHWA) has reported on extreme heat and documented heat impacts on asset management, where the Department of Transportation (DOT) in multiple states, including Arizona’s DOT, and the National Cooperative Highway Research Program have developed evaluation methods for quantifying impacts, and
• (b) Impacts to critical infrastructure have been quantified across sectors and should include representative agencies such as transportation (e.g., FHWA, DOT), transit (e.g., Federal Transit Authority (FTA)), energy (e.g., Department of Energy (DOE), EPA, water/sanitation (e.g., U.S. Army Corps of Engineers (USACE), Bureau of Reclamation (BOR)), telecommunications (e.g., Department of Homeland Security, Federal Communications Commission), social (e.g., HUD, HHS, Department of Education (ED)), and environmental infrastructures (e.g., EPA, USACE, National Parks Service (NPS)). 

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.

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.

Preparedness

(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.

Response

(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.

Conclusion

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.

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:

• CDC should actively support efforts within the NSSP to expand tracking of more conditions tied to the health impacts of extreme weather events.  In parallel, new research initiatives are needed to link these new surveillance syndromes with health system burden and health outcomes to improve the real-world predictive utility of these efforts.
• CDC should work with the Department of Education to track school closures and student absences, and with OSHA to track work-related injuries during extreme weather conditions. The National Institute for Occupational Safety and Health (NIOSH) at CDC will be a key partner in developing worker tracking as they already conduct surveillance including worker absenteeism and mortality. Similar programs should be constructed for schools, for example, leveraging the student attendance counts already collected by states to make a school-absenteeism surveillance program (e.g., by expanding existing efforts like the School-Based Active Surveillance Program or the Youth Risk Behavior Surveillance Program, which each track limited data for different goals).
• CDC should develop guidelines and funding for cities and states to expand their individual syndromic surveillance capabilities. Achieving uniformity across the nation is a major difficulty with expanding the NSSP, and CDC should work with the NSSP Community of Practice to develop, then promote, best practices through partnership with jurisdiction-specific syndromic surveillance.

To improve forecasting capabilities of health impacts:

• Congress should fund the CDC to expand its Center for Forecasting and Outbreaks Analytics (CFA) to include forecasting of environmental conditions and their health impacts. The HeatRisk service is exactly the kind of program that should also be available for smoke and cold—it clearly integrates the best science of health impacts of extreme weather events with best practices for public communications.
• Congress should fund the CDC to expand the CFA to make forecasts of operational needs for hospitals. Many hospitals now operate on a just-in-time system of stocking medical equipment that relies on typical-use rates that rapidly change during an extreme-weather event. A key piece of this operational forecasting should include potentials for cascading failures, as extreme-heat-caused failure of the electric grid is predicted to have major cascading failures in the health system. 

To improve the ability to track health impacts:

• CDC should develop guidance and training on reporting environmental conditions as contributing factors on death certificates, similar to their toolkit on Death Scene Investigation After Natural Disaster or Other Weather-Related Events and other existing training. The guidance and training could be developed by analyzing existing practices from across the county. Additional training for medical providers are listed in a separate memo.
• CDC’s National Center for Environmental Health, as part of their Disaster Epidemiology and Response program, should develop guidance for states on reporting heat-related deaths to the National Vital Statistics System that includes information about how free-form text from medical examiners is coded by state-level health officials. This recommendation builds on the prior recommendation—both are needed to ensure that heat-related deaths are appropriately counted at the national level.
• CDC should expand its use of excess-death and flu-burden methods to provide official estimates of the health impacts attributable to extreme heat beyond those reported on death certificates. Such methods exist and have been used for heat; they should be standardized and regularly applied at the federal level.
• CDC should work with the Environmental Protection Agency (EPA) to expand its 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 isused widely in policy. Specifically, EPA should expand its BenMAP software to: (1) include the ability to model deaths due to heat and cold and their consequences (e.g., wildfires, industrial accidents); (2) add the capability to run in real time on real-time environmental data feeds; (3) include forecasting in the tools based on short-term forecast feeds and longer-term climate models; (4) integrate the outputs as a health-impact “nowcast” available with other data feeds such as the Heat and Health Tracker, the Heat Related EMS Activation Surveillance Dashboard, and/or the HeatRisk tool.
• Develop an extreme weather event impact self-report tool and database similar to the USGS “Did You Feel It?” web-based local data collection system.  The resulting  qualitative data will permit more in-depth understanding of the personal, family, community, and health system  impacts of  weather-related emergencies.
• Several actions are needed to support the preceding recommendation, including additional interagency (EPA/CDC/National Oceanic and Atmospheric Administration (NOAA)) collaboration and data sharing. Research is needed to develop the health-impact functions for the BenMAP tool, which could be solicited in a research call such as through National Institutes of Health (NIH) Climate and Health initiative, conducted by CDC epidemiologists, 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.

Recommendation 2. Improving Patient Care

To integrate environmental conditions into EHRs nationwide:

• Environmental conditions should be integrated with EHRs as part of data modernization efforts within federal medical providers. Examples include the Federal Electronic Health Record Modernization program and Veterans Health Administration (VHA) EHR modernization effort.
• The major EHR providers should pilot the incorporation of environmental data into EHRs beyond the federal medical systems. University medical centers would be ideal test partners for this before expansion to all hospitals nationwide.
• Federal agencies promoting the uptake of EHRs, such as the Centers for Medicare and Medicaid Services (CMS) Promoting Interoperability Program, should include the integration of environmental data in electronic health records in the tools they promote.
• CDC should add “Tracking Disasters” as a key priority in its Data Modernization Initiative and use that program to encourage tracking of disaster-relevant data, such as environmental conditions, along with health records.

To support patients during extreme heat:

• Expand the definition of medical devices to include items that protect against extreme weather. For example, air-conditioning units and other strategies that reduce personal risk of heat illness should be eligible for purchase with health savings accounts and with Medicare/Medicaid.

Conclusion

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.

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. 

Conclusion

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.

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:

• Direct studies to evaluate and directly quantify the ecosystem services and disservices of urban forestry under current and future climate scenarios.
• Dedicate resources to expeditiously create a national inventory of urban forests, indexed by location, species, and age.
• Direct agencies to build methodologies as a first case study to detail how natural capital assessments for nature-based solutions can be undertaken.
• Build a strategic plan for tree planting and maintenance by climate region and city type, including the development of decision support tools for state and city-wide urban foresters to best allocate resources.
• Undertake evaluative work to direct already appropriated funds through the IRA and BIL to urban forestry projects with the highest benefit to communities locally and regionally.

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:

• Undertake studies to quantify and evaluate health-related ecosystem services and disservices of urban forestry under various climate scenarios in the short and long term (NIH, CDC, USDA).
• Quantify the correlation between increased greening and lower air temperatures, reductions in energy demand, benefits to energy efficiency of buildings and homes, and decreases in greenhouse gas emissions (EPA, DOE, NOAA, NASA, USDA).
• Examine the differential impacts of urban forests according to the principles of environmental justice (NIH, USDA, EPA, NSF).
• Determine the future-proofing needs of urban forestry investments across the U.S.’s 12 climatic regions (USDA, NOAA, NASA).
• Reexamine existing correlative studies to determine underlying causation regarding urban forestry human health benefits and ecosystem impacts (CDC, NSF, EPA, USDA).
• Undertake implementation studies to ensure the feasibility, cost, and efficacy of an urban forest intervention to limit the effects of extreme heat on communities (USDA, NOAA, NIH, NASA).

Conclusion 

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.