Adapting the Nation to Future Temperatures through Heat-Resilient Procurement

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

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

Challenge and Opportunity

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

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

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

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

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

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

Plan of Action

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

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

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

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

Non-Federal Stakeholders

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

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

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

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

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

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