Through partnership with the Doris Duke Foundation, FAS is building bridges between the environmental community and the health community around extreme heat. Informed by the Metropolitan Area Planning Council’s and Boston University’s symposium on heat-health action and partnerships in Massachusetts, FAS seeks to showcase how local and state governments are working across sectors to address extreme heat. With heat being a rising cause of illness and death, these case studies show how governments are engaging in policy entrepreneurship to protect lives through targeted data collection, research, and policy and program design. Lessons learned from these cases can inform how state and local governments can leverage their existing capabilities to reduce risk and improve health outcomes.

Promising examples of progress are emerging from the Boston metropolitan area that show the power of partnership between researchers, government officials, practitioners, and community-based organizations. These include efforts to (1) assess the risk that heat poses to populations, operations, and ways of life, (2) reduce the potential for harmful exposures, and (3) strengthen the public health response. The following cases draw from examples shared at “Fostering Collaborations: A Symposium to Advance Equitable Heat Health Actions”, hosted by Boston University and the Metropolitan Area Planning Council (MAPC) in June of 2025, and show what historically cold places can do to adapt to extreme heat. These cases serve as a resource for documenting progress made across the region. The recommendations in this report are informed by the cases and build from the Metro Mayors Climate Taskforce’s “Keeping Metro Boston Cool: A Regional Heat Preparedness and Adaptation Plan” and upon leading practices identified in MAPC’s Climate Resilience Playbook (a guide of resilience actions for Massachusetts municipalities).

Case studies in this brief include:

• Targeting Assistance to the Most Heat-Impacted Homes and Buildings
• Data-Informed Land Use and Urban Planning Solutions to Cool Blocks and Communities
• Leveraging an Ecosystem of Health System Partnerships to Advance Extreme Heat Emergency Management 

Many people traditionally associate extreme heat with “hot” places, like the Southwest, Texas, and the Southeast, and their record-breaking heat and humidity. While stark, these places are more likely to have the infrastructure (such as widespread adoption of cooling systems) and policies and practices (such as Chief Heat Officers, heat response plans, and protections like utility shutoff prevention and indoor cooling standards) needed to safeguard populations from excess heat exposure. While there is still a lot to do, many communities in the southern United States have already begun to adapt daily life and routines to extreme heat conditions. 

The northern United States is at a frontier of grappling with extreme heat. Places with typically colder climates, like Massachusetts – state motto, “By the sword we seek peace, but peace only under liberty”–  are experiencing extreme heat. The populations here are neither acclimatized to extreme heat nor equipped with the necessary adaptations. This is putting significant pressure on people’s health and livelihoods, the built environment, and the local economy. For example, this summer, the City of Boston declared three heat emergencies, including a June heat wave that smashed previous early season records as temperatures soared to 102°F. In total, the Boston metropolitan area experienced 19 days over 90°F in 2025. By 2030, less than five years away, the area could experience nearly 40 days over 90°F.

Health Dangers of Extreme Heat

Extreme heat exposure causes heat-related illnesses such as heat stress and heat stroke and puts significant pressure on the cardiovascular system and the kidneys, and strains the health of populations with pre-existing conditions or on medications that impact sweat production. While extreme heat can impact everyone, certain populations face higher risks, including children, elderly adults, pregnant mothers, those without access to air conditioning, and outdoor workers. Heat related health impacts are on the rise in Boston.

Protecting human health from extreme heat requires a combination of approaches, including preventing exposure, minimizing risk, increasing adaptive capacity, and bolstering health system preparedness:

• To prevent exposure, decision makers need to consider the “settings” where populations spend the most time from day to day, like homes, schools, child and elder care facilities, workplaces, public transportation, and outdoor recreation spaces, and the institutions and policies that can determine the physical design and operations of these spaces. 
• To minimize risk, populations that are more vulnerable need to be made aware of and protected by strategies that minimize heat gain, such as wearing optimal clothing and reducing behaviors that increase metabolic rate and generate heat.
• To increase adaptive capacity, populations will need to engage in strategies that help their bodies acclimatize to the hotter temperatures as well as recognizing symptoms of over-exposure and taking steps to seek protection or care. 
• To bolster health system preparedness, public safety and health care institutions need to be readied and supported to act quickly and effectively to save lives.

Massachusetts’ Heat Policy Heats Up

Strong policies that support public health response to heat can reduce the risk of systemic failures and protect more lives. To succeed, these policy efforts require public-private partnerships, empowered public health responses, and strong community engagement. 

There is a growing ‘community of practice’ on heat in Massachusetts, consisting of local and state government leaders, academic partners, non-profits, health care institutions, and private sector actors seeking to advance solutions to safeguard lives during heat emergencies and build towards a heat resilient future. Effective partnerships help understand the extreme heat problem, realize new heat-health interventions, develop the evidence around effectiveness, and foster shared accountability. At this critical juncture of changes to federal policy and governance on heat, effective state and local preparedness for extreme heat is critical to safeguard human health, prevent critical infrastructure damages, and secure economic livelihoods. These following cases show what’s possible.

Massachusetts’ Heat-Health Actions and Innovations

Innovation 1. Targeting Assistance to the Most Heat-Impacted Homes and Buildings

In Massachusetts, most residential buildings and many public buildings were designed for a climate with cold winters and temperate summers and were not built with air conditioning (AC) and other cooling systems. The cost and difficulty of retrofitting these buildings for increasingly hot summers is a significant barrier to being better prepared for heat. Many homeowners, renters, and public building operators rely on window AC units, which are both less effective and less efficient than central AC. This in turn increases the cost of operation and monthly energy bills.

For housing, the role of public policy is threefold: (1) establishing minimum habitability standards that affirm a right to cooling, such as indoor temperature maximums for rental housing, (2) maintaining access to energy during extreme heat events through utility shut off moratoriums and expanded energy bill assistance, and (3) streamlining available funds to systematically improve the housing stock to make it more adapted to rising temperatures. The Massachusetts state government can play their part in this ecosystem of protections by regulating utility companies to ensure consumer protections during extreme heat events, improving the floor of minimum habitability through the state sanitation code, bringing together state, federal, and private funding resources that can be used to retrofit the housing stock and develop new housing stock more resilient to extreme heat. Municipal governments’ can play their part by setting beyond code measures to ensure safe indoor temperatures, bringing together resources to serve households in need of housing upgrades, coordinating and empowering local partners to serve the most energy insecure populations and upgrading the public housing stock under their management. Given limited public resources, the most important first step is to prioritize where support should be directed.

Data gathering about risk and vulnerability can help communities get started. With investment from the state of Massachusetts’ Municipal Vulnerability Preparedness program, cities and towns in the Boston metropolitan area, like Everett, have been able to identify their community “hot spots”, where residents experience higher ambient temperatures as a result of urban design choices. This is a part of a broader trend in the Boston metro region to map heat vulnerability, such as the Wicked Hot Mystic Campaign and the Framingham-Natick-Ashland-Holliston Heat Watch Campaign. These higher ambient temperatures can also lead to overheating indoors, requiring more mechanical cooling to maintain habitable temperatures and also limiting the use of passive ventilation cooling at night as cities take longer to cool down. 

With the hot spots identified, key anchor institutions like Cambridge Health Alliance and community organizations like Everett Community Growers are working together to meet the needs of the most vulnerable residents, which includes improving housing’s resilience to extreme heat. One-stop shops for residential weatherization, such as Philadelphia’s Built to Last program, can bring all sources of funding for home improvements under one roof with technical support, making it easier for low-income residents to access available resources. Further, as places like Everett seek to expand their housing supply, it is critical that new stock is built to withstand rising temperatures, mitigate urban heat island effects, and is affordable to current residents.

Boston University’s C-Heat Study is another example of a community-engaged temperature sampling study to understand the lived experiences of residents during extreme heat events. This study places sensors inside of people’s homes in Chelsea and East Boston to see how hot it gets indoors. Many of the homes sampled exceeded temperatures widely recognized as “comfortable” by international standards bodies like the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) in spite of 100% of households having some form of air conditioning. Factors that impacted household’s ability to cool include whether they could use their AC (e.g. due to cost), AC-type, location of the unit, and roof type. Through this critical participatory research, the research team and the community partners developed a set of policy recommendations to mitigate heat’s impacts indoors. These include updates to the state sanitary code or municipal ordinances that set indoor temperature maximums and require AC, weatherization, and other strategies in rental units to maintain safe indoor temperatures, as well as creating programs that encourage landlords to retrofit rental housing. Looking ahead, it will be essential to ensure that the energy needed to run these AC systems is affordable, especially as energy prices rise. The proposed legislation “Energy Affordability, Independence, and Innovation Bill” seeks to lower the cost of energy while also protecting people from utility shutoffs while “An Act Promoting Resilience Against the Heat-Related Impacts of Climate Change” seeks to create energy assistance programs for cooling-related costs.

Publicly-owned buildings and other infrastructure also need to be retrofitted to be more resilient to temperature extremes through cooling system upgrades and passive cooling designs. These strategies benefit populations that spend a significant amount of time in public buildings, such as school-aged children and their instructors. Understanding the scope and scale of the problem is also essential for these buildings. For example, researchers at Boston University (BU) are partnering with Boston Public Schools (BPS) to understand the conditions inside of classrooms. Dr. Patricia Fabian of BU and BPS have installed temperature sensors in over 3,600 rooms within school buildings and created a one-of-a-kind dataset of the state of heat inside of schools. Their results show that within a single school building, the difference between the coolest and hottest classrooms could be more than 50°F. Understanding which classrooms cannot stay cool on extreme heat days is critical for facilities managers and school leadership to be aware of and capable of responding to. It also helps to identify places to target cooling interventions, and justify infrastructure upgrades. The proposed Mass Ready Act would create sources of funding that could be used to finance these identified improvements.

Opportunity Areas for Further Action:

• Expand community-led and cross-sector partnerships to study indoor temperatures and its impacts on population health, wellbeing, and livelihoods.

• Secure near-term access and affordability to cooling by creating programs that provide financial assistance to households that struggle to pay their energy bills.

• Institutionalize cooling in building and housing policy by crafting and implementing building codes and public health regulations that formally integrate thermal safety.

• Retrofit infrastructure for climate resilience, targeting the most vulnerable buildings and homes first. One stop shops for housing upgrades are especially beneficial to reduce the application burden on the most vulnerable homeowners.

• Ensure new construction is built to keep occupants comfortable in the face of anticipated future extreme temperatures.

Innovation 2. Data-Informed Land Use and Urban Planning Solutions to Cool Blocks and Communities

Community-wide cooling solutions can lower ambient outdoor temperatures, reducing the load on indoor cooling systems and mitigating the health risks of being outside. Public policy is a critical enabling function. For example, zoning policy can be leveraged to require or encourage strategies that cool communities, such as urban forestry, shade infrastructure, cool pavements, walls, and roofs, and green roofs. Outdoor spaces under public ownership can be also outfitted with these heat-mitigation strategies, benefiting populations that use transit or primarily walk or bike as well as populations that spend significant amounts of time outdoors. 

Municipal governments in Massachusetts have oversight over land use and zoning as well as own, manage and maintain some public outdoor spaces and right-of-ways. Thus, municipal governments can introduce zoning regulations to drive innovation in heat-resilient design through new construction or upgrades to existing construction. For example, the Massachusetts state government operate the public transportation system, either through the Massachusetts Bay Transportation Authority or 15 Regional Transportation Authorities, manages land and property, and reviews local zoning ordinances for consistency with state law. Thus, the state is responsible for ensuring transportation users have adequate protection from extreme heat exposure and can also be a partner to local governments implementing heat-resilient zoning. The state also is a source of funds, bringing in revenue and also distributing federal dollars. Data on the current impacts of heat can inform the work of land use and urban planners to design high-impact solutions that minimize future heat exposures while also educating the public on heat’s risks.

Governments in the Boston metropolitan area are developing innovative solutions to understanding urban heat. For example, the Boston Region Metropolitan Planning Organization (MPO), the transportation planning agency for the region, was awarded a $1 million dollar grant from the State of Massachusetts to assess heat’s risk to pedestrians and bikers. The “Neutralizing Onerous Heat Effects on Active Transportation” (NO-HEAT) study produced a new set of microclimate data focused on human-scale perception of heat and leveraged that alongside mobility data to identify high-volume routes in vulnerable communities with high risk of heat exposure. Following identification of priority corridors in partnership with Dr. Rounaq Basu of the Georgia Institute of Technology, the project leads from the MPO are now working with municipal staff and advocacy organizations to understand the impacts of this heat risk on people who are walking/biking and identifying solutions that minimize exposure. The project will also make its analysis of heat risk along walk/bike routes public on the Boston Region’s MPO’s website. In addition, an app will be piloted that can guide community members on how to choose transportation routes with more shade and greenery.  Going forward, this work could be expanded to the impacts of heat on public transportation users and how to mitigate that risk, such as through shaded bus shelters and cooling inside T-stations. 

Municipalities are also utilizing their existing resources and policy levers to drive urban transformation. In the City of Cambridge, planners are turning well-known heat islands in the city into gathering spaces with public art installations that reduce heat exposure. The Shade is Social Justice Program partners the City with local and regional artists, such as Massachusetts-based Art for Public Good, on installations around Cambridge that create shaded “third spaces” for public gathering and programming during hotter days. Through art and design, the City of Cambridge is facilitating both public education about extreme heat and its risks, reducing exposure, and creating forums to build community relationships that are key for community resilience. Beyond this work, the City of Cambridge is a leader in resilient land-use policy, creating one of the first performance-based standards for extreme heat mitigation. The “cool score” seeks to drive uptake of infrastructure solutions that mitigate urban heat island effects, and is required for all developments subject to the Green Factor Standard (e.g. new buildings, building enlargements of 50% or more, and surface parking area creation). These efforts underscore the importance of local government programs and policy in both providing and enabling shade and other cooling solutions that lower temperatures community-wide, ultimately benefiting businesses and residents who can stay cooler for less money.

Opportunity Areas for Further Action:

• Identify which stakeholders need to be at the table to create standardized heat vulnerability tools and how they guide decision-making. These tools can be used by city planners, public health departments, and community groups to prioritize high-risk areas and align investments. 

• Understand all the actors inside of each government and at different levels of government who are creating plans to reduce the risk of extreme heat in the built environment (e.g. MPOs and city planning offices) and de-silo these efforts.

• Craft best practices for heat land use and urban planning policy, such as effective heat action and resilience plans, standardized zoning and land use codes, and design guidance for reducing the risk of heat to transportation system users.

• Continue working with the state and fellow Regional Planning Agencies to implement and align the priorities of ResilientMass with ongoing regional planning work

• Invest in both temporary (e.g. pop up shade structures) and long-term solutions (e.g. expanded tree canopy) that mitigate heat at the local level.

Innovation 3. Leveraging an Ecosystem of Health System Partnerships to Advance Extreme Heat Emergency Management 

Across the nation, extreme heat is a public health emergency, causing increased rates of heat-related illness, emergency room visits, hospitalizations, and deaths. These impacts put strain on public safety systems and health care systems. Yet there is no widely agreed upon “playbook” for how to respond to public health emergencies caused by extreme weather events and no agreement on what resources should be made available. Federal law is unclear in its expectations of the roles of state and local governments in heat preparedness and response as well as the federal role in providing assistance. For example, it is unclear if a heat event would qualify for a Major Disaster Declaration under the Stafford Act and/or the Public Health Emergency Declaration under the Public Health Service Act. The costs to human health and wellbeing are not well-captured by the federal disaster declaration processes, which focus on acute and time-bound structural damage. 

The state of Massachusetts has the authority to declare a state of emergency, enabling flexibility to leverage state agency capacity to respond to emerging hazards. There has never been an extreme heat event declared as a state of emergency in Massachusetts. The City of Boston is one of the only municipalities in Massachusetts to have created a local heat emergency pathway and declare heat emergencies. The threshold for declaring a local emergency in Boston is clear, two or more days with a heat index of 95 degrees, which is below the threshold used by the National Weather Service. During these events, the City of Boston opens cooling centers, splash pads, and public pools, as well as creates pathways for shelter for the unhoused. Response is led by the Office of Emergency Management, which relies on federal funding for its operations and staff, and could be impacted by proposed policy changes at the federal level to put the onus of emergency preparedness on state and local governments. Boston’s model is one to learn from, where understanding the successes and challenges can help determine how to replicate across Massachusetts’s municipalities. Effective emergency management relies on public-private partnerships and the health sector is one of the most critical partners in responding to extreme heat.

Safeguarding health during acute extreme heat events is a matter of preparedness.  To be sufficiently prepared, residents should have access to basic information and support on how to effectively protect themselves from extreme heat, reducing their exposures, securing access to cool spaces, and ensuring adequate hydration. This needs to be done in languages that impacted populations speak, which has been done in cities like Los Angeles. More vulnerable residents should be supported in securing these protections by members of their community and by health care teams. For example, health care providers should screen patients for pre-existing conditions that make them more vulnerable to extreme heat, and be able to identify social services programs that can help them mitigate potential exposures, such as energy assistance. For example, the Boston Medical Center has created an innovative “Clean Power Prescription” program to provide energy assistance to the most vulnerable patients in their complex care management program. The Harvard T.H. Chan School of Public Health and Americares have also created a resource guide for physicians and clinics to prepare for extreme heat events, including a ‘Heat Action Plan’ that can be walked through with patients.

When a heat wave is predicted, it is critical to have early warning systems that allow people to activate their preparedness plans and brace themselves for the heat. The Bureau of Climate and Environmental Health at the Massachusetts Department of Public Health has created an unhealthy heat forecast which uses statewide hospitalization data to determine health-based “heat thresholds” for alerting the public and practitioners about upcoming heat events. The Bureau also sends tailored alerts to local public health officials, health care providers, and community-based organizations (this group must opt-in) to help them identify how to spot heat-related illness during the more extreme heat events, three or more days of 85°F. This communication is critical as these personnel are trusted messengers in their communities. Boston-area health systems are also taking action. Mass General Brigham is piloting artificial intelligence-powered tools that utilize patient records to identify those most at risk (e.g. because of age, health conditions, medications and where they live) and then provide patient-specific alerts based on that risk. Cambridge Health Alliance sends email alerts to patients during heat waves.

Finally, during a heat event, the emergency response workforce and the health care workforce needs to be prepared and able to triage and treat surges in heat-related and heat-exacerbated illnesses. Many health care providers are not trained on how to identify and effectively treat heat-related illness, which can hamper their effectiveness. That is why physician training programs like Harvard Medical School are integrating climate change into the curriculum for medical students and offering new fellowships to train climate-ready care providers. Yet these programs are only reaching a small portion of the health professions workforce each year. Scaling these types of programs is needed to ensure a wider swath of the health care workforce knows how to treat heat-illness and its broader impacts on human health, which will in turn improve data accuracy for heat-related health impacts. Additionally, health care systems are also not required to plan for heat and its impacts on care delivery and operations. There is also no regional coordination between systems to manage surges in care needs. Local governments and regional planning organizations like MAPC should be engaged with health care partners about their readiness for extreme heat.

Opportunity Areas for Further Action:

• Test and compare communication strategies (e.g. messages, channels, and messengers) to understand which strategies (e.g. heat alerts in clinical practice) are best at informing and encouraging action-oriented responses from the public.

• Develop screening questions for clinical settings to assess availability of air conditioning, social isolation, and other housing-related conditions as part of health screening.

• Determine what data is needed by municipalities to guide their response actions (e.g. the health impacts of extreme heat) and plan the acquisition of these data sets, like electronic health record data.

• Train local public safety, emergency medical services, health professionals, and other key partners in response to better capture the health impacts of extreme heat.

• Work regionally to develop a heat relief network, such as Maricopa County’s Heat Relief Network, to build connections and collaboration as well as resourcing and personnel sharing to ensure that the entire Boston Metropolitan area is ready for extreme heat.

Conclusion

Extreme heat governance is rapidly maturing to meet the needs of communities unaccustomed to extreme heat, particularly at the local and state levels. As described above, this work cannot be done alone: partnerships and collaborations are necessary to make even modest progress and most effective use of limited resources. Further, the above examples showcase how collaborative research in partnership with key stakeholders can be a powerful tool in guiding local and state government decision-making and informing the policymaking process. Through collective effort, real progress can be made to safeguard health in the face of extreme heat.

The opportunity areas identified by participants at Fostering Collaborations: A Symposium to Advance Equitable Heat Health Actions provide a roadmap for what can come next in local and state heat action in Massachusetts. Interested in getting involved? Please contact Kat Kobylt at KKobylt@mapc.org and head to our website here to learn more.

Currently, standardized testing is a necessary but often time-consuming process that is used to measure educational progress to improve educational outcomes and curricula; however, the immediate consumers of standardized tests are educators, students, and their caregivers who do not typically receive detailed information in exchange for the time spent studying for and taking these exams. This brief proposes reforming standardized test score reporting to improve achievement level labeling using more strengths-based language as well as to provide actionable feedback and personalized resources. This brief also proposes actionable steps to achieve this by one, increasing the number of test administrations to increase progress monitoring and adjustment opportunities before the end of the school year and two, provide educators with detailed information in the form of dashboards and ready  resources

Introduction

Standardized tests are ubiquitous in K-12 education in the United States. In fact, the average student spends 20-25 hours or more during the school year just taking standardized tests. In addition, the scores from these tests have high consequences for students and their educators, including promotion to the next grade or measurement of teacher quality. However, the data shows that test scores have largely stagnated since the 2002 passage of No Child Left Behind, which introduced the nationwide requirement to implement high-stakes testing. 

Due to the high stakes nature of these assessments, many educators feel that they have to adjust their curriculum and instruction to best suit material they believe will be on the test. This is sometimes to the detriment of teaching other skills or performing activities that might be more cognitively challenging or engaging. There is also limited information about the specifics of what is on the test, due to the proprietary nature of the questions and tasks on these exams. Many educators do not feel confident that they have thoroughly taught all of the material on the accountability exam. Finally, parents and guardians  also have difficulty understanding score reports. Regrettably, test results are often delivered between school years, after any potential tutoring or support could be delivered. 

To address these challenges, we need to overhaul the standardized testing and score reporting system to be more accessible to all of the end users of standardized tests: educators, students, and their families. This is especially important at a time when more universities are becoming test-optional and more families are choosing to opt their K-12 students out of summative standardized testing. Additionally, this poses a potential existential threat to testing publishers and also necessitates that the system adjust to the needs of the public. 

Improving Standardized Testing Score Reporting For Students and Guardians 

The core group most  impacted by standardized score reporting are students and their caregivers. Most families receive score reports that provide very high-level information about students’ performance, such as their overall test score relative to other students in their state and district. Some score reports provide slightly more information, but they are typically not specific to the individual student’s strengths and areas for growth. Nor do they provide actionable feedback or resources for how the student can improve low scoring sections or extend learning for areas of strength. Additionally, these reports do not include accompanying information, so it is very difficult for a parent/guardian to extrapolate from the score report specific areas to support or extend their child’s learning. 

Standardized test reports have a damaging effect on students’ academic identity and self-esteem. Many of these score reports use labels to describe achievement levels and more care should be embedded in this language. Results are sometimes described with labels like “below proficient,” which have been found to be damaging to students’ self-perception of their academic performance and ability to improve. Even slight changes to labels like the inclusion of the word ‘yet’ in “not yet meeting expectations” were found to be more encouraging than deficit-based labeling. Finally, many of these reports are not designed to be accessible for a wide range of disabilities or non-English languages, nor do they explain where the scores originated or how to apply them, which limits the number of students and caregivers who can access these reports or use their information to improve educational outcomes. 

The solution for students is  to redesign the score reports so that they are more actionable and positively framed in their achievement labels. Scoring should especially highlight what the student does well and frame the areas where the student needs support using growth mindset-facing language rather than deficit-based language. Additionally, these reports should provide resources and recommendations to remediate areas that still need improvement and to extend learning for learning domains that the student has already mastered.

Improving Score Reporting and Data Analysis For Educators 

The secondary group impacted by standardized testing score reporting are educators. Depending on the state or district, educators typically receive a general summative report about their incoming students’ performance on last school year’s standardized testing as well as a report about their previous students’ performance, especially as it applies to measures of teacher quality. Depending on the state/district, this report tends to have slightly more granular information than the student-facing reports. However, this still does not provide detailed information on the specific skills where each student needs additional support. Moreover, even if the educator receives detailed standards/objectives that each student missed on the previous year’s exam, they do not receive specific information on how to take that report and use it to remediate skills into their current curriculum. There is also frequently no time in the school year to remediate the skills that still need to be learned from the previous year nor planning time for educators to adjust current grade level curricula to allow for robust remediation. Finally, when educators receive these reports over the summer or in the early fall, this is far too late for the educator to adjust their instruction and support their learners during the school year. Ideally, teachers would have interim progress reports during the school year so that they could address and support existing issues while they are still teaching.

To support educators, the score reporting process needs an additional component that helps educators translate score reports into actionable pedagogy that blends with current grade level curricula. This should include diverse programs of support for the different patterns of skills and types of students. Additionally, there should be a mid-year process for collecting and reporting data. This way, educators can support struggling students before the accountability test at the end of the year. This could mean that the testing system shifts such that the more summative assessment is offered at the middle of the school year; or it could mean distributing the average 2-3 day end-of-year assessment days throughout the school year, to not increase the number of days being spent testing.

Areas for Improvement 

A three-pronged approach would greatly improve the testing system. The first is to create more in-depth score reports that are more actionable. The second is to create skill-based dashboards that teachers can access to support remediation in real time. Thirdly, the long-term plan for this work would be to distribute accountability testing across the school year so that there are more opportunities for catching students who struggle before the school year is over. Taken together, this approach provides a starting point for improving the testing system for educators, students, and their communities. 

More Actionable Score Reporting That Includes Resources

The first, most easily fixed issue is to support an improved score reporting system that is more detailed and actionable for students and their caregivers. Instead of just a scale score and the overall achievement level that the student has attained, a revamped score would include more detailed feedback about the student’s strengths and areas for improvement. For example, these reports could include links or attachments to additional open educational resources recommended by that state/district to help improve those skills. These reports should also include information about what the student does well and provide resources or recommendations for how to extend or further develop those skills as well. 

To create enhanced score reports, there needs to be a larger consensus about a score report’s basic guidelines. The Standards for Educational and Psychological Testing can assist with basic score reports; however, these recommendations do not include any information about using score reporting as a method for supporting student learning or fully capturing student learning.  As part of this process, the larger organizational, state, and federal educational regulatory bodies must decide on a set of guidelines for score reporting. As a starting point, groups like State and District-Level Education Associations, as well as the Association of Test Publishers, could develop resources describing best practices.

One potential method for funding these innovative changes to testing would be for the states who were interested in overhauling their system to apply for an Innovative Assessment Demonstration Authority Grant; however, this might need adjustment to fund the proposed policy adjustment. Additionally, standardized testing represents a large expenditure for each state. Each state’s Department of Education could decide to use a “Pay for Success” approach in which each state or large district sets outcome measurements for how they would like their testing program to be adjusted to be more usable for students and educators and then only deliver on their procurement decision if these measures are met. 

More Checkpoints, Fewer Stakes

More radically, the accountability system needs to shift to one in which huge decisions about student ability and teacher quality are not just down to one test that takes place one time a year that is not directly related to the students’ context or immediate knowledge. There are a variety of different reasons why that test would not reflect the true ability of students; everything from illness or anxiety to certain types of disability that are not compatible with one-time assessment. Instead, smaller, lower-stakes assessments should be offered more frequently throughout the school year so that misconceptions and gaps in knowledge can be addressed more effectively and responsively. One model that was piloted in Louisiana was to offer three smaller exams across the school year that were aligned to the English Language Arts (ELA) curriculum instead of reading unrelated, decontextualized passages. This approach is fairer because it removes the impact of students’ background knowledge and is a truer measure of students’ learning from  that year’s curriculum. Additionally, many schools have switched to using the Star assessment system, which is a computer-adaptive test that can be administered multiple times throughout the year to support frequent checks on student learning. The Star assessment system also provides more detailed progress monitoring for measuring student learning than one summative assessment. 

Alternatively, instead of standardized assessment, Performance-Based Learning is another way to capture what students have learned throughout the whole school year. This model involves project-based assessments that lead to a summative portfolio review that determines graduation/retention criteria instead of reliance on external standardized assessments. This system is lower stakes for students because it gives them the whole school year to demonstrate their knowledge and mastery of the curricular standards. It also provides a lot more agency for students and educators to scaffold and support students in demonstrating their knowledge in much more diverse ways. The largest difficulty with this process would be state and nation-wide consensus on what these systems look like and how to ensure consistency between grade level projects and accountability.

Dashboards for Teachers

In addition to improved score reporting, educators should receive a more detailed set of skills and their current students’ progress in each of these. This report should also be tied in the current curriculum that the teacher is using. This way, the system can recommend lessons and materials to remediate the skills students struggle with as well as to provide extension for areas where students are already proficient. An example of this that was found to work was an increase in math performance in Maine using the ASSISTments platform to tie specific content to targeted student homework practice.  Classroom time is precious. Knowing more about the specific lessons that are needed to best support growth and achievement is paramount to improving student learning. The decision about what to include in the dashboard would initially be left to the discretion of the curriculum/test makers; however, this would also likely need to be decided based on best practices as well. 

Conclusion 

The current state of the field for standardized testing is very unidirectional – students take summative assessments and these scores are used to make judgements about students, teachers, and funding for their schools. Despite spending a large amount of classroom time just taking the exams, not including all of the test preparation that goes into sitting for those exams, there is very little direct benefit to teachers and students from taking these assessments. For example, student scores have not improved nationally on the “Nation’s Report Card” in over a decade, despite increased nationwide testing and accountability. Additionally, testing is experienced as an extremely stressful period that has little positive immediate benefit for students.  Making the score reporting system more of a “two way street” in which students, educators, and their families can glean actionable information about how to support student success will make this much more of a useful process that will support student achievement, especially for students with disabilities and students who are approaching grade-level proficiency. 

Frequently Asked Questions

What is an example of innovative assessment used at the state level?

The Massachusetts Consortium for Innovative Education Assessment (MCIEA) is an example of many of the features discussed above. Many schools and districts within the state of Massachusetts have agreed to use performance tasks throughout the school year as a more robust measure of student learning. MCIEA also has an overview dashboard that measures school quality, not just through academic achievement. The dashboard considers school culture, access to resources, and student and community wellbeing. While MCIEA does not address student-specific feedback, it does provide alternative methods of measuring school quality. It is also an example of dashboards being used to disseminate school quality information to the larger public.

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What is an example of how test scores are explained to students and their guardians?

One example of how some of the recommendations above function is evidenced through the work done at ERB. This company is an assessment provider; however, they provide specific reports to the school leadership, the teachers and students, and their families. Each of these reports is tailored to the specific needs of each group and the team also helps facilitate webinars and other resources to help all groups to understand the test scores and how to use these best in improving student learning and outcomes.

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Extreme heat poses serious and growing risks to children’s health, safety, and education. Yet, schools and childcare facilities are unprepared to handle rising temperatures. To protect the health and well-being of American children, Congress should (1) set policies that guide childcare facilities and schools in preparing for and responding to extreme heat, (2) collect the data required to inform extreme heat readiness and adaptation, and (3) strategically invest in necessary infrastructure upgrades to build heat resilience.

Children are Uniquely Vulnerable to Extreme Heat Exposure and Acute and Chronic Health Impacts

At least five factors drive children’s vulnerability to negative health outcomes from extreme heat, like heat-related illnesses and chronic complications. First, children’s bodies take a longer time to increase sweat production and acclimatize to higher temperatures. Second, young children are more prone to dehydration than adults because a larger percentage of their body weight is water. Third, infants and young children have challenges regulating their body temperatures and often do not recognize when they should act to cool down. Fourth, compared with adults, children spend more time active outdoors, which results in increased exposure to high ambient heat. Fifth, children usually depend on others to provide them with water and protect them from unsafe outdoor environments, but children’s caretakers often underestimate the seriousness of the symptoms of heat stress. Research shows that extreme heat days are linked to increased emergency room (ER) visits for children, especially the 16% of children living at or below the federal poverty line. Extreme heat also exacerbates children’s chronic diseases, like asthma and eczema, increasing health care costs and decreasing children’s overall quality of life.

The Consequences of Chronic Extreme Heat Exposure on Children’s Learning and Well-Being 

Studies show that excess temperatures reduce cognitive functioning. Hot weather also impacts children’s behavior, making them more prone to restlessness, irritability, aggression, and mental distress. Finally, nighttime extreme heat exposure can disrupt sleep patterns, making it harder to fall asleep and stay asleep. These factors can all reduce children’s ability to focus, learn and succeed in school. For each 1°F rise in average annual temperature in school districts without air conditioning or proper heat protections, there is a 1% drop in learning. The Environmental Protection Agency found that these learning losses could translate into nearly $7 billion dollars in annual future income losses if warming trends continue.

Extreme Heat’s Threat to Schools and Childcare Facilities

Rising temperatures force school districts and childcare facilities into a dilemma: choosing between staying open in unsafe heat or closing and disrupting learning and care. 

Staying open can expose students and young children to extreme indoor and outdoor temperatures. The Government Accountability Office found that 41% of U.S. schools need to upgrade their heating, ventilation, and air conditioning (HVAC) systems: upgrades that will cost billions of dollars that schools in low-income areas do not have. Similar infrastructure challenges extend to childcare facilities. Extreme heat also makes outdoor recess more dangerous, as unshaded playgrounds and asphalt surfaces can heat up far above ambient temperatures and pose burn risks. 

Yet when schools close for heat, children still suffer. Even five days of closures for inclement weather in a school year can cause measurable learning loss. Additionally, students may lose access to school meals; while food service continuation plans exist, overheated facilities can complicate implementation. Many children, especially in low-income families, also don’t have access to reliable cooling at home, meaning that when schools close for heat, these children receive little respite. Finally, parents are directly impacted as well: school closures also mean parents lose access to childcare, forcing many to miss work or pay for alternative arrangements, straining vulnerable households. 

Advancing Solutions that Safeguard American Children from the Impacts of Extreme Heat

To support the capacity of child-serving facilities to adapt to extreme heat, Congress should direct the Department of Education to develop extreme heat guidance, technical assistance programs, and temperature standards, following existing state-level policies as a model for action. Congress should also direct the Administration for Children and Families to develop analogous policies for early childhood facilities and daycare centers receiving federal funding. Finally, Congress should direct the U.S. Department of Agriculture to develop a waiver process for continuing school food service when extreme heat disrupts schedules during the school year. 

To support improved federal data collection efforts on extreme heat’s impacts, Congress should direct the Department of Education and Administration for Children and Families to collect data on how schools and childcare facilities are experiencing and responding to extreme heat. There should be a particular focus on the infrastructure upgrades that these facilities need to make to be more prepared for extreme temperatures — especially in low-income and rural communities.Lastly, to foster much-needed infrastructure improvements in schools and childcare facilities, Congress should consider amending Title I of the Elementary & Secondary Education Act or directing the Department of Education to clarify that funds for Title I schools may be used for school infrastructure upgrades needed to avoid learning losses. These upgrades can include the replacement of HVAC systems or installation of cool roofs, walls, and pavement, solar and other shade canopies, and green roofs, trees, and other green infrastructure, which can keep school buildings at safe temperatures during heat waves. Congress should also direct the Administration for Children and Families to identify funding resources that can be used to upgrade federally-supported childcare facilities.

Public health insurance programs, especially Medicaid, Medicare, and the Children’s Health Insurance Program (CHIP), are more likely to cover populations at increased risk from extreme heat, including low-income individuals, people with chronic illnesses, older adults, disabled adults, and children. When temperatures rise to extremes, these populations are more likely to need care for their heat-related or heat-exacerbated illnesses. Congress must prioritize addressing the heat-related financial impacts onthese programs. To boost the resilience of these programs to extreme heat, Congress should incentivize prevention by enabling states to facilitate health-related social needs (HRSN) pilots that can reduce heat-related illnesses, continue to support screenings for the social drivers of health, and implement preparedness and resilience requirements into the Conditions of Participation (CoPs) and Conditions for Coverage (CfCs) of relevant programs. 

Extreme Heat Increases Fiscal Impacts on Public Insurance Programs

Healthcare costs are a function of utilization, which has been rapidly rising since 2010. Extreme heat is driving up utilization as more Americans seek medical care for heat-related illnesses. Extreme heat events are estimated to be annually responsible for nearly 235,000 emergency department visits and more than 56,000 hospital admissions, adding approximately $1 billion to national healthcare costs. 

Heat-driven increases in healthcare utilization are especially notable for public insurance programs. One recent study found that there is a 10% increase in heat-related emergency department visits and a 7% increase in hospitalizations during heat wave days for low-income populations eligible for both Medicaid and Medicare. Further demonstrating the relationship between increased spending and extreme heat, the Congressional Budget Office found that for every 100,000 Medicare beneficiaries, extreme temperatures cause an additional 156 emergency department visits and $388,000 in spending per day on average. These higher utilization rates also drive increases in Medicaid transfer payments from the federal government to help states cover rising costs. For every 10 additional days of extreme heat above 90°F, annual Medicaid transfer payments increase by nearly 1%, equivalent to an $11.78 increase per capita. 

Additionally, Medicaid funds services for over 60% of nursing home residents. Yet Medicaid reimbursement rates often fail to cover the actual cost of care, leaving many facilities operating at a financial loss. This can make it difficult for both short-term and long-term care facilities to invest in and maintain the cooling infrastructure necessary to comply with existing requirements to maintain safe indoor temperatures. Further, many short-term and long-term care facilities do not have the emergency power back-ups that can keep the air conditioning on during extreme weather events and power outages, nor do they have emergency plans for occupant evacuation in case of dangerous indoor temperatures. This can and does subject residents to deadly indoor temperatures that can worsen their overall health outcomes.

The Impacts of the One Big Beautiful Bill Act

The One Big Beautiful Bill Act (H.R. 1) will have consequential impacts on federally-supported health insurance programs. The Congressional Budget Office projects that an estimated 10 million people could lose their healthcare coverage by 2034. Researchers have estimated that a loss of coverage could result in 50,000 preventable deaths. Further, health care facilities and hospitals will likely see funding losses as a result of Medicaid funding reductions. This will be especially burdensome to low-resourced hospitals, such as those serving rural areas, and result in reductions in available offerings for patients and even closure of facilities. States will need support navigating this new funding landscape while also identifying cost-effective measures and strategies to address the health-related impacts of extreme heat.

Advancing Solutions that Safeguard America’s Health from Extreme Heat

To address these impacts in this additionally challenged context, there are common-sense strategies to help people avoid extreme heat exposure. For example, access to safely cool indoor environments is one of the best preventative strategies for heat-related illness. In particular, Congress should create a demonstration pilot that provides eligible Medicare beneficiaries with cooling assistance and direct CMS to encourage Section 1115 demonstration waivers for HRSN related to extreme heat. Section 1115 waivers have enabled states to finance pilots for life-saving cooling devices and air filter distributions. These HRSN financing pilots have helped several states to work around the challenges of U.S. underinvestment in health and social services by providing a flexible vehicle to test methods of delivering and paying for healthcare services in Medicaid and CHIP. As Congress members explore these policies, they should consider the impact of H.R. 1’s new requirements for 1115 waiver’s proof of cost-neutrality.

To further support these efforts for heat interventions, Congress should direct CMS to continue Social Drivers of Health (SDOH) screenings as a part of Quality Reporting Programs and integrate questions about extreme heat exposure risks into the screening process. These screenings are critical for identifying the most vulnerable patients and directing them to the preventative services they need. This information will also be critical for identifying facilities that are treating high proportions of heat-vulnerable patients, which could then be sites for testing interventions like energy and housing assistance.

Congress should also direct the CMS to integrate heat preparedness and resilience requirements and metrics into the Conditions of Participation (CoPs) and Conditions for Coverage (CfCs), such as through the Emergency Preparedness Rule. This could include assessing the cooling capacity of a health care facility under extreme heat conditions, back-up power that is sufficient to maintain safe indoor temperatures, and policies for resident evacuation in the event of high indoor temperatures. For safety net facilities, such as rural hospitals and federally qualified health centers, Congress should consider allocating resources for technical assistance to assess these risks and the infrastructure upgrades.

Agriculture, food, and related industries produce nearly 90% of the food consumed in the United States and contribute approximately $1.54 trillion to the national GDP. Given the agricultural sector’s importance to the national economy, food security, and public health, Congress must pay attention to the impacts of extreme heat. To boost the resilience of this sector, Congress should design strategic insurance solutions, enhance research and data, and protect farmworkers through on-farm adaptation measures.  

Extreme Heat Reduces Farm Productivity and Profitability

Extreme heat threatens agricultural productivity by increasing crop damage, causing livestock illness and mortality, and worsening water scarcity. Hotter conditions can damage crops through crop sunburn and heat stress, reducing annual yields for farms by as much as 40%. Animals raised for meat, milk, and eggs also experience increased risks of heat stress and heat-related mortality. For dairy production in particular, an estimated 1% of total annual yield is lost to heat stress alone. Further straining agricultural productivity, extreme heat accelerates water scarcity by increasing water evaporation rates. These higher evaporation rates force farmers to use even more water, drawing often from already stressed water sources. The compounding pressures posed by extreme heat can translate into significant economic losses: a study of Kansas commodity farms found that for every 1°C (1.8°F) increase in temperature, net farm incomes drop by 66%. Together, this means reduced revenue for farms and less food available for people.

Insurance solutions can help mitigate these financial impacts from extreme heat if employed responsibly. Multiple permanently authorized federal programs provide insurance or direct payments to help producers recover losses from extreme heat, including the Federal Crop Insurance Program, the Noninsured Crop Disaster Assistance Program, the Livestock Indemnity Program, and the Emergency Assistance for Livestock, Honey Bees, and Farm-Raised Fish Program. These programs need to ensure that producers are adequately covered against heat-related impacts and incentivize practices that reduce the risk of extreme heat related damages. This in turn will reduce the fiscal exposure of federal farm risk management programs. Congress should call on the United States Department of Agriculture (USDA) to research the feasibility of incentivizing heat resilience through federal crop insurance rates. Congress should also consider insurance premium subsidies for producers who adopt practices that enhance heat resilience for crops and livestock. 

Given the increasing stress of extreme heat on the water systems necessary to sustain agricultural production, National Oceanic and Atmospheric Administration (NOAA) should build on its Weather, Water, and Climate Strategy and collaborate with USDA on a national water security strategy that accounts for current and future hotter temperatures. To enhance system-wide drought resilience, Congress can also appropriate funds to leverage existing USDA programs to support on-farm adoption of shade systems, effective water management, cover crops, and soil regeneration practices. 

Finally, there are still notable knowledge gaps around extreme heat and its impacts on agriculture. These gaps include the long-term effects of higher temperatures on yields, farm input costs, and federal program spending. To address these information gaps and guide future research, Congress can direct the USDA Secretary to submit a report to Congress on the impacts of extreme heat on agriculture, farm input costs and losses, consumer prices, and the federal government’s spending (e.g.,  federal insurance and direct payment programs for losses of agricultural products and the provision of Supplemental Nutrition Assistance Program (SNAP) benefits).

Extreme Heat Lowers Agricultural Workers’ Productivity and Exposes Them to Health Risks

Higher temperatures and resulting heat stress are endangering farmer and farmworker safety and reducing their overall productivity, impacting bottom lines. Farmworkers are essential to the American food system, yet they are among the most vulnerable to extreme heat, facing a 35 times greater risk of dying from heat-related illnesses than workers in other sectors. This risk is intensifying as the sector increasingly relies on H‑2A farmworkers, who are hired to fill persistent domestic farm labor shortages. In many regions, over 25% of certified H‑2A farmworkers are required to work when local average temperatures exceed 90°F, and counties with the highest concentrations of H‑2A workers often coincide with the hottest parts of the country. After the work day, many of these workers return to substandard employer-provided housing that lacks essential cooling or ventilation, preventing effective recovery from daily heat exposure and exacerbating heat-related health risks. On top of the health risks, these conditions make people less effective on the job, which translates to economy-wide impacts: heat-related labor productivity losses across the U.S. economy currently exceeds $100 billion annually.

To address these risks, Congress should pass legislation requiring the Occupational Safety and Health Administration to finalize a federal heat standard that provides sufficient coverage for farming operations. In tandem with Occupational Safety and Health Administration (OSHA) finalizing the standard, USDA should be funded to provide technical assistance to agricultural employers for tailoring heat illness prevention plans and implementing cost-effective interventions that improve working conditions while maintaining productivity. This should include support for agricultural employers to integrate heat awareness into workforce training, resources for safety equipment and education, and support for the addition of shade structures. Doing so would ensure that agricultural workers across both large and small-scale farming operations have access to essential protections, like shade, clean water, and breaks, as well as sufficient capacity to comply. Current funding streams that could have an extreme heat infrastructure “plus-up” include the Environmental Quality Incentives Program and the Farm Service Agency’s microloans program.Lastly, Congress should also direct OSHA to continue implementing its National Emphasis Program on Heat, which enforces employers’ obligation to protect workers against heat illness or injury. OSHA should additionally review employers’ practices to ensure that H2A and other agricultural workers are protected from job or wage loss when extreme heat renders working conditions unsafe.

Extreme heat is a major occupational hazard with far-reaching impacts on the national economy as well as worker health and safety. Extreme heat costs an estimated $100 billion per year in lost productivity, and causes an average of at least 3,389 heat-related injuries and 33 heat-related fatalities annually – numbers that are likely vast undercounts. To protect workers, Congress must mandate a federal heat standard, retain federal workers with expertise in heat stress management strategies, and establish Centers of Excellence to support research, training, and sector-specific mitigation strategies. Through investments in infrastructure for heat safety, Congress can save lives, protect the economy, and enhance resilience nationwide.

Heat-Related Risks are Heightened in Many Work Environments

Extreme heat puts workers of all types at risk: OSHA has documented hospitalizations and heat-related deaths in close to 275 industries. Some work environments present extreme heat risk, particularly those involving high exposures to the outdoors and limited access to cooling. With roughly one in three U.S. employees regularly working outdoors, a large share of the workforce is at elevated risk during summer months. Indoor workers also face high exposure, especially in kitchens, warehouses, manufacturing plants, and other poorly ventilated environments because heat and humidity easily build up in enclosed spaces without adequate air flow and climate-control. 

Business and Economic Impacts of High Heat Exposure in the Workplace 

On top of the $100 billion in direct annual losses, high temperatures are also linked to increased healthcare costs for employers and workers’ compensation claims, with claim frequencies rising by up to 10% during temperature extremes. Some industries are more exposed than others; for example, agriculture, construction, and utility companies face twice the risk of incurring increased healthcare claims due to extreme weather and other environmental conditions. This growing number of claims increases companies’ experience modification rates, which insurers use as a key factor for calculating higher future premiums. Higher premiums translate to greater insurance and overall operating costs, which is especially burdensome for small and low-margin businesses. Despite all these risks, many employers continue to underestimate the financial burden of extreme heat and other weather-related health impacts. 

Many Military Personnel and Federal Workers Face Above-Average Risks of Heat-Related Illness

Military personnel, federal law enforcement officers, border patrol officers, wildland firefighters, federal transportation workers like railroad inspectors, and postal employees are all in positions that require long, labor-intensive hours outdoors, raising the risk for heat-related illness. In 2024, heat-related illnesses were among the top five most reported medical events among U.S. active duty service members. Without consistent standards in place to protect these workers from extreme heat, military and other federal operations will continue to be vulnerable to disruption and reduced workforce capacity.

Advancing Solutions: Establish a Strong Federal Heat Standard and Sector-Specific Centers of Excellence for Heat Workplace Safety

To begin to address heat-related injuries and illnesses in workplaces, OSHA in 2022 established the National Emphasis Program (NEP) on Outdoor and Indoor Heat-Related Hazards, which remains in effect until April 2026. As of 2025, OSHA reports that this NEP has conducted nearly 7,000 inspections connected to heat risks, which lead to 60 heat citations and nearly 1,400 “hazard alert” letters being sent to employers.

However, in the absence of a federal mandate for effective heat safety practices, most workplaces rely on voluntary guidance that is not tailored to specific job conditions, backed by consistent data, or subject to enforcement. This puts both workers and businesses at risk. OSHA’s proposed Heat Injury and Illness Prevention rule would be a critical step forward to establishing common-sense baseline protections. According to the agency’s projections, compliance with this standard could prevent thousands of heat-related illnesses and deaths. The projected benefits from reduced fatalities, illness, and injury amount to $9.18 billion per year. Importantly, this action has broad public backing: 90% of American voters support the implementation of federal protections from extreme heat in the workplace. 

Congress should act swiftly to ensure OSHA finalizes and enforces a strong, evidence-based heat standard. To do this effectively, it is essential that funding for experts at the National Institute for Occupational Safety and Health (NIOSH) is retained in the FY26 budget request, as these critical workers develop criteria for recommended standards on occupational heat stress. These experts have been impacted by reductions in force at NIOSH, and as of July 2025 have not been brought back by the agency.

Some employers have raised concerns about the technical and financial feasibility of the proposed rule. To address these concerns, Congress should pair regulation with practical support by creating federally funded, sector-specific Centers of Excellence (CoEs)for Heat Workplace Safety. These Centers would develop and implement evidence-based solutions tailored to different work environments, such as agriculture and construction. The CoE approach includes comprehensive data collection at worksites that form the basis of occupational safety and health protocols best practices and policies to enhance productivity, prevent injury and illness, and ensure a return on investment. Once strategies are developed, CoEs implement them, track their impact, and work with workers, employers, and cross-sector partners to ensure long-term success.

By leveraging advanced technology, predictive analytics, and continuously updated industry standards, CoEs can help modernize OSHA regulations and make them more aligned with current workplace realities that go beyond simple compliance or post-injury responses.  Federal agencies and other industries with sizable workforces that receive government contracts are key places to develop best practices, technologies, and public-private partnerships for these interventions, all while reducing fiscal risk to the federal government.  

The transition to a clean energy future and diversified sources of energy requires a fundamental shift in how we produce and consume energy across all sectors of the U.S. economy. The transportation sector, a sector that heavily relies on fossil-based energy, stands out not only because it is the sector that releases the most carbon into the atmosphere, but also for its progress in adopting next-generation technologies when it comes to new technologies and fuel alternatives. 

Over the past several years, the federal government has made concerted efforts to support clean energy innovation in transportation, both for on-road and off-road. Particularly, in hard-to-electrify transportation sub-sectors, there has been added focus such as through the Sustainable Aviation Fuel (SAF) Grand Challenge. These efforts have enabled a wave of biotechnology-driven solutions to move from research labs to commercial markets, such as LanzaJets alcohol-to-jet technology in producing SAF. From renewable fuels to bio-based feedstocks, biotechnologies are enabling the replacement of fossil-derived energy sources and contributing to a more sustainable, secure, and diversified energy system. 

SAF in particular has gained traction, enabled in part by public investment and interagency coordination, like the SAF Grand Challenge Roadmap. This increased federal attention demonstrated how strategic federal action, paired with demand signals from government, targeted incentives, and industry buy-in, can create the conditions needed to accelerate biotechnology adoption.

To better understand the factors driving this progress, FAS conducted a landscape analysis at the federal and regional level of biotechnology innovation within the clean energy sector, complemented by interviews with key stakeholders. Several policy mechanisms, public-private partnerships, and investment strategies were identified that were enablers of advanced SAF adoption and production and similar technologies. By identifying the enabling conditions that supported biotechnology’s uptake and commercialization, we aim to inform future efforts on how to accelerate other sectors that utilize biotechnologies and overall, strengthen the U.S. bioeconomy.

Key Findings & Recommendations

An analysis of the federal clean energy landscape reveals several critical insights that are vital for advancing the development and deployment of biotechnologies. Federal and regional strategies are central to driving innovation and facilitating the transition of biotechnologies from research to commercialization. The following key findings and actionable recommendations address the challenges and opportunities in accelerating this transition.

Federal Level Key Findings & Recommendations

The federal government plays a pivotal role in guiding market signals and investment toward national priorities. In the clean energy sector, decarbonizing aviation has emerged as a strategic objective, with SAF serving as a critical lever. Federal initiatives such as the SAF Grand Challenge, the SAF Roadmap, and the SAF Metrics Dashboard have helped to elevate SAF within national climate priorities and enabled greater interagency coordination. These mechanisms not only track progress but also communicate federal commitment. Still, despite these efforts, current SAF production remains far below target levels, with capacity largely concentrated in HEFA, a pathway with constrained feedstock availability and limited scalability. 

This production gap reflects deeper structural challenges, many of which parallel broader issues across the clean-energy biotech interface. One of the main challenges is the fragmented, short-duration policy incentives currently in use. Tax credits like 40B and 45Z, while important, lack the longevity and clarity required to unlock large-scale, long-term private investment. The absence of binding fuel mandates further undermines market certainty. These policy gaps limit the ability of the clean energy sector to serve as a sustained demand signal for emerging biotechnologies and slow the transition from pilot to commercial scale. 

Importantly, these challenges point to a broader opportunity: SAF as a test case for how the clean energy sector can serve as a driver of biotechnology uptake. Promising biotechnologies, such as alcohol-to-jet and power-to-liquid, are currently stalled by high capital costs, uncertain regulatory pathways, and a lack of coordinated federal support. Addressing these bottlenecks through aligned incentives, technology-neutral mandates, and harmonized accounting frameworks could not only accelerate SAF deployment but also establish a broader policy blueprint for scaling biotechnology across other clean energy applications.

To alleviate some of the challenges identified, the federal government should:

Extend & Clarify Incentives

While tax incentives such as the 45Z Clean Fuel Production Credit offer a promising framework to accelerate low-carbon fuel deployment, current design and implementation challenges limit their impact, particularly for emerging bio-based and synthetic fuels. To fully unlock the climate and market potential of these incentives, Congress and relevant agencies should take the following steps:

• Congress should amend the 45Z tax credit structure to differentiate between fuel types, such as SAF, e-fuels, biofuels, and renewable diesel, based on life cycle CI and production pathways. This would better reflect technology-specific costs and accelerate deployment across multiple clean fuel markets, adding specificity as to how to utilize and earn the credits based on the type of fuel. 
• Congress should extend the duration of the 45Z credit and other clean-fuel related incentives to provide long-term policy certainty. Multi-year extensions with a defined minimum value floor would reduce investment risk and enable financing of capital-intensive projects.
• Congress and the Department of Treasury should clarify eligibility to ensure inclusion of co-processing methods and hybrid production systems, which are currently in regulatory gray areas. This would ensure broader participation by innovative fuel producers.
• Federal agencies, including the Department of Energy (DOE), Department of Transportation (DOT), and the Department of Defense, should be directed to enter into long-term (more than 10 years) procurement agreements for low-carbon fuels, including electrofuels and SAF. These offtake mechanisms would complement tax incentives and send strong market signals to producers and investors.

Scale Biotech Commercialization Support

The clean energy transition depends in part on the successful commercialization of enabling biotechnologies, ranging from advanced biofuels to bio-based carbon capture, SAF and biomanufacturing platforms that reduce industrial emissions. Recent or proposed funding cuts to clean energy programs risk stalling this progress and undermining U.S. competitiveness in the bioeconomy. 

To accelerate biotechnology deployment and bridge the gap between lab-scale innovation and commercial-scale production, Congress should take the following actions:

• Authorize and appropriate expanded funding to the DOE, particularly through Bioenergy Technologies Office (BETO) and to the Department of Agriculture (USDA) to support pilot, demonstration, and first-of-a-kind commercial scale projects that enable biotechnology applications across clean energy sectors.
• Direct and fund the DOE Loan Programs Office to establish a dedicated loan guarantee program focused on biotechnology commercialization, targeting platforms that can be integrated into the energy system, such as bio-based fuels, bioproducts, carbon utilization technologies, and electrification-enabling materials.
• Encourage DOE and USDA to enter into long-term offtake agreements or structured purchasing mechanisms with qualified bioenergy and biomanufacturing companies. These agreements would help de-risk early commercial projects, crowd in private investment, and provide market certainty during the critical scale-up phase. 
• Strengthen public-private coordination mechanisms, such as cross-sector working groups or interagency task forces, to align commercialization support with industry needs, improve program targeting, and reduce time-to-market for promising technologies. 

Design and Promote Next-Gen Biofuel Policies

To accelerate the deployment of low-carbon fuels and enable innovation in next-generation bioenergy technologies, Congress and relevant agencies should take the following actions:

• Congress should direct the Environmental Protection Agency (EPA) to modernize the Renewable Fuel Standard by incorporating life cycle carbon intensity as a core metric, moving beyond volume-based mandates. Legislative authority could also support the development of a national Low Carbon Fuel Standard, modeled on successful state-level programs to drive demand for fuels with demonstrable climate benefits.
• EPA should update its emissions accounting framework to reflect the latest science on life cycle greenhouse gas (GHG) emissions, enabling more accurate assessment of advanced biofuels and synthetic fuels. 
• DOE should expand R&D and demonstration funding for biofuel pathways that meet stringent carbon performance thresholds, with an emphasis on scalability and compatibility.

Regional Level Key Findings & Recommendations

Regional strengths continue to serve as foundational drivers of clean energy innovation, with localized assets shaping the pace and direction of technology development. Federal designations, such as the Economic Development Administration (EDA) Tech Hub program (Tech Hub), have proven catalytic. These initiatives enable regions to unlock state-level co-investment, attract private capital, and align workforce training programs with local industry needs. Early signs suggest that the Tech Hub framework is helping to seed innovation ecosystems where they are most needed, but long-term impact will depend on sustained funding support and continued regional coordination. 

Workforce readiness and enabling infrastructure remain critical differentiators. Regions with deep and committed involvement from major research universities, national labs, or advanced manufacturing clusters are better positioned to scale innovation from prototype to deployment. Real-world testbeds provide environments for stress-testing technologies and accelerating regulatory and market readiness, reinforcing the importance of place-based strategies in federal innovation planning. 

At the same time, private investment in clean energy and enabling biotechnologies remains crucial to developing and scaling innovative technologies. High capital costs, regulatory uncertainty, and limited early-stage demand signals continue to inhibit market entry, especially in geographies with less mature innovation ecosystems. Addressing these barriers through coordinated federal procurement, long-term incentives, and regional capacity-building will be essential to supporting growth in regions with strong assets to develop industry clusters that could yield clean energy benefits. 

To accomplish this, the federal government and regional governments should: 

Strengthen Regional Workforce Pipelines

A skilled and regionally distributed workforce is essential to realizing the full economic and technological potential of clean energy investments, particularly as they intersect with the bioeconomy. While federal funding is accelerating deployment through initiatives such as the IRA and DOE programs, workforce gaps, especially outside major innovation hubs, pose barriers to implementation. Addressing these gaps through targeted education, training, and talent retention efforts will be critical to ensuring that clean energy projects deliver durable, regionally inclusive economic growth. To this end:

• Federal agencies like the Department of Education and National Science Foundation should explore expanding support for STEM programs at community colleges and Minority Serving Institutions, with a focus on biosciences, engineering, and agricultural technologies relevant to the clean energy transition.
• Federally supported training and reskilling programs tailored to regional clean energy and biomanufacturing workforce needs could benefit new and existing cross-sector partnerships between state workforce agencies and regional employers. 
• State and local governments should consider implementing talent retention strategies, including local hiring incentives, relocation support, and career placement services, to ensure that skilled workers remain in and contribute to regional clean energy ecosystems.

Strengthen Regional Infrastructure and Foster Cross-Sector Collaboration

Robust regional infrastructure and cross-sector collaboration are essential to accelerating the deployment of clean energy technologies that leverage advancements in biotechnology and manufacturing. Strategic investments in shared facilities, modernized logistics, and coordinated innovation ecosystems will strengthen supply chain resilience and improve technology transfer across sectors. Facilitating access to R&D infrastructure, particularly for small and mid-sized enterprises, will ensure that innovation is not limited to large firms or major metropolitan areas. To support these outcomes: 

• Federal support for regional testbeds, prototyping sites, and grid modernization labs, coordinated by agencies such as DOE and EDA,  would support the demonstration and scaling of biologically enabled clean energy technologies.
• State and local governments, in coordination with federal agencies including DOT and DOC, explore investment in logistics infrastructure to enhance supply chain reliability and support distributed manufacturing.
• States should consider creating or expanding the use of innovation voucher programs that allow small and mid-sized enterprises to access national lab facilities, pilot-scale infrastructure, and technical expertise, fostering cross-sector collaboration between clean energy, biotech, and advanced manufacturing firms. 

Attract and De-Risk Private Capital

Attracting and de-risking private capital is critical for scaling clean energy and biotechnology innovations. By offering targeted financial mechanisms and leveraging federal visibility, governments can reduce the financial uncertainties that often deter private investment. Effective strategies, such as state-backed loan guarantees and co-investment models, can help bridge funding gaps while strategic partnerships with philanthropic and venture capital entities can unlock additional resources for emerging technologies. To this end: 

• State governments, in collaboration with the federal agencies such as DOE and Treasury, should consider implementing state-backed loan guarantees and co-investment models to attract private capital into high-risk clean energy and biotech projects. 
• Federal agencies like EDA, DOE, and the SBA should explore additional programs and partnerships to attract philanthropic and venture capital to emerging clean energy technologies, particularly in underserved regions.
• Federal agencies should increase efforts to facilitate connecting early-stage companies with potential investors, using federal initiatives to build investor confidence and reduce perceived risks in the clean energy sector.

Cross-Cutting Key Findings

The successful deployment of federal clean energy and biotechnology initiatives, such as the SAF Grand Challenge, relies heavily on the capacity of regional ecosystems and the private sector to absorb and implement national goals. Many regions, particularly those outside established innovation hubs, lack the infrastructure, resources, and technical expertise to effectively utilize federal funding. As a result, the impact of national policies is often limited, and the full potential of federal investments goes unrealized in certain areas.

Federal programs often take a one-size-fits-all approach, overlooking regional variability in feedstocks, industrial bases and cost structures. Programs like tax credits and life cycle analysis models can unintentionally disadvantage regions with different economic contexts, creating disparities in access to federal incentives. This lack of regional customization prevents certain areas from fully benefiting from national clean energy and biotech initiatives. 

The diffusion of innovation in clean energy and biotechnology remains concentrated in a few key regions, leaving others underutilized. Despite robust federal R&D investments, commercialization and scaling of innovations are primarily concentrated in regions with established infrastructure, hindering the broader geographic spread of these technologies. In addition, workforce development efforts across federal and regional programs are fragmented, creating misalignments in talent pipelines and further limiting the ability of local industries to leverage available resources effectively. The absence of a unified system for tracking key metrics, such as SAF production and emissions reductions, makes it difficult to coordinate efforts or assess progress consistently across regions. To address this, the federal and regional governments should:

Create a Federal–Regional Clean Energy Deployment Compact

A Federal-Regional Clean Energy Deployment Compact is critical for aligning federal clean energy initiatives with the unique capabilities and needs of regional ecosystems. By establishing formal mechanisms, such as intergovernmental councils and regional liaisons, federal programs can be more effectively tailored to local conditions. These mechanisms will ensure two-way communication between federal agencies and regional stakeholders, fostering a collaborative approach that adapts to evolving technological, economic, and environmental conditions. In addition, treating regional tech hubs and initiatives as testbeds for new policy tools, such as performance-based incentives or carbon standards, will allow for innovative solutions to be tested locally before scaling them nationally, ensuring that policies are effective and contextually relevant across diverse regions. To this end:

• The White House Office of Science and Technology Policy (OSTP), in collaboration with the DOE and EPA, should establish formal intergovernmental councils or regional liaisons to facilitate ongoing dialogue between federal agencies and regional stakeholders. These councils would focus on aligning federal clean energy initiatives with regional needs, ensuring that local priorities, such as feedstock availability or infrastructure readiness, are considered in policy design.
• The DOE and EPA should treat tech hubs and regional clean energy initiatives as testbeds for policy innovation. These regions can pilot performance-based incentives, carbon standards, and other policy tools to assess their effectiveness before scaling them nationally. Successful models developed in these testbeds should be expanded to other regions, with lessons learned shared across state and local governments.
• Regional universities and innovation hubs should collaborate with federal and state agencies to develop pilot programs that test new policy tools and technologies. These institutions can serve as incubators for innovative clean energy solutions, providing valuable data on what policies work best in specific regional contexts.

Build a National Innovation-to-Deployment Pipeline

Creating a seamless innovation-to-deployment pipeline is essential for scaling clean energy technologies and ensuring that regional ecosystems can fully participate in national clean energy transitions. By linking DOE national labs, Tech Hubs, and regional consortia into a coordinated network, the U.S. can support the full life cycle of innovation, from early-stage R&D to commercialization and deployment, across diverse geographies. Additionally, co-developing curricula and training programs between federal agencies, regional tech hubs, and industry partners will ensure that talent pipelines are closely aligned with the evolving needs of the clean energy sector, providing the skilled workforce necessary to implement and scale innovations effectively. To accomplish this the:

• DOE should facilitate the creation of a national network that connects federal labs, regional tech hubs and innovation consortia. This network would provide a clear pathway for the transition of technologies from research to commercialization, ensuring that innovations can be deployed across different regions based on local needs and capacities. 
• Regional Tech Hubs, in partnership with local universities and research institutions, should be integrated into the pipeline to provide localized innovation support and commercialization expertise. These hubs can act as nodes in the broader network, offering the infrastructure and expertise necessary for scaling up clean energy technologies.

Develop a Shared Metrics and Monitoring Platform

A centralized dashboard for tracking key metrics related to clean energy and biotechnology initiatives is crucial for guiding investment and policy decisions. By integrating federal and regional data can provide a comprehensive, real-time view of progress across the country. This shared platform would enable better coordination among federal, state, and local agencies, ensuring that resources are allocated efficiently and that policy decisions are informed by accurate, up-to-date data. Moreover, a unified system would allow for more effective tracking of regional performance, enabling tailored solutions and based on localized needs and challenges. To this end:

• The DOE, in partnership with the EPA, should lead the development of a centralized dashboard that integrates existing federal and regional data on SAF production, emissions reductions, workforce needs, and infrastructure gaps. This platform should be publicly accessible, allowing stakeholders at all levels to monitor progress and identify opportunities for improvement.
• State and local governments should contribute relevant data from regional initiatives, including workforce training programs, infrastructure development projects, and emissions reductions efforts. These contributions would help ensure that the platform reflects the full range of activities across different regions, providing a more accurate picture of national progress.
  The Department of Labor and the DOC should integrate workforce development and industrial capacity data into the platform. This would include information on training programs, regional workforce readiness, and skills gaps, helping policymakers align talent development efforts with regional needs.
  The DOT should ensure that transportation infrastructure data, particularly related to SAF production and distribution networks, is included in the platform. This would provide a comprehensive view of the supply chain and infrastructure readiness necessary to scale clean energy technologies across regions.

The clean energy sector, and specifically SAF, highlights both the promise and the persistent challenges of scaling biotechnologies, reflecting broader issues, such as fragmented regulation, limited commercialization support, and misaligned incentives that hinder the deployment of advanced biotechnologies. Overcoming these systemic barriers requires coordinated, long-term policies including performance-based incentives, and procurement mechanisms that reduce investment risk and free up capital. SAF should be seen not as a standalone initiative but as a model for integrating biotechnology into industrial and energy strategy, supported by a robust innovation pipeline, expanded infrastructure, and shared metrics to guide progress. With sustained federal leadership and strategic alignment, the bioeconomy can become a key pillar of a low-carbon, resilient energy future.

Summer officially kicked off this past weekend with the onset of a sweltering heat wave. As we hit publish on this piece, tens of millions of Americans across the central and eastern United States are experiencing sweltering temperatures that make it dangerous to work, play, or just hang out outdoors.

The good news is that even when the mercury climbs, heat illness, injury, and death are preventable. The bad news is that over the past five months, the Trump administration has dismantled essential preventative capabilities.

At the beginning of this year, more than 70 organizations rallied around a common-sense Heat Policy Agenda to tackle this growing whole-of-nation crisis. Since then, we’ve seen some encouraging progress. The new Congressional Extreme Heat Caucus presents an avenue for bipartisan progress on securing resources and legislative wins. Recommendations from the Heat Policy Agenda have already been echoed in multiple introduced bills. Four states, California, Arizona, New Jersey, and New York, now have whole-of-government heat action plans, and there are several States with plans in development. More locally, mayors are banding together to identify heat preparedness, management, and resilience solutions. FAS highlighted examples of how leaders and communities across the country are beating the heat in a Congressional briefing just last week.

But these steps in the right direction are being forestalled by the Trump Administration’s leap backwards on heat. The Heat Policy Agenda emphasized the importance of a clear, sustained federal governance structure for heat, named authorities and dedicated resourcing for federal agencies responsible for extreme heat management, and funding and technical assistance to subnational governments to build their heat readiness. The Trump Administration has not only failed to advance these goals – it has taken actions that clearly work against them.

The result? It’s summer, America’s heating up, and we’re deeply unprepared.

The heat wave making headlines today is just the latest example of how extreme heat is a growing problem for all 50 states. In just the past month, the Pacific Northwest smashed early-summer temperature records, there were days when parts of Texas were the hottest places on Earth, and Alaska – yes, Alaska – issued its first-ever heat advisory. Extreme heat is deadlier than hurricanes, floods, and tornadoes combined, and is exacerbating a mental-health crisis as well. By FAS’ estimates, extreme heat costs the nation more than $162 billion annually, costs that have made extreme heat a growing concern to private markets.

To build a common understanding of the state of federal heat infrastructure, we analyzed the status of heat-critical programs and agencies through public media, government reports, and conversations with stakeholders. All known impacts are confirmed via publicly available sources. We highlight five areas where federal capacity has been impacted:

• Leadership and governance infrastructure
• Key personnel and their expertise
• Data, forecasts, and information availability
• Funding sources and programs for preparedness, risk mitigation and resilience
• Progress towards heat policy goals

This work provides answers to many of the questions our team has been asked over the last few months about what heat work continues at the federal level. With this grounding, we close with some options and opportunities for subnational governments to consider heading into Summer 2025.

What is the Current State of Federal Capacity on Extreme Heat?

Loss of leadership and governance infrastructure

At the time of publication, all but one of the co-chairs for the National Integrated Heat Health Information System’s (NIHHIS) Interagency Working Group (IWG) have either taken an early retirement offer or have been impacted by reductions in force. The co-chairs represented NIHHIS, the National Weather Service (NWS), Health and Human Services (HHS), and the Federal Emergency Management Agency (FEMA). The National Heat Strategy, a whole-of-government vision for heat governance crafted by 28 agencies through the NIHHIS IWG, was also taken offline. A set of agency-by-agency tasks for Strategy implementation (to build short-term readiness for upcoming heat seasons, as well as to strengthen long-term preparedness) was in development as of early 2025, but this work has stalled. There was also a goal to formalize NIHHIS via legislation, given that its existence is not mandated by law – relevant legislation has been introduced but its path forward is unclear. Staff remain at NIHHIS and are continuing the work to manage the heat.gov website, craft heat resources and information, and disseminate public communications like Heat Beat Newsletter and Heat Safety Week. Their positions could be eliminated if proposed budget cuts to the National Oceanic and Atmospheric Administration (NOAA) are approved by Congress.

Staffing reductions and actualized or proposed changes to FEMA and HHS, the federal disaster management agencies implicated in addressing extreme heat, are likely to be consequential in relation to extreme heat this summer. Internal reports have found that FEMA is not ready for responding to even well-recognized disasters like hurricanes, increasing the risk for a mismanaged response to an unprecedented heat disaster. The loss of key leaders at FEMA has also put a pause to efforts to integrate extreme heat within agency functions, such as efforts to make extreme heat an eligible disaster. FEMA is also proposing changes that will make it more difficult to receive federal disaster assistance. The Administration for Strategic Preparedness and Response (ASPR), HHS’ response arm, has been folded into the Centers for Disease Control and Prevention (CDC), which has been refocused to focus solely on infectious diseases. There is still little public information for what this merger means for HHS’ implementation of the Public Health Service Act, which requires an all-hazards approach to public health emergency management. Prior to January 2025, HHS was determining how it could use the Public Health Emergency authority to respond to extreme heat.

Loss of key personnel and their expertise

Many key agencies involved in NIHHIS, and extreme heat management more broadly, have been impacted by reductions in force and early retirements, including NOAA, FEMA, HHS, the Department of Housing and Urban Development (HUD), the Environmental Protection Agency (EPA), the U.S. Forest Service (USFS), and the Department of Energy (DOE). Some key agencies, like FEMA, have lost or will lose almost 2,000 staff. As more statutory responsibilities are put on fewer workers, efforts to advance “beyond scope” activities, like taking action on extreme heat, will likely be on the back burner.

Downsizing at HHS has been acutely devastating to extreme heat work. In January, the Office of Climate Change and Health Equity (OCCHE) was eliminated, putting a pause on HHS-wide coordination on extreme heat and the new Extreme Heat Working Group. In April, the entire staff of the Climate and Health program at CDC, the Low Income Home Energy Assistance Program (LIHEAP), and all of the staff at the National Institute for Occupational Safety and Health (NIOSH) working on extreme heat, received reduction in force notices. While it appears that staff are returning to the CDC’s National Center for Environmental Health, they have lost months of time that could have been spent on preparedness, tool development, and technical assistance to local and state public health departments. Sustained funding for extreme heat programs at HHS is under threat, the FY2026 budget for HHS formally eliminates the CDC’s Climate and Health Program, all NIOSH efforts on extreme heat, and LIHEAP.

Risks to data, forecasts, and information availability, though some key tools remain online

Staff reductions at NWS have compromised local forecasts and warnings, and some offices can no longer staff around-the-clock surveillance. Staff reductions have also compromised weather balloon launches, which collect key temperature data for making heat forecasts. Remaining staff at the NWS are handling an increased workload at one of the busiest times of the year for weather forecasting. Reductions in force, while now reversed, have impacted real-time heat-health surveillance at the CDC, where daily heat-related illness counts have been on pause since May 21, 2025 and the site is not currently being maintained as of the date of this publication.

Some tools remain online and available to use this summer, including NWS/CDC’s HeatRisk (a 7-day forecast of health-informed heat risks) and the National Highway Traffic Safety Administration’s Heat-Related EMS Activation Surveillance Dashboard (which shows the number of heat-related EMS activations, time to patient, percent transported to medical facilities, and deaths). Most of the staff that built HeatRisk have been impacted by reductions in force. The return of staff to the CDC’s Climate and Health program is a bright spot, and could bode well for the tool’s ongoing operations and maintenance for Summer 2025.

Proposed cuts in the FY26 budget will continue to compromise heat forecasting and data. The budget proposes cutting budgets for upkeep of NOAA satellites crucial to tracking extreme weather events like extreme heat; cutting budgets for the National Aeronautics and Space Administration’s LandSat program, which is used widely by researchers and private sector companies to analyze surface temperatures and understand heat’s risks; and fully defunding the National Environmental Public Health Tracking Network, which funds local and state public health departments to collect heat-health illness and death data and federal staff to analyze it.

Rollbacks in key funding sources and programs for preparedness, risk mitigation and resilience

As of May 2025, both NIHHIS Centers of Excellence – the Center for Heat Resilient Communities and the Center for Collaborative Heat Monitoring – received stop work orders and total pauses in federal funding. These Centers were set to work with 26 communities across the country to either collect vital data on local heat patterns and potential risks or shape local governance to comprehensively address the threat of extreme heat. These communities represented a cross-cut of the United States, from urban to coastal to rural to agricultural to tribal. Both Center’s leadership plans to continue the work with the selected communities in a reduced capacity, and continue to work towards aspirational goals like a universal heat action plan. Future research, coordination, and technical assistance at NOAA on extreme heat is under fire with the proposed total elimination of NOAA Research in the FY26 budget.

At FEMA, a key source of funding for local heat resilience projects, the Building Resilience Infrastructure and Communities (BRIC) program, has been cancelled. BRIC was the only FEMA Resilience grant that explicitly called out extreme heat in its Notice of Funding Opportunity, and funded $13 million in projects to mitigate the impacts of extreme heat. Many states have also faced difficulties in getting paid by FEMA for grants that support their emergency management divisions, and the FY26 budget proposes cuts to these grant programs. The cancellation of Americorps further reduces capacity for disaster response. FEMA is also dropping its support for improving building codes that mitigate disaster risk as well as removing requirements for subnational governments to plan for climate change. 

At HHS, a lack of staff at CDC has stalled payments from key programs to prepare communities for extreme heat, the Building Resilience Against Climate Effects (BRACE) grant program and the Public Health Preparedness and Response program. BRACE is critical federal funding for state and local climate and health offices. In states like North Carolina, the BRACE program funds live-saving efforts like heat-health alerts. Both of these programs are proposed to be totally eliminated in the FY26 budget. The Hospital Preparedness Program (HPP) is also slated for elimination, despite being the sole source of federal funding for health care system readiness. HPP funds coalitions of health systems and public health departments, which have quickly responded to heat disasters like the 2021 Pacific Northwest Heat Domes and established comprehensive plans for future emergencies. The National Institutes of Health’s Climate and Health Initiative was eliminated and multiple grants paused in March 2025. Research on extreme weather and health may proceed, according to new agency guidelines, yet overall cuts to the NIH will impact capacity to fund new studies and new research avenues. The National Institute of Environmental Health Sciences, which funds research on environmental health, faces a 36% reduction in its budget, from $994 million to $646 million.

Access to cool spaces is key to preventing heat-illness and death. Yet cuts, regulatory rollbacks, and program eliminations across the federal government are preventing progress towards ensuring every American can afford their energy bills. At DOE, rollbacks in energy efficiency standards for cooling equipment and the ending of the EnergyStar program will impact the costs of cooling for consumers. Thankfully, DOE’s Home Energy Rebates survived the initial funding freezes and the funding has been deployed to states to support home upgrades like heat pumps, insulation, air sealing, and mechanical ventilation. At HUD, the Green and Resilient Retrofits Program has been paused as of March 2025, which was set to fund important upgrades to affordable housing units that would have decreased the costs of cooling for vulnerable residents. At EPA, widespread pauses and cancellations in Inflation Reduction Act programs have put projects to provide more affordable cooling solutions on pause. At the U.S. Department of Agriculture, all grantees for the Rural Energy for America Program, which funds projects that provide reliable and affordable energy in rural communities, have been asked to resubmit their grants to receive allocated funding. These delays put rural community members at risk of extreme heat this summer, where they face particular risks due to their unique health and sociodemographic vulnerabilities. Finally, while the remaining $400 million in LIHEAP funding was released for this year, it faces elimination in FY26 appropriations. If this money is lost, people will very likely die and utilities will not be able to cover the costs of unpaid bills and delay improvements to the grid infrastructure to increase reliability.

Uncertain progress towards heat policy goals

Momentum towards establishing a federal heat stress rule as quickly as possible has stalled. The regulatory process for the Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings is proceeding, with hearings that began June 16 and are scheduled to continue until July 3. It remains to be seen how the Occupational Safety and Health Administration (OSHA) will proceed with the existing rule as written. OSHA’s National Emphasis Program (NEP) for Heat will continue until April 6, 2026. This program focuses on identifying and addressing heat-related injuries and illnesses in workplaces, and educating employers on how they can reduce these impacts on the job. To date, NEP has conducted nearly 7,000 inspections connected to heat risks, which lead to 60 heat citations and nearly 1,400 “hazard alert” letters being sent to employers.

How Can Subnational Governments Ready for this Upcoming Heat Season?

Downscaled federal capacity comes at a time when many states are facing budget shortfalls compounded by federal funding cuts and rescissions. The American Rescue Plan Act, the COVID-19 stimulus package, has been a crucial source of revenue for many local and state governments that enabled expansion in services, like extreme heat response. That funding must be spent by December 2026, and many subnational governments are facing funding cliffs of millions of dollars that could result in the elimination of these programs. While there is a growing attention to heat, it is still often deprioritized in favor of work on hazards that damage property.

Even in this environment, local and state governments can still make progress on addressing extreme heat’s impacts and saving lives. Subnational governments can:

• Conduct a data audit to ensure they are tracking the impacts of extreme heat, like emergency medical services activations, emergency room visits, hospitalizations, and deaths, and tracking expenditures dedicated to any heat-related activity. 
• Develop a heat preparedness and response plan, to better understand how to leverage existing resources, capacities, and partnerships to address extreme heat. This includes understanding emergency authorities available at the local and state level that could be leveraged in a crisis. 
• Use their platforms to educate the public about extreme heat and share common-sense strategies that reduce the risk of heat-illness, and public health departments can target communications to the most vulnerable. 
• Ensure existing capital planning and planned infrastructure build-outs prioritize resilience to extreme heat and set up cooling standards for new and existing housing and for renters. Subnational governments can also leverage strategies that reduce their fiscal risk, such as implementing heat safety practices for their own workforces and encouraging or requiring employers to deploy these practices as a way to reduce workers compensation claims. 

FAS stands ready to support leaders and communities in implementing smart, evidence-based strategies to build heat readiness – and to help interested parties understand more about the impacts of the Trump administration’s actions on federal heat capabilities. Contact Grace Wickerson (gwickerson@fas.org) with inquiries.

46 million rural Americans face mounting risks from temperature extremes that threaten workforce productivity, raise business operational costs, and strain critical public services. Though extreme heat is often portrayed in research and the media as an urban issue, almost every state in the contiguous U.S. has rural communities with above-average rates of vulnerability to extreme heat. To protect rural America, Congress must address extreme heat’s impacts by repairing rural health systems, strengthening the preparedness of rural businesses, and hardening rural energy infrastructure.

Extreme heat exacerbates rural communities’ unique health vulnerabilities

On average, Americans living in rural areas are twice as likely as those in urban areas to have pre-existing health conditions, like heart disease, diabetes, and asthma, that make them more sensitive to heat-related illness and death. Further compounding the risk, rural places also have larger populations of underinsured and uninsured people than urban areas, with 1 in 6 people lacking insurance. 

Limited healthcare infrastructure in rural places worsens these vulnerabilities. Rural areas have higher shortages of healthcare professionals who provide primary care, mental health, and dental services than urban areas. Over the last decade, 100 rural hospitals have closed, and hundreds more are vulnerable to closure. Finally, many rural communities do not have public health departments, and those that do are underfunded and understaffed. Because public health systems and healthcare professionals are the first responders to extreme heat, rural residents are severely underprepared. 

Congress should provide flexible resources and technical assistance to rural hospitals to prepare for emerging threats like extreme heat. Additionally, Congress should continue to enable the U.S. Department of Agriculture and the Department of Health and Human Services to provide loans or grant assistance to help rural residents retain access to health services and improve the financial position of rural hospitals and clinics. And because Medicaid expansion correlates with better rural hospital financial performance and fewer closures, Congress should invest in Medicaid to protect rural healthcare access.

Extreme heat puts rural businesses and workers at risk

Rural economic health relies on the outdoors (e.g., recreation tourism) and outdoor labor (e.g., agriculture and oil and gas extraction). Extreme heat in many of these places makes it dangerous to be outside, which impacts worker productivity and local business revenues. Indoor workers in facilities like manufacturing plants, food processing, and warehouses also face heat-related safety threats due to the presence of heat-producing machines and poorly ventilated buildings with limited cooling. These facilities are rapidly growing components of rural economies, as these sectors employ almost 1 in 5 rural workers. 

Simple protections like water, rest, shade, and cooling can improve productivity and generate returns on investments. But small-to-medium rural enterprises need support to adopt affordable cooling systems, shade and passive cooling infrastructure, and worker safety measures that reduce heat-related disruptions. Congress should help rural businesses reduce heat’s risks by appropriating funding to support workplace heat risk reduction and practical training on worker protections. Additionally, Congress should require OSHA to finalize a federal workplace heat standard.

Extreme heat threatens rural energy security

When a power outage happens during a severe extreme heat event, the chance of heat-related illness and death increases exponentially. Extreme heat strains power infrastructure, increasing the risk of power outages. This risk is particularly acute for rural communities, which have limited resources, older infrastructure, and significantly longer waits to restore power after an outage.

Weatherized housing and indoor infrastructure are one of the key protective factors against extreme heat, especially during outages. Yet rural areas often have a higher proportion of older, substandard homes. Manufactured and mobile homes, for example, compose 15% of the rural housing stock and are the one of the most at-risk housing types for extreme heat exposure. When the power is on, rural residents spend 40% more of their income on their energy bills than their urban counterparts. Rural residents in manufactured housing spend an alarming 75% more. Energy debt can force people to choose between paying for life-saving energy or food and key medications, compounding poverty and health outcomes. 

To drive the energy independence and economic resilience of rural America, Congress should support investments in energy-efficient and resilient cooling technologies, weatherized homes, localized energy solutions like microgrids, and grid-enhancing technologies.

As temperatures rise, the strain on energy infrastructure escalates, creating vulnerabilities for the efficiency of energy generation, grid transmission, and home cooling, which have significant impacts on businesses, households, and critical services. Without action, energy systems will face growing instability, infrastructure failures will persist, and utility burdens will increase. The combined effects of extreme heat cost our nation over $162 billion in 2024 – equivalent to nearly 1% of the U.S. GDP. 

The federal government needs to prepare energy systems and the built environment through strategic investments in energy infrastructure — across energy generation, transmission, and use. Doing so includes ensuring electric grids are prepared for extreme heat by establishing an interagency HeatSmart Grids Initiative to assess the risk of energy system failures during extreme heat and the necessary emergency responses. Congress should retain and expand home energy rebates, tax credits, and the Weatherization Assistance Program (WAP) to enable deep retrofits that prepare homes against power outages and cut cooling costs, along with extending the National Initiative to Advance Building Codes (NIABC) to accelerate state and local adoption of code language for extreme heat adaptation.  

Challenge & Opportunity: Grid Security

Extreme Heat Reduces Energy Generation and Transmission Efficiency

During a heatwave, the energy grid faces not only surges in demand but also decreased energy production and reduced transmission efficiency. For instance, turbines can become up to 25% less efficient in high temperatures. Other energy sources are also impacted: solar power, for example, produces less electricity as temperatures rise because high heat slows the flow of electrical current. Additionally, transmission lines lose up to 5.8% of their capacity to carry electricity as temperatures increase, resulting in reliability issues such as rolling blackouts. These combined effects slow down the entire energy cycle, making it harder for the grid to meet growing demand and causing power disruptions.

Rising Demand and Grid Load Increase the Threat of Power Outages

Electric grids are under unprecedented strain as record-high temperatures drive up air conditioning use, increasing energy demand in the summer. Power generation and transmission are impeded when demand outpaces supply, causing communities and businesses to experience blackouts. According to data from the North American Electric Reliability Corporation (NERC), between 2024 and 2028, an alarming 300 million people across the United States could face power outages. Texas, California, the Southwest, New England, and much of the Midwest are among the states and regions most at risk of energy emergencies during extreme conditions, according to 2024 NERC data. 

Data center build-out, driven by growing demand for artificial intelligence, cloud services, and big data analytics, further adds stress to the grid. Data centers are estimated to consume 9% of US annual electricity generation by 2030. With up to 40% of data centers’ total yearly energy consumption driven by cooling systems, peak demand during the hottest days of the year puts demand on the U.S. electric grid and increases power outage risk. 

Power outages bear significant economic costs and put human lives at severe risk. To put this into perspective, a concurrent heat wave and blackout event in Phoenix, Arizona, could put 1 million residents at high risk of heat-related illness, with more than 50% of the city’s population requiring medical care. As we saw with 2024’s Hurricane Beryl, more than 2 million Texans lost power during a heatwave, resulting in up to $1.3 billion in damages to the electric infrastructure in the Houston area and significant public health and business impacts.  The nation must make strategic investments to ensure energy reliability and foster the resilience of electric grids to weather hazards like extreme heat. 

Advancing Solutions for Energy Systems and Grid Security

Investments in resilience pay dividends, with every federal dollar spent on resilience returning $6 in societal benefits. For example, the DOE Grid Resilience State and Tribal Formula Grants, established by the Bipartisan Infrastructure Law (BIL), have strengthened grid infrastructure, developed innovative technologies, and improved community resilience against extreme weather. It is essential that funds for this program, as well as other BIL and Inflation Reduction Act initiatives, continue to be disbursed.  

To build heat resilience in communities across this nation, Congress must establish the HeatSmart Grids Initiative as a partnership between DOE, FEMA, HHS, the Federal Energy Regulatory Commission (FERC), NERC, and the Cybersecurity and Infrastructure Security Agency (CISA). This program should (i) perform national audits of energy security and building-stock preparedness for outages, (ii) map energy resilience assets such as long-term energy storage and microgrids, (iii) leverage technologies for minimizing grid loads such as smart grids and virtual power plants, and (iv) coordinate protocols with FEMA’s Community Lifelines and CISA’s Critical Infrastructure for emergency response. This initiative will ensure electric grids are prepared for extreme heat, including the risk of energy system failures during extreme heat and the necessary emergency and public health responses.  

Challenge & Opportunity: Increasing Household and Business Energy Costs

As temperatures rise, so do household and business energy bills to cover cooling costs. This escalation can be particularly challenging for low-income individuals, schools, and small businesses operating on thin margins. For businesses, especially small enterprises, power outages, equipment failures, and interruptions in the supply chain become more frequent and severe due to extreme weather, negatively affecting production and distribution. One in six U.S. households (21.2 million people) find themselves behind on their energy bills, which increases the risk of utility shut-offs. One in five households report reducing or forgoing food and medicine to pay their energy bills. Families, school districts, and business owners need active and passive cooling approaches to meet demands without increasing costs.

Advancing Solutions for Businesses, Households, and Vital Facilities

Affordably cooled homes, businesses, and schools are crucial to sustaining our economy. To prepare the nation’s housing and infrastructure for rising temperatures, the federal government should:

• Expand the Weatherization Assistance Program (WAP), the Low-Income Home Energy Assistance Program, existing rebates and tax credits (including HER, HEAR, 25C, 179D, 45L, Direct Pay) to include passive cooling technology such as cool walls, pavements, and roofs (H.R. 9894). Revise 25C to be refundable at purchase to increase accessibility to low-income households.
• Authorize a Weatherization Readiness Program (H.R. 8721) to address structural, plumbing, roofing, and electrical issues and environmental hazards with dwelling units to make them eligible for WAP.
• Direct the DOE to work with its WAP contractors to ensure home energy audits consider passive cooling interventions, such as cool walls and roofs, strategically placing trees to provide shading and high-efficiency windows. 
• Extend the National Initiative to Advance Building Codes (NIABC) to include (i) the development of codes and metrics for sustainable and passive cooling, shade, materials selection, and thermal comfort and (ii) the identification of opportunities to accelerate state and local adoption of code language for extreme heat adaptation. Partner with the National Institute of Standards and Technology to create an Extreme Heat clearinghouse for model building codes.
• Authorize an extension to the DOE Renew America’s Schools Program to continue funding cost-saving, energy-efficient upgrades in K-12 schools. 
• Provide supportive appropriations to heat-critical programs at DOE, including: the Affordable Home Energy Shot, State and Community Energy Programs (SCEP), Office of Clean Energy Demonstrations (OCED), Office of Energy Efficiency & Renewable Energy (DOE), and the Home Energy Rebates program

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The Federation of American Scientists: Who We Are

At the Federation of American Scientists (FAS), we envision a world where the federal government deploys cutting-edge science, technology, ideas, and talent to solve and address the impacts of extreme heat. We bring expertise in embedding science, data, and technology into government decision-making and a strong network of subject matter experts in extreme heat, both inside and outside of government. Through our 2025 Heat Policy Agenda and broader policy library, FAS is positioned to help ensure that public policy meets the challenges of living with extreme heat.

Consider FAS a resource for… 

• Understanding evidence-based policy solutions
• Directing members and staff to relevant academic research 
• Connecting with issue experts to develop solutions that can immediately address the impacts of extreme heat

We are tackling this crisis with initiative, creativity, experimentation, and innovation, serving as a resource on environmental health policy issues. Feel free to always reach out to us:

Senior Manager, Climate and Health

Grace Wickerson

Medical Innovation,
Emerging Technologies

read more

Senior Associate, Climate, Health, and Environment

Autumn Burton

Environmental Health,
Resilient Communities,
Extreme Weather,
Inclusive Innovation & Technology

read more

Associate Director, Climate and Environment

Hannah Safford

read more

Last year the Federation of American Scientists (FAS), Jordan Schneider (of ChinaTalk), Chris Miller (author of Chip War) and Noah Smith (of Noahpinion) hosted a call for ideas to address the U.S. chip shortage and Chinese competition. A handful of ideas were selected based on the feasibility of the idea and its and bipartisan nature. This memo is one of them.

Summary

1. Danger Ahead: Until now, the U.S. semiconductor policy agenda focused on getting an edge over China in the production of advanced semiconductors. But now a potentially even more  substantial challenge looms. Possible Chinese dominance in so-called ‘legacy’ chips  essential for modern economic life could grant it unacceptable leverage over the United  States. This challenge will require tools far more disruptive than ever before considered by policymakers for the chip competition. 
   
2. The Foot on America’s Economic Neck: Collecting offensive economic leverage lies at the  heart of Chinese leader Xi Jinping’s strategy. Chinese dominance in legacy chips could  enable Beijing’s bullying of the United States it has thus far reserved for U.S. allies. China’s  growing leverage over Washington may embolden Beijing to think it could attack Taiwan with  relative impunity. 
   
3. Familiar Semiconductor Policy Tools Won’t Work Alone: China increasingly has access to  the tech it needs for its legacy ambitions (via stockpiling and indigenization), damaging  possible expanded export controls. And unfair Chinese trade practices could reduce the  benefits of subsidies, as it has for solar and critical minerals. 
   
4. Learning to Love Trade Protection: Only when the U.S. market cannot access Chinese  chips will they have sufficient incentive to manufacture chips in third countries. Washington could either turn to tariffs or outright bans on Chinese chips. Washington has several options  to block China’s chips – AD/CVD, 337, ‘ICTS’, 5949, and 232. But the most powerful tool would be Section 301 of the Trade Act of 1974. 
   
5. The Keys to Success: Trade measures will have to target Chinese chips contained within  other products, not just the chips themselves. The U.S. government’s clarity into global  supply chains will have to grow dramatically. Allied participation and knowledge-sharing  might be needed. The United States can ease enforcement of a chips trade war by  incentivizing private industry to share the burden of detecting violations of U.S. law.  

The Generational Leap in U.S. Chip Policy 

For five years, U.S. concerns over China’s semiconductor sector focused on its cutting-edge chip  production. The bipartisan instinct has been to mix restrictions on Chinese access to Western  technology and to fund manufacturing of advanced chips at home. It began with the Trump  administration’s sanctions against Chinese chip giants Fujian Jinhua, Huawei, and SMIC. The Biden administration’s October 2022 export controls on China’s advanced chipmakers and the CHIPS and Science Act crowned a new era of technology competition focused on the absolute bleeding edge.  

Fast forward to July 2024: Washington entered the next phase of the chip war.  

Biden administration concerns about legacy chips emerged subtly last summer from one-off statements from Commerce Secretary Gina Raimondo. Before long Team Biden began to formally investigate the issue in an industry survey. Then in May the administration doubled existing tariffs on Chinese-made chips from 25% to 50%. 

Congress is equally concerned. The bipartisan China Committee endorsed tariffs on Chinese legacy chips in its December 2023 economic report and in a January 2024 letter to the administration. China’s growing position in the production of mature-node chips took center stage in a Committee hearing in June 2024, where Committee Chair John Moolenaar called for “a reliable domestic supply of semiconductors outside the reach of the CCP”. 

This apparently sudden shift reflects the growth of the stakes in the U.S.-China chip competition over the past year: 

• Legacy Chips Fuel Modern Life: Cars, aircraft, home appliances, consumer electronics,  military systems, and medical devices rely on legacy chips. About 70% of chips produced  globally are non-advanced. 
• China’s Bid for Legacy Dominance: China already accounts for 30% of global logic  chip capacity, a number that is projected to rise to 39% by 2027. And if Beijing makes good  on its threats to annex Taiwan, the world’s other major manufacturer of legacy  semiconductors, China could potentially control 60% of global production of chips in the  range of 20 to 45 nanometers and 75% of overall legacy chip production by 2027. 

Despite the scale of the challenge, Washington has not yet decided on its strategy to take on the  problem. The best approach to the legacy challenge will be one that can prevent U.S. reliance on  Chinese-made chips to ensure China cannot capture decisive leverage over the U.S. economy.  Doing so will require using trade measures to reject Chinese chips from the U.S. altogether.  

Dominance Means Leverage 

China’s fast-rising position in the legacy chip industry threatens U.S. national security because it  would grant Beijing extraordinary strategic leverage over the United States. That would encourage Chinese economic coercion and even a war over Taiwan.  

2.1. Xi’s Plan for ‘Offensive Leverage’: Geoeconomics lies at the heart of Chinese leader Xi  Jinping’s international strategy. The strategy is to exploit foreign dependence on Chinese critical  supply chains to accomplish Beijing’s objectives abroad. 

Xi himself laid the foundation of this vision in a pair of speeches in 2020 in which he called for  economic “deterrence” over the rest of the world. He called for an economic “gravitational field”  to “benefit the formation of new advantages for participating in international competition and  cooperation”. China would achieve this by heightening “the dependent relationships of international  industrial chains on our country, to form a powerful countermeasure and deterrence capability  against external parties who artificially cut off supply”, according to Xi. 

The Chinese Communist Party’s 2021 Five-Year Plan enshrined these principles in Party jargon,  calling for a “powerful domestic market and strong-trading country” to “form a powerful gravitational  field for global production factors and resources”. This is often called the “dual circulation” strategy by outside observers. It could more usefully be  called “offensive leverage”. 

2.2. Beijing’s Bullying Could Come for Washington: Since Xi Jinping rose to power in 2012, China  has repeatedly demonstrated these geoeconomic principles by flashing its economic strength to accomplish strategic objectives. 

The list of examples of Chinese economic coercion is long. In 2010, China limited Japanese  purchases of rare-earth minerals over a Senkaku Islands dispute. Norwegian salmon rotted that  same year on Chinese docks in retaliation for dissident Liu Xiaobo winning the Nobel Peace Prize. In  2012, Philippine bananas also rotted over the Scarborough Shoal dispute. In 2016, Beijing conveyed its displeasure toward Seoul for agreeing to host U.S. missile defense systems by squeezing South  Korean auto sales in China and slashing Chinese tourism in the country. 

This bullying has not slowed since Xi unveiled his economic thinking in 2020. That year, China  embargoed Australian wine, barley, wheat, coal, fish, and other products after Canberra passed  laws to reduce foreign influence and called for an investigation into the origins of Covid-19.In 2021, China blocked imports of Lithuanian goods over the state opening a “Taiwanese Representative  Office”. In just the past month, Beijing has threatened French luxury brands, German car makers, and Spanish pork producers in retaliation for EU duties on Chinese electric vehicles. 

Washington faces less blatant coercion compared to its allies. True, China has targeted U.S. firms  such Micron over the past few years. But the scale and ambition of this bullying has never  approached what China has applied to the likes of Australia and Lithuania. This may be because  Beijing does not believe it yet maintains necessary leverage over Washington to brandish its  economic blade as it does toward smaller economies.  

China’s growing position in the legacy semiconductor market could change that. How would  Beijing’s behavior change if sales of the Ford F-150 relied on Beijing’s willingness to sell its semiconductors?  

2.3. Reliance Endangers Taiwan: Western European reliance on Russian energy was one factor (among many) that encouraged Vladimir Putin to believe he could invade Ukraine with relative impunity. Likewise, deepening U.S. dependence on China for strategic supply chains could make it  far more difficult to challenge Beijing on sensitive geopolitical issues.  

The United States already relies on China for other key inputs to its economy: generic  pharmaceuticals, critical minerals, solar panels, and printed circuit boards, among others. U.S.  reliance on Chinese-made legacy chips – the product at the heart of modern economic life – could be the crown jewel of Chinese geoeconomics. American economic reliance on China could embolden Xi Jinping to think he could attack Taiwan with tolerable penalty.  

The Case for Blocking China’s Chips 

Familiar semiconductor policy approaches – export controls and subsidies – are inadequate alone to prevent reliance on Chinese-made legacy chips. Washington and its allies will instead have to turn  to the old-fashioned, disruptive tools of trade defense in the face of a challenge of this scale.  

3.1. It’s Too Late for Export Controls: The crux of current U.S. semiconductor policy toward China  is to contain the growth of Chinese advanced chip production by limiting its access to exquisite  machine tools produced by the United States and its allies (often called the ‘restrict’ agenda). Without those tools, China will be unable to build the cutting-edge chips that enable AI and  advanced weapons.  

Why not do the same for legacy chips? Washington and its allies could grow its existing rules so that China could not purchase machines capable of manufacturing legacy chips from Western producers. 

The issue is that China increasingly already has the tools it needs for its legacy chip production, in two ways: 

• China Has Stockpiled Western Tech: Beginning in 2020, China became the world’s top  buyer of semiconductor manufacturing equipment, a strong indicator of future capacity.Over the past year, China has risen to represent nearly half of all sales for Dutch giant ASML  and U.S. firm Lam Research. China’s demand is ‘non-market’. As ASML’s CEO put it: “Our  Chinese customers say: We are happy to take the machines that others don’t want”.
  
• Chinese Tools are Replacing Foreign Ones: Chinese semiconductor industrial policy has  pivoted in the past two years to cultivate domestic alternatives to Western tech. Advanced  Micro-fabrication Equipment, an etching firm competing with U.S. company Lam Research,  can produce some kinds of etching equipment for chip production at 5 nanometers and 28  nanometers. Shanghai Microelectronics Equipment, China’s lithography champion,  reportedly hopes to reveal soon a machine capable of servicing 28-nanometer  manufacturing. Chinese semiconductor players may soon be able to produce legacy chips  without Western tech. 

Export controls may have worked for the legacy challenge five or ten years ago. It’s unlikely to work alone today. 

3.2. Chinese Trade Practices Undermine Subsidies: The second pillar of Washington  semiconductor strategy for the past couple of years has been what’s often called the ‘promote’  agenda. The United States is deploying $39 billion in subsidies through the 2022 CHIPS and Science  Act to incentivize new chip factories at home. The strategy has helped galvanize $447 billion in  private investment across 25 states, 37 new chip fabs, and expansions at 21 other fabs. The United  States is now projected to make 30% of all advanced logic chips by 2032. But the CHIPS and Science Act  focuses on advanced chips, not legacy ones. Only a quarter of CHIPS funding ($10 billion) is planned to be spent on legacy-chip production.

Why not pass a Chips Act for legacy chips? California Representative Ro Khanna has called for doing  so: “a Chips Act 2.0 and 3.0 to better focus on legacy chips for our cars, refrigerators, and dryers”.  Indeed, subsidies may be a key tool to spur additional domestic legacy chip  production.  

But subsidies alone are unlikely to rise to the challenge. China’s “brute force” economic strategy  might render a legacy ‘promote’ agenda stillborn.  Beijing’s approach is to eliminate foreign  competitors with low prices by flooding international markets with state-sponsored artificially high  supply. China could flood the market with cheap chips to deter private Western investment into new chip production despite generous subsidies. The result could be billions of taxpayer dollars spent  with insufficient new chip capacity to show for it. 

Two recent examples demonstrate how Chinese industrial policy practices can undermine  Washington ‘promote’ policy: 

• Solar Panels: Two years ago, the Biden administration placed a two-year waiver on tariffs on  solar panels manufactured mostly in China but with minor processing in Southeast Asia  (Cambodia, Malaysia, Thailand, Vietnam). The administration waived these tariffs (between  50% and 254%) to help meet Inflation Reduction Act (IRA) targets for solar installation. But  in 2024 officials became worried that rock-bottom prices of imports (down 50% over the previous  year) caused U.S. firms to abandon plans to build new U.S. factories, undermining the  separate IRA goal of funding domestic solar manufacturing. Last month the administration  let that waiver lapse.
  
• Critical Minerals: Low global prices are also disrupting administration goals to reshore  critical mineral mining with domestic incentives. Lithium prices, for example, dropped by  75% in 2023. Mining investments globally grew at a lower rate last year than in 2022, despite Washington concern about reliance on Chinese minerals. 

One Pentagon-funded Idaho mine, the only cobalt mine in the United States, was planned to open last year. It’s instead been mothballed since over low cobalt prices – down by almost two-thirds in two years.The  owner of that mine, Australian firm Jervois, told investors in March it would lay off 30% of its senior corporate management over “adverse cobalt market conditions caused by Chinese  overproduction and its impact on pricing”.

The warning signs in the legacy chip sector are already flashing. Chinese semiconductors were “20  to more than 30%” cheaper than their international counterparts in 2022 and 2023, according to the  Silverado Policy Accelerator.This price advantage will likely only widen with time. 

3.3. Don’t Compete with China on Price: The challenge facing U.S. policymakers is that Chinese  industrial policy is designed to make it impossible for Western firms to offer prices competitive  against Chinese players. The solution is to deny Chinese chips access to Western markets.  

The logic is simple yet unfamiliar for some following semiconductor policy. Only if the U.S. market is denied to Chinese chips will those producing for the United States be forced to source chips outside  of China, and only then will the construction of scaled chipmaking capacity in third countries  become economic.  

How It Would Work 

Preventing U.S. reliance on Chinese chips would be more complicated than simply raising the tariff  on Chinese-made chips imported into the U.S. market. For it to work, Washington would need to  target goods that contain Chinese chips, not just the imports of the chips themselves. It also may need allied cooperation.  

4.1. Target Chips as Components, not the Chips Themselves: Semiconductors are  overwhelmingly an intermediate good, not a final product of the sort Washington typically tariffs or blocks at the border. U.S. policy will have to reflect that complexity.  

The Biden administration in May doubled U.S. tariffs on imported Chinese chips from 25% to 50%,  citing China’s “rapid capacity expansion that risks driving out investment by market-driven firms”. The original 25% tariff, imposed by the Trump administration in 2018, reduced direct imports of  Chinese chips by around 72%, according to the U.S. International Trade Commission. But direct  imports represent only a portion – likely a minority portion – of the Chinese-made chips that  otherwise enter the United States as components within other devices. 

The original 2018 tariffs had no effect on Chinese chips arriving as components of other goods – and  neither will the new Biden tariffs, which double the rate of the 2018 tariffs without changing their design. Closing this loophole would require the administration to do just that.  

One way of doing so would be to apply a “component tariff”, effectively increasing the import cost of  the final good (whatever it is) because it contains a chip or chips made in China. The China Committee called for this in January 2024. Another way would be to deny outright products containing Chinese chips entry into the United States. Both options could work, assuming a component tariff is  high enough to overcome any possible Chinese price advantage (e.g., 200% or higher).  

Some experts have expressed doubt that it is even possible as a policy matter to target Chinese chips  because they are intermediate goods. But this view is erroneous. In fact, various laws allow  Washington to tariff or outright exclude from the U.S. market any product made with Chinese  semiconductors. (See Section 5). 

4.2. Bring the Allies Along: A strategy to prevent U.S. reliance on Chinese chips would have higher  odds of success if U.S. allies join, most importantly Europe and Japan. The risk is that without allies,  international chip players would continue to design their microelectronics with Chinese chips, leaving the United States out of the best the market has to offer. A more optimistic assessment would be that the U.S. consumer market is so large that unilateral Washington action would be  enough to force leading market players to design their products without Chinese chips. 

Either way, allied signals are positive. The EU said about legacy chips last  April that it was “gathering  information on this issue”, and that it would coordinate with the United States to “collect and share  non-confidential information” about Chinese “non-market policies and practices”.The bloc’s new  duties on Chinese automakers indicate it could be open to similar measures toward chips. Japan  has taken fewer concrete steps than Europe, but Tokyo’s Minister for Economy, Trade and Industry Ken Saito told reporters that participants took “great interest” in legacy chips at the first Japan Korea-U.S. Commerce and Industry Ministerial Meeting on 28 June 2024. 

Washington’s Toolkit 

The United States has multiple policy tools that could be used to prevent U.S. reliance on Chinese made semiconductors. Th following summarizes these tools, in roughly ascending order of magnitude.  

5.1. Countervailing Duties: This form of tax can be placed by the Commerce Department on foreign goods that it finds to be subsidised and that the U.S. International Trade Commission (ITC) finds  materially injure a U.S. domestic industry. After an investigation prompted either by a petition from U.S. industry or initiated by Commerce itself, Commerce can impose “CVDs” on the goods in  question. 

Two challenges, however: First, it can sometimes be difficult to prove that Chinese state subsidies  have boosted specific goods. Second, chips imported as components of other goods aren’t a natural  fit for CVD investigations, so some policy creativity would likely be required. 

5.2. Anti-Dumping Duties: This alternative tax is like its sister duty in how it comes about and who  investigates it, but in this case it seeks to counter imports that have been “dumped” at artificially low prices in the U.S. market. 

As with CVDs, however, some policy creativity may be required to use anti-dumping duties for chips  imported as components of other goods. Further, it can be challenging to establish a baseline “fair”  price against which to measure the price of any Chinese goods in the U.S. market. Former senior Commerce official Nazak Nikakhtar noted: “It is nearly impossible to find a surrogate  country that has not been adversely affected by the PRC’s predatory pricing. . . . Virtually all  benchmark prices in trade cases are now understated and inadequate for measuring [dumping] by the PRC.” 

5.3. Section 337: This provision (from the Tariff Act of 1930) allows the U.S. ITC to investigate  imported goods for alleged links to intellectual-property theft and a range of other unfair trade  practices. Relief can take the form of exclusion orders, cease-and-desist orders, or sequestration of goods.  

But the 337’s bureaucratic process might be too burdensome. The ITC is an independent agency not subject to direction by the White House. In 2018, the Commission on the Theft of American  Intellectual Property, led by ex-ambassador and ex-governor Jon Huntsman, recommended speeding up the ITC’s 337 process.

5.4. Section 5949: With relatively little fanfare, Congress in late 2022 enacted a measure that will  curb some Chinese legacy-chip sales in the U.S. market – but only some, and slowly. Via Section  5949 of the annual defence bill, Congress prohibited the U.S. federal government and its contractors  from procuring semiconductors for “critical” uses from three Chinese firms (SMIC, YMTC, CXMT),  beginning in four years. This provision could be expanded in multiple ways that would block Chinese chips from large swathes of the U.S. market. Policymakers could shorten the phase-in period, blacklist additional companies (beside SMIC, YMTC and CXMT), or force U.S. government  contractors not to buy proscribed Chinese chips even for their own private use.

The federal government does not, however, have the authority to force state governments to adopt similar rules. This approach would also allow any company that does not contract with the federal  government to purchase Chinese chips.  

5.5. ‘ICTS’: The Commerce Department’s “Information and Communications Technology and  Services” (ICTS) regime is probably capable of restricting the import of goods containing Chinese made chips. The regime, first outlined in the final days of the Trump administration and embraced by  the Biden administration, has broad authorities to restrict transactions (from limits on cross-border  data flows to import bans) across theoretically the entire digital economy: critical infrastructure,  network infrastructure, data hosting, surveillance and monitoring tech, communications software, and emerging technology.The ICTS office’s current investigation on Chinese ‘Connected Vehicles’, will restrict Chinese-controlled critical components from being used in cars on U.S. roads. The  president might similarly be able to use ICTS to restrict the import of products containing Chinese made semiconductors.  

Taking on Chinese legacy chips, however, would not fit the ICTS Office neatly:

• ICTS’s policy emphasis thus far has been on technologies key for connectivity applications.  In the ongoing ‘Connected Vehicles’ investigation, for example, the office cited its worries  about Chinese electric vehicles as centering on software and hardware that enables the  car’s connection back to China (e.g., cellular telecommunications systems).Legacy chips  do enable connectivity, but the challenge is much broader than that. Mature-node chips  enable the entire modern economy. 
  
• It would be daunting task such a new Washington bureaucracy. The office only began fully  staffing up in summer 2022, and its first action was taken against a single firm three years  after the Biden administration first confirmed it would maintain the authority. ICTS is not  likely ready to oversee a mission with such deep implications for the entire microelectronics  industry and U.S. trade with China and the rest of the world.  

5.6. Section 232: This instrument (from the Trade Expansion Act of 1962) allows any federal  department to require a Commerce Department investigation of specified imports that may threaten  national security (defined broadly). The President may then impose tariffs or quotas as a remedy.  The Trump administration used Section 232 to tariff imports of steel and aluminum in 2018, and it  could be a viable approach to legacy chips too.  

232’s main drawback is that it does not allow import bans. An obvious workaround would be to apply a component tariff onto Chinese semiconductors so high that it works effectively as a ban (e.g., north  of 200%).  

5.7. Washington’s Most Powerful Tool – Section 301: The strongest tool for the legacy-chips  challenge might be the Section 301 of the Trade Act of 1974, which gives the Office of the U.S. Trade  Representative broad scope investigate “unreasonable”, “discriminatory”, or  “unjustifiable” actions that burden U.S. commerce.  After an investigation, USTR has sweeping  powers to impose remedies as it sees fit, e.g. with tariffs, import bans, or other sanctions. It gives a president notably broad, flexible, and discretionary powers. 

301 has become the bipartisan tool of choice to address unfair Chinese trade and industrial practices and to reshore supply chains: 

• The Trump administration used 301 as its main instrument for adjusting trade with China. Trump launched a Section 301 investigation into Chinese intellectual-property theft and  technology transfer in August 2017, then used its conclusions to apply tariffs in multiple  tranches in 2018 and 2019. This is what came to be called the U.S.-China “trade war”. With  301, the Trump administration was able to apply tariffs on Chinese goods to a level unseen  (and overwhelmingly unexpected) since before China’s accession to the World Trade  Organization. 
  
• The Biden administration has similarly embraced Section 301 to limit Chinese access to  the U.S. market at will. In May, the Biden administration used Trump’s 301 investigation to  increase tariffs on strategic goods: semiconductors, electric vehicles, batteries, certain  critical minerals, solar cells, port cranes, and medical products (e.g., face masks and rubber  gloves). The administration doubled U.S. tariffs on Chinese chips imported as such from 25% to 50%. Most Chinese chips enter the U.S. markets within other devices. This move is unlikely to solve the legacy-chip challenge.

• Biden administration officials had in April 2024 pointed to China’s “overcapacity” in  critical sectors as justification.  That same month, Biden also opened a 301 investigation into China’s activities in the shipbuilding sector.

A future 301 investigation could almost certainly find a way to prohibit goods with Chinese-made semiconductors from entering the U.S. market. The United States could open a 301 investigation into  Beijing’s state-led subsidy strategy to do so, as the Biden administration considered doing in 2021. 

Some may worry that 301’s required investigation before applying remedies would slow down a  solution that would ideally begin as soon as possible. But a public investigation of China’s position in the semiconductor industry could have major benefits. It could provide the administration insight into the international microelectronics supply chain, needed to implement a legacy restriction policy. 

And it would send industry a clear message that it should begin shifting its supply chains before the new U.S. policy began.  

Some of History’s Lessons on Decoupling  

One challenge facing this strategy is if it is practically possible to stop Chinese-made chips from  entering the U.S. market, no matter U.S. law. Some have called banning Chinese chips tantamount to trying to “hold sand in your hands”. The U.S. government has limited visibility into global supply chains. How could Washington enforce the next phase of China chips containment? 

Two examples of U.S. efforts to remove goods from international supply chains point to lessons about how the United States could go about doing so successfully today: implementation of the  Uyghur Forced Labor Prevention Act (UFLPA), and the ‘Kimberley Process’ to prevent sourcing blood  diamonds from Africa. They show that Washington will need three things to enforce this strategy: supply chain clarity, active participation from private industry to detect lawbreakers, and an allied  coalition to ensure success in preventing U.S. reliance on Chinese-made chips.  

6.1. Improving on the UFLPA Enforcement: Removing Chinese-made legacy chips from the U.S.  market would not be the first time Washington moved to fundamentally change the U.S.-China  trading relationship in pursuit of excising specific Chinese goods from the United States. The Uyghur Forced Labor Prevention Act, passed by Congress in late 2021, prohibited entirely any goods from  Xinjiang – or those with supply chains stemming from there – from coming into the United States on  grounds that they were tainted with forced labor. UFLPA Republican co-author Marco Rubio vowed  in 2021 that it would “fundamentally change our relationship with Beijing”. Jim McGovern, the  Democratic congressman who authored the House version of the bill, said “No more business as  usual”. 

Yet the law has had a less significant impact on U.S.-China trade flows than initially anticipated, most importantly in the solar industry. Some half of all global polysilicon, a base material for solar panels, comes from Xinjiang. Chinese firms have nonetheless increased their market share in the  United States since the passage of the UFLPA. 

There are three lessons to take from these challenges that policymakers can apply to the coming legacy chip trade war: 

1. Supply Chain Clarity Needed: The UFLPA granted the administration no additional funding  for enforcement, likely forcing difficult decisions across the administration of how to fund  the stiff demands for research into global forced labor supply chains. Enforcing legacy-chip  protectionism would likely require a major expansion of supply chain analytical capabilities  across the U.S. government, including in the Commerce Department and within Customs  and Border Protection. 
   
2. Let Private Industry Help with Enforcement: UFLPA enforcement might have been more  successful if detecting those who violated U.S. law was the responsibility of private industry,  not that of the government. Is this even possible?  

It appears so. The False Claims Act of 1863 allows private parties to initiate a lawsuit on  behalf of the U.S. government against those who have defrauded the U.S. government. Whistleblowers receive some 15% to 30% of the government’s award if they win. This law,  originally passed in the Civil War to crack down on fraud from military contractors, has  increasingly been used against those who commit customs and tariffs fraud. The law triples damages and civil penalties for violators.  

These cases (called “qui tam” cases) have been brought against those who transshipped  Chinese goods through third countries to dodge 301 tariffs. In one case, manufacturing  tools firm King Kong Tools paid $1.9 million in November 2023 to settle allegations that the  firm dodged paying 301 tariffs by falsely claiming its goods were made in Germany. The  case began when a competitor to King Kong brought a qui tam suit alleging that King Kong  produced its products in China, shipped them to Germany, then sent them to the United  States. The whistleblower received an award of $286,000. 

Washington could similarly enlist the private sector to help detect violations of legacy-chip trade rules. At a minimum, the Justice Department could begin a public campaign to  encourage whistleblowers to bring qui tam cases against violators. (Including technology research firms. TechInsights, the company known for teardowns of Chinese  microelectronics to determine their quality, comes to mind here.) The U.S. government  could also find ways to increase the incentive for private parties to bring cases against tariff  dodgers. Congress could update the False Claims Act to boost the reward for whistleblowers,  for example.  

6.2. An Allied System for Legacy-Chip Trade Protection: The Kimberley Process is a UN-mandated  certification scheme launched in 2003 to prevent diamonds that fund conflict from entering global  markets. 85 member states, civil society groups, and industry agreed to commit to transparent  practices and share data to certify that imported diamonds are not tainted by conflict. 

Washington and its allies should agree to collectively work to restrict the import of Chinese made legacy chips. They could share best practices and supply chain intelligence. It could make it  easier for Washington to know where Chinese semiconductors are moving throughout global supply chains. Doing so would help build an allied coalition collectively more resilient against Beijing’s economic coercion. 

In the quest for sustainable energy and materials, biomass emerges as a key player, bridging the gap between the energy sector and the burgeoning U.S. and regional bioeconomies (microbioeconomies). Despite often being pigeonholed as fuel for energy production, biomass holds far-reaching potential that extends beyond combustion. Identifying sustainable biomass feedstocks that are easily accessible and consistent in their makeup could be a game-changer to help regions unlock their bioeconomy potential and support scientific innovations toward more environmentally sustainable materials and chemicals.

Biomass is defined as “any organic matter that is available on a renewable or recurring basis, including agricultural crops and trees, wood and wood residues, plants, algae, grasses, animal manure, municipal residues, and other residue materials” by the Foundation for Food & Agriculture Research (FFAR). Biomass has mainly been viewed by the public as a source of energy through burning or for chemical conversion into biofuels, encouraged by federal incentive programs, including those from the United States Department of Agriculture (USDA) and the Department of Energy (DOE). However, aside from burning or conversion for biofuel, biomass can undergo a complex process of chemical or biological breakdown and be transformed into various building block components that can be used for a wide range of biotechnology applications.

Once the biomass is broken down into its functional components it can be used as a feedstock, which is a “resource used as the basis for manufacturing another product. [Often], . . . a source of carbon to produce an array of chemicals.” For example, lignocellulosic biomass, plant or plant-based materials not used for food, can be hydrolyzed into sugars, which serve as precursors for bio-based chemicals and materials. This allows for new, environmentally sustainable chemicals for use in biotechnology and biomanufacturing applications, thus positioning biomass as a cornerstone resource of the U.S. bioeconomy. In addition to biochemical production, biomass, and feedstock are used in the bioeconomy in bioplastics and biomaterials. To push the U.S. bioeconomy toward environmental sustainability, it is critical to begin building programmatic and physical infrastructure to harness biomass, which is ultimately converted into feedstock using biotechnology applications and used in the biomanufacturing process to create everyday materials for the public.

Not All Biomass is Used for Energy, or Sustainably Produced

While biomass holds promise as a renewable energy source, not all biomass is used for energy, and not all of it is sustainable. Corn is a consistent poster child of the biomass and biofuel industry as a sustainable way to power combustion engines. Yet, the growth of corn relies heavily on the extensive use of fertilizers and pesticides, which can lead to soil erosion, water pollution, and habitat degradation. Depending on how a company conducts its Life Cycle Assessment and Carbon Intensity of its supplies, corn may not truly represent an environmentally sustainable biomass solution.

However, it is tough to beat the productivity of corn and its ability to be used for various biomass and atmospheric carbon capture applications. For example, corn stover, the byproduct stalks and leaves leftover from harvest, can be broken down into biochar for reuse in soil nutrient replenishment and is excellent for carbon sequestration from the atmosphere. Carbon sequestration is the “storage of carbon dioxide (CO2) after it is captured from industrial facilities and power plants or removed directly from the atmosphere”. One California-based company, Charm, is harvesting the leftover corn leaves, husks, and stalks and breaking them down into bio-oil which is stored deep underground in EPA-regulated wells. This bio-oil now contains sequestered carbon from corn crops and locks it away for thousands of years thus allowing a simple, and effective, way to use farm waste materials as carbon sequestration machines. This corn stover may otherwise have been burned or left to rot, releasing its carbon into the atmosphere.

As the DOE Bioenergy Technology Office puts it:

“Crops can serve as a carbon sink, capturing CO2 from the atmosphere. During CO2 fermentation, some of this recycled CO2 can be harnessed for various applications, such as carbon capture and storage, where it can be compressed or stored underground. The convergence of lower input costs, improvement of ethanol production, and CO2 management showcases a sector poised to contribute to a sustainable and prosperous future.”

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While corn remains the leader of the biomass pack for usage in atmospheric carbon capture, it is necessary to begin broadening the biomass portfolio into other crops, both conventional and not, that can offer similar carbon capture and biomass benefits for industrial energy and feedstock use. The introduction of more sustainable biomass inputs, like waste hulls from almond crops, winter oilseed crops, or macro/microalgae, might be the key to introducing options for industries to use for their biomanufacturing processes. To make the U.S. bioeconomy more environmentally sustainable, it will be necessary to prioritize the use of biomass that is sustainable for the creation of bio-based products. To achieve this, policymakers and industry leaders can come together to understand the physical infrastructure needed to support the processing and utilization of sustainable biomass.

Biomass in Carbon Accounting

A contentious issue in biomass utilization revolves around carbon accounting, particularly concerning the differentiation between biogenic and fossil fuel carbon. Biogenic carbon originates from recently living organisms and is part of the natural carbon cycle, while fossil fuel carbon is derived from the remains of extinct carbon-rich plants and animals that decomposed as they were compressed and heated in the ground. When burned, this fossil fuel carbon is released into the atmosphere, contributing to greenhouse gas emissions. The current carbon accounting frameworks often conflate these distinctions, leading to misconceptions and controversies surrounding biomass utilization’s carbon neutrality claims. Addressing this ambiguity is crucial for aligning policy frameworks with scientific realities and ensuring informed decision-making in biomass utilization. As microbioeconomies grow, any confusion about biogenic versus fossil fuel carbon could become another barrier to entry for burgeoning bioeconomy opportunities.

Environmental and Economic Impacts

All across rural America, local economic developers are seeing more biomass conversion projects come to their communities, which offers the chance to boost economic revenues from turning biomass into energy, fuel, or feedstock and creates a broad spectrum of jobs for the area. To capitalize on this, increased bioliteracy on how growing biomass could offer additional financial support for farmers, provide energy to heat communities, and become feedstock for the biotechnology and biomanufacturing industry is critical. The more we activate and connect parts of America that are not located in existing high-density technology hubs, the better prepared these communities will be when biomass projects look to settle in those places. For example, woody biomass was emphasized throughout the DOE 2023 Billion Ton report as an important biomass source for fuel and energy production, yet the process of getting the timber and woody biomass out of the forest and into processing facilities is slow to launch due to concerns over environmental impacts.

While environmental impacts are valid and of great concern in some ecosystems around the U.S., harvesting wood waste and timber in areas that are primed for increased forest fire risk might be a sustainable option for protecting forest ecosystems while also benefiting the community for energy and heat concerns. The USDA Wildland Fire Mitigation and Management Commission discussed the need for further research into forest biomass to understand how it can generate profit for communities with otherwise waste materials while also mitigating fire risk. One recommendation stated the need for “Increase[d] resources for programs to help private landowners dispose of woody biomass”. Although several programs assist landowners in this effort, there are still significant expenses involved. These costs may discourage landowners from conducting fuel reduction activities, leading them to either burn the material, which can harm air quality, or leave it on the land, potentially worsening wildfire severity in case of an outbreak. There’s a necessity for initiatives supporting the disposal of biomass, including wood chipping, hauling, and its utilization. These initiatives could receive support from USDA Rural Development and should explore ways to encourage landowners to sustainably harvest their woody biomass for both financial incentives and for reducing wildfire risk.

Billion Ton Report Recommendations

According to the 2023 DOE Billion-Ton Report, the U.S. used 342 million tons of biomass for energy and bio-based chemicals in 2022. The top biomass source for biofuels is corn, with the U.S. producing nearly 150 tons per year of corn that is converted to ethanol. Whereas ~140 million tons of forestry/wood and wood waste (woody biomass) are used for heat and power purposes. However, many other types of biomass exist and are used for various purposes including transportation or industrial and electrical power. Below is an abbreviated list, based on the Billion-Ton Report, of common biomass examples and some of their uses.

The recent Billion Ton report makes it clear that the U.S. has plenty of available biomass for use in the production of biofuel, heat/energy, and bio-based products, and that further utilization of biomass in these applications and in biotechnology and biomanufacturing industries could be a way forward to mitigate climate change and improve sustainability of the U.S. bioeconomy. To change the mindset of biomass as more than corn grown for biofuel, it will take a concerted effort by the federal agencies involved in funding biomass use projects, like the DOE, USDA, National Science Foundation, and the Department of Defense, to communicate to farmers that growing biomass can be profitable. It will also take a joint effort from the federal government and local governments to build pilot and commercial scale facilities to begin processing diverse biomass.

Overall, there is immense promise in connecting biomass growers, processors, and bio-powered industries. It allows the players in the U.S. bioeconomy to think critically about their waste outputs and how to harness biomass as the key to unlocking a future where all communities, be they rural or urban, benefit from our national bioeconomy. You can learn more about biomass use in biotechnology and biomanufacturing at our upcoming webinar May 1st at 10 AM ET.