Science Policy
day one project

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

04.05.24 | 10 min read | Text by Johanna Lawton

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

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

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

Challenge and Opportunity

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

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

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

Plan of Action

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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