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

04.03.24 | 9 min read | Text by Grace Wickerson & Autumn Burton & John A. “Skip” Laitner

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

As a proactive measure, there needs to be a mandate for the implementation of an Executive Order or an interagency Memorandum of Understanding (MOU) mandating the expansion of Public Health and Emergency Response Planning for Widespread Grid Failure Under Extreme Heat. This urgently needed action would help mitigate the worst impacts of future grid failures under extreme heat, safeguarding lives, the economy, and national security as the U.S. moves toward a more sustainable, stable, and reliable electric grid system.

When the lights go out, restoring power across America is a complex, intricate process requiring seamless collaboration among various agencies, levels of government, and power providers amid constraints extending beyond just the loss of electricity. In a blackout, access to critical services like telecommunications, transportation, and medical assistance is also compromised, which only intensifies and compounds the urgency for coordinated response efforts. To avert blackouts, operators frequently implement planned and unplanned rolling blackouts, a process for load shedding that eases strain on the grid. However, these actions may lack transparent protocols and criteria for safeguarding critical medical services. Equally crucial and missing are frameworks to prioritize regions for power restoration, ensuring equitable treatment for low-income and socially vulnerable communities affected by grid failure events.

Thus, given the gravity of these high-risk, increasingly probable scenarios facing the United States, it is imperative for the federal government to take a leadership role in assessing and directing planning and readiness capabilities to respond to this evolving disaster.


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

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

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

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

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

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

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

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

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

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


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

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

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

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

Plan of Action

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

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

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

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

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

FEMA should:

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

Recommendation 2. Establish an interagency MOU

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

This MOU should outline the following actions:


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

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

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

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

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

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

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

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