Turning the Heat Up On Disaster Policy: Involving HUD to Protect the Public
This memo addresses HUD’s learning agenda question, “How do the impacts, costs, and resulting needs of slow-onset disasters compare with those of declared disasters, and what are implications for slow-onset disaster declarations, recovery aid programs, and HUD allocation formulas?” We examine this using heat events as our slow-onset disaster, and hurricanes as declared disaster.
Heat disasters, a classic “slow-onset disaster”, result in significant damages, which can exceed damage caused by more commonly declared disasters like hurricanes due to high loss of life from heat. The Federal Housing and Urban Development agency (HUD) can play an important role in heat disasters because most heat-related deaths occur in the home or among those without homes; therefore, the housing sector is a primary lever for public health and safety during extreme heat events. To enhance HUD’s ability to protect the public from extreme heat, we suggest enhancing interagency data collection/sharing to facilitate the federal disaster declarations needed for HUD engagement, working heat mitigation into HUD’s programs, and modifying allocation formulas, especially if a heat disaster is declared.
Challenge and Opportunity
Slow-Onset Disasters Never Declared As Disasters
Slow-onset disasters are defined as events that gradually develop over extended periods of time. Examples of slow-onset events like drought and extreme heat can evolve over weeks, months, or even years. By contrast, sudden-onset disasters like hurricanes, occur within a short and defined timeframe. This classification is used by international bodies such as the United Nations Office for Disaster Risk Reduction (UNDRR) and the International Federation of Red Cross and Red Crescent Societies (IFRC).
HUD’s main disaster programs typically require a federal disaster declaration , making HUD action reliant on action by the Federal Emergency Management Agency (FEMA) under the Stafford Act. However, to our knowledge, no slow-onset disaster has ever received a federal disaster declaration, and this category is not specifically addressed through federal policy.
We focus on heat disasters, a classic slow-onset disaster that has received a lot of attention recently. No heat event has been declared a federal disaster, despite several requests. Notable examples include the 1980 Missouri heat and drought events, the 1995 Chicago heat wave, which caused an estimated 700 direct fatalities, as well as the 2022 California heat dome and concurrent wildfires. For each request, FEMA determined that the events lacked sufficient “severity and magnitude” to qualify for federal assistance. FEMA holds a precedent that declared disasters need to have a discrete and time-bound nature, rather than a prolonged or seasonal atmospheric condition.
“How do the impacts, costs, and resulting needs of slow-onset disasters compare with those of declared disasters?”
Heat causes impacts in the same categories as traditional disasters, including mortality, agriculture, and infrastructure, but the impacts can be harder to measure due to the slow-onset nature. For example, heat-related illness and mortality as recorded in medical records are widely known to be significant underestimates of the true health impacts. The same is likely true across categories.
Sample Impacts
We analyze impacts within categories commonly considered by federal agencies–human mortality, agricultural impacts, infrastructure impacts, and costs for heat, and compare them to counterparts for hurricanes, a classic sudden-onset disaster. Other multi-sectoral reports of heat impacts have been compiled by other entities, including SwissRe and The Atlantic Council Climate Resilience Center.
We identified 3,478 deaths with a cause of “cataclysmic storms” (e.g., hurricanes; International Classification of Disease Code X.37) and 14,461 deaths with a cause of heat (X.30) between 1999-2020 using data from the Centers for Disease Control and Prevention’s (CDC). It is important to note that the CDC database only includes death certificates that list heat as a cause of death, while it is widely recognized that this can be a significant underaccount. However, despite these limitations, CDC remains the most comprehensive national dataset for monitoring mortality trends.
HUD can play an important role in reducing heat mortality. In the 2021 Pacific Northwest Heat Dome, most of the deaths occurred indoors (reportedly 98% in British Columbia) and many in homes without adequate cooling. In hotter Maricopa County, Arizona, in 2024, 49% of all heat deaths were among people experiencing homelessness and 23% occurred in the home. Therefore, across the U.S., HUD programs could be a critical lever in protecting public health and safety by providing housing and ensuring heat-safe housing.
Agricultural Labor
Farmworkers are particularly vulnerable to extreme heat, and housing can be part of a solution to protect them. According to the Environmental Protection Agency (EPA), between 1992 to 2022, 986 workers across industry sectors died from exposure to heat, with agricultural workers being disproportionately affected. According to the Environmental Defense Fund, farmworkers in California are about 20 times more likely to die from heat-related stress, compared to the general population, and they estimate that the average U.S agricultural worker is exposed to 21 working days in the summer growing season that are unsafe due to heat. A study found that the number of unsafe working days due to extreme heat will double by midcentury, increasing occupational health risks and reducing labor productivity in critical sectors. Adequate cooling in the home could help protect outdoor workers by facilitating cooling periods during nonwork hours, another way in which HUD could have a positive impact on heat.
Infrastructure and Vulnerability
Rising temperatures significantly increase energy demand, particularly due to the widespread reliance on air conditioning. This surge in demand increases the risk of power outages during heat events, exacerbating public health risks due to potential grid failure. In urban areas, the built environment can add heat, while in rural areas residents are at greater risk due to the lack of infrastructure. This effect contributes to increased cooling costs and worsens air quality, compounding health vulnerabilities in low-income and urban populations. All of these impacts are areas where HUD could improve the situation through facilitating and encouraging energy-efficient homes and cooling infrastructure.
Costs
In all categories we examined, estimates of U.S.-wide costs due to extreme heat rivaled or exceeded costs of hurricanes. For mortality, the estimated economic impact of mortality (scaled by value of statistical life, VSL = $11.6 million) caused by extreme heat reached $168 billion, significantly exceeding the $40.3 billion in VSL losses from hurricanes during the same period. Infrastructure costs further reflect this imbalance. Extreme heat resulted in an estimated $100 billion in productivity loss in 2024 alone, with over 60% of U.S. counties currently experiencing reduced economic output due to heat-related labor stress. Meanwhile, Hurricanes Helene and Milton together generated $113 billion in damage during the 2024 Atlantic hurricane season.
Crop damage reveals the disproportionate toll of heat and drought, with 2024 seeing $11 billion in heat/drought impacts compared to $6.8 billion from hurricanes. The dairy industry experiences a substantial recurring burden from extreme heat, with annual losses of $1.5 billion attributed to heat-induced declines in production, reproduction, and livestock fatalities. Broader economic impacts from heat-related droughts are severe, including $14.5 billion in combined damages from the 2023 Southern and Midwestern drought and heatwave, and $22.1 billion from the 2022 Central and Eastern heat events. Comparatively, Hurricane Helene and Hurricane Milton produced $78.7 billion and $34.3 billion in damages, respectively. Extreme heat and drought exert long-term, widespread, and escalating economic pressures across public health, agriculture, energy, and infrastructure sectors. A reassessment of federal disaster frameworks is necessary to appropriately prioritize and allocate funds for heat-related resilience and response efforts.
Resulting Needs
Public Health and Medical Care: Immediate care and resources for heat stroke and exhaustion, dehydration, and respiratory issues are key to prevent deaths from heat exposure. Vulnerable populations including children, elderly, and unhoused are particularly at risk. There is an increased need for emergency medical services and access to cooling centers to prevent the exacerbation of heat stress and to prevent fatalities.
Cooling and Shelter: Communities require access to public cooling centers and for air conditioning. Clean water supply is also essential to maintain health.
Infrastructure and Repair: The use of air conditioning increases energy consumption, leading to power outages. Updated infrastructure is essential to handle demand and prevent blackouts. Building materials need to include heat-resistant materials to reduce Urban Heat Island effects.
Emergency Response Capacity: Emergency management systems need to be strengthened in order to issue early warnings, produce evacuation plans, and mobilize cooling centers and medical services. Reliable communication systems that provide real-time updates with heat index and health impacts will be key to improve community preparedness.
Financial Support and Insurance Coverage: Agricultural, construction, and service workers are populations which are vulnerable to heat events. Loss of income may occur as temperatures rise, and compensation must be given.
Social Support and Community Services: There is an increasing need for targeted services for the elderly, unhoused, and low-income communities. Outreach programs, delivery of cooling resources, and shelter options must be communicated and functional in order to reduce mortality. Resilience across these sectors will be improved as data definitions and methods are standardized, and when allocations of funding specifically for heat increase.
“What are implications for slow-onset disaster declarations, recovery aid programs, and HUD allocation formulas?”
Slow-onset disaster declarations
No heat event–or to our knowledge or other slow-onset disaster–has been declared a disaster under the Stafford Act, the primary legal authority for the federal government to provide disaster assistance. The statute defines a “major disaster” as “any natural catastrophe… which in the determination of the President causes damage of sufficient severity and magnitude to warrant major disaster assistance 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.” Though advocacy organizations have claimed that the reason for the lack of disaster declaration is because the Stafford Act omits heat, FEMA’s position is that amendment is unnecessary and that a heat disaster could be declared if state and local needs exceed their capacity during a heat event. This claim is credible, as the COVID-19 pandemic was declared a disaster without explicit mention in the Stafford Act.
Though FEMA’s official position has been openness to supporting an extreme-heat disaster declaration, the fact remains that none has been declared. There is opportunity to improve processes to enable future heat declarations, especially as heat waves affect more people more severely for more time. The Congressional Research Service suggests that much of the difficulty might stem from FEMA regulations focusing on assessment of uninsured losses makes it less likely that FEMA will recommend that the President declare a disaster. Heat events can be hard to pin down with defined time periods and locations, and the damage is often to health and other impacts that are slow to be quantified. Therefore, real-time monitoring systems that quantify multi-sectoral damage could be deployed to provide the information needed. Such systems have been designed for extreme heat, and similar systems are being tested for wildfire smoke–these systems could rapidly be put into use.
The U.S. Department of Housing and Urban Development (HUD) plays a critical role in long-term disaster recovery, primarily by providing housing assistance and funding for community development initiatives (see table above). However, HUD’s ability to deploy emergency support is contingent upon disaster declaration under the Stafford Act and/or FEMA activation. This restriction limits HUD’s capacity to implement timely interventions, such as retrofitting public housing with cooling systems or providing emergency housing relief during extreme heat events.
Without formal recognition of a heat event as a disaster, HUD remains constrained in its ability to deliver rapid and targeted support to vulnerable populations facing escalating risks from extreme temperatures. Without declared heat disasters, the options for HUD engagement hinge on either modifying program requirements or supporting the policy and practice needed to enable heat disaster declarations.
HUD Allocation Formulas
Congress provides funding through supplemental appropriations to HUD following major disasters, and HUD determines how best to distribute funding based on disaster impact data. The calculations are typically based on Individual and Public Assistance data from FEMA, verified loss data from the Small Business Administration (SBA), claims from insurance programs such as the National Flood Insurance Program (NFIP), and housing and demographic data from the U.S Census Bureau and American Community Survey. CDBG-DR and CDBG-MIT typically require that at least 70% and 50% of funds benefit low and moderate income (LMI) communities respectively. Funding is limited to areas where there has been a presidentially declared disaster.
For example, the Disaster Relief Supplemental Appropriations Act, 2025 (approved on 12/21/2024) appropriated $12.039 billion for CDBG-Disaster Recovery funds (CDBG-DR) for disasters “that occurred in 2023 or 2024.” HUD focused its funding on areas with the most serious and concentrated unmet housing needs from within areas that experienced a declared disaster within the time frame. Data used to determine the severity of unmet housing needs included FEMA and SBA inspections of damaged homes; these data were used in a HUD formula.
Opportunities exist to adjust allocation formulas to be more responsive to extreme heat, especially if CDBG is activated for a heat disaster. For example, HUD is directed to use the funds “in the most impacted and distressed areas,” which it could interpret to include housing stock that is unlikely to protect occupants from heat.
Gaps
Extreme heat presents multifaceted challenges across public health, infrastructure, and agriculture, necessitating a coordinated and comprehensive federal response. The underlying gap is the lack of any precedent for declaring an extreme-heat disaster; without such a declaration, numerous disaster-related programs in HUD, FEMA, and other federal agencies cannot be activated. Furthermore, likely because of this underlying gap, disaster-related programs have not focused on protecting public health and safety from extreme heat despite its large and growing impact.
Plan of Action
Recommendation 1. Improve data collection and sharing to enable disaster declarations.
Because lack of real-time, quantitative data of the type most commonly used by disaster declarations (i.e., uninsured losses; mortality) is likely a key hindrance to heat-disaster declarations, processes should be put in place to rapidly collect and share this data.
Health impacts could be tracked most easily by the CDC using the existing National Syndromic Surveillance System and by expanding the existing influenza-burden methodology, and by the National Highway Traffic Safety Association’s Emergency Medical Services Activation Surveillance Dashboard. To get real-time estimates of mortality, simple tools can be built that estimate mortality based on prior heatwaves; such tools are already being tested for wildfire smoke mortality. Tools like this use weather data as inputs and mortality as outputs, so many agencies could implement–NOAA, CDC, FEMA, and EPA are all potential hosts. Additional systems need to be developed to track other impacts in real time, including agricultural losses, productivity losses, and infrastructure damage.
To facilitate data sharing that might be necessary to develop some of the above tools, we envision a standardized national heat disaster framework modeled after the NIH Data Management and Sharing (DMS) policy. By establishing consistent definitions and data collection methods across health, infrastructure, and socioeconomic sectors, this approach would create a foundation for reliable, cross-sectoral coordination and evidence-based interventions. Open and timely access to data would empower decision-makers at all levels of government, while ethical protections—such as informed consent, data anonymization, and compliance with HIPAA and GDPR—would safeguard individual privacy. Prioritizing community engagement ensures that data collection reflects lived experiences and disparities, ultimately driving equitable, climate-resilient policies to reduce the disproportionate burden of heat disasters.
While HUD or any other agency could lead the collaboration, much of the National Integrated Heat Health Information System (NIHHIS) partnership (HUD is a participant) is already set up to support data-sharing and new tools. NIHHIS is a partner network between many federal agencies and therefore has already started the difficult work of cross-agency collaboration. Existing partnerships and tools can be leveraged to rapidly provide needed information and collaboration, especially to develop real-time quantification of heat-event impacts that would facilitate declaration of heat disasters. Shifting agency priorities have reduced NIHHIS partnerships recently; these should be strengthened, potentially through Congressional action.
Recommendation 2. Incorporate heat mitigation throughout HUD programs
Because housing can play such an important role in heat health (e.g., almost all mortality from the 2021 Heat Dome in British Columbia occurred in the home; most of Maricopa County’s heat mortality is either among the unhoused or in the home), HUD’s extensive programs are in a strong position to protect health and life safety during extreme heat. Spurring resident protection could include gentle behavioral nudges to grant recipients, such as publishing guidance on regionally tailored heat protections for both new construction and retrofits. Because using CDBG funds for extreme heat is uncommon, HUD should publish guidance on how to align heat-related projects with CDBG requirements or how to incorporate heat-related mitigation into projects that have a different focus. In particular, it would be important to provide guidance on how extreme heat related activities meet National Objectives, as required by authorizing legislation.
HUD could also take a more active role, such as incentivizing or requiring heat-ready housing across their other programs, or even setting aside specific amounts of funds for this hazard. The active provision of funding would be facilitated by heat disaster declarations, so until that occurs it is likely that the facilitation guides suggested above are likely the best course of action.
HUD also has a role outside of disaster-related programs. For example, current HUD policy requires residents in Public Housing Agency (PHA) managed buildings to request funding relief to avoid surcharges from heavy use of air conditioning during heat waves; policy could be changed to proactively initiate that relief from HUD. In 2024, Principal Deputy Assistant Secretary Richard Monocchio sent a note encouraging broad thinking to support residents through extreme heat, and such encouragement can be supported with agency action. While this surcharge might seem minor, ability to run air conditioning is key for protecting health, as many indoor heat deaths across Arizona to British Columbia occurred in homes that had air conditioning but it was off.
Recommendation 3. HUD Allocation Formula: Inclusion of Vulnerability Variables
When HUD is able to launch programs focused on extreme heat, likely only following an officially declared heat disaster, HUD allocation formulas should take into account heat-specific variables. This could include areas where heat mortality was highest, or, to enhance mitigation impact, areas with higher concentrations of at-risk individuals (older adults, children, individuals with chronic illness, pregnant people, low-income households, communities of color, individuals experiencing houselessness, and outdoor workers) at-risk infrastructure (older buildings, mobile homes, heat islands). By integrating heat-related vulnerability indicators in allocations formulas, HUD would make the biggest impact on the heat hazard.
Conclusion
Extreme heat is one of the most damaging and economically disruptive threats in the United States, yet it remains insufficiently recognized in federal disaster frameworks. HUD is an agency positioned to make the biggest impact on heat because housing is a key factor for mortality. However, strong intervention across HUD and other agencies is held back by lack of federal disaster declarations for heat. HUD can work together with its partner agencies to address this and other gaps, and thereby protect public health and safety.
How do the impacts, costs, and resulting needs of slow-onset disasters compare with those of declared disasters, and what are implications for slow-onset disaster declarations, recovery aid programs, and HUD allocation formulas?
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