Federal Agencies Reinvigorate Climate Adaptation


Last month, the federal government returned to a crucial task: to ensure that it can continue to do its job as the climate changes. Climate change threatens every aspect of U.S. government operations and assets, from a safe and healthy workforce, to functioning office buildings, vehicle fleets, and chains. reliable supplies. But climate adaptation plans initially developed by federal agencies under the Obama administration have languished under Trump. The Biden-Harris administration deserves a lot of credit for recognizing the current and growing danger of more extreme weather and for moving quickly to release 26 new agency adaptation plans in response to Executive Order 14008.

Wildland firefighters receive a tactical briefing on the Cedar fire in California.

US Department of Agriculture / Lance Cheung, public domain

The NRDC has just filed formal comments on the 26 climate adaptation plans, offering several recommendations to the White House Council on Environmental Quality (CEQ) and the Office of Management and Budget (OMB) to make plans even more comprehensive, fair and achievable.

In general, the 2021 plans are more specific and targeted than the previous generation. Yet improvements are needed at all levels to ensure that workers are better protected, that disaster prevention takes priority over response, that vulnerable communities receive the help they need, and that leadership places these problems in the foreground. We can’t let those plans rot in agency filing cabinets.

Here are our top recommendations for improving accommodation plans.

Agencies should pay more attention to protecting their most important asset: their employees.

More than half of 26 agency plans had minimal or no commitments to protect their staff from heat-related illness, exposure to wildfire smoke or other related health and safety threats to climate change. We urge agencies and Congress to prioritize accommodation measures to protect federal workers. This includes ensuring agencies have the staff and skills they need to meet the increased demand for basic services in the face of more frequent and severe weather events.

A federal engineer performing a safety inspection of a levee pumping station in Virginia Beach, Virginia.

US Army Corps of Engineers / Vince Little, Creative Commons / CC BY 2.0

Agencies should more thoroughly address the threat of rising average temperatures and increasingly frequent, severe and longer extreme heat events.

Most plans did not take into account the direct effects of the heat on human health, infrastructure or natural areas – a noticeable absence given the wake-up call from last summer’s catastrophic heat wave in northwestern Peaceful. Heat requires a different approach than most other climate hazards, in part because every piece of human infrastructure and technology and every living thing has an upper temperature limit.

Agencies should incorporate the implementation of the reinstated Federal Flood Risk Management Standard (FFRMS) into their plans.

In May 2021, the Biden-Harris administration formally reinstated the Federal Flood Risk Management Standard (FFRMS), which requires that the location and design of all federally funded projects take into account the increasing risk flooding and sea level rise. Although this recovery has come too late for some agencies to fully integrate the FFRMS into their adaptation plans, CEQ and OMB should ensure that agencies move quickly to implementation.

Agencies should integrate more nature-based solutions into their climate strategies.

Our review suggested that agencies do not fully appreciate the role of nature-based solutions in addressing climate change. Nature-based solutions, such as conserving existing natural areas and better managing agricultural land, have the potential to reduce climate change-related pollution and protect communities from heat, floods and other climatic hazards. All federal agencies should do more to explain how they incorporate green infrastructure and other nature-based solutions into their planning and grant funding programs.

A US Forest Service volunteer collecting seeds from native plants in Illinois.

Forest Service, Eastern Region, Public Domain

Agencies need to dedicate additional resources and capacity to developing and implementing equitable and just adaptation policies, programs and practices.

We have been encouraged by the stated intent of federal agencies to identify and address the inequitable damages of climate change. However, the plans generally lacked specifics on how equity will be incorporated into adaptation measures. Agencies should also deal more deliberately and vigorously with the threat of maladaptation, especially in vulnerable communities. Even well-intentioned climate adaptation strategies can have a range of negative consequences for people who already suffer disproportionate damage from climate hazards. This phenomenon, known as “maladaptation,” should be an integral consideration for organizations when reviewing existing practices, policies, and programs and designing new ones.

Adaptation plans should spark a sustained national conversation about the urgency of climate adaptation, job creation, and the resources still needed to build a resilient, climate-smart United States.

Agencies should seize every possible opportunity to make climate adaptation visible to the public and key stakeholders. The CEQ and OMB are also expected to produce a focused summary of the 26 plans to help Congress identify key funding shortfalls, legislative remedies for impediments to agency action or mismatched policies, and other items for action.

The catastrophic wildfires, hurricanes, floods and heat waves of just the last year – not to mention the seven-plus years since agencies updated their adaptation plans – illustrate the urgent need for an ambitious approach to climate adaptation. Thanks to the Biden-Harris administration, the federal government is once again working to understand how its own operations, facilities, services and missions must adapt to the reality of climate change. We look forward to working with CEQ, OMB and individual agencies to build a safer and healthier nation for people, communities and nature.


NRDC’s comments to the CEQ and OMB are based on in-depth reviews of the 13 agency plans listed below and keyword research of the remaining 13.

  • Department of Defense (DOD)
  • Department of Energy (DOE)
  • Department of Homeland Security (DHS)
  • Department of Housing and Urban Development (HUD)
  • Department of Interior (DOI)
  • Department of Transportation (DOT)
  • General Services Administration (GSA)
  • Health and Human Services (HHS)
  • Occupational Safety and Health Administration (OSHA)
  • United States Agency for International Development (USAID)
  • United States Army Corps of Engineers (USACE)
  • United States Department of Agriculture (USDA)
  • US Environmental Protection Agency (EPA)

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