Posted on 21 June 2011.
Coauthored by Aimee Delach
Big changes are afoot in the federal government when it comes to preparing agencies for the impacts of climate change. As we highlighted previously the administration established a Climate Change Adaptation Task Force to coordinate Federal agency efforts to plan for and address the myriad ways that climate change will impact their lands and infrastructure and their ability to deliver programs and fulfill their missions.
In April, 2011, the administration released Instructions for Implementing Climate Change Adaptation Planning (pdf) and supporting documentation (pdf). By June 3, 2011, all agencies were to have issued national policy statements committing to analyzing the risks of climate change and preparing adaptive actions.
As of this writing (June 21), 21 agencies have released their adaptation policies publicly. How well did the agencies stack up to the administration’s directives? We ranked them according to the criteria (described below) laid out in the Instructions and Support Document.
agency adaptation policy table
Of the plans out so far, the Commerce Department was the clear leader, hitting every element required in the policy. The Environmental Protection Agency and Agriculture Departments weren’t far behind. Fittingly, each of these agencies already has strong history of engaging in the science, impacts and policies connected with climate change. For other agencies, the question of how to adapt to a changing climate in order to continue to fulfill their missions is clearly new territory. Thus, the Farm Credit Administration openly acknowledged in their policy that they will need to leverage the resources and expertise of others. Similarly, the Pension Benefit Guaranty Corporation, for whom climate change issues are likely an even more remote consideration, issued a very brief statement that nonetheless gets points for willingness to take on the problem, as well as for beating a number of members of the Task Force at making their policy statement public. The State Department’s plan, while missing a number of the directives that were laid out, demonstrated its commitment to work across agencies and multilaterally, bringing its own unique capacities to international adaptation efforts. The Department of Health and Human Services’ plan expressed an understanding of ways climate impacts will exacerbate health problems among already-vulnerable populations. The Department of Labor is particularly concerned about hurricane and other weather-related impacts to Job Centers and other infrastructure, and the Department of Energy emphasized adaptation as a complement to its work furthering clean energy technologies.
The Department of the Interior gets credit for being an early adopter of adaptation. In the fall of 2009, Secretary Salazar issued a secretarial order that made responding to climate change a priority. However, Interior’s “Action Memorandum” on climate adaptation issued in response to the CEQ guidance falls short on being agency-specific, fostering collaboration outside of the department, and including strong language on analyzing the effects of climate change and on implementing adaptation actions.
As of this writing, we are still awaiting release of adaptation policy statements from most federal agencies, including the following members of the Interagency Climate Change Adaptation Task Force:
Department of Defense
Department of Homeland Security
Department of Housing and Urban Development
Department of Treasury
Agency for International Development (USAID)
National Intelligence Council (NIC)
Millennium Challenge Corporation (MCC)
These policy statements are only the first step in a year-long process that each agency has been directed to undertake. While issuance of a policy is important, and we urge all those departments who have not yet made theirs public to do so, the policies are only useful if they are acted upon. We will be watching carefully to see if agencies continue to follow through with the next steps of the process: 1) Completing a preliminary agency vulnerability analysis and outlining five priority adaptation actions by September 30; 2) Completing a final, detailed vulnerability analysis by next March; and 3) Issuing their final adaptation plan by June 2012.
It is also critical that these future steps take place at the level of the individual agency, not the entire department, since the missions, resources, and vulnerabilities differ so widely from agency to agency, even within a single department.
Explanation of Evaluation Criteria:
1) Agency-level plan: Policy statement is at agency level rather than Department level, or very clearly directs individual agencies within Department to develop adaptation plans. (Implementing instructions, I.A)
2) 2012 due date: Policy commits the agency to complete an agency-wide adaptation plan by June, 2012.
3) Compliance with Implementing Instructions: Policy commits the agency to fully implementing and complying with CEQ Adaptation Implementing Instructions in general and coordinating with the Interagency Climate Adaptation Task Force.
4) Strong purpose and vision: Policy states the purpose of the policy, including both the agency’s vision for successful adaptation planning and initial adaptation goals as well as recognition that climate change adaptation is a critical complement to climate change mitigation and that both are required to address the causes and consequences of climate change. (Implementing instructions I.A.2a)
5) ICCATF Principles & Framework: Policy adopts the Interagency Climate Change Adaptation Task Force’s guiding principles and framework for adaptation planning either directly or by reference (Implementing Instructions I.A.2b).
6) Coordination within agency programs: Policy describes how the agency will coordinate adaptation planning across programs and operations within the agency. (Implementing Instructions I.A.2c, part 1)
7) Coordination with other agencies: Policy describes how the agency will coordinate adaptation planning with other agencies on climate change adaptation matters of common interest. (Implementing Instructions I.A.2c, part 2)
8 ) Identifies resources within agency: Policy identifies programs and resources within the agency to support the climate change adaptation planning process. (Implementing Instructions I.A.2d)
9) Strong analysis language: Policy requires (using “will”, “shall”, or “must” language) the agency to analyze how climate change may impact its ability to achieve its mission, policy, program, and operation objectives by reviewing existing programs, operations, policies, and authorities. (Support Document)
10) Strong implementation language: Policy describes the agency process to ensure effective adaptation planning implementation (using “will”, “shall”, or “must” type language). (Support Document)