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)

Next Steps:

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)

One of the biggest impacts of climate change is on water – Higher temperatures will increase the amount of water in the atmosphere, changing precipitation patterns and increasing the variability within patterns, leading to declines in snowpack and a higher frequency of heavy precipitation events, heat waves and other extremes.  The transformations driven by climate change will redistribute stream flow and wetlands. So it was good news when, last October, the Interagency Climate Change Adaptation Task Force recommended  a coordinated response to addressing the impacts of climate change on freshwater resources in the U.S.  The Task Force recently took a step forward by releasing its draft National Action Plan: Priorities for Managing Freshwater Resources in a Changing Climate. 

The action plan proposes six recommendations federal agencies can take to support water resource managers in understanding and reducing climate change risks.  The recommendations are elements familiar from other climate adaptation strategies, such as the need for improved information, for increased capacity, for integrated water resource management and for water use efficiency. 

The plan’s highlights are its issuance, the diversity of the workgroup and the commitment to periodic revisions of the plan.  The mere existence of a climate adaptation strategy for water resources is something to applaud, and the collaboration of so many federal agencies in its development is itself progress in the otherwise fractured world of water resources management.

There are also, however, lowlights.  First and foremost, “action plan” is a misnomer because “it is important to note that the proposal of an action in this report and the association of an action with a ‘lead agency’ do not commit an agency to provide or seek funding for the action or to make related policy or program changes.”  Taken together with the admission that actions were deemed priorities in part because they are achievable within current and foreseeable agency capacity, the plan looks more like a repackaging of things the agencies are already doing.  This is worrisome for an action plan, because this same workgroup found that existing efforts to reduce climate risks to freshwater resources are not sufficient.

And, from Defenders’ point of view, the plan punts on protecting water quality and aquatic ecosystems in response to a changing climate, postponing achievement of that goal to development of the national fish, wildlife and plants climate adaptation strategy.  If we are truly to achieve protection of aquatic ecosystems in the face of climate change, the collaborative approach valued by the workgroup is indeed critical, and we can no longer segregate fish and wildlife management from water resources management.  The two go hand in hand.  Water resource managers are in dire need of direction and recommendations for how to protect aquatic ecosystems.  Since it is a goal of the freshwater action plan, there must be recommendations and actions to achieve that goal.

It is heartening that the Task Force recognized that the breadth and severity of climate change impacts to water resources warrants a coordinated plan for freshwater ecosystems.  Through no fault of its own, the plan also suffers for lack of a unifying national water policy that would provide a backdrop to the goal of assuring adequate water supplies, protecting human health and property and protecting water quality and aquatic ecosystems in the face of climate change.  Reducing the risks of climate change is a much different proposition than managing the full spectrum of freshwater issues, threats and needs.  Without guiding principles regarding what it means to have adequate water supplies – for what purposes?, what is “adequate”?, can we have adequate supplies for everything we want? – the plan’s goal will remain elusive.

The Council on Environmental Quality will be accepting public comments for 45 days.  As we at Defenders continue to review and comment on the action plan, we will be looking for opportunities for federal agencies to take bold, climate-smart actions to protect aquatic ecosystems and sustain the functions and services of these ecosystems.

By: Timothy Male and Noah Matson

On October 5, 2009, President Obama signed Executive Order 13514 committing the federal government to “lead by example” on sustainability issues including energy and water use and solid waste reduction.  As summarized by the press statement accompanying the Executive Order, it “requires Federal agencies to set a 2020 greenhouse gas emissions reduction target within 90 days; increase energy efficiency; reduce fleet petroleum consumption; conserve water; reduce waste; support sustainable communities; and leverage Federal purchasing power to promote environmentally-responsible products and technologies.”

As we have reported in previous blog posts, the Executive Order also included provisions on adaptation.

The Executive Order (E.O.)  is sweeping and complicated, and parts of it read like international climate change negotiations, with each federal agency or department developing its own emissions reductions targets for “class 1, 2 and 3” emissions types.  We’ll define those later – the important thing to know is that the E.O. sets up a whole new infrastructure within the federal government to meet concrete sustainability performance objectives that will greatly reduce the government’s environmental footprint, and through its massive purchasing power, will also influence the broader market.  For this the administration deserves credit. A year and a half later, on April 19, 2011, the Office of Management and Budget (OMB) which helps oversee the program, released sustainability “scorecards” for 24 agencies as a measure of performance and progress in meeting sustainability goals as the agencies begin revising their annual sustainability performance plans.

Below we have compiled all of the scorecards into one infographic.

As can be expected from such a sweeping program among such diverse federal agencies as the Department of the Interior and the Social Security Administration, performance is mixed in meeting the President’s sustainability agenda.  Though the administration should be given credit for rating its performance and making that information available to the public, the administration didn’t provide a single display for all the scorecards and their information.  They provide links to each agency’s sustainability website, which of course are all different, and the scorecards on some are hard to find.  The visualization on this site makes it easy to compare agencies’ performance against each other.

Definitions:

“Scope 1, 2, and 3″ emissions mean; (i) scope 1: direct greenhouse gas emissions from sources that are owned or controlled by the Federal agency; (ii) scope 2: direct greenhouse gas emissions resulting from the generation of electricity, heat, or steam purchased by a Federal agency; and (iii) scope 3: greenhouse gas emissions from sources not owned or directly controlled by a Federal agency but related to agency activities such as vendor supply chains, delivery services, and employee travel and commuting; Click here for the criteria the federal government used to evaluate success for each category.