In the first installment of this blog series, I discussed some of the macro trends likely to be front and center in the next iteration of federal agency Climate Adaptation Plans. As part of a directive within Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” nearly two dozen U.S. agencies issued their first ever climate adaptation plans in October of 2021. Agencies will provide updates and report their progress annually.
Soon after publication of these plans, the administration published the Federal Sustainability Plan. This plan sets forth government-wide targets for carbon pollution-free electricity, zero emission vehicle acquisition, net-zero federal building emissions, net-zero procurement and net-zero operations. In updating this year’s climate adaptation plans, agencies must now consider these targets.
Federal sustainability plan targets:
- 100% Carbon Pollution-Free Electricity (CFE) by 2030, including 50% on a 24/7 basis
- 100% Zero-Emission Vehicle (ZEV) Acquisitions by 2035, including 100% light-duty acquisitions by 2027
- Net-Zero Emissions Buildings by 2045, including a 50% reduction by 2032
- Net-Zero Emissions Procurement by 2050
- Net-Zero Emissions Operations by 2050, including a 65% reduction by 2030
Agency efforts toward these government-wide measures will likely feature heavily in the next iteration of climate adaptation plans.
What should agencies’ second annual plans include?
As agency leaders craft these second annual plans, how can they improve upon them? Here are five recommendations to create plans that are more measurable, actionable and impactful:
- Policy insights. Include a list of policy changes made at the agency-level to support climate adaptation and resilience. The plans should not only detail new policies, but also any proposed or considered regulatory changes, including any barriers to enacting those changes (e.g., required legislative action). Particularly in light of the Supreme Court ruling in West Virginia v. EPA, agencies may need lawmakers to take action before they can adopt new policies.
- Quantifiable success measures. Each action within an agency plan should contain quantifiable success measures, including not only the date the measure will be ultimately achieved, but also interim measures to confirm ongoing progress. Many of the inaugural plans focused on high-level measures without quantifiable targets. In many cases, it is likely that those items had no baselines from which to measure. Some plans listed “potential success indicators” without committing to a discrete measurement. Others described a number of climate risks, with actions to date, but lacked a forward-looking perspective. The next iteration of plans should articulate where baselines have been established. They should also set targets for success, including interim targets for longer-term initiatives wherever possible.
- Discrete action owners. Reviewing each agency action plan reveals another area of variability—clarity regarding ownership for each priority action. Some agency plans only list the bureau or department taking the lead on a given action. We assume that each agency maintains further documentation to clarify office and program responsibilities, including the individuals within those organizations responsible for leading initiatives associated with that action. However, we recommend increased clarity regarding the specific individual or program taking the lead on a given action—the single accountable resource. Agencies should also identify: (1) who is responsible for identifying success measures, (2) which organization(s) are responsible for collecting those measures and (3) who is responsible for leading course-correction if those measures are not met.
- Clear articulation of inter-agency dependencies. Within the first days of his administration, President Biden called for a “whole of government” approach to climate change. Inherently, climate action will require cross-agency collaboration. The agency-level plans should detail the collaboration required across agencies to achieve results. Many plans included “intergovernmental coordination” as a discrete element for each action and identified the agencies needed to accomplish the goal. By way of example, one Department of Commerce action focused on the development of forward-looking building standards for a more climate-ready infrastructure.
Commerce’s plan detailed not only NOAA and NIST’s roles in standards development but also the required coordination with GSA and Defense regarding their building standards. We encourage all agencies to consider cross-coordination with other agencies (federal, state and municipal), as well as with industry, when citing priority actions to address in FY23.
- Resource and funding requirements. Each plan should cite resource implications, including any new resources needed to accomplish the actions and measures set forth. Some agencies addressed resource implications at the plan level, while the departments of Commerce, Defense, Justice, Health and Human Services and others spelled out resource implications at the action level. Detailing potential limitations and constraints at the action level provides greater transparency to the public and Congress on potential barriers to achieving measurable results. Making these constraints known early can help drive toward funding to move these actions forward.
The continued focus of the federal government on climate change and sustainability, including the continued documentation of efforts within agency climate adaptation plans, is encouraging. We all play a part in helping to advance sustainability through our own actions, and now agencies have provided us with additional insight into the actions they are taking as well. We look forward to these second annual plans.
As a global company, CGI has committed to achieving net zero emissions by 2030, and we’re working with our clients in the public and private sector to advance their sustainability goals. Learn more about CGI's commitment to sustainability.