By Marc Kodack
The Government Accountability Office (GAO) identified climate change as a high risk to federal agencies beginning in 2013, and has continued that assessment with its most current list of high risks released in late 2019. The list is updated every other year at the start of a new Congress. According to the GAO, the “High Risk List has served to identify and help resolve serious weaknesses in areas that involve substantial resources and provide critical services to the public.” The reason that climate change was included, is that the GAO has determined that it represents a significant fiscal risk to the federal government. This is due to the projection that if climate resilience is not increased today, significantly higher costs will be incurred in the future to address damage and destruction caused by climate change. Of the 62 recommendations that GAO has made concerning climate risk since 2013, 25 remain open as of December 2018. Thus, the GAO concludes, “…the federal government has not made measurable progress to reduce its fiscal exposure to climate change.” The lack of progress has informed two, 2019 GAO audits related to climate resilience – one for the federal government released in October, and another for the Department of Defense (DoD) released in June.
The two audits complement one another. For federal agencies, GAO reviewed “the federal approach to prioritizing and funding climate resilience projects that address the nation’s most significant climate risks.” It found that the federal government lacked a strategy for determining investments in important climate resilience projects. For the DoD audit, GAO examined what, if any, processes DoD had created to incorporate severe weather into its facility designs. GAO recommended that DoD incorporate assessments of severe weather and climate risk into installation master planning and facility designs. GAO further recommended that DoD update its policy guidance to require these assessments. In the following, I discuss in more detail the GAO audit across federal agencies and the audit focused on DoD.
For GAO’s federal agency audit, it examined three main categories:
(1) the extent to which the federal government has a strategic approach for investing in climate resilience projects; (2) key steps that provide an opportunity for the federal government to strategically identify and prioritize climate resilience projects for federal investment; and (3) the strengths and limitations of options for focusing federal funding on high-priority climate resilience projects.”
GAO found through this and past audits that the federal government has no strategic approach for investing in important climate resilience projects. Federal government strategic planning lacks the ability to identify and then prioritize these projects. Individual agencies, e.g., the U.S. Army Corps of Engineers’ Civil Works program, provide funding for projects within their own mission areas, but these projects are not conceived as primarily climate resilience projects within the program that is used for funding. This results in an uncoordinated, fragmented approach to climate resilience across federal agencies. The absence of coordination directly reflects the bias embedded in agency activities that are skewed towards reaction to disaster events versus strategically planning for multi-hazards beforehand. There is no single federal entity that is responsible “to implement a strategic investment approach for climate resilience that includes identifying and prioritizing projects for federal investment in an iterative fashion.” To address these deficiencies, GAO offers a comprehensive, risk-informed, six step process “for identifying high-priority climate resilience projects for federal investment” that the federal government could adopt.
GAO identified two options to fund “high-priority climate resilience projects—coordinating funding provided through multiple existing federal programs with various purposes and crating a new federal funding source specifically for high-priority climate resilience projects—and these options have strengths and weaknesses.” A new funding source could be created by Congress to serve as a federal assistance program to award grants, make loans, or issue loan guarantees. Another option is an infrastructure bank that could accept both federal and non-federal funds for disbursement to non-federal climate resilience projects.
GAO’s audit of DoD’s climate resilience efforts at its installations focused on the master planning process, e.g., how had severe weather and projected climate risks been incorporated into master plans and if individual projects had addressed these risks. GAO selected 23 installations to gather information from based on the installation’s exposure to one or more climate vulnerabilities, e.g., non-coastal related flooding; hurricane damage; permafrost melting; sea level rise. For 21 of the 23 installations, “the installations’ master plans and related installation planning documents did not (1) identify a range of possible extreme weather events and climate change effects that could affect the installation, (2) assess the likelihood of each event occurring and the possible effect on the installation, and (3) identify potential responses to these events.”
While DoD has existing policy guidance that requires the Services to assess risks to both the built and natural environments, risks that explicitly include extreme weather and climate change were not a part of the requirements for maser planning when GAO was published its audit (June 2019). They have since been updated [October 2019] to include the following sentence, “Each installation must identify and assess the risks to the installation from the effects of extreme weather and climate change, and develop plans to address those risks as appropriate [Section 2-2.17].” Given the update cycle for master plans, it will take up to five years before all installation plans incorporate this requirement into their master plans.
GAO was concerned that master plans did not incorporate climate projections, e.g., 15 of the 23 installations that were part of their audit. Eleven of the 23 installations commented to GAO that they were unsure of which projections to use in their planning or how to use these projections. In DoD’s master planning requirements update, the following section is unedited from the prior version, “In order to anticipate changing environmental conditions during the design life of existing or planned new facilities and infrastructure, projections from reliable and authorized sources such as the Census Bureau (for population projections), the National Academies of Sciences (for land use change projections and climate projections), the U.S. Geological Survey (for land use change projections), and the U.S. Global Change Research Office and National Climate Assessment (for climate projections) shall be considered and incorporated into military construction designs and modifications.” This unchanged language failed to address GAO’s comment from its audit:
Simply updating the language…on master planning…to require the use of climate projections does not provide guidance to installations on how to use climate projections, such as what future time periods to consider and how to incorporate projections involving multiple future scenarios…
GAO found that 11 of the 23 installations had incorporated resilience to severe weather or climate change into individual projects and/or across an installation. However, 17 of the 23 installations did not use climate projections in their individual facility designs. As with master planning it is unclear from existing DOD guidance how climate projections should be incorporated into individual facility designs (here), e.g., time periods; scenarios.
With climate change an on-going high risk to federal agency programs, agencies act within their own silos even when programs that have relevance to climate resilience exist. The absence of a single, coordinating entity within the federal government hinders strategic, risk-informed investments for climate resilience projects that would benefit multiple stakeholders, including the American public. In the absence of a strategic planning/investment process for climate resilience, the federal government will continue to sub-optimize any efforts it undertakes to address the long-term effects and implications of climate change. For the Department of Defense, without integration into government-wide climate resilience efforts, leaves it to decide by itself how to meet its’ installation master planning and facility design needs. Its’ installations have suffered and will continue to suffer devastating climate change effects that currently are not included in each installation master plan and facility design. While DoD may include these effects in planning and facility designs at some future date, it may become unable to address the large infrastructure replacement costs it will continue to incur if multiple installations, over time, are severely damaged or destroyed.