Hazard Planners Aren’t Planning for Heat Hazards

Extreme heat doesn’t get the attention it deserves from state programs charged with reducing risks from natural hazards. That’s the main takeaway of a new NRDC analysis of how states in the southeastern United States address extreme heat in their federally mandated hazard mitigation plans (HMPs). These plans have historically prioritized risks to property over people, meaning that health hazards such as heat are underemphasized compared to highly destructive hazards such as floods. 

Following an initial analysis conducted earlier this year for NRDC by UCLA student Celia Patricia Sánchez Zelaya (link forthcoming), I evaluated how 11 southeastern states treat heat in their most recent hazard mitigation plans. States could receive a maximum score of 12 for the quality of heat-related risk assessments and mitigation strategies in their plans. You can see the full methods here.

State Plans Give Short Shrift to Heat

Long, sweltering summers are obviously a fact of life for Southeast residents and air conditioning units are common across the region. But heat waves can still exact a heavy toll. A third of the nearly 35,000 U.S. residents treated by emergency medical service providers for heat illness in 2017 and 2018 were in the South Atlantic census region, which spans from Delaware to Florida. From April to September 2022, the Southeast had the fourth highest rate of heat-related illnesses per 100,000 emergency room visits in the country.

Because of fossil fuel-driven climate change, the health dangers of heat are growing year after year. Although the Southeast hasn’t warmed as quickly as other parts of the country, experts expect the number of days with a dangerous heat index of 100°F or more to dramatically increase over the next three decades.

Despite the clear threat of rising temperatures to Southeast residents, states scored an average of 3.5 out of 12 for their treatment of heat (Table 1). Alabama was at the top with a score of 6; Arkansas was at the bottom with a score of 1.

States Underestimate the Health Harms of Heat

Extreme heat is the top weather-related killer in the United States. But most states downplay the threat, concluding in their hazard plans that heat poses a low to moderate risk. Virginia even deemed the risk “negligible” in its plan. This stems directly from the failure of states to use appropriate health data or to do at least a high-level analysis of heat-related health costs.

About 73 percent of plans mentioned the threat of “classic” heat-related illnesses such as heat exhaustion and heat stroke. However, heat can have many indirect effects on health, including exacerbation of lung disease and diabetes. Fewer than 20 percent of states examined these indirect impacts. Not a single plan discussed how extreme heat exposure is linked to pregnancy outcomes such as preterm birth.

The states also used death and illness counts from the National Weather Service’s Storm Events Database as their main way to assess health risks. The Storm Events Database is a highly conservative estimate of the health toll of heat, in part because it relies on contributions from an array of insufficiently trained observers. None of the plans included state or county-level data from state health agencies or the Centers for Disease Control and Prevention.

Finally, none of the states attempted to quantify the financial costs of heat-related illness. NRDC-led research from California and Wisconsin demonstrates that even a single heat event can result in the equivalent of hundreds of millions of dollars in premature deaths, hospitalizations, emergency room visits, and outpatient visits.

As Rebuild By Design’s recent Atlas of Disaster points out:

“Until heat is understood to have equally severe effects as other weather-related disasters, governments will continue to underinvest in heat hazard mitigation.”

Most States Ignore the Most Heat-Vulnerable Communities

Heat can hurt anyone, but some communities are repeatedly hit first and worst. State planners can’t develop appropriate solutions or target help for the people who need it most without understanding who, and where, they are.

More than half of the plans that included risk assessments for heat recognized the elevated vulnerability of older adults and children (Table 2). However, mentions of other highly vulnerable groups dropped steeply from there. For example, only a third of states acknowledged low-income people, and not a single state mentioned people of color, pregnant people, or unhoused people.

Furthermore, Louisiana was the only state that appeared to solicit input on any hazard from underserved or vulnerable communities during the planning process. This lack of targeted engagement likely results in a mismatch between what planners and residents think is most important.

States Need a More Rigorous Approach to Integrating Climate Change

FEMA has required hazard mitigation plans since 2015 to consider climate change, due in part to a legal petition filed in 2012 by NRDC. About 82 percent of the Southeast plans included at least a general discussion of how climate change will affect future heat hazards, but only 27 percent factored it into their heat probability analysis. The whole point of including climate change in a hazard plan is to get a better handle on future risks. It’s not enough to just say the words and hope for the best.

Insufficient Risk and Vulnerability Analyses Lead to Insufficient Solutions

Given the many shortcomings of the risk assessments, it’s no surprise that the HMPs scored even more poorly on their heat mitigation strategies. Alabama’s plan was the only one to include a mitigation action clearly intended to reduce heat risks, but it deemed the action a low priority.

Tennessee’s plan even concluded—incorrectly—that "extreme heat is not a hazard that responds to the traditional mitigation measures of building codes or land use restrictions." Thankfully, organizations such as the American Planning Association are trying to overcome that perception. Hazard mitigation planners should look to essential resources such as Planning for Urban Heat Resilience for practical ideas on how to use traditional mitigation measures to protect people—and property—from heat.

States Need More Guidance from FEMA

The lack of attention to the health harms of extreme heat is not unique to state hazard mitigation planners. Every level of government from cities through federal agencies has been slow to recognize and adequately respond to the growing threat of rising average temperatures and heat extremes. However, FEMA can greatly improve the potential for states to create a more climate-resilient nation by:

• working with its federal partners in the National Integrated Heat Health Information System to develop more robust guidance for states on how to assess and prepare for heat hazards in their mitigation plans.
• increasing the stringency of its review process to ensure that plans aren’t just “checking the box” when it comes to climate change or extreme heat.
• further clarifying the grant eligibility requirements and funding criteria for heat resilience projects.
• increasing dedicated funding and technical support for capacity building (including hazard mitigation plan development), so that state and local governments can better plan for heat hazards and access grants for heat resilience projects.
• requiring states to meaningfully engage and provide accommodations to heat-vulnerable groups in their planning process. This includes disabled people, who historically have been shut out of emergency management and climate adaptation planning.  

FEMA took a good step this fall with new guidance on how to use hazard mitigation grants to build resilience to extreme temperatures. However, the fact sheet is extremely high level, and doesn’t direct potential grantees to heat-specific technical resources or assistance. Some of the resources included in the fact sheet are not available to state governments, so they can’t support state HMP improvements. 

FEMA also offered an alternative method of benefit-cost analysis that could  make it more likely that heat mitigation projects will be eligible for grants. Projects that meet certain conditions, such as enhancing climate resilience to extreme heat, may now use a lower threshold for cost effectiveness under some FEMA funding programs. Unfortunately, even that lower benefit-cost ratio may still be difficult to attain for heat mitigation projects that mostly save lives, not property, and thus have benefits that are hard to quantify. FEMA could aid grantees by offering additional Pre-Calculated Benefits for avoided heat-related illnesses, deaths, and wage losses. 

The combination of climate change and rising inequality is making it more likely that heat waves will turn into mass casualty events in the United States. Although Southeast states are no strangers to high temperatures, they shouldn’t discount the risks of unusually severe heat waves. This is particularly true in places where healthcare services may be repeatedly disrupted by sea level rise or climate-fueled storms such as Hurricane Ian. State hazard mitigation officials and their partners in FEMA should quickly work to improve their efforts to protect people from heat. Lives depend on it.