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FEMA Promises To Revise State Disaster Planning Guidance To Require Consideration Of Climate Change Impacts

Becky Hammer

Posted January 27, 2014

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Earlier this month, NRDC got encouraging news from the Federal Emergency Management Agency (FEMA) about its intentions to update its guidance for state hazard mitigation planning: the agency will be revising the guidance to more explicitly require state governments to consider  the impacts of climate change and prioritize preparedness. A revised draft from FEMA is expected to be available for public review and comment as early as this summer.

State governments prepare these hazard mitigation plans in order to assess their risk of natural disasters and to identify and implement actions they can take to reduce those risks. Once FEMA has approved a state’s plan, the state is eligible to receive federal funding to carry out pre-disaster mitigation projects that are designed to build resilience and reduce vulnerability.

While federal regulations require the plans to consider the risk of “future events,” FEMA has thus far not required state plans to take account of the projected impacts of climate change. Not surprisingly, most states consequently develop insufficient plans that leave them unprepared for the more frequent and severe disasters that climate models predict, including flooding, drought, and other extreme weather events.

In order to address this problem, NRDC petitioned FEMA in 2012 to require states to consider climate change impacts when developing their plans. FEMA responded to our petition a few months ago. As I blogged about here, FEMA declined to amend its regulations to make the obligation for states to consider climate change impacts more explicit, but the agency did state that all future guidance for state mitigation planning would “incorporate elements of climate change, as appropriate.”

The week before last, a few of my NRDC colleagues and I met with FEMA officials to discuss their plans to implement this promise. We were excited to hear directly from FEMA that the agency is already moving forward with revisions to its state mitigation planning guidance, known as the “Blue Book.” Once finalized (after a draft is issued for public review and comment this summer), the new guidance will apply to plans developed in 2015 and onward.

FEMA officials told us that they have two main goals for the revised guidance:

  • Making sure states comply with the existing regulatory requirement to consider the risk of “future events,” including consideration of the effects of climate change on disaster risk.

FEMA has committed to make sure that states are considering data about the projected future effects of climate change when they perform their risk assessments. By ensuring that this current requirement is adequately enforced, FEMA will be helping states increase their preparedness for disasters.

As part of this revision to the guidance, FEMA will have to decide which data the agency will require states to consider, and what states should be doing with that data when writing their plans. Many state emergency management officials are not accustomed to dealing with data that are expressed in terms of ranges and probabilities.  As a result, FEMA will need to provide additional support for the transition to this new approach by developing new tools that states can use to better incorporate climate data into their plans. FEMA must also make sure that the risk assessments embodied in the plans are written in such a way that they can be “operationalized” into specific actions that states can take to reduce disaster risk.

  • Making sure states revise their plans in response to changing conditions.

States are required to update their plans every three years. Even still, sometimes a severe or unexpected hazard event can demonstrate that a state’s plan is out of date – and needs to be improved – by showing, for example, that the plan’s assessment underestimated the risk or failed to include relevant mitigation actions. Events like these should trigger state actions to re-examine and update their plans as appropriate. FEMA intends to strengthen oversight of the plan update requirements in the revised guidance.

Ensuring that plans are updated promptly to reflect the most current information is critically important, especially in a changing climate when the frequency and severity of disasters are constantly evolving. Some states are already seeing changes in the hazards they’re experiencing, but their plans are focused on assessing the problems and risks of the past. To build resiliency in our communities, we need to plan with an eye towards future challenges we know we’ll have to face with climate change.  

We look forward to working with FEMA on the new guidance and to seeing the revised draft this summer. We’re hopeful that it will provide helpful information to the states, empowering and enabling them to better prepare for future disasters.

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Brad BartholomewJan 29 2014 07:29 PM

I'm not sure what you think mitigation plans are? They in no way prevent disasters or damage. They outline the risk using the best available data, if a large event occurs, there is no "failure' of the plan. The plans already consider "future risks" as to the extent possible.

The real issue is not the plans but the lack of funding and support to implement the plans. We can plan until we are blue in the face but if we have no funding to address these issues, nothing changes. We can address every type of disaster you can think of, but without mitigation project funding, the disaster will still cause damage. And this is not due to poor planning.

Becky HammerJan 30 2014 09:41 AM

Hi Brad, thanks so much for your comment. NRDC absolutely supports increased mitigation funding so that states can implement their plans with projects that reduce the risk of disaster damage. We also want to make sure that states are in fact using the "best available data" to assess their risks when developing their plans. Because many states don't consider the projected effects of climate change, their risk assessments may not give them the full picture. That's why we're looking forward to working with FEMA on ensuring that states do take account of this information in their plans. Thanks again.

Luke MeyersJan 30 2014 10:46 AM

As a country we should look at all hazard funding. We have spent billions on building capabilities. Many of these are for response. During this time, we have also spent a disproportionate amount of funding on human-caused hazards, while not doing the same for natural hazards. I believe in the all hazard mitigation planning. But if we continue to reduce or limit the funding for this important element, we will never change the perspective in this country. We have spent a greater deal of funding on terrorism related planning. If you took a whole community approach and said what are top ten dependencies in your community (property, facially, infrastructure) and did hazard mitigation planning for those from an all hazard perspective, we would have a greater resiliency to varying threats in our country. We must look at the impacts of the vulnerabilities in the community. This is where the FEMA Guidance for Mitigation Planning is lacking. If you look at the EMAP Standard as an example it is drives a program to look at this more holistically including consequences. If you look at FEMA’s latest risk assessment methodology, THIRA, one would wonder was there a mitigation planner involved in the development of this process. More work is needed!

Becky HammerJan 30 2014 10:49 AM

Thanks for your comment, Luke. I encourage you to reach out and get in touch with the folks in FEMA's mitigation office to share these thoughts with them. They're very receptive to ideas right now as they begin work on the revisions to the mitigation planning guidance. Please email me directly ( if you'd like me to pass on the contact information for the relevant people.

Kevin GeigerJan 30 2014 02:34 PM

This is good news. Vermont has included climate change as an overarching issue, since it is not really a hazard but affects a suite of hazards. Next up, will FEMA make their own flood maps include the risk of future flooding and sea level rise?

Mike GavinJan 31 2014 08:45 AM

Brad and Luke both expressed some great points. We update our HMP annually or after any event. The risk profile may change but funding to implement the plan stays the same. We are in the recovery process from several wildland fires and floods in my state. With added mitigation funding, there is still concern about implementing the plan. EMAP's evaluation process in this area is a much better tool than the THIRA, however with lack of funding at the local level, plans will not be implemented. Climate impact on hazards and their relationship to infrastructure and recovery (resiliency) is an issue that a White House Committee is currently trying to address. Much more work is needed in this area.

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