On October 6, 2022, the Biden Administration released updates from 25 agencies covering their climate adaptation and resilience program progress over the past year. Just one year earlier, agencies released their agency-level climate adaptation and resilience plans (CAPs). These plans are required under Executive Order 14008, “Tackling the Climate Crisis at Home and Abroad,” and provide insight into the steps agencies plan to take to ensure their facilities and operations are prepared for and responsive to climate change impacts and risks.

The annual progress reports provide a retrospective summary and anecdotal examples of actions taken over the past year along with updates on key adaptation topics: climate-related operating and financial risk reduction, climate vulnerabilities assessments, climate literacy, tribal engagement, environmental justice and partnerships to advance climate adaptation. The original CAPs and these progress reports play an important role in spelling out the actions and investments agencies will make to meet the requirements of Executive Order 14008 as well as Executive Order 14057, “Catalyzing America’s Clean Energy Industries and Jobs Through Federal Sustainability” and the accompanying Federal Sustainability Plan.

The CAPs — and associated annual progress reports — are designed to detail priorities and progress, and new guidance provides agencies with insight into how plans will be used moving forward. In September 2022, the White House Council of Environmental Quality (CEQ) issued Implementation Instructions for Executive Order 14057. These instructions remind principal agencies (and encourage independent agencies) to submit a sustainability plan as well as to update and submit CAPs and progress reports to CEQ and the Office of Management and Budget by June 30 of each year. Agencies that already submitted plans under Executive Order 14008, including principal agencies, must update their CAPs by September 30, 2023.

As I read the CEQ guidance and the agency accomplishments in the progress reports, I reflected on the need for more and more significant actions in the future — specifically, what should agencies be considering as they update their plans to make them more actionable and measurable?

Key considerations for sustainability plans and climate adaptation and resilience plans

As agencies look to update their plans, I believe they should focus on the following key elements for delivering impact:

1. Procurement: Government procurement will play an even more critical role in achieving the administration’s objectives in the Federal Sustainability Plan. Agencies are under pressure to make environmental impact a high priority in making acquisition decisions. Expect them to increasingly use their procurement power to make incremental progress toward the plan’s federal-wide targets.
2. Supply chain: Agencies will continue to focus on reducing supply chain greenhouse gas (GHG) emissions as part of their sustainability plans. The federal supply chain is the major source of emissions from agency operations. While topics such as replacing the federal fleet with zero-emission vehicles and achieving net-zero emissions from federal buildings, campuses and installations have been top of mind, I anticipate near-term focus on reducing emissions associated with the federal supply chain, covering not only products but especially services. The General Services Administration estimates that in 2019, contractors and subcontractors emitted a total of 150 million metric tons carbon dioxide-equivalent (CO₂e) associated with federal contracts, more than twice the government’s reported direct and indirect emissions combined. As a result, the Department of Defense, the GSA and NASA published an advance notice of proposed rulemaking in October of 2021 soliciting feedback on a potential amendment to the Federal Acquisition Regulation. The amendment would require federal suppliers to disclose GHG emissions and climate-related financial risks, and set science-based reduction targets.
3. Coordination: Addressing the challenges of climate change will require the full capacity of the federal government. Given the problem’s scale, government agencies need to work across organizational lines. Executive Order 14008 launched the National Climate Task Force, which includes cabinet-level leaders from 21 federal agencies and departments. International coordination through bodies such as the Greening Government Initiative hold promise for agencies looking to cooperate on ways to make government operations more sustainable.
4. Measurement: The original CAPs demonstrate varying levels of detail on how the agency will measure progress against the plan’s objectives. Many plans focus on high-level measures without quantifiable targets. Some plans list “potential success indicators” without committing to a discrete measurement. Others describe a number of climate risks, with actions to date, but lack a forward-looking perspective. The next iteration of plans should articulate where baselines have been established. They should also set measurable targets for success, including interim targets for longer-term initiatives.
5. Ownership: Another area of variability in the plans is clarity regarding ownership for each priority action. Some agency plans list the bureau or department taking the lead on a given action. Providing more transparency into the programs taking the lead on a given action, including the accountable leader in charge of each action, will increase public (and Congressional) confidence in action governance. Agencies should also identify: (1) the federal leaders 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.

In order to address the challenges of climate change, the federal government must act with both urgency and a clear sense of purpose. Agency plans should provide the North Star targets to which the agency must commit. Agencies must strive to make their plans as actionable and measurable as possible. Without this level of focus, the targets could be out of reach.

Mark Flugge is sustainability and climate change lead at CGI Federal.

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