CLIMATE CHANGE
Improved Federal
Coordination Could
Facilitate Use of
Forward-Looking
Climate Information in
Design Standards,
Building Codes, and
Certifications
Report to the Honorable Matthew
Cartwright, House of Representatives
November 2016
GAO-17-3
United States Government Accountability Office
United States Government Accountability Office
Highlights of GAO-17-3, a report to the
Honorable Matthew Cartwright, House of
Representatives
November 2016
CLIMATE CHANGE
Improved
Federal Coordination Could Facilitate Use
of
Forward-Looking Climate Information in Design
Standards
, Building Codes, and Certifications
Why GAO Did This Study
Over the last decade, extreme weather
cost the federal government more than
$320 billion for, among other things,
repairs to federal infrastructure, and
according to the President’s 2017
budget request, these costs may rise
as the climate continues to change.
GAO’s prior work found that using the
best available climate information,
including forward-looking projections,
can help manage climate-related risks.
Federal, state, local, and private
decision makers use design standards,
building codes, and voluntary
certifications in the construction of
infrastructure. Standards-developing
organizations, such as professional
engineering societies, issue standards,
model codes, and certifications.
GAO was asked to review the use of
forward-looking climate information by
standards-developing organizations.
This report examines (1) what is known
about the use of such information in
standards, codes, and certifications;
(2) challenges standards organizations
face to using climate information; and
(3) actions federal agencies have
taken to address such challenges and
additional actions they could take.
GAO analyzed laws and policies,
reviewed reports, and interviewed
representatives from 17 selected
organizations and officials from
agencies that address climate issues.
What GAO Recommends
GAO recommends that NIST, in
consultation with USGCRP and
MitFLG, convene an ongoing
governmentwide effort to provide
forward-looking climate information to
standards organizations. Commerce
neither agreed nor disagreed with
GAO’s recommendation.
What GAO Found
Selected standards-developing organizations generally have not used forward-
looking climate information—such as projected rainfall rates—in design
standards, building codes, and voluntary certifications and instead have relied on
historical observations. Further, some organizations periodically update climate
information in standards, codes, and certifications, but others do not. Some
standards-developing organizations have taken preliminary steps that may lead
to the use of forward-looking climate information. For example, in 2015, the
American Society of Civil Engineers issued a paper that recommended engineers
work with scientists to better understand future climate extremes.
Standards-developing organizations face institutional and technical challenges to
using the best available forward-looking climate information in design standards,
building codes, and voluntary certifications, according to reports, representatives
of these organizations, and federal officials. Institutional challenges include a
standards-developing process that must balance various interests and can be
slow to change. For example, representatives of some standards-developing
organizations told GAO that their members have not expressed interest in
standards that use forward-looking climate information. Technical challenges
include difficulties in identifying the best available forward-looking climate
information and incorporating it into standards, codes, and certifications. For
example, representatives from one organization said that climate models provide
a wide range of possible temperatures that is difficult to use in their standards.
Agencies have initiated some actions and could take more to help standards-
developing organizations address challenges, according to various reports,
representatives of standards-developing organizations, and agency officials. For
example, in 2015, the National Institute of Standards and Technology (NIST)
convened a panel that seeks to identify gaps in standards and codes to make
infrastructure more resilient to extreme weather. In addition, officials from the
U.S. Global Change Research Program (USGCRP)—which coordinates research
across 13 federal agencies—told GAO they have begun discussions with
representatives of standards-developing organizations on their climate
information needs. In 2015, the Mitigation Framework Leadership Group
(MitFLG)—which coordinates hazard mitigation efforts—issued a draft strategy to
encourage federal support for more resilient standards and codes. Opportunities
exist for additional agency actions that may help address the challenges
organizations identified to using forward-looking climate information. Specifically,
agencies that address climate issues could improve interagency coordination to
help standards-developing organizations address institutional challenges and
could provide the best available forward-looking climate information to help them
address technical challenges. Federal policy directs agency standards
executives—senior-level officials who coordinate agency participation in
standards organizations—to coordinate their views when they participate in the
same standards activities so as to present, whenever feasible, a single, unified
position. The policy also directs the Secretary of Commerce, who has delegated
the responsibility to NIST, to coordinate and foster executive branch
implementation of the policy governing federal participation in the development of
voluntary consensus standards. A governmentwide effort could also present a
benefit by reducing the federal fiscal exposure to the effects of climate change.
View GAO-17-3. For more information, contact
J. Alfredo Gomez at (202) 512
-3841 or
.
Letter
Page i GAO-17-3 Climate Change
Letter 1
Background 5
Standards-Developing Organizations Have Not Generally Used
Forward-Looking Climate Information in Design Standards,
Building Codes, and Voluntary Certifications 14
Reports and Representatives of Standards-Developing
Organizations Identified Institutional and Technical Challenges
to Using Forward-Looking Climate Information 17
Agencies Have Initiated Some Actions and Could Take More to
Help Address Challenges, According to Reports, Standards-
Developing Organizations, and Agency Officials 21
Conclusions 30
Recommendation for Executive Action 31
Agency Comments and Our Evaluation 31
Appendix I Objectives, Scope, and Methodology 34
Appendix II Comments from the Department of Commerce 39
Appendix III GAO Contact and Staff Acknowledgments 40
Table
Table 1: Selected Standards-Developing Organizations and the
Areas Their Design Standards, Building Codes, and
Voluntary Certifications Focus On 35
Figure
Figure 1: Generalized Standards-Developing Process 10
Contents
Letter
Page ii GAO-17-3 Climate Change
Abbreviations
DHS Department of Homeland Security
DOD Department of Defense
DOE Department of Energy
DOT Department of Transportation
EPA Environmental Protection Agency
FEMA Federal Emergency Management Agency
FHWA Federal Highway Administration
GSA General Services Administration
HUD Department of Housing and Urban Development
ICSP Interagency Committee on Standards Policy
LEED Leadership in Energy and Environmental Design
MitFLG Mitigation Framework Leadership Group
NIST National Institute of Standards and Technology
NOAA National Oceanic and Atmospheric Administration
NTTAA National Technology Transfer and Advancement
Act of 1995, as amended
OMB Office of Management and Budget
USGCRP U.S. Global Change Research Program
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Page 1 GAO-17-3 Climate Change
441 G St. N.W.
Washington, DC 20548
November 30, 2016
The Honorable Matthew Cartwright
House of Representatives
Dear Mr. Cartwright:
Over the last decade, the federal government has incurred direct costs of
over $320 billion due to extreme weather events for, among other things,
repairs to federal facilities and infrastructure; and these costs are
expected to rise as the impacts of climate change intensify, according to
the President’s fiscal year 2017 budget request.
1
In 2014, the Third
National Climate Assessment—which integrated findings from the 13-
agency U.S. Global Change Research Program (USGCRP)—stated that
damages to infrastructure from sea level rise, heavy downpours, and
extreme heat are projected to increase with continued climate change.
2
Further, in 2013, the Department of Homeland Security’s (DHS) National
Infrastructure Protection Plan stated that extreme weather—including
more severe storms, extreme and prolonged drought, and severe
flooding—poses a significant risk to infrastructure such as buildings,
roads, and power lines.
3
The plan also stated that ongoing and future
changes to the climate have the potential to compound these risks and
could have a major impact on infrastructure.
As a result of the significant risks posed by climate change and the
nation’s fiscal condition, in February 2013, we added Limiting the Federal
1
U.S. Government Publishing Office, Analytical Perspectives, Budget of the United States
Government for Fiscal Year 2017 (Washington, D.C.: 2016). Specifically, $205 billion was
spent for domestic disaster response and relief; $90 billion for crop and flood insurance;
and $28 billion for maintenance and repairs to federal facilities and federally managed
lands, infrastructure, and waterways.
2
Jerry M. Melillo, Terese (T.C.) Richmond, and Gary W. Yohe, Eds., USGCRP, Climate
Change Impacts in the United States: The Third National Climate Assessment
(Washington, D.C.: October 2014). The USGCRP coordinates and integrates global
change research across 13 federal agencies. The Office of Science and Technology
Policy within the Executive Office of the President oversees the USGCRP.
3
Department of Homeland Security, National Infrastructure Protection Plan 2013:
Partnering for Critical Infrastructure Security and Resilience (Washington, D.C.: 2013).
The plan outlines the national effort—that is, the effort of government and private-sector
participants—to manage risk to infrastructure whose incapacity or destruction would have
a debilitating impact on national security, economic security, or public health or safety.
Letter
Page 2 GAO-17-3 Climate Change
Government’s Fiscal Exposure by Better Managing Climate Change
Risks to our list of areas at high risk for fraud, waste, abuse, and
mismanagement, or most in need of transformation.
4
For example, the
federal government is the owner or operator of infrastructure, such as
defense facilities, and the insurer of property vulnerable to climate
impacts through the National Flood Insurance Program. State, local, and
private-sector decision makers can also drive federal climate-related
fiscal exposure because they are responsible for planning, constructing,
and maintaining certain types of vulnerable infrastructure paid for with
federal funds, insured by federal programs, or eligible for federal disaster
assistance. The federal government also provides data and technical
assistance to federal, state, local, and private-sector decision makers
responsible for managing the impacts of climate change on their
activities. In November 2015, we found that using the best available
climate information can be a part of a risk-management strategy for those
making federal, state, local, and private-sector decisions and
investments.
5
In that report we defined climate information to encompass
both historical observations of climate conditions as well as forward-
looking projections of what climate change may mean for local areas,
such as how increased flow for a particular river may increase flooding.
We also found that to be useful, climate information must be tailored to
meet the needs of each decision maker, such as an engineer responsible
for building a bridge in a specific location.
Standards-developing organizations, such as professional engineering
societies and trade associations within the construction industry,
generally develop design standards, building codes, and voluntary
certifications. Design standards and building codes are technical
guidelines that promote the safety, reliability, productivity, and efficiency
of infrastructure, while voluntary certifications encourage design and
operation that exceed design standards and building codes. The building
codes that standards-developing organizations issue are referred to as
“model codes.” States and local governments may adopt model codes—
4
GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: Feb. 14, 2013).
5
GAO, Climate Information: A National System Could Help Federal, State, Local, and
Private Sector Decision Makers Use Climate Information, GAO-16-37 (Washington, D.C.:
Nov. 23, 2015). We recommended that the Executive Office of the President direct a
federal entity to develop a set of authoritative climate change projections and observations
and create a national climate information system with defined roles for federal agencies
and nonfederal entities. Relevant Executive Office of the President entities did not provide
official comments and, as of October 2016, had not implemented our recommendations.
Page 3 GAO-17-3 Climate Change
in whole or in part—into state laws and regulations and local ordinances,
which makes compliance with them a requirement for builders and
building owners.
6
Some design standards, building codes, and voluntary
certifications incorporate weather and climate information. For example,
they may include information about average seasonal temperatures or
expected precipitation rates for particular areas that may be relevant in
the selection of materials or construction techniques.
You asked us to review the use of forward-looking climate information in
design standards, building codes, and voluntary certifications.
7
Our
objectives were to examine (1) what is known about the use of forward-
looking climate information in design standards, building codes, and
voluntary certifications; (2) challenges, if any, that reports and
representatives of standards-developing organizations identified to using
forward-looking climate information; and (3) any actions that federal
agencies have taken to help address such challenges and additional
actions, if any, that reports, representatives of standards-developing
organizations, and agency officials identified.
To address our objectives, we reviewed reports by selected standards-
developing organizations, federal agencies, and experts in the
development and use of standards and climate change. We also
interviewed representatives of standards-developing organizations and
agency officials. We identified standards-developing organizations
through interviews with academics, subject-matter experts,
representatives of professional societies, as well as through our prior
work. We selected 17 organizations that develop design standards,
building codes, and voluntary certifications for which climate information
6
Most building codes enacted by state and local governments are based on model codes,
although typically these governments adopt building codes that take into account factors
such as resource conservation and regional construction practices, according to the
American Institute of Architects. References in our report to building codes are to model
codes, and not to any particular state or local government’s building codes.
7
This review was conducted in response to a 2014 request from Representative Matt
Cartwright—then Ranking Member, House Subcommittee on Economic Growth, Job
Creation, and Regulatory Affairs; Committee on Oversight and Government Reform—to
review how standards-developing organizations account for climate change in design
standards, building codes, and voluntary certifications.
Page 4 GAO-17-3 Climate Change
is relevant.
8
These organizations do not represent all organizations that
develop standards, codes, and certifications, but they include all major
standards-developing organizations that met our selection criteria.
To examine what is known about the use of forward-looking climate
information in design standards, building codes, and voluntary
certifications, we reviewed reports by the 17 standards-developing
organizations and subject-matter experts, as well as documents that
standards-developing organizations provided to us, such as examples of
the use of climate information in standards, codes, and certifications. We
also interviewed representatives of the 17 standards-developing
organizations. To examine any challenges that reports and
representatives of standards-developing organizations identified to using
forward-looking climate information, we reviewed reports by standards-
developing organizations, federal agencies, and subject-matter experts
and interviewed representatives of standards-developing organizations.
To examine any actions that federal agencies have taken to help address
these challenges and any additional actions they could take, we identified
and analyzed federal laws, policies, and reports. We interviewed
representatives of standards-developing organizations and officials from
agencies and entities with a role in coordinating, developing, and
adopting standards, codes, and certifications; assessing the impacts of
climate change; or helping to coordinate the federal government response
to climate change. These agencies and entities were the Department of
Commerce’s National Institute of Standards and Technology (NIST) and
National Oceanic and Atmospheric Administration (NOAA); the
Department of Energy (DOE); DHS’s Federal Emergency Management
Agency (FEMA); the Department of Housing and Urban Development
(HUD); the Department of Transportation (DOT); the Environmental
Protection Agency (EPA); and the General Services Administration (GSA)
and, within the Executive Office of the President, the Council on
Environmental Quality, the National Security Council, the Office of
8
The 17 organizations are the Air Conditioning Contractors of America Association;
American Association of State Highway and Transportation Officials; American Society of
Civil Engineers; American Society of Heating, Refrigerating, and Air-Conditioning
Engineers; American Society for Testing and Materials International; American Water
Works Association; Green Building Initiative; Home Innovation Research Labs; Institute of
Electrical and Electronics Engineers; Institute for Sustainable Infrastructure; Insurance
Institute for Business & Home Safety; International Association of Plumbing & Mechanical
Officials; International Code Council; International Living Future Institute; National
Electrical Manufacturers Association; National Fire Protection Association; and U.S.
Green Building Council.
Page 5 GAO-17-3 Climate Change
Management and Budget (OMB), the Office of Science and Technology
Policy, and USGCRP. We compared relevant federal laws, policies, and
reports with any actions that federal agencies have taken and could take
that, according to reports, representatives of standards-developing
organizations, and agency officials, could help standards-developing
organizations address the challenges they face. A more detailed
description of our objectives, scope, and methodology is presented in
appendix I.
We conducted this performance audit from July 2015 to November 2016
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Design standards, building codes, and voluntary certifications provide
guidelines for the construction of infrastructure. Standards-developing
organizations are the primary source of the standards, codes, and
certifications that federal, state, local, and private-sector infrastructure
planners follow. Standards-developing organizations typically develop
standards, codes, and certifications through a formal, consensus-based
process, and federal law and policies govern the participation of agency
officials in their development. Design standards, building codes, and
voluntary certifications play a role in the federal fiscal exposure to the
effects of climate change.
Design standards, building codes, and voluntary certifications provide
guidelines for the construction of infrastructure, specifically:
• Design Standards. OMB Circular A-119—which establishes policies
on the federal government’s role in development and use of
standards—defines “standards” to include the common and repeated
use of rules, conditions, guidelines, or characteristics for products or
related processes and production methods.
9
For example, the
9
Office of Management and Budget, Circular A-119: Federal Participation in the
Development and Use of Voluntary Consensus Standards and in Conformity Assessment
Activities (Washington, D.C.: Jan. 27, 2016).
Background
Design Standards,
Building Codes, and
Voluntary Certifications
Provide Guidelines for
Infrastructure Construction
Page 6 GAO-17-3 Climate Change
American Society of Civil Engineers issued a design standard that
specifies minimum structural load requirements under various types of
conditions, taking into accounts factors such as soil type and potential
for floods, snow, rain, ice, and wind.
• Building Codes. Building codes are minimum safeguards to ensure
the public health, safety, and general welfare of the occupants of new
and existing buildings and structures, according to the International
Code Council, a standards-developing organization.
10
For example,
building codes may ensure that exterior walls and roofs are resistant
to the weather, such as by including flashing and drainage. Building
codes may reference one or more design standards.
• Voluntary Certifications. Voluntary certifications assess
infrastructure across a spectrum of key criteria, including
environmental performance, and recognize those that go beyond
minimum code compliance. For example, the U.S. Green Building
Council developed the Leadership in Energy and Environmental
Design (LEED) certification, which offers four ratings levels—certified,
silver, gold, and platinum—depending on how many points a project
earns in various categories.
11
In addition to design standards, building codes, and voluntary
certifications, broader considerations, such as planning ordinances and
asset management, may govern the construction of infrastructure. For
example, planning ordinances may specify where to site new residential
or commercial buildings and place conditions on their design, such as
building height. Further, asset management—a decision-making
approach for providing the best level of service to customers at the lowest
appropriate cost—can guide what to build. For example, builders and
owners may use an asset management framework to decide whether to
repair or replace a building or another physical asset. In this report, we
focus on the use of climate information in standards, model codes, and
certifications, although climate information may also be relevant to
broader planning processes and asset management decisions.
10
The International Code Council is an association that helps the building safety
community and construction industry provide safe, sustainable, and affordable
construction through the development of model codes and standards used in the design,
construction, and compliance process.
11
The U.S. Green Building Council is a nonprofit organization. Among other things, it
implements, through a committee structure, the LEED rating systems, which are voluntary
certifications for environmentally sound buildings.
Page 7 GAO-17-3 Climate Change
In the United States, standards-developing organizations are the primary
source of design standards, building codes, and voluntary certifications
that federal, state, local, and private-sector infrastructure planners follow.
For example, a 2015 report by the National Institute of Building Sciences’
Consultative Council on the priorities of the building industry stated that
standards-developing organizations develop and maintain standards and
codes, while state and local governments adapt, adopt, and enforce
them.
12
In April 2013, we found that federal agencies rely on professional
associations in adopting design standards.
13
In 2015, we found that
federal agencies and the private sector use voluntary certifications that
third-party organizations—such as standards-developing organizations—
develop.
14
A variety of organizations, including professional societies and
trade associations such as the American Society of Civil Engineers and
the International Association of Plumbing & Mechanical Officials, develop
design standards, building codes, and voluntary certifications. Members
of these organizations can include academics; professionals, such as
architects, engineers, and planners; and federal, state, and local
government officials.
Various federal laws and regulations govern the use of design standards,
building codes, and voluntary certifications that standards-developing
organizations issue, including the following:
• The National Technology Transfer and Advancement Act of 1995, as
amended (NTTAA), codified the OMB Circular A-119 directive for
federal agencies to use voluntary consensus standards in lieu of
government-unique standards except where inconsistent with law or
otherwise impractical.
15
12
National Institute of Building Sciences, Moving Forward: Findings and
Recommendations from the Consultative Council (Washington, D.C.: 2015). The National
Institute of Building Sciences convenes representatives of government; the professions,
such as architects and engineers; and other interests to focus on issues affecting the
building industry.
13
GAO, Climate Change: Future Federal Adaptation Efforts Could Better Support Local
Infrastructure Decision Makers, GAO-13-242 (Washington, D.C.: Apr. 12, 2013).
14
GAO, Federal Green Building: Federal Efforts and Third-Party Certification Help
Agencies Implement Key Requirements, but Challenges Remain, GAO-15-667
(Washington, D.C.: July 23, 2015).
15
Pub. L. No. 104-113, § 12(d)(1), 110 Stat. 775, 783 (1996) (classified as amended at 15
U.S.C. § 272 Note).
Standards-Developing
Organizations Are the
Primary Source of Design
Standards, Building
Codes, and Voluntary
Certifications
Page 8 GAO-17-3 Climate Change
• Federal Highway Administration (FHWA) regulations incorporate, by
reference, certain design standards that the American Association of
State Highway and Transportation Officials develops, thereby
requiring their use for projects in the National Highway System.
16
• The Public Buildings Amendments of 1988 requires that each building
constructed or altered by GSA or any other federal agency, to the
maximum extent feasible, comply with one of the nationally
recognized model building and other applicable codes.
17
• The Cranston-Gonzalez National Affordable Housing Act, as
amended, requires the Secretaries of Agriculture and HUD to
establish by regulation energy efficiency standards for certain housing
(i.e., public housing and homes whose mortgages are insured by
HUD’s Federal Housing Administration) that meet or exceed the
requirements of specified design standards and building codes and, in
certain circumstances, to amend the regulation when the standards or
codes are revised.
18
• The Energy Conservation and Production Act, as amended, requires
the Secretary of Energy to determine whether each revision of certain
model energy codes for residential and commercial buildings would
improve energy efficiency.
19
If the Secretary makes an affirmative
determination, states have 2 years to certify that they have
determined whether it was appropriate to revise their residential
building energy code to meet or exceed the revised model code and
updated their commercial building energy code to meet or exceed the
revised model codes.
• If a federal agency chooses to use a green building voluntary
certification for a covered new building or major renovation, it must
meet the certification standards in DOE’s regulations.
20
The
regulations require that the system used to certify the building be
developed by an organization that provides an opportunity for
developing the system through a consensus-based process and
16
23 C.F.R. § 625.4(d).
17
Pub. L. No. 100-678, § 6(a), 102 Stat. 4049, 4051 (1988) (codified as amended at 40
U.S.C. § 3312(b)).
18
Pub. L. No. 101-625, § 109, 104 Stat. 4079, 4093 (1990) (codified as amended at 42
U.S.C. § 12709).
19
42 U.S.C. § 6833(a)(5)(A), (b)(2)(A).
20
79 Fed. Reg. 61563 (Oct. 14, 2014) (codified at 10 C.F.R. pt. 433, 435, 436).
Page 9 GAO-17-3 Climate Change
subject to periodic evaluation and assessment of the environmental
and energy benefits that result, among other things.
Standards-developing organizations follow similar, formal, consensus-
based processes in the development of American National Standards—
which include design standards, building codes, and voluntary
certifications. The American National Standards Institute, an organization
that accredits standards-developing organizations, established
requirements for due process that standards-developing organizations
must follow when developing American National Standards.
21
In 2000,
NIST and the American National Standards Institute signed a
memorandum of understanding to, among other things, improve
communication and coordination among the private and public sector on
voluntary standards issues.
22
This memorandum recognizes NIST’s
responsibility to coordinate standards activities with responsible federal
agencies to use voluntary consensus standards to the extent practicable,
participate appropriately in their development, and ensure that they meet
federal agency needs. It recognizes the American National Standards
Institute’s role of accrediting standards developers and approving
proposed standards as American National Standards. Standards-
developing organizations that plan to develop an American National
Standard use a process that may differ in some of the details, such as
how to determine consensus, but must follow the principles of due
process, including openness; balance of interests; and consensus and
the same basic steps, as seen in figure 1.
21
American National Standards Institute Essential Requirements: Due Process
Requirements for American National Standards (New York, NY: January 2016). Click here
to access these requirements. The American National Standards Institute may approve
standards that accredited standards developers issue according to its essential
requirements as American National Standards, including some building codes and
standards used for voluntary certification purposes.
22
Memorandum of Understanding between the American National Standards Institute and
NIST (2000). Click here to access this memorandum. The memorandum recognized the
responsibilities of individual federal agencies as well as the desirability of direct
cooperation among standards-developing organizations and any federal agency and does
not preempt the responsibility of any federal agency, take away any authority from any
federal agency to pursue its legislated regulatory programs, or take precedence over any
other memoranda of understanding between American National Standards Institute and
any other federal agency.
Standards-Developing
Organizations Develop
Certain Design Standards,
Building Codes, and
Voluntary Certifications
through a Formal,
Consensus-Based
Process
Page 10 GAO-17-3 Climate Change
Figure 1: Generalized Standards-Developing Process
Page 11 GAO-17-3 Climate Change
1. Initiate standards-developing activity. Members of standards-
developing organizations and, in some cases, members of the public
may propose to initiate standards activity. Proposals may include
information about the need for and anticipated benefits to the public of
the new or revised standard, as well as potential costs. The
standards-developing organization determines whether to draft a new
standard or revise an existing standard. If the standards-developing
organization agrees to draft a new standard or revise the existing one,
it directs a committee to undertake the activity. The committee may
include members of the organization as well as nonmembers—i.e.,
representatives of companies and nonprofit organizations and
government officials with subject-matter expertise who serve on a
voluntary basis.
2. Draft new or revised standard. The committee drafts the new or
revised standard and seeks public input by notifying members of the
standards-developing organization, the American National Standards
Institute, and other interested parties.
3. Review draft standard. The committee considers public comments
and the views of all interested parties and revises the draft standard.
4. Finalize draft standard. The committee uses a consensus-based
process to vote on whether to approve the draft standard. For
example, to approve a draft standard, some standards-developing
organizations require a supermajority—at least two-thirds—of the
members who cast ballots as well as resolution of any negative
comments. The standards-developing organization must provide an
appeals process for procedural decisions, including whether a
technical issue was afforded due process.
5. Issue new or revised standard. If the draft standard is approved, the
standards-developing organization issues the new or revised standard
and notifies the American National Standards Institute. The committee
establishes a schedule for review, generally at least every 5 years.
23
At that time, the standards-developing organization may reaffirm,
revise, or withdraw the standard.
23
The American National Standards Institute generally requires standards-developing
organizations to revise or reaffirm American National Standards at least every 5 years.
However, some standards-developing organizations opt to revise or reaffirm them more
frequently. For example, the International Code Council, which publishes building safety
and fire prevention codes, revises or reaffirms its codes every 3 years.
Page 12 GAO-17-3 Climate Change
Federal law requires agencies to participate in the development of
standards when it is in the public interest and is compatible with agency
mission, authority, priorities, and budget resources. In addition, NIST is
authorized to cooperate with other departments and agencies of the
federal government, state and local governments, and private
organizations, among other entities, in establishing voluntary consensus
standards and codes.
24
The Energy Policy Act of 1992 requires DOE to
support the upgrading of model building energy codes for new buildings
and periodically review their technical and economic basis.
25
OMB
Circular A-119 encourages federal representatives to participate actively
and on an equal basis with other members, consistent with the
procedures of the standards bodies, in the standards organization,
including in developing and adopting new standards by being fully
involved in discussions and technical debates, registering opinions, and
serving in leadership positions if selected. OMB Circular A-119 notes that
agency representatives should avoid the practice or the appearance of
undue influence relating to their participation in standards bodies and
activities. The Secretary of Commerce, through NIST, coordinates and
fosters the implementation of OMB Circular A-119.
In our prior work, we found that decisions regarding how to account for
climate change in the design of infrastructure—such as those in design
standards, building codes, and voluntary certifications—could affect the
federal fiscal exposure. In our February 2015 high-risk update, we noted
that, among other things, governmentwide improvement is needed to
reduce federal fiscal exposure, since climate change may affect the
federal government in various ways, such as through its role as a provider
of aid in response to disasters.
26
In our past work, we have found that
infrastructure is typically designed to operate within past climate
conditions. For example, in April 2013, we found that changes in the
climate may reduce the useable lifespan of infrastructure like bridges that
are expected to last as long as 50 to 100 years because historical
weather patterns—in particular, those related to extreme weather—no
longer provide reliable predictions for planning purposes.
27
Also in our
24
15 U.S.C. § 272(b)(10).
25
Pub. L. No. 102-486, § 101(a)(2), 106 Stat. 2776, 2785-86 (1992) (codified at 42 U.S.C
§ 6836).
26
GAO, High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015).
27
GAO-13-242.
Federal Law and Policies
Govern the Participation of
Agency Officials in the
Development of Design
Standards, Building
Codes, and Voluntary
Certifications
Design Standards,
Building Codes, and
Voluntary Certifications
Play a Role in the Federal
Fiscal Exposure to the
Effects of Climate Change
Page 13 GAO-17-3 Climate Change
April 2013 report, we found that taking actions to adapt to the effects of
climate change—such as raising river or coastal dikes to protect
infrastructure from sea level rise, building higher bridges, or increasing
the capacity of stormwater systems—may be costly, but that there is a
growing recognition that the cost of inaction could be greater.
As a result of the increasing costs of natural disasters, such as Hurricane
Sandy, federal agencies, state and local officials, and private-sector
entities have begun to acknowledge the role of design standards, building
codes, and voluntary certifications in managing the fiscal exposure to
extreme weather events and the potential long-term effects of climate
change, according to reports and our prior work. For example, in 2013,
the Hurricane Sandy Rebuilding Strategy—which identified actions that
federal agencies can take to enhance resilient rebuilding—noted that
investments now will last for decades, so current construction must be
completed to standards that anticipate future conditions and risks.
28
In
July 2015, we found that some state and city officials in areas affected by
Hurricane Sandy have strengthened their building codes to enhance the
resilience—the ability to adapt to changing conditions and withstand and
rapidly recover from disruption—of communities to future disasters.
29
In
October 2014, we found that, according to a representative of an
insurance industry group, more resilient building codes would help reduce
exposure to weather-related risks, including hurricanes, floods, wildfires,
hail, and wind storms, which are associated with climate change.
30
Further, in May 2014, we found that Department of Defense (DOD)
installation planners are unlikely to go beyond current building codes,
which could limit their ability to consider climate change in their facility
investment decisions.
31
28
Hurricane Sandy Rebuilding Task Force, Hurricane Sandy Rebuilding Strategy (August
2013).
29
GAO, Hurricane Sandy: An Investment Strategy Could Help the Federal Government
Enhance National Resilience for Future Disasters, GAO-15-515 (Washington, D.C.: July
30, 2015).
30
GAO, Climate Change: Better Management of Exposure to Potential Future Losses Is
Needed for Federal Flood and Crop Insurance, GAO-15-28 (Washington, D.C.: Oct. 29,
2014).
31
GAO, Climate Change Adaptation: DOD Can Improve Infrastructure Planning and
Processes to Better Account for Potential Impacts, GAO-14-446 (Washington, D.C.: May
30, 2014). We found in this report that the building codes and design standards that DOD
follows do not account for potential climate change impacts.
Page 14 GAO-17-3 Climate Change
Standards-developing organizations generally have not used forward-
looking climate information in design standards, building codes, and
voluntary certifications and instead have relied on historical observations,
according to our analysis, reports we reviewed, and representatives of
standards-developing organizations we interviewed. Specifically,
according to our analysis of documents that standards-developing
organizations provided to us, standards, codes, and certifications do not
use forward-looking climate information. Reports and representatives of
standards-developing organizations stated that such standards, codes,
and certifications were generally based on climate information from
historical observations. For example, a 2014 report by the National
Institute of Building Sciences’ Consultative Council on the priorities of the
building industry stated that standards and codes are based on the
science and experience of the past.
32
In a 2011 report, authors from the
University of Michigan and the U.S. Green Building Council stated that
climate-related decisions for the design of infrastructure are based on
historic climate data and past trends.
33
In addition, representatives of
standards-developing organizations told us they use climate information
based on historical observations in standards, codes, and certifications.
Further, standards-developing organizations vary in whether they update
the climate information in design standards, building codes, and voluntary
certifications on a regular basis, according to our analysis. Some
standards-developing organizations periodically update the climate
information they use. For example, the American Society of Heating,
Refrigerating, and Air-Conditioning Engineers uses climate information—
including average monthly temperatures and various measures of
humidity—based on historical data that it updates periodically to balance
both long-term and recent climate change trends and incorporate
changes in climate as they occur.
34
However, other organizations do not
regularly update the climate information they use. For example, the
International Code Council uses climate zones based on observations of
annual precipitation and average temperatures from 1961 through 1990
32
National Institute of Building Sciences, Moving Forward: Findings and
Recommendations from the Consultative Council (Washington, D.C.: 2014).
33
University of Michigan and U.S. Green Building Council, Green Building and Climate
Resilience: Understanding Impacts and Preparing for Changing Conditions (2011).
34
American National Standards Institute/American Society of Heating, Refrigerating, and
Air-Conditioning Engineers Standard 169-2013, Climatic Data for Building Design
Standards (Atlanta, GA: 2013). This standard is based on historical observations,
generally from 1982 to 2006.
Standards-
Developing
Organizations Have
Not Generally Used
Forward-Looking
Climate Information in
Design Standards,
Building Codes, and
Voluntary
Certifications
Page 15 GAO-17-3 Climate Change
to specify insulation levels for condensation control and has not updated
these observations in 26 years.
35
Moreover, the International Association
of Plumbing & Mechanical Officials uses rainfall rates from a 1961 federal
technical paper for the sizing of stormwater drainage pipes.
36
Representatives from the International Code Council told us that the
organization may not be updating this information because being able to
do so would depend on whether federal agency officials or other
participants provide more recent information during the standards-
developing process.
Some standards-developing organizations have taken preliminary steps,
such as issuing guidance and statements, that may lead to the use of
forward-looking climate information in standards, codes, and
certifications. For example, in 2015 the American Society of Civil
Engineers issued a white paper about adapting engineering practices to a
changing climate that recommended, among other things, that engineers
work with scientists to better understand future climate extremes to
improve the planning and design of infrastructure.
37
The American
Association of State Highway and Transportation Officials provides
guidance on its website to better prepare transportation design managers
and engineers for changing climate trends.
38
Further, the American
Institute of Architects and the National Institute of Building Sciences
worked with 19 organizations, including standards-developing
organizations, to issue a statement indicating their commitment to, among
other things, improving the resilience of infrastructure.
39
In a progress
35
International Code Council, 2015 International Building Code (May 2014). Accessed on
August 31, 2015, http://codes.iccsafe.org/app/book/toc/2015/I-
Codes/2015%20IBC%20HTML/index.html.
36
American National Standards Institute/International Association of Plumbing &
Mechanical Officials UPC 1-2015, Uniform Plumbing Code (Ontario, CA: Feb. 20, 2015)
uses climate information from the Department of Commerce’s Weather Bureau, Technical
Paper No. 40, Rainfall Frequency Atlas of the United States, for Duration from 30 Minutes
to 24 Hours and Return Periods from 1 to 100 Years (Washington, D.C.: May 1961).
37
American Society of Civil Engineers, Adapting Infrastructure and Civil Engineering
Practice to a Changing Climate, ed. J. Rolf Olsen (Reston, VA: 2015).
38
American Association of State Highway and Transportation Officials Subcommittee on
Materials, AASHTO Extreme Weather & The Transportation System. Click here to access
the guidance, which lists the FHWA climate change adaptation website, available here.
39
American Institute of Architects and National Institute of Building Sciences, Industry
Statement on Resilience (May 13, 2014). Click here to access the statement. Among the
19 organizations are the American Society of Civil Engineers; the International Code
Council; the National Fire Protection Association; and the U.S. Green Building Council.
Page 16 GAO-17-3 Climate Change
report on this statement, signatories made initial commitments to develop
design standards that are informed by climate data.
40
In addition, the
American Association of State Highway and Transportation Officials is
funding a Transportation Research Board project to develop tools that
hydraulic engineers could use to account for climate change in their
designs.
41
Some standards-developing organizations also encourage the use of
forward-looking climate information on a more limited basis. For example,
the U.S. Green Building Council has offered an optional pilot credit for its
voluntary certification that encouraged the use of forward-looking climate
information.
42
The U.S. Green Building Council suggested various
sources for forward-looking climate information, including (1) local climate
change studies, if available; (2) consultation with climate scientists; or (3)
U.S. regional predictions based on information available from EPA,
NOAA, FEMA, and the USGCRP. In addition, the Green Building
Initiative, a different standards-developing organization, includes the EPA
National Stormwater Calculator as a possible information source for its
voluntary certification.
43
The calculator allows users to consider future
climate change scenarios to demonstrate performance for the voluntary
certification. Further, representatives from the Green Building Initiative
told us that they may add references to forward-looking climate
40
American Institute of Architects and the National Institute of Building Sciences,
Preparing to Thrive: The Building Industry Statement on Resilience (May 10, 2016).
Accessed on May 10, 2016.
http://www.aia.org/aiaucmp/groups/aia/documents/pdf/aiab108838.pdf.
41
National Research Council, Transportation Research Board, NCHRP 15-61, Applying
Climate Change Information to Hydrologic and Hydraulic Design of Transportation
Infrastructure. For additional information on this research project, click here. The National
Research Council is the principal operating agency of the National Academy of Sciences
and the National Academy of Engineering.
42
According to a representative from the U.S. Green Building Council, the organization is
currently analyzing projects that applied for this pilot credit and may offer it again in the
future. Pilot credits are a testing area for new ideas in LEED.
43
The calculator is a desktop application that estimates the amount of stormwater runoff
from a specific site on the basis of local soil conditions, slope, land cover, and historical
rainfall records.
Page 17 GAO-17-3 Climate Change
information in their voluntary certification to address the Council on
Environmental Quality’s recently updated Guiding Principles.
44
Standards-developing organizations face institutional and technical
challenges to using the best available forward-looking climate information
in design standards, building codes, and voluntary certifications,
according to reports we reviewed and representatives of these
organizations and federal officials we interviewed.
Institutional challenges to using forward-looking climate information in
design standards, building codes, and voluntary certifications include a
standards-developing process that (1) must balance various interests and
(2) can be decentralized and slow to change, according to reports we
reviewed and representatives of standards-developing organizations we
interviewed. First, with regard to the challenge of balancing various
interests, as stated in GSA’s 2014 climate change risk-management plan,
it is unlikely that building codes will meet the needs for site-specific
climate resistant design of buildings in a timely way because of the rapidly
changing climate and the divergent motivations and beliefs of
stakeholders that participate in the code development process.
45
44
Council on Environmental Quality, Guiding Principles for Sustainable Federal Buildings
and Associated Instructions (Washington, D.C.: February 2016). The Guiding Principles
direct agencies constructing new federal buildings to identify projected climate change
impacts and consider these projections in the design of their projects. For certain existing
buildings, the Guiding Principles direct agencies to assess and consider climate change
risk and take action to mitigate risk considering mission criticality, potential climate change
impacts, security, and cost.
45
General Services Administration, FY 2014 Climate Change Risk Management Plan
(Washington, D.C.: June 30, 2014).
Reports and
Representatives of
Standards-
Developing
Organizations
Identified Institutional
and Technical
Challenges to Using
Forward-Looking
Climate Information
Institutional Challenges
Page 18 GAO-17-3 Climate Change
Representatives of some standards-developing organizations told us that
the various interests of their members drive their process. For example,
representatives of one standards-developing organization told us that
their members have not expressed interest in standards that use forward-
looking climate information because it would require increased upfront
construction costs. Representatives of two other standards-developing
organizations noted that in some cases their standards are for equipment
with a relatively short life-cycle—as little as 10 to 15 years—so they would
not realize appreciable benefits from increased resilience.
Second, design standards and building codes can be slow to change, as
stated in a 2015 report on adapting infrastructure to climate change by
the American Society of Civil Engineers.
46
Representatives of some
standards-developing organizations told us that the process they follow to
develop their standards is decentralized and can be slow to change. For
example, they stated that they cannot use forward-looking climate
information unless someone submits a proposal that includes forward-
looking climate information and their members reach consensus to
approve the proposal. Further, representatives of two standards-
developing organizations told us they reference climate information from
other standards-developing organizations in their standards, so it would
be difficult for them to unilaterally begin to use forward-looking climate
information. In addition, representatives of other standards-developing
organizations told us that standards and codes are by their nature stable
and slow to change. For example, representatives of one standards-
developing organization stated that code development is a conservative
process and does not accept change easily, and representatives from
another standards-developing organization stated that following the
consensus process takes time.
46
Adapting Infrastructure and Civil Engineering Practice to a Changing Climate.
Page 19 GAO-17-3 Climate Change
Technical challenges to using forward-looking climate information include
difficulty (1) identifying the best available forward-looking climate
information and (2) incorporating it into design standards, building codes,
and voluntary certifications, according to reports, federal officials, and
representatives of standards-developing organizations. First, with respect
to identifying the best available forward-looking climate information,
authors from the University of Michigan and the U.S. Green Building
Council noted a lack of connection between climate change research and
the design of infrastructure in their 2011 report.
47
Further, participants in
our July 2015 Comptroller General’s Forum on Preparing for Climate-
Related Risks: Lessons from the Private Sector stated that the absence
of consistent, authoritative climate information made it hard for private-
sector entities to consider climate information in planning.
48
Representatives of some standards-developing organizations told us they
had difficulties identifying the best available forward-looking climate
information models. For example, representatives of one standards-
developing organization stated that they are not aware of updated tools—
such as interactive web-based projections of flood hazards for particular
locations—or forward-looking climate information from the last 4 or 5
years. In addition, representatives of some standards-developing
organizations told us that they could not identify forward-looking climate
information with sufficient specificity. For example, representatives of one
standards-developing organization stated that they need forward-looking
climate information for a site-specific project area rather than at the
country or state level, which is what is available from climate models.
Representatives of another standards-developing organization stated that
they needed additional detailed information, such as whether any
projected increased precipitation would occur evenly throughout the year
or in concentrated bursts.
Second, it can be difficult to incorporate forward-looking climate
information into planning decisions, such as those involved in developing
design standards, building codes, and voluntary certifications, according
to reports, including the Third National Climate Assessment, and
USGCRP officials.
49
For example, in 2014, the Transportation Research
47
Green Building and Climate Resilience: Understanding Impacts and Preparing for
Changing Conditions.
48
GAO, Highlights of a Forum, Preparing for Climate-Related Risks: Lessons from the
Private Sector, GAO-16-126SP (Washington, D.C.: Nov. 19, 2015).
49
Climate Change Impacts in the United States: The Third National Climate Assessment.
Technical Challenges
Page 20 GAO-17-3 Climate Change
Board found that climate models do not generally provide climate
information that is directly usable in design—they require some
translation or derivation—because, for example, they do not account for
seasonal or spatial variability.
50
USGCRP officials told us that it may be
difficult for standards-developing organizations to move from using
historical observations, such as average summer heating degree days, to
model projections on the basis of a variety of assumptions.
51
Representatives of one standards-developing organization told us that
climate models provide a wide range of possible temperatures that is
difficult to use in their standards because the technical committee does
not know how to reflect this variability. In addition, representatives of
some standards-developing organizations told us that it is difficult to
reconcile the dynamic nature of climate change with the stable framework
of infrastructure design. Moreover, representatives of some standards-
developing organizations stated that they do not have such expertise in-
house and would have to rely on outside experts to provide forward-
looking climate information during the standards-developing process.
Representatives of another organization stated that using forward-looking
climate information would increase the complexity of their voluntary
certification and could deter potential users.
50
Transportation Research Board, National Cooperative Highway Research Program,
Report 750, Strategic Issues Facing Transportation, Volume 2, Climate Change, Extreme
Weather Events, and the Highway System: Practitioner’s Guide and Research Report
(Washington, D.C.: 2014).
51
As noted in the Third National Climate Assessment, while uncertainties limit scientists’
ability to predict the future changes in climate, scientists can develop plausible projections
of what might happen under a given set of assumptions, such as population, energy
sources, technology, and atmospheric levels of carbon dioxide.
Page 21 GAO-17-3 Climate Change
Federal agencies have initiated some actions to help standards-
developing organizations address institutional and technical challenges to
using forward-looking climate information. Moreover, according to reports
we reviewed, our prior work, and representatives of some standards-
developing organizations and agency officials we interviewed, agencies
have opportunities to take additional actions. These sources also
indicated that taking further actions to address these challenges could
present an additional benefit by reducing the federal fiscal exposure.
Agencies Have
Initiated Some
Actions and Could
Take More to Help
Address Challenges,
According to Reports,
Standards-
Developing
Organizations, and
Agency Officials
Page 22 GAO-17-3 Climate Change
Federal agencies have initiated some actions that could help standards-
developing organizations address institutional and technical challenges to
using forward-looking climate information. Officials from USGCRP and
from some federal agencies, including DOT and NOAA, told us they have
initiated efforts to coordinate with other federal agencies to provide the
best available forward-looking climate information to standards-
developing organizations. For example, DOT and NOAA officials told us
that they participate in the Mitigation Framework Leadership Group
(MitFLG), which, since 2013, has coordinated federal, state, and local
government efforts to mitigate the impact of hazards, including natural
disasters. Further, officials from NOAA told us they provided information
on their Digital Coast tools, including the Sea Level Rise Viewer, to a
standards-developing organization at its request, and that they generally
make these and other tools publicly available.
52
Officials from EPA stated
that they consulted with a standards-developing organization to develop a
tool that provides forward-looking climate information to water utility
owners and operators and helps them assess the related climate risks at
their individual utilities, but that they have not directly provided this
information to standards-developing organizations.
53
Officials from FEMA and NIST told us they have taken actions to help
make design standards, building codes, and voluntary certifications more
resilient to natural disasters. For example, in response to a proposal from
FEMA, the 2015 International Code Council residential building code
increased the minimum required building elevation above the 100-year
flood plain by 1 foot. FEMA officials told us that they proposed this
change because they determined it would be cost-effective under current
climate conditions. Furthermore, in November 2015, MitFLG—which
FEMA chairs—issued a draft implementation strategy that seeks to
encourage federal support for more resilient standards and codes, but the
strategy does not specifically focus on using forward-looking climate
information.
54
In 2015, NIST convened the Community Resilience Panel
for Buildings and Infrastructure Systems, which seeks to, among other
things, identifys gaps in standards and codes to make infrastructure more
52
NOAA’s Sea Level Rise Viewer can be found here. It is a web mapping tool for
visualizing community-level impacts from coastal flooding or sea level rise.
53
Environmental Protection Agency, Office of Water, Climate Resilience Evaluation and
Awareness Tool, Version 3.0, Methodology Guide (Washington, D.C.: May 2016).
54
MitFLG, Draft Implementation Strategy for Increasing Disaster Resilience through
Federal Support for Building Code Adoption & Enforcement (Nov. 24, 2015).
Agencies Have Initiated
Some Actions that Could
Help Standards-
Developing Organizations
Address Institutional and
Technical Challenges
Page 23 GAO-17-3 Climate Change
resilient to extreme weather and other risks. The President’s 2013
Climate Action Plan recognized the panel’s role in helping to improve the
resilience of infrastructure, although NIST officials told us that the panel
does not currently focus on addressing potential climate change effects.
55
According to reports we reviewed, our prior work, and representatives of
some standards-developing organizations and federal agency officials we
interviewed, opportunities exist for agencies to take additional actions that
may help address the challenges standards-developing organizations
face to using forward-looking climate information. Specifically, according
to these sources, federal agencies with a role in coordinating, developing,
and adopting standards, codes, and certifications or assessing and
responding to climate-related issues could help address the challenges
standards-developing organizations face by taking two types of actions.
First, agencies could improve interagency coordination to address
institutional challenges. Second, agencies could provide the best
available forward-looking climate information to standards-developing
organizations to help address their technical challenges. In addition,
helping standards-developing organizations address these challenges
could present opportunities to reduce federal fiscal exposure to the
effects of climate change, according to federal agency officials, our prior
work, and reports we reviewed.
Improving Interagency Coordination to Help Address Institutional
Challenges
Federal agencies with a role in coordinating, developing, and adopting
standards, codes, and certifications or assessing and responding to
climate-related issues could improve interagency coordination to help
address the institutional challenges standards-developing organizations
face, according to reports we reviewed, our prior work, and
representatives of standards-developing organizations and federal
agency officials we interviewed. For example, a 2015 report from the
National Institute of Building Sciences’ Consultative Council on the
priorities of the building industry found that efforts to improve resilience,
such as incorporating anticipated climate change effects into design
standards and building codes, would benefit from a coordinated effort
55
Executive Office of the President, President’s Climate Action Plan (Washington, D.C.:
June 2013).
Opportunities Exist for
Federal Agencies to Take
Additional Actions,
According to Reports,
Representatives of
Standards-Developing
Organizations, and
Agency Officials
Page 24 GAO-17-3 Climate Change
among federal agencies that address climate-related issues.
56
Further, a
2012 National Academies report found that the roles and responsibilities
for improving the resilience of buildings are not coordinated by the federal
government, either through a single agency or authority, or through a
unified vision.
57
This report stated that a national vision could be a more
effective approach to encouraging resilience. Also, in November 2015, we
found that providing climate information is an inherently interagency
activity that relies on the cooperation and shared resources of many
agencies, but interagency coordination is weak by design.
58
In that report
we found that agency climate programs were created to meet individual
agency missions and are not necessarily focused on the needs of other
decision makers.
Both representatives of standards-developing organizations and federal
agency officials we interviewed recognized the need for improved
coordination to address institutional challenges to using climate
information in design standards, building codes, and voluntary
certifications. Representatives of several standards-developing
organizations stated that improved coordination among federal agencies
could help increase the legitimacy and visibility of efforts to use forward-
looking climate information in standards, codes, and certifications. GSA’s
March 2016 standards for government-owned and -leased buildings
noted that federal leadership is essential—especially for buildings that are
vulnerable to climate change and critical to the public good—because
building codes do not consider climate change.
59
Emphasizing the key
role for the federal government, OMB officials stated that standards and
codes are critically important to planning for climate change and that
proactive federal engagement with standards-developing organizations is
necessary. In addition, USGCRP officials stated that there is a need for
conversations among a coordinated group of federal agencies and
standards-developing organizations to help address the institutional
challenges these organizations face.
56
Moving Forward: Findings and Recommendations from the Consultative Council (2015).
57
The National Academies, Committee on Increasing National Resilience to Hazards and
Disasters; Committee on Science, Engineering, and Public Policy, Disaster Resilience: A
National Imperative (Washington, D.C.: 2012).
58
GAO-16-37.
59
General Services Administration, PBS-100, Facilities Standards for the Public Buildings
Service (Washington, D.C.: March 2016).
Page 25 GAO-17-3 Climate Change
Federal policy directs agency standards executives—senior-level officials
who coordinate agency participation in standards organizations—to
coordinate their views on matters of paramount importance when they
participate in the same standards activities. The President has also
established a council to, among other things, coordinate interagency
efforts on priority federal government actions related to climate
preparedness and resilience. First, OMB Circular A-119 directs agency
standards executives to coordinate their views on matters of paramount
importance when they participate in the same standards activities so as to
present, whenever feasible, a single, unified position, and where not
feasible, a mutual recognition of differences.
60
OMB Circular A-119 also
directs the Secretary of Commerce, who has delegated this responsibility
to NIST, to coordinate and foster executive branch implementation of the
Circular, which addresses federal participation in the development and
use of voluntary consensus standards, and to sponsor, support, and chair
the Interagency Committee on Standards Policy (ICSP). According to the
ICSP charter, the objective of the ICSP is to help foster cooperative
participation by the federal government, among others, in standards
activities. The ICSP coordinates with a view to encouraging more
effective federal participation in the development of standards, among
other things. Second, acknowledging that the management of climate
change risks requires deliberate preparation, close cooperation, and
coordinated planning by the federal government, Executive Order 13653
established the interagency Council on Climate Preparedness and
Resilience.
61
The Council is to, among other things, (1) coordinate
interagency efforts on priority federal government actions related to
climate preparedness and resilience and (2) facilitate the integration of
climate science in policies and planning of government agencies and the
private sector. In 2016, the Council issued a report, noting that with
respect to integrating climate resilience into agencies’ missions,
60
OMB Circular A-119 directs the heads of agencies that use standards for regulatory,
procurement, or other mission-related activities to designate a senior-level official as the
agency standards executive who will be responsible for the agency’s implementation of
this Circular, among other duties.
61
Executive Order 13653, Preparing the United States for the Impacts of Climate Change
(Washington, D.C.: Nov. 1, 2013). Officials from the Executive Office of the President—the
Chair of the Council on Environmental Quality, the Director of the Office of Science and
Technology Policy, and the Assistant to the President for Homeland Security and
Counterterrorism—co-chair the interagency Council on Climate Preparedness and
Resilience.
Page 26 GAO-17-3 Climate Change
operations, and culture, strong coordination across the federal
government creates the best outcomes.
62
Officials from the Executive Office of the President and federal agencies
told us that they have not specifically coordinated efforts to help
standards-developing organizations use the best available forward-
looking climate information. Officials from USGCRP and the Office of
Science and Technology Policy also stated that interagency coordination
is unlikely to produce new climate analyses that depart from agency
missions. NIST officials stated that they coordinate other governmentwide
activities related to standards, codes, and certifications—for example, the
ICSP serves as a forum for federal agencies to share best practices.
NIST officials also told us that they coordinate the federal use of
standards but they do not have the authority to coordinate federal
agencies’ participation in the standards-developing process.
63
However,
as we noted above, OMB Circular A-119 directs the Secretary of
Commerce to coordinate and foster executive branch implementation of
the Circular, which addresses federal participation in the development of
voluntary consensus standards, among other things. Moreover, NIST is
authorized to cooperate with other federal agencies, among other entities,
in establishing voluntary consensus standards and codes.
Providing the Best Available Forward-Looking Climate Information
to Help Address Technical Challenges
Federal agencies that participate in the standards-developing process
and respond to climate-related issues could help address technical
challenges by providing the best available forward-looking climate
information for consideration in the standards-developing process,
according to reports we reviewed, our prior work, and representatives of
some standards-developing organizations and federal agency officials we
interviewed. For example, in November 2014, the State, Local, and Tribal
62
Council on Climate Preparedness and Resilience, Opportunities to Enhance the Nation’s
Resilience to Climate Change (Washington, D.C.: October 2016).
63
This is not consistent with the memorandum of understanding NIST entered into with the
American National Standards Institute in 2000, which states that NIST’s role under the
NTTAA and OMB Circular A-119 is to, among other things, coordinate federal activities in
voluntary standards. Moreover, the memorandum of understanding states that NIST
coordinates standards activities with responsible government agencies to participate
appropriately in the development of voluntary standards, among other things.
Page 27 GAO-17-3 Climate Change
Leaders Task Force on Climate Preparedness and Resilience reported
that the greatest need is often not the creation of new data or information
but assistance and tools for decision makers to navigate the wide array of
resources already available.
64
The Task Force also recommended that
the federal government help establish standards for climate resilience in
infrastructure, thus encouraging their adoption by the private sector, other
levels of government, and nongovernmental organizations. Similarly, we
found in November 2015 that federal technical assistance could help
decision makers access, translate, and use climate information.
65
In April
2013, we found that the federal government plays a critical role in
producing the information needed to facilitate a more informed response
to the effects of climate change.
66
However, in this report we stated that
this information exists in an uncoordinated confederation of networks and
is not easily accessible. Representatives of some standards-developing
organizations told us that federal agencies have the expertise and
resources to identify and help incorporate the best available forward-
looking climate information in standards, codes, and certifications. For
example, representatives of some standards-developing organizations we
interviewed stated that USGCRP agencies could work with standards-
developing organizations to provide forward-looking climate information.
Representatives of one standards-developing organization stated that
federal agencies could provide, for example, projections of snow levels,
minimum and maximum temperatures, storm surges, and coastal wind
speeds. OMB officials and representatives of some standards-developing
organizations stated that federal efforts would be more effective if
agencies worked directly with standards-developing organizations rather
than making information and tools publicly available.
Federal law requires federal agencies to participate in the standards-
developing process under certain circumstances. As required by the
NTTAA and consistent with OMB Circular A-119, federal agencies must
consult with standards-developing organizations and participate in the
64
The State, Local, and Tribal Leaders Task Force on Climate Preparedness and
Resilience, Recommendations to the President (Washington, D.C.: November 2014). The
Task Force on Climate Preparedness and Resilience was established by Executive Order
13653 and included 26 governors, mayors, county officials, and tribal leaders. It was
tasked with providing recommendations to the President and an interagency council on
how the federal government can support state, local, and tribal resilience to climate
change, among other things.
65
GAO-16-37.
66
GAO-13-242.
Page 28 GAO-17-3 Climate Change
development of technical standards when such participation is in the
public interest and compatible with the agencies’ missions, authorities,
priorities, and budget resources. Federal policies also direct agencies to
mitigate the effects of natural disasters, including by communicating and
using the best available localized climate projections, and to help
translate climate science for risk-management decision making.
Specifically, the National Mitigation Framework states, among other
things, that reducing long-term vulnerability can include adopting and
enforcing hazard-resistant design standards and building codes.
67
It
identifies as a critical task for improving community resiliency the
communication and use of the best available localized climate projections
so that the public and private sectors can make informed decisions. In
addition, OMB Circular A-11, which provides guidance on the preparation
and execution of the President’s budget, directs agency proposals for
construction of federal facilities to comply with relevant guidance on
climate change.
68
Further, USGCRP’s 2012 strategic plan calls on
USGCRP to assist in the translation of science for societal benefit and
related risk-management decision making.
69
It also notes that it will be
critical for USGCRP to build new partnerships with engineers, architects,
and planners and their supporting federal agencies because of the
vulnerability of infrastructure to the effects of climate change.
Officials from some federal agencies, including FEMA, and USGCRP told
us that they have provided forward-looking climate information to
standards-developing organizations to a limited extent because they do
not have clear direction to do so. FEMA officials told us that although
MitFLG has coordinated federal, state, and local government hazard
mitigation efforts, it does not have any measures that focus on providing
forward-looking climate information to standards-developing
organizations. Officials from USGCRP told us that they need to improve
their understanding of the information needs of standards-developing
organizations in order to take them into account for USGCRP research
and product development. Further, officials from USGCRP told us that
67
Department of Homeland Security, National Mitigation Framework (Washington, D.C.:
May 2013). The National Mitigation Framework establishes a forum for coordinating and
addressing how the nation manages risk through mitigation capabilities.
68
Office of Management and Budget, Circular A-11, Preparation, Submission, and
Execution of the Budget (Washington, D.C.: July 1, 2016).
69
U.S. Global Change Research Program, The National Global Change Research Plan
2012-2021, A Strategic Plan for the U.S. Global Change Research Program (Washington,
D.C.: Apr. 2, 2012).
Page 29 GAO-17-3 Climate Change
they are beginning to engage the civil engineering community, including
standards-developing organizations, in this discussion. Such engagement
is consistent with USGCRP’s strategic plan, which notes that it will be
critical for USGCRP to build new partnerships with engineers, architects,
and planners because of the vulnerability of infrastructure to the effects of
climate change. However, officials also noted that USGCRP assists many
users and sectors and does not have the practical or financial capacity to
provide detailed, tailored analyses for each sector. NIST officials told us
that they have not provided forward-looking climate information to
standards-developing organizations for various reasons, including
because they have not conducted research on the way climate change
may impact design standards. These officials stated that their research
focuses on improving the resilience of communities to a variety of
disruptive events but leaves it to the communities to decide for
themselves what the appropriate levels of risk, mitigation, and response
should be, given their local resources. However, by consulting with
MitFLG and USGCRP, NIST could help coordinate a governmentwide
effort to provide the best available forward-looking climate information to
standards-developing organizations for consideration in the development
of design standards, building codes, and voluntary certifications.
Helping Standards-Developing Organizations Address Challenges
Presents a Benefit by Reducing the Federal Fiscal Exposure to the
Effects of Climate Change
Helping standards-developing organizations consider forward-looking
climate information in the development of voluntary consensus standards
that promote the safety, reliability, productivity, and efficiency of
infrastructure presents an additional benefit by reducing the federal fiscal
exposure, according to federal agency officials, our prior work, and
reports we reviewed. First, helping standards-developing organizations
could help increase the efficiency and consistency of federal efforts to
mitigate the risk that climate change poses to federal facilities. For
example, GSA officials told us that the use of forward-looking climate
information in developing standards and codes would help mitigate much
of the climate risk to their facilities (i.e., government-owned and -leased
buildings), lessening the need for the resource-intensive screenings that
GSA currently conducts. Specifically, GSA officials stated that they are
screening fiscal year 2017 capital building projects for climate risk in an
effort to reduce or eliminate emergency response costs over the lifespan
of the new buildings. GSA’s climate risk screen uses forward-looking
climate information from the Third National Climate Assessment to
consider—for each new building—the importance of the project to the
Page 30 GAO-17-3 Climate Change
mission of the agency, expected service life, historic or cultural status,
and whether the building is vulnerable to projected changes in the
climate.
70
Second, as previously noted, federal, state, local, and private-
sector decision makers use the design standards, model building codes,
and voluntary certifications that standards-developing organizations issue
to plan and construct infrastructure that may be paid for with federal
funds, insured by federal programs, or eligible for federal disaster
assistance—key aspects of federal fiscal exposure to climate change. For
example, in 2015, the National Institute of Building Sciences’ Consultative
Council reported that communities need standards and codes that can
help them recognize the risks associated with a changing climate and
prevent disruptive hazards from becoming disasters.
71
Similarly, in 2014,
the State, Local, and Tribal Leaders Task Force on Climate Preparedness
and Resilience reported that anticipating and planning for climate change
impacts now—including through the standards and codes that
communities adopt—can reduce harm and long-term costs.
72
Extreme weather costs the federal government billions of dollars each
year and poses a significant risk to infrastructure, such as buildings,
roads, and power lines that provides essential services to the American
public. Ongoing and future changes to the climate have the potential to
compound these risks and increase federal fiscal exposure. Design
standards, building codes, and voluntary certifications play a role in
ensuring the resilience of federal and nonfederal infrastructure to the
effects of natural disasters and extreme weather but generally use climate
information based on historical observations. We have previously found
that using the best available climate information, including forward-looking
projections, can be a part of a risk-management strategy for federal,
state, local, and private-sector decisions and investments. However,
standards-developing organizations, not federal agencies, are the primary
source for standards, codes, and certifications that specify how weather
and climate information is considered in infrastructure planning. These
70
GSA officials told us that they develop a climate profile for every capital project for which
they require a climate screen. To do so, they use climate projections based on the
Representative Concentration Pathway 8.5, which roughly corresponds to a continuation
of global emissions increases. They stated that they chose these projections to better
understand the extreme values of climate variables, upper limits of adaptation, and
impacts that they can avoid through adaptation.
71
Moving Forward: Findings and Recommendations from the Consultative Council (2015).
72
Recommendations to the President.
Conclusions
Page 31 GAO-17-3 Climate Change
organizations face institutional and technical challenges to using forward-
looking climate information, and federal agencies have initiated actions
that could help them address these challenges. For example, NIST
convened a panel to, among other things, identify gaps in standards and
codes to make infrastructure more resilient to extreme weather and other
risks. Various reports we reviewed and representatives of standards-
developing organizations and agency officials we interviewed identified
additional actions federal agencies could take to help standards-
developing organizations use forward-looking climate information. Some
agencies, such as GSA, are beginning to consider the risk climate change
poses to their infrastructure, but these efforts are done on a case-by-case
basis. Taking a coordinated, governmentwide approach could present an
additional benefit by reducing federal fiscal exposure. Given NIST’s
statutory authority and role in coordinating implementation of OMB
Circular A-119, it is well-positioned to convene federal agencies for such
an effort.
To help reduce federal fiscal exposure by enhancing the resilience of
infrastructure to extreme weather, we recommend that the Secretary of
Commerce, through the Director of NIST, in consultation with MitFLG and
USGCRP, convene federal agencies for an ongoing governmentwide
effort to provide the best available forward-looking climate information to
standards-developing organizations for their consideration in the
development of design standards, building codes, and voluntary
certifications.
We provided the Department of Commerce, DHS, and the Office of
Science and Technology Policy with a draft of this report for comment.
The Department of Commerce neither agreed nor disagreed with our
recommendation and provided written comments, which are summarized
below and reproduced in appendix II. DHS did not provide written
comments. The Office of Science and Technology Policy did not provide
official written comments, but, along with OMB and USGCRP, provided
technical comments, which we incorporated as appropriate.
Recommendation for
Executive Action
Agency Comments
and Our Evaluation
Page 32 GAO-17-3 Climate Change
In its response, the Department of Commerce stated that it strongly
supports efforts to foster greater and more effective participation by
federal agencies in the development of consensus standards for climate
resilience in infrastructure and other areas. However, the Department of
Commerce stated that GAO’s recommendation that NIST coordinate a
governmentwide effort to deliver the best available climate change
information to standards-developing organizations is inconsistent with
NIST's well-established role in the voluntary consensus standards-
developing process. Specifically, it noted that NIST does not have the
necessary expertise to play the role of arbiter of what climate information
is “best.” We agree that NIST should not play the role of arbiter of what
climate information is “best,” which is why we recommended that NIST
coordinate the governmentwide effort to provide the best available
forward-looking climate information to standards-developing organizations
in consultation with MitFLG and USGCRP. As we found in our 2015
report on climate information, reducing the risks and realizing the
opportunities of climate change require making good decisions based on
reliable and appropriate information about past, present, and future
climate, as well as properly integrating that information into the decision-
making process.
73
That 2015 report also found that the federal
government has a key role in providing authoritative climate information to
meet the needs of federal, state, local, and private-sector decision
makers. USGCRP, in particular, is well-positioned to perform this role and
has the necessary expertise to identify the best available forward-looking
climate information because, as we noted in our report, it coordinates
global change research across 13 federal agencies.
The Department of Commerce further noted that NIST could—consistent
with its mission and authority—convene stakeholders, including federal
agencies, to discuss forward-looking climate information for potential use
by the standards community. Our recommendation reflected that NIST is
the entity responsible for coordinating executive branch implementation of
OMB Circular A-119, which governs federal participation in the
development and use of voluntary consensus standards. However, in
response to the Department of Commerce’s comments, we clarified our
recommendation to better reflect its views of NIST’s mission and
authority. The Department of Commerce also provided technical
comments, which we incorporated as appropriate.
73
GAO-16-37.
Page 33 GAO-17-3 Climate Change
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies to appropriate congressional
committees; the Secretary of Commerce; the Secretary of Homeland
Security; the Director of the Office of Science and Technology Policy; and
other interested parties. In addition, this report will be available at no
charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please
contact me at (202) 512-3841 or [email protected]. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are listed in
appendix III.
Sincerely yours,
J. Alfredo Gomez
Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and
Methodology
Page 34 GAO-17-3 Climate Change
Our objectives were to examine (1) what is known about the use of
forward-looking climate information in design standards, building codes,
and voluntary certifications; (2) challenges, if any, that reports and
representatives of standards-developing organizations identified to using
forward-looking climate information; and (3) any actions that federal
agencies have taken to help address these challenges and additional
actions, if any, that reports, representatives of standards-developing
organizations, and agency officials identified.
To address our audit objectives, we reviewed reports by selected
standards-developing organizations, federal agencies, and experts in the
development and use of standards and climate change that we identified
through scoping interviews and prior work. We also conducted interviews
with representatives of standards-developing organizations and agency
officials. We focused on standards-developing organizations that develop
design standards, building codes, and voluntary certifications in four
infrastructure sectors: energy, government facilities, transportation
systems, and water and wastewater systems. These sectors provide
cities, neighborhoods, and buildings with essential services; permit
movement and connection; and are components of critical infrastructure,
according to the Department of Homeland Security’s 2013 National
Infrastructure Protection Plan. We identified standards-developing
organizations through interviews with academics, subject-matter experts,
and representatives of professional societies, as well as through our prior
work. We selected 17 organizations that develop such standards, codes,
and certifications for which climate information is relevant. For example,
they incorporate or reference information about the intensity, duration,
and frequency of precipitation, average daily temperatures, or flood
hazards. A majority of the standards-developing organizations we
selected—14 of 17—are accredited by the American National Standards
Institute or similarly follow an open, consensus-based process to develop
their standards, codes, or certifications. We asked each of the
representatives of organizations we interviewed whether there were other
organizations we should contact and adjusted our list as needed. While
the standards-developing organizations we selected do not represent all
organizations that develop standards, codes, and certifications in the
infrastructure sectors on which we focused, they include all the major
standards-developing organizations within the sectors that met our
selection criteria. Table 1 lists the organizations we reviewed and the
areas of focus—the scope and purpose—of their design standards,
building codes, and voluntary certifications.
Appendix I: Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and
Methodology
Page 35 GAO-17-3 Climate Change
Table 1: Selected Standards-Developing Organizations and the Areas Their Design Standards, Building Codes, and Voluntary
Certifications Focus On
Organization
Areas of focus of design standards, building codes, and voluntary
certifications
1. Air Conditioning Contractors of America
Association
Design, installation, operation, maintenance, and repair of heating, ventilating,
air conditioning, and refrigeration systems
2. American Association of State Highway and
Transportation Officials
Highway and street geometric design
3. American Society of Civil Engineers
General structural design
4. American Society of Heating, Refrigerating and
Air-Conditioning Engineers
Design, planning, and sizing of building energy systems and equipment
5. American Society for Testing and Materials
International
a
Characteristics and performance of materials, products, systems, and services
6. American Water Works Association
Reliability, life, and usage in the water profession
7. Green Building Initiative
Emissions
Energy
Indoor environment
Project and environmental management
Resources
Site
Water
8. Home Innovation Research Labs
Design, assembly, construction, inspection, maintenance, and performance of
residential sites, dwellings, and facilities; light commercial construction; and
building products, components, or systems
9. Institute of Electrical and Electronics
Engineers
a
Electrical, electronics, radio, and related engineering
10. Institute for Sustainable Infrastructure
Climate and risk
Leadership
Natural world
Quality of life
Resource allocation
Appendix I: Objectives, Scope, and
Methodology
Page 36 GAO-17-3 Climate Change
Organization
Areas of focus of design standards, building codes, and voluntary
certifications
11. Insurance Institute for Business & Home Safety
Burglary
Electrical surge
Flood
Hail
Hurricane/high wind
Internal fire
Seismic
Severe winter weather
Tornado
Water loss
Wildfire
12. International Association of Plumbing &
Mechanical Officials
Composition, dimensions, and properties of materials, fixtures, devices, and
equipment used in plumbing or mechanical systems
13. International Code Council
Building construction
14. International Living Future Institute
Beauty
Energy
Equity
Health and happiness
Materials
Place
Water
15. National Electrical Manufacturers Association
a
Connectors for electrical utility transmission
Overhead and underground distributions and substations
16. National Fire Protection Association
Fire, electrical, and building safety
17. U.S. Green Building Council
Energy and atmosphere
Indoor environmental quality
Innovation
Integrative process
Location and transportation
Materials and resources
Sustainable sites
Water efficiency
Source: GAO analysis of data from selected standards-developing organizations. | GAO-17-3
a
These standards-developing organizations provided minimal responses and did not respond to
follow-up requests. We included their responses as appropriate.
To address our first objective, we reviewed reports by standards-
developing organizations and subject-matter experts and documents that
standards-developing organizations provided to us. For example,
standards-developing organizations provided us with examples of one or
Appendix I: Objectives, Scope, and
Methodology
Page 37 GAO-17-3 Climate Change
more standards, codes, or certifications that referenced climate
information such as average temperatures or rainfall rates to show how
this information is typically used. We interviewed representatives of these
organizations using semi-structured interview techniques, including a
mixture of both open-ended and closed-ended questions. Some of the
questions in our interviews were about the organizations’ use of historical
observations and forward-looking climate information and other actions
they may have taken to consider how climate change may affect their
standards, codes, and certifications. In this report, we defined “use
forward-looking climate information” to mean that the standards-
developing organization specified a particular source or sources of data
and required their use in order to meet the design standard or building
code or to earn the voluntary certification. Similarly, to address our
second objective, we reviewed reports by standards-developing
organizations, federal agencies, and subject-matter experts. Other
questions in our interviews with representatives of standards-developing
organizations, as seen above, were aimed at identifying any challenges
they face and steps they plan, if any, to address these challenges.
To address our third objective, we identified and analyzed federal laws,
policies, and reports relevant to federal use of design standards, building
codes, and voluntary certifications; preparedness for natural disasters;
and potential responses to the effects of climate change on infrastructure.
These laws, policies, and reports included the National Technology
Transfer and Advancement Act of 1995, as amended; Office of
Management and Budget (OMB) Circulars A-11 and A-119; Executive
Order 13653; and the National Mitigation Framework. We also examined
our prior work on the federal response to climate change, federal green
buildings, and response to natural disasters. As part of our interviews with
representatives of standards-developing organizations, described above,
we asked them to identify the types of federal actions that could help
address any challenges they face. We also interviewed officials from
agencies and entities with a role in coordinating, developing, and
adopting standards, codes, and certifications; assessing the impacts of
climate change; or helping to coordinate the federal government response
to climate change to identify any actions they have taken and any
additional actions they could take. These agencies and entities were the
Department of Commerce’s National Institute of Standards and
Technology and National Oceanic and Atmospheric Administration; the
Department of Energy; the Department of Homeland Security’s Federal
Emergency Management Agency; the Department of Housing and Urban
Development; the Department of Transportation; the Environmental
Protection Agency; and the General Services Administration and, within
Appendix I: Objectives, Scope, and
Methodology
Page 38 GAO-17-3 Climate Change
the Executive Office of the President, the Council on Environmental
Quality, the National Security Council, OMB, the Office of Science and
Technology Policy, and the U.S. Global Change Research Program.
We analyzed standards-developing organizations’ responses to our
interview questions and other information to identify the actions these
organizations have taken to use forward-looking climate information, any
challenges they face in doing so, and any actions that federal agencies
have taken, and additional actions they could take, if any, to help address
these challenges. We identified categories of challenges and agency
actions on the basis of scoping interviews with academics and subject-
matter experts, reports, and our analysis of the interviews with
representatives of standards-developing organizations and federal
agency officials. These categories encompassed a majority of the
challenges and actions we identified and were mutually exclusive. We
categorized challenges as either institutional or technical. Categories of
federal actions were improving coordination of federal efforts to help
standards-developing organizations use the best available forward-
looking climate information and providing such information for
consideration in the standards-developing process. We did not report on
challenges and actions that did not fit within the categories we developed
because they were generally outside the scope of our review. For
example, some challenges and federal actions were related to the
adoption and enforcement of design standards and building codes. We
compared relevant federal laws, policies, and reports with the actions that
federal agencies have taken and could take that, according to reports we
reviewed and representatives of standards-developing organizations and
agency officials we interviewed, could help standards-developing
organizations address the challenges they face.
We conducted this performance audit from July 2015 to November 2016
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Appendix II: Comments from the Department
of Commerce
Page 39 GAO-17-3 Climate Change
Appendix II: Comments from the Department
of Commerce
Appendix III: GAO Contact and Staff
Acknowledgments
Page 40 GAO-17-3 Climate Change
J. Alfredo Gomez, (202) 512-3841 or [email protected]
In addition to the individual named above, Joseph Dean Thompson
(Assistant Director), Mark Braza, Alicia Cackley, Martin (Greg) Campbell,
Christopher Currie, Swati Deo, Kathryn Godfrey, Brian Lepore, Armetha
Liles, Tim Persons, Kiera Reifschneider, Oliver Richard, Michelle Sager,
Amber Sinclair, Jeanette Soares, Ruth Solomon, Anne Stevens, Marie
Suding, Kiki Theodoropoulos, and David Wise made key contributions to
this report.
Appendix III: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments
(100246)
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