Climate Change: Improved Federal Coordination Could Facilitate Use of Forward-Looking Climate Information in Design Standards, Building Codes, and Certifications
Published: 2016-11-30T00:00:00

Fast Facts:
The houses we live in, buildings we work in, and roads and bridges we use daily are supposed to be built to last—whatever the local forecast has in store.
However, design standards and building codes generally use historical climate observations. Forward-looking climate information would help account for the changing frequency and intensity of extreme weather.
Continuing to build with current standards and codes could cost the government billions of dollars in repairs, flood insurance, and disaster relief. We recommend that federal agencies work together to provide forward-looking climate information for consideration in standards and codes.

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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. 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.  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. 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  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. 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. 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— 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. 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. 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  is relevant. 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  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.
subsections: section_title: Background
paragraphs: 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.
subsections: section_title: Design Standards, Building Codes, and Voluntary Certifications Provide Guidelines for Infrastructure Construction
paragraphs: 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. For example, the  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. 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.
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.
section_title: Standards-Developing Organizations Are the Primary Source of Design Standards, Building Codes, and Voluntary Certifications
paragraphs: 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. In April 2013, we found that federal agencies rely on professional  associations in adopting design standards. In 2015, we found that  federal agencies and the private sector use voluntary certifications that  third-party organizations—such as standards-developing organizations— develop. 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.
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.
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.
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.
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. 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. 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  subject to periodic evaluation and assessment of the environmental  and energy benefits that result, among other things.
section_title: Standards-Developing Organizations Develop Certain Design Standards, Building Codes, and Voluntary Certifications through a Formal, Consensus-Based Process
paragraphs: 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. 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. 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.  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.  At that time, the standards-developing organization may reaffirm,  revise, or withdraw the standard.
section_title: Federal Law and Policies Govern the Participation of Agency Officials in the Development of Design Standards, Building Codes, and Voluntary Certifications
paragraphs: 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. 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. 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.
section_title: Design Standards, Building Codes, and Voluntary Certifications Play a Role in the Federal Fiscal Exposure to the Effects of Climate Change
paragraphs: 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. 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. Also in our 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. 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. 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.  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.
section_title: Standards- Developing Organizations Have Not Generally Used Forward-Looking Climate Information in Design Standards, Building Codes, and Voluntary Certifications
paragraphs: 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. 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. 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. 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 to specify insulation levels for condensation control and has not updated  these observations in 26 years. Moreover, the International Association  of Plumbing & Mechanical Officials uses rainfall rates from a 1961 federal  technical paper for the sizing of stormwater drainage pipes.  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. 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. 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. In a progress report on this statement, signatories made initial commitments to develop  design standards that are informed by climate data. 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.
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. 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. 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  information in their voluntary certification to address the Council on  Environmental Quality’s recently updated Guiding Principles.
section_title: Reports and Representatives of Standards- Developing Organizations Identified Institutional and Technical Challenges to Using Forward-Looking Climate Information
paragraphs: 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.
subsections: section_title: Institutional Challenges
paragraphs: 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.
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. 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.
section_title: Technical Challenges
paragraphs: 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. 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.   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. For example, in 2014, the Transportation Research  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. 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.  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.
section_title: Agencies Have Initiated Some Actions and Could Take More to Help Address Challenges, According to Reports, Standards- Developing Organizations, and Agency Officials
paragraphs: 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.
subsections: section_title: Agencies Have Initiated Some Actions that Could Help Standards- Developing Organizations Address Institutional and Technical Challenges
paragraphs: 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. 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.
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. 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  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.
section_title: Opportunities Exist for Federal Agencies to Take Additional Actions, According to Reports, Representatives of Standards-Developing Organizations, and Agency Officials
paragraphs: 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  among federal agencies that address climate-related issues. 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. 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. 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. 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.
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. 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. 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,  operations, and culture, strong coordination across the federal  government creates the best outcomes.
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. 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  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. 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. 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. 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 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. 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. 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. 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  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  mission of the agency, expected service life, historic or cultural status,  and whether the building is vulnerable to projected changes in the  climate. 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. 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.
section_title: Conclusions
paragraphs: 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  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.
section_title: Recommendation for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
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. 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.
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 gomezj@gao.gov. 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.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: 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.
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  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  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.
section_title: Appendix II: Comments from the Department of Commerce
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.